Will & sale-deed of property without partition dees

My father-in-law & his three cousin brothers purchased land jointly by one sale-dded of of seller for residence purpose in 1945 in ahmadabad (gujarat)..they constructed four equal tenements and took respective possessions of one each. got mutation by entries in city survey record in around 1983. my uncle-in-law sold his property in 1984 by registered document. my father-in-law destroyed his tenement in 1996 and got constructed flats without permissions of others. he sold 4 flats (40%) to two women purchasers (wives of contractor and engineer). Willed 15% each to 3 sons and my mother-in-law in 1997. In 1999 my f-in-law applied to Mamlatdar for granting/according partition by making a change entry. The officer made a note to produce a registered partition deed but when not produced, the officer cancelled the change entry. Recently, the will entry and one sale entry are certified by the City Survey Spdt. My wife is preparing for Appeal. What citations she should produced in the Appeal application?