CASE INFORMATION FORMAT CIVIL Gi

CRIMINAL (]
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[Link] PLAINTIFF/PETITIONER/COMPLAINANT / APPELLANT / DECREE HOLDER ETC.

(PLEASE FILL UP ALL THE RELEVANT FIELDS & (*) FIELDS ARE MANDATORY

*Name of Plaintiff/
1. Complainant etc. SANTAY KUMAR

2, | *S/0, W/o, D/o LATE GH. RAM NARAIN

PLOT NO. 381-10, FT ast Floor, GAL MATA WelT,
3. * Address é
TE LUWARA ,DELYI—11000
4. | Aadhar Card No. 116 WIZ OSE Pincode Ji }ifjololo [6
Ss. *Gender Male Female Others Nationality |"CND LAN

6. | Date of Birth PNA IMM a Oe NA "Age 54 Years

7. _| *Mobile No./ = capital Letters <2
8. “Act / Section —_——7 —_—
Court Fee Ascertained : —_—__—

9. Valuation of Suit Court Fee Paid / Deposited: <

a *Police Station _ {In Criminal Matters Only)

ii. = |*F,..R. No. & Year > {In Criminal Matters Only)

[Link] DEFENDANT / ACCUSED / RESPONDENT /JAJUUDGEMENT DEBATOR ETC.

(PLEASE FILL UP THE RELEVANT FIELDS & (*) FIELDS ARE MANDATORY)
1. *Name of The
Defendant / Accused Etc. RUKMANI Devt LANA,
2, | *S/0, W/o, D/o LAT? SH. RAM NARAIN

3. | *Address PLOT NO. 381-19, GRovwD FLOOR, HALL HATA WALT,

TEL WARA, DELH( - \lo006

4. | aadhar Card No. Pin Code | { lolololé

5. |*Gender Vodka came [ini Others Nationality | IND TAN
6. | Date of Birth op [MM fa Age Years
Mobile No. OAS NUMAIN) _| capital retters Vikoanohtagt@ greeill. corm
[Link] | ADVOCATE FOR PLAINTIFF/COMPLAINANT/ PETITIONER/ DECREE HOLDER ETC.

1. Name of Advocate
Enrl No.

2. Offi c h ber
Chamber N No. ae

7 7 Ronaa! One Age

fof VIKAS ROHTAG!
3. | Mobile No. |e-mail: Ch. No. 1208, Lesvc SSOCIATES
Rohini Courts, Dethi-85 M:- 987424
Emaii:- vikasrohtagi@gmait con

Submitted by :-
(Plaintiff/Petitioner/Defendant/Accused/Others/Advocate)

|
 IN THE COURT OF SH. KAPIL GUPTA, CIVIL JUDGE,
DISTRICT-CENTRAL, TIS HAZARI COURTS, DELHI
CIVIL SUIT NO. 1797 OF 2024

IN THE MATTER OF: -

SANJAY KUMAR eEoEEee PLAINTIFF
VERSUS
RUKMINI DEVI & ANR. .ss00se DEFENDANTS
N.D.O.H — 19.10.2024

INDEX
S. NO. PARTICULARS PAGE NO.
1. MEMO OF PARTIES A
2. WRITTEN STATEMENT FILED ON BEHALF OF
JHE DEFENDANTS ALONG-WITH SUPPORTING 4-24
AFFIDAVITS AND DOCUMENTS.
3. | VAKALATNAMA 22
4, | PROOF OF SERVICE 72
en
DELHI | Wore Wena
DATED: 08.10.2024 DEFENDANTS
REPRESENTED & FILED IN THE COURT BY:
a
VIKAS ROHTAGI
ADVOCATE
FOR: ROHTAGI LAW ASSOCIATES
LAWYER'S CHAMBER NO.1208,
12™ FLOOR, LAWYER'S CHAMBER BLOCK,
ROHINI COURT COMPLEX,
ROHINI, DELHI-110085
09871242111, 07011551611
email: rohtagilawassociates@[Link]
vikasrohtagi@[Link]
 IN THE COURT OF SH. KAPIL GUPTA, CIVIL JUDGE, DISTRICT-
CENTRAL, TIS HAZARI COURTS, DELHI
CIVIL SUIT NO. 1797 OF 2024

IN _THE MATTER OF: -

SANJAY KUMAR 00 sss ee --PLAINTIFF
VERSUS
RUKMINI DEVI & ANR. sereees DEFENDANTS

MEMO OF PARTIES
Sh. Sanjay Kumar
S/O Late Sh. Ram Narain
R/O Plot No. 389-90, First Floor,
Gali Mata Wali, Teliwara,
Delhi-110006 Through his S.P.A Holder
[Link] — aasensnenes PLAINTIFF
VERSUS
i. Smt. Rukmini Devi
W/O Late Sh. Ram Narain .»sDEFENDANT NO. 1
2. Mukesh Kumar
S/O Late Sh. Ram Narain sees DEFENDANT NO. 2

Both R/O Plot No.389-90, OWN AE

Ground Floor, Gali Mata Wali,
Teliwara, Delhi-110006 +s0ses DEFENDANTS /
we eo yoy

DELHI
DATED: 08.10.2024 DEFENDANTS
REPRESENTED & FILED IN THE COURT BY:

cop r—- ;
VIKAS ROHTAGI
ADVOCATE
FOR: ROHTAGI LAW ASSOCIATES
LAWYER'S CHAMBER NO.1208,
12™ FLOOR, LAWYER'S CHAMBER BLOCK,
ROHINI COURT COMPLEX,
ROHINI, DELHI-110085
09871242111, 07011551611
email: rohtagilawassociates@[Link]
vikasrohtagi@[Link]
 IN THE COURT OF SH. KAPIL GUPTA, CIVIL JUDGE,
DISTRICT-CENTRAL, TIS HAZARI COURTS, DELHI
CIVIL SUIT NO. 1797 OF 2024

IN THE MATTER OF: -

SANJAY KUMAR aseoess PLAINTIFF
VERSUS
RUKMINIDEVI&® ANR. 2 2 sseese DEFENDANTS

WRIT TENN STAT

RITTE EMENTT FILED ON
STATEMEN LFE OFee
BENAL
ON BEHA THE
DEFENDANTS

SS ULLY
8 RESPECTF
MOST
ee
SHOWETH:

All grounds taken and averments made in this written statement

are in the alternative and without prejudice to each other. All
averments made by the Defendants are generally and
specificallydenied unless otherwise so stated expressly and the
answering Defendant shall not be deemed to have made any
admission unless expressly stated otherwise.
Before adverting to the various averments contained in
the suit on merit the answering Defendants crave leave
to raise the following submissions:

PRELIMINARY OBJECTIONS AND SUBMISSIONS

a. The Present suit has not been validly instituted, as such,
liable to be dismissed.

B. That the Plaintiff in the present suit has not approached this
Hon’ble Court with clean hands and deliberately suppressed
 material facts. The accompanying suit is misrepresentation
of facts to harass and torture the answering Defendants,
hence the present Suit is liable to be rejected and the
Plaintiff is not entitled for the relief claimed for in its Suit.
c. That the present suit is nothing but an endeavour on the
part of the Plaintiff to harass the Defendants and to burden
them unnecessary litigation expenses. The present suit is
liable to be dismissed on this ground alone.
D. That the present suit is not maintainable and the same is
liable to rejected Under Order 7 Rule 11 CPC as the plaint
does not disclose any cause of action.

E. That as a matter of fact the whole Suit of the Plaintiff is

patently false, bogus and sham. The Plaintiff has fabricated
a cock and bull story to create illusion of some right and
cause of action in his favour by resorting to gross perjury.
Hence the present Suit is liable to dismissed in limine.
F. That the present suit is not maintainable being barred by
Order 1 Rule 13 of CPC for non-joinder of necessary parties.
The father of the Plaintiff namely Late Sh. Ram Narain died
intestate leaving behind the following Class-I Legal Heirs:
(i) Rukmini Devi -Widow/Defendant No.1
(ii) © Mukesh Kumar -Son/Defendant No. 2
(iii) Rajender -Son
(iv) Rekha -Daughter
(v) Veena -Daughter (now deceased)
(vi) Devender -Son
(vii) Babita -Daughter
(viii) Sanjay Kumar -Son/Plaintiff

The bare perusal of the Memo of Parties annexed with the

present suit reflects that except Smt. Rukmini Devi/Defendant
No. 1 and Sh. Mukesh Kumar/Defendant No. 2, no other Class-
I Legal Heir as mentioned here in above is impleaded as a
necessary party in the present suit whereas in the Para No. 3 of
the Plaint itself the above mentioned chart of the Class-I Legal
Heir is elaborated but despite this the Plaintiff failed to array all
fon
of them as necessary party in the present suit. Moreover, the
Hon’ble Apex Court laid down in catena of judgments that suit
is liable to be dismissed if a necessary party is not impleaded.
Therefore, the present suit is liable to be dismissed on this score
alone.

G. That the present suit is not maintainable and is liable to be

rejected on the ground that the civic authority that is MCD
is not arrayed as a necessary party in the present suit. In
this context it is submitted that the suit property was
constructed around 100 years ago and therefore, is an old
aged property consisting of weak walls and gaarder based
ceiling with cracks and seepage all around and a mere
glance on the Suit Property shows that it Is a dilapidated
building which needs immediate repairs and any kind of
fresh construction or addition alteration or modification may
cause severe damage to the basic structure of the Suit
Property and therefore, permission from the concerned civic
authority for raising any construction in the Suit Property is
essential but the Plaintiff failed to array the MCD as a
necessary party in the present suit. Without prejudice to the
rights and contentions of the Defendants it is submitted that
the permission of the Defendants is secondary in nature and
primarily the permission of the MCD which is the civic agency
in Delhi is necessary for raising any construction in the Suit
Property and therefore, in the absence of the MCD, the
present suit is not maintainable in the present form and is
liable to be rejected on this ground also.
H. That by means of the present suit; the Plaintiff intends to
construct a toilet in the balcony of the Suit Property. To show
the present condition of the balcony as well as of the Suit
Property; the Defendants are annexing some photographs
of the Suit Property which are essential for the just and
proper adjudication of the present suit.

e Some photographs representing the present condition of

the Suit Property as well as of the balcony forming part
of the Suit Property are annexed herewith for the kind
perusal of this Hon’ble Court and is marked as
ANNEXURE D-1 (COLLY). H

py Warr
 The bare perusal of the annexed photographs vindicates
the true state of affairs and vindicates the dilapidate
condition of the Suit Property and split the beans on the
floor and reflects the malafide intentions of the Plaintiff.
In the backdrop it is submitted that the Suit Property
needs immediate repairs to strengthen its structure and
any addition/alteration/modification or further illegal
construction in the balcony can become a root cause of
collapse of the entire balcony and the adjoining structure
and therefore, the present suit whereby relief of
mandatory injunction is sort by the Plaintiff is not
maintainable. In this context it is not out of the place to
mentioned here that medical grounds as enshrined in the
present suit under reply cannot create any legal right or
remedy in favour of the Plaintiff and hence, the present
suit is liable to be rejected on this score alone.

PARAWISE REPLY ON MERITS: -

1. That the contents of the Corresponding Paragraph No. 1 are
wrong and denied. It is stoutly denied to the extent that the
Plaintiff is a Law-Abiding Citizen and is residing at the
abovesaid address i.e. Plot No. 389-90, First Floor, Gali Mata
Wali, Teliwara, Delhi-110006. The Plaintiff may be put to
strict proof thereof.
That the site plain filed by the Plaintiff on the Judicial Record
along with the Plaint is false and fabricated and the
answering Defendants hereby dispute the site plan.

. That the contents of the corresponding Paragraph No. 2 need

no reply being matter of record.

. That the contents of the corresponding Paragraph No. 3 need

no reply being matter of record. However, it is submitted that
in the Present Suit; the Plaintiff has arrayed name of the only
Class-I Legal Heirs of Late Sh. Ram Narain as Defendants
whereas the rest of the Class-I Legal Heirs as mentioned in
the Para under reply also are necessary party to the Present
Suit and therefore, it is again reiterated that the Present Suit

an ET AT”
- 4
f Yr Ne
 hit by the non-joinder of the parties and is liable to be
dismissed.

4. That the contents of the corresponding Paragraph No. 4 need

no reply being matter of record. However, in response it is
submitted that when all the Class-I Legal Heirs left behind by
the Late Sh. Ram Narain became joint owners of the Suit
Property then as to what prevented the Plaintiff to array all
of them as Defendants in the Present Suit and without
prejudice it is also submitted that it is also a substantial
question of Law that as to how the sole consent of the
Defendant No. 1 & 2 without the consent of the remaining
Class-I Legal Heirs; will be sufficient for the illegal
construction intended to be raised by the Plaintiff; when the
capacity of Defendant No. 1 & 2 is also limited to the extent
of the joint owners qua the Suit Property.

5. That the contents of the corresponding Paragraph No. 5 need

no reply being the matter of the record.

e However, in response it is submitted that by means of the

present Para the Plaintiff is describing the positions of the
facilities like Toilet, Bathroom etc. comprised in the Suit
Property but not disclosing the true fact that at present
the condition of the Suit Property is absolutely dilapidated
and needs immediate repairs and renovation and any
further construction in any portion of the building
including the Balconies may cause severe damage to the
root structure of the building. In other words, any addition
or alteration in the structure of the old aged Suit Property
may not only endangered the basic structure of the
building but shall also pose life threat to the occupants of
the adjacent buildings. The Plaintiff is hiding the true state
of affairs and only revolved and centralized the averments
of the Present Suit to the extent of the construction of
Toilet in the Balcony and concealed the status of the
seepage in the walls and other portions of the building.
Moreover, the Plaintiff knocked the door of this Hon’ble
 Court without assessing the consequences of fresh
construction in the Balcony and the sole motive behind
this entire exercise is the harassment of the Defendants
and not the construction of any toilet as the Plaintiff is
absolutely comfortable in using the Toilets already
maintained in the Suit Property. What has been stated
hereinabove may be referred to.

6. That the contents of the corresponding Paragraph No. 6 are

wrong and denied. It is emphatically denied _ that
unfortunately the plaintiff has suffered with the disease of
spinal problem/fracture L2 and due to this reason, he is
unable to use the latrine/bathroom on the ground floor
portion as the doctors advised him not to do anything which
may affect to his spinal problem. It is submitted that the pain
increased on standing and walking. In this regard, the
plaintiff tried to construct a toilet in his portion i.e. first floor
of the said property but the defendants started raising
objection for the same and they did not allow the plaintiff to
construct any toilet on the first-floor portion /suit property.

e In response it is submitted that contrary to the projection

of the Plaintiff the true picture is other way round, It is
submitted that due to the problem of the Spinal Code; the
Plaintiff is under treatment as claimed by him but so far as
the knowledge of the Defendants are concerned, after
some treatment from the Doctors, the Plaintiff is absolutely
fine and is comfortably using the Toilets of the Suit
Property as he was using in the Past. It is not out of the
place to mention here that dispute crop up between the
parties here to because of the repairing work initiated by
the Defendant No. 2 for rectifying the cracks emerged in
the rooms of the Defendant No. 1 as drops of waters are
oozing out from the ceiling and was disturbing the
habitation in the said room. The inception of the repairing
and rectification work irritated the Plaintiff and to show his
dominion; he is adamant to construct a Toilet in the
Balcony by ignoring the actual condition of dilapidated of
Ronde 4
waren ™
 the Suit Property, hence the objection on the part of the
Defendants is bonafide and genuine and merely for the
sake of safeguarding the actual structure of the Building.

7. That the contents of the corresponding Paragraph No. 7 are

wrong and misconstrued. It is vehemently denied that on
15.08.2024 the plaintiff brought the labours to construct the
toilet on the first-floor portion / suit property, but the
defendants threatened to the said Laboure’s not to enter in
the house otherwise they will face consequences. Thereafter
the plaintiff in requesting manner asked the defendants that
since the plaintiff is unable to use the toilet on the ground
floor portion due to his spinal problem/ fracture L2, but the
defendants are adamant. In this process the respectable of
the locality also came to the spot and they also advised to
the defendants to allow the plaintiff to raise construction in
the suit property, but the defendants are adamant. The
medical documents are annexed herewith for the kind
perusal of this Hon’ble Court.

e In response it is submitted that the factual scenario

regarding the dilapidated status of the Suit Property is
already elaborated in the submissions made in response
to the preceding Para’s. It is further submitted that the
Plaintiff is presenting a wrong picture of the incident of
15.08.2024. And in fact, the labour hired by the Plaintiff
started demolishing the walls of the Balcony without
taking due care and caution and posed a serious threat to
the basic structure of the Suit Property. In this context it
is also submitted that the answering Defendants already
requested the Plaintiff to first initiate the repairing work
from the Ground Floor so that the Suit Property can bear
the weight and burden of the Fresh Construction and
further requested the Plaintiff to take advise of an
architect vis a vis permission from the MCD for raising the
Fresh Construction. Apart from this it is also submitted
that the respectable persons of the locality contrary to the
projection of the Plaintiff; advised the Plaintiff to not to

Tapeh
 raise fresh construction in the old aged Suit Property and
first initiate the repairing work from the Ground Floor
itself. It is further submitted that medica! condition does
not give any liberty or privilege to raise illegal and unlawful
construction and for safeguarding the old structure of the
Suit Property and protecting the life and lim of the local
residents of the Locality proper permissions from the Civic
Authorities are required and taking shelter of the medical
condition do not give any privilege or permission to the
Plaintiff to raise the illegal construction in the Balcony.

8. That the contents of the corresponding Paragraph No. 8 are

being false and fabricated. It is stoutly denied that the
plaintiff has been making requests to the defendants from
time to time but the defendants are adamant and they did
not allow the plaintiff to raise the construction on the suit
property.

e In response it is submitted that what has been stated

hereinabove may be referred to. Moreover, regard may
kindly be had to the Preliminary Objections and
Submissions made in response to the preceding Para’s the
contents of which are not repeated herein for the sake of
prolixity and may be treated as part and parcel of the
present Para under reply. However, it is also submitted
that in reality the Plaintiff is adamant to raise illegal
construction by putting the entire structure of the Suit
Property on stake.

9. That the contents of the corresponding Paragraph No. 9 are

denied for want of knowledge.

e In response it is submitted that the Defendants are not

aware regarding lodging of any false and frivolous
Complaint Dated 16.08.2024. It is further submitted that
as the contents of the said Complaint Dated 16.08.2024
are amorphous and vexatious; this was the reason that no
action was initiated by the concerned departments. It is
a
LH
i el
 also submitted that lodging false and frivolous Complaint
do not give any right to the Plaintiff to raise illegal and
unlawful construction. It is further submitted that instead
of lodging Complaint; the Plaintiff should apply for the
permission, sanction plan etc. from the MCD and should
have started repairing work from the Ground Floor
onwards to strengthen the basic structure of the Suit
Property. In this context it is also submitted that the
Complaint Dated 16.08.2024 was forwarded to the
concerned Police Station just for the sake of mounting
pressure on the Defendants whereas in reality the Police
Authorities has no role to play in the controversy involved
in the Present Suit.

10. That the contents of the corresponding Paragraph No. 10

are false and fabricated. It is vehemently denied that now
the plaintiff has no other alternative remedy than to file
the present suit.

In response it is submitted that what has been stated

hereinabove may be referred to. Moreover, regard may
kindly be had to the Preliminary Objections and
Submissions made in response to the preceding Para’s the
contents of which are not repeated herein for the sake of
prolixity and may be treated as part and parcel of the
present Para under reply.

11. That the contents of the corresponding Paragraph No. 11

are wrong and denied being false and fabricated.

e In response it is submitted that Cause of Action never

accrued in favour of the Plaintiff and against the
answering defendants. The Plaintiff may put to strict
proof thereof. It is further submitted that regard may
kindly be had to the submission made in response to the
preceding Paras and Preliminary Objections, the contents
of which are not repeated herein to avoid prolixity and
may be treated as part and parcel i the Present Para
OM Hl IT

dems WA
©
under reply. Moreover, the contents of Preliminary
submissions mentioned herein above may kindly be
referred to.

12. That the contents of the corresponding Paragraph No. 12

are wrong and mischievous.

In response it is submitted that the suit of the Plaintiff is

patently bogus and therefore, the claim enshrined therein
is also false and illegitimate qua the answering
Defendants. It is further submitted that the corresponding
Paragraph of Plaint relates to territorial jurisdiction of this
Hon’ble Court. What has been stated hereinabove be
referred to. Answering Defendants hereby dispute the
territorial Jurisdiction of this Hon‘ble Court to entertain
and adjudicate upon instant suit. Moreover, the contents
of the Preliminary Submissions mentioned herein above
may kindly be referred to.

13. That the contents of the corresponding Paragraph No. 13

are wrong and denied being wrong and misconstrued.

In reply to contents and averments in Para under reply it

is submitted that the Plaintiff has not properly valued
instant suit for the purposes of Court Fee & Jurisdiction
and has paid deficit Court Fees. Moreover, the contents of
Preliminary Submissions mentioned herein above may
kindly be referred to.

PRAYER
In the peruses, it is prayer that in view of the preliminary
objections and other submissions made herein above: -
(a) The Suit filed by the Plaintiff, which is devoid of merits may
kindly be rejected with exemplary cost.
- eo
a, Ode} THT

Aan’ wee’
(b) Any other relief which this Hon'ble court deems fit and
proper may also be passed in favor of the answering
Defendants and against the Plaintiff.
ons) <i
PLACE OF FILING: -DELHI Wd yee
DATED: 08.10.2024 DEFENDANTS

REPRESENTED IN THE COURT & FILED BY: -

VIKAS ROHTAGI
ADVOCATE FOR THE DEFENDANTS
FOR: ROHTAGI LAW ASSOCIATES
LAWYER’S CHAMBER NO.1208,
12™ FLOOR, LAWYER'S CHAMBER BLOCK,
ROHINI COURT COMPLEX, ROHINI,
DELHI-110085
09871242111 & 07011551611
email: rohtagilawassociates@[Link]
vikasrohtagi@[Link]

VERIFICATION
Verified on solemn affirmation at Delhi on this 8" day of October,
2024 that the contents of the above written statement
containing Paragraph No. A to H of the Preliminary Objections
are believed to be correct on the basis of the Legal Advice
received and those of Paragraph No. 1 to 10 are believed to be
true and correct to the best of my knowledge and belief. The
Contents of Paragraph No. 11 to 13 are correct to the Legal
Knowledge/Advice and no part of it is false and nothing material
has been concealed there from. Last Para is a Prayer to this
Hon’ble Court. on A at
vO
aos EAS
DEFENDANTS
 IN THE COURT OF SH, KAPIL GUPTA, CIVIL JUDGE,
DISTRICT-CENTRAL, TIS HAZARI COURTS, DELHI
IVIL SUIT
CIVIL NO. 1797
SUIT NO. <Uc%
OF 2024
1797 OF

IN THE MATTER OF: -

SANJAY KUMAR oseeeeePLAINTIFF
VERSUS
RUKMINI DEVI & ANR. eereeesDEFENDANTS

AFFIDAVIT
Affidavit of Smt. Rukmini W/O Late Sh. Ram Narain R/O Plot No. 389-90,
Ground Floor, Gali Mata Wali, Teliwara, Delhi-110006, aged about
__years.
as
I, the above-named Deponent, do hereby solemnly affirm and declare
under: -
well
1. That I am the Defendant No. i in the above noted Suit and am
compet ent to swear this
conversant with the facts of the case as such
Affidavit.
by my
2, That the accompanying Written Statement has been drafted
and
counsel under my instructions, contents of the same are true
part and
correct to my knowledge and the same may kindly be read
being
parcel of the -affidavit, athe contents of the same are not
far the
abbir{ Sae |of brevity and to avoid repetition.
co
BLY Touetr
\ c
DEPONENT
wt
ola ph os™ VERIFICATION
5 ®t Delhi on this 08" day of Oct. 2024 that the contents of Paras
F'and 2_ of the above affidavits are true and correct to my knowledge,
SY)wy : . ~
Qe etho part of it is false and nothing material has been concealed therefrom.
wo
CERTIFIED Jrat ou) OSBONENS QAH TT
~ mie XOle A
HU ( ithe

. soi DEPONENT
2! a a
ie iB —
Rotel mor
PROS éru lus &

Cha cS mimesioner Deini

‘
 IN THE COURT OF SH. KAPIL GUPTA, CIVIL JUDGE,
DISTRICT-CENTRAL, TIS HAZARI COURTS, DELHI
CIVIL SUIT NO. 1797 OF 2024

IN THE MATTER OF: -

SANJAY KUMAR oesenes PLAINTIFF
VERSUS
RUKMINI DEVI & ANR. «sese:sDEFENDANTS

AFFIDAVIT
Affidavit of Mukesh Kumar S/O Late Sh. Ram Narain R/O Plot No. 389-90,
Ground Floor, Gali Mata Wali, Teliwara, Delhi-110006, aged about
__years.

I, the above-named Deponent, do hereby solemnly affirm and declare as

under: -

aS
= Eammnigsy=Cffjat
ell

1 am Defendant No. 2 in the above noted Suit and am well

LAO 9. ersant with the facts of the case as such competent to swear this
(% on ove
: ‘ThAt the accompanying Written Statement has. been drafted by my
SS . .
“counsel under my instructions, contents of the same are true and
‘ A;
No Fon CO correct to my knowledge and the same may kindly be read part and
parcel of the affidavit as the contents of the same are not being
repeated herein for the sake of brevity and to avoid repetition. WA
yous

al DEPONENT
» yi
WO ANS \6 VERIFICATION
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max peunana oe
eeeneniiin PS. 2papa Hinpu Rao
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IN THE COURT OF Sk: katy. Guemm, Civil SyBGeE-oe (Cow mm] TY HAZER| GER |
5 BELHI
Suit/Appeal No.__C $ SCF No,: cs ie JURISDICTON of 20
In re :-
Sanjay Kvmigt, Plaintiff / Apptt/Petitioner/Complainant

VERSUS
Ruinmypa Devi & PooheR, Defendant/Respondent/Accused
KNOW ALL to whom these present shall come that I/ / WeSwq. Rutan bev) Wo Late £1 Ay
nA A Oo ta AE oat oe Ghovnp
Rem naan & MVKESH kumne s}o SHq A
eC euhenTs ‘ mnTR Hereby appoin DEL Newt,
The above named__

vi KA Ss Eo
NEERAJ SINGH
ba ess G I En. No. D-1135/17 ADVOCATE
ROLTAGI lew ASSD CIATE sd Ch. No. 1208, 12th Floor, Lawyer's Chamber
Ch. No. 1208. Lin wae 5 Chamber aes apes fon Courts Complex, Delhi 110085
ee Mie ; -mail-rokin.
Rohini Courts, Deihi-B5 M:- 9871242111
Email:- vikasrohtagi@[Link]
Mobile No SOS7a 14103 ceosaeGoT
(herein after called the advocate/s)to be my/ourAdvocate in the above-noted case authorise him :-
To act, appear and plead in the above-noted case in this court or in any other Court in which the same may be tried
or heard and also in the appellate court including High Court subject to payment of fees separately for each court by me/us.
To sign file, verify and present pleadings, appeals cross-objections or petitions for executions review, revision,
. i |
withdrawal, compromise or other petitions or affidavits or other documents as may be deemed
necessary or proper for the prosecution of the said case in all its stages subjects to payment of fees

6689¢S)
for each stage.
To file and take back documents to admit and/or deny the documents of opposite party ;
To withdrsw or compromise the said case or submit to arbitration any differences or disputes
b

that may arise touching or in any manner relating to the said case.
Te take execution proceedings
The deposit, draw and receive money, cheques, cash and grant receipts hereof and to do all
other acts and things which may be necessary to be done for the progress and in the course of the
prosecution of ihe said case.
To appoint and instruct any other Legal Practitioner authorising him to exercise the power
and-authority hereby conferred upon the Advocate whenever he may think fit to do so and to sign the J
powerof attorney on our behalf.
And ifwe the undersigned do hereby agree to ratify and confirm all acts done by the Advocate or his substitute in
the matter as my/ourown acts, as if done by me/us to all .ntents and purpose.
And I/We undertake that I/We or my/our duly authorised agent would appear in court on all hearings and will inform
the Advocate for appearance when the case is called.
And I/We undersigned do hereby agree not to hold the advocate of his substitute responsible for the result of the
said case The adjournment costs whenever ordered by the court shall be of the Advocate which he shall receive and retain
for himself.
And We undersigned do hereby agree that in the event of the whole or part of the fee agreed by me/us to be paid
to the advocate remaining unpaid he shall be entitled to withdraw from the prosecution of the said case until the same is
paid up. The fee settled is only for the above case and above Court I/We hereby agree that once the fee is paid, We will
not be entitled for the refund of the same in any case whatsoever and if the case prolongs for more than 3 years the original
fee shall be paid again by me/us.
IN WITNESS WHERE OF I/We dojnereuntoset my/our hand to these presents the contents of which have been
agus on this................3 a Cerrar nent e rn tsversscetnceenrt sas day

Vanesew
fe f..202:t4..... Accepted subject to the terms of the fees.
WHT
Client Client
I identify The Signature/Thumb Impression Of Below Mentioned Person,
Signed In My Presence. a ——
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Please find attached :

The copy of Written Statement
In the Matter entitled
Sanjay Kumar VS Rukmini Devi & Ant.
Regards Adv. PANKAJ ROHILLA
FOR: ROHTAGI LAW ASSOCIATES if

re? Forwarded

CASE INFORMATION FORMAT a

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WS Sanjay Kumar VS Rukmini Devi &

Anr. .pdf