IN THE COURT OF CIVIL JUDGE, SENIOR DIVISION AT PUNE

CIVIL SUIT NO. 487 OF 2024

Mr. Rayish More
S/o Mahesh Patel
Residing at: Flat No. 302,
Sai Harmony Apartments,
Baner Road, Baner,
Pune – 411045
…Plaintiff
VERSUS
Ram Sharma (since deceased through legal heirs)
S/o Late Mohan Sharma
Formerly residing at: 204,
Mittal Grandeur Society,
Koregaon Park, Pune - 411001
...Defendant
INTERLOCUTORY APPLICATION UNDER ORDER 22, RULE 2 OF
THE CODE OF CIVIL PROCEDURE, 1908
MOST RESPECTFULLY SHEWETH:
- That the above-mentioned suit is pending before this Hon'ble Court
for adjudication.
- That the defendant, Ram Sharma, who was a party to the suit, passed
away on 15/02/2025. The death of the defendant was duly brought to
the notice of this Hon'ble Court by the plaintiff, and necessary steps
were taken for substitution.
- That the legal heirs of the deceased defendant are as follows:
a) [Link] Sharma, Daughter of Ram Sharma,
b) [Link] Sharma, Son of Ram Sharma,
 - That the plaintiff has already filed an application under Order 22 Rule
3 of the CPC for substitution of the legal heirs of the deceased
defendant in the record of this Hon'ble Court. The said application is
pending.
- That in the interim, certain proceedings of the suit may need to be
continued, including filing of documents or seeking certain directions,
which cannot be done until the legal heirs are substituted as parties in
this case. Therefore, it is just and necessary that the Court grant an
appropriate order under Order 22 Rule 2 of the Code of Civil
Procedure, permitting the suit to continue against the legal heirs of the
deceased defendant.
- That the plaintiff submits that there is no delay or any legal
impediment in substitution of the legal heirs and requests this Hon'ble
Court to substitute the legal heirs of the deceased defendant into the
proceedings.
- That this application is made bona fide and in the interest of justice.
PRAYER
In view of the above, it is most respectfully prayed that this Hon'ble Court may
be pleased to:
- Pass an order under Order 22 Rule 2 of the Code of Civil Procedure,
1908, permitting the plaintiff to continue the suit against the legal
heirs of the deceased defendant, and
- Grant such other relief or order as this Hon'ble Court may deem fit and
proper in the circumstances of the case.

Mr. Rayish More

Plaintiff
 Advocate for Plaintiff
Chamber No. 203, District Court Complex,
Shivajinagar, Pune - 411005
Mobile: 9876543210
Email: [Link]@[Link]
Place: Pune
Date: 10/04/2025

Q.2 Draft of Precipe

[Link] SINGH
B.L.S LLB, LLM
Mob. No : 8291608893
Email: Singh2002sakshiii@[Link]
Venkatesh Chambers, 203, 2nd Floor Ghanshyam Talwatkar Marg, Fort, Mumbai, Maharashtra
400001

Date: 05/04/2025
To,
The Registrar, Appellate Side,
High Court, Bombay.

Ref: IN THE HGH COURT OF JUDICATURE AT BOMBAY CRIMINAL

APPELLATE JURISDICATION
Interim Application No. (L) 8150 OF 2025.
[Link] Goenka
…Applicant
Versus
Kuber developers
 …Defendant’s
I am concerned for the Applicants in Interim Application No. (L) 8150 OF
2025.

Be pleased to circulate the papers and proceedings in the captioned matter on

14th April, 2025 or any other date convenient to this Hon’ble Court as the
Applicant/ petitioner is desirous of seeking interim relief.

The urgency in the said matter is that after the death of the deceased partner
Late [Link] Goenka, the existing partners have not bothered to settle the
accounts of the deceased.

Hence this matter may kindly be placed before the Hon’ble Court and the
advocate for the Applicant/ Petitioner will serve the defendant in advance.

Dated this 05 day of April, 2025

Advocate for the Applicant/ Petitioner.
Q.3 Draft 2(two) minutes application in Bombay highcourt, Appellate side,
presided by hon’ble Shri justice XYZ for mistake in case number while
uploading

[Link] SINGH
B.L.S LLB, LLM
Mob. No : 8291608893
Email: Singh2002sakshiii@[Link]
Venkatesh Chambers, 203, 2nd Floor Ghanshyam Talwatkar Marg, Fort, Mumbai, Maharashtra
400001

Date: 05/04/2025
To,
The Registrar,
Appellate Side, Bombay High Court.
Ref:
IN THE HIGH COURT OF JUDICATURE
AT BOMBAY
CIVIL APPELLATE JURISDICTION
CIVIL WRIT PETITION NO. 245/2020
The Institute of Event Management
...Petitioner
VERSUS
State of Maharashtra & Ors.
… Respondent’s
Sir,
The above matter was heard by the Hon'ble Division Bench presided over by
Hon'ble Shri Justice ABC and Hon'ble Shri Justice XYZ on 23.06.2020,
whereby the Hon'ble Court vide its order of the same date directed the matter to
stand over to 26th June 2020, to be listed along with Writ Petition (ST). NO.
234/2019.
However, the order which got uploaded on 23.06.2020, states that "Stand over
to 26th June 2020, to be listed along with Writ Petition (St.) No. 345 of 2020
It is in these circumstances that we are compelled to approach the Hon'ble Court
for seeking modification/ corrections of the said order dated 23.06.2020. It is
respectfully submitted that order is required to be modified/ corrected to as
under, if it is found by the Hon'ble Court to be proper:
a) Stand over to 26th June 2020, to be listed along with Writ Petition (St.)
No. 234 of 2019.
 b) That, the Petition No. 245/2020 which is directed to be listed along has to
be corrected from Writ Petition (St.) No. 345 of 2020 to Writ Petition
(ST). NO. 234/2019.
That the aforesaid correction in the order passed by the Hon'ble Court has
become necessary the circumstances stated herein above. There is no legal
impediment in doing the same.

Dated this 05th Day of April 2025.

Yours faithfully
Advocate for Petitioner
Q.4 Draft a Notice of Motion , in Bombay High court , Original side
jurisdiction Civil Side for attachment of properties of defendants , also to
restrain the defendants and their agents to create third party interest on it

IN THE CITY CIVIL COURT GOREGAON, DINDOSHI BRANCH

AT MUMBAI
NOTICE OF MOTION NO.____ 2025
IN
CIVIL SUIT NO. 254 OF 2025
Mr. Ashish Singh )
302, Kadri Park Society )
Erla, S.V Road, )
Opp Kunal Motors, )
Mumbai-400056 )
…Plaintiff
Versus
Mr. Mehul Mehta )
801A, Oracle Apartments, )
S.V Road, Near Sanyas Ashram Mandir )
Mumbai:400056 )
…Respondent
PLEASE TAKE NOTICE THAT this Hon'ble Court will be moved before his
Honour Judge Shri. Rajesh Yadav Presiding in the Court room no. 2 on the 5 th
day of April 2025at 11:00 . O’ Clock in the forenoon or so soon thereafter as
the counsel can be heard by the Counsel on the part of the Plaintiff for the
following reliefs –
1. Permanent Injunction: For a permanent injunction restraining the
Defendant, their agents, servants, or any person acting on their behalf,
from carrying out or continuing the illegal construction at the property
situated at Prem nagar, irla S.V Road, Vile Parle West Mumbai-400056 or
from making any further alterations or additions to the said property
without proper permissions from the concerned authorities.
2. Temporary Injunction: For an interim or temporary injunction
restraining the Defendant from carrying out, continuing, or permitting
any illegal construction or alterations to the property situated at Prem
nagar, irla S.V Road, Vile Parle West Mumbai-400056 pending the final
disposal of the suit.
You are hereby required to attend the Court on the aforesaid date and time. If
you wish to oppose the Motion, you may file your reply in writing before the
hearing date and serve a copy of the same to the Plaintiff's Advocate at the
address mentioned below.

Advocate for Plaintiff

Adv. Sakshi Singh
904A,Sunteck Grandeur,
Near Andheri Subway
Andheri West
Mumbai-400056
Mob:8291608893
Email:Singh2002sakshiii@[Link]

Sign
Plaintiff
Q.5 Draft of Affidavit in Support of notice of Motion in the Above matter

IN THE CITY CIVIL COURT GOREGAON, DINDOSHI BRANCH

AT MUMBAI
NOTICE OF MOTION NO.____ 2025
IN
CIVIL SUIT NO. 254 OF 2025
Mr. Ashish Singh )
302, Kadri Park Society )
Erla, S.V Road, )
Opp Kunal Motors, )
Mumbai-400056 )
…Plaintiff
Versus
Mr. Mehul Mehta )
801A, Oracle Apartments, )
S.V Road, Near Sanyas Ashram Mandir )
Mumbai:400056 )
…Respondent
AFFIDAVIT IN SUPPORT OF NOTICE OF MOTION
I, Ashish Singh, aged about 45 years, Adult, Indian Inhabitant, residing at 302,
Kadri Park Society, Erla, S.V Road, Opp Kunal Motors, Mumbai-400056, do
hereby solemnly affirm and state as under:
1. I am the Plaintiff in the above matter and am fully conversant with the
facts and circumstances of the case. I am competent to swear this
affidavit.
2. I have filed the above suit seeking permanent and temporary injunction
against the Respondent to restrain illegal construction being carried out at
property situated at Prem nagar, Irla S.V Road, Vile Parle West Mumbai-
400056 (hereinafter referred to as "the said property").
3. I state that I am the lawful owner of premises adjoining the said property
where the Respondent is carrying out illegal construction activities.
4. I state that the Respondent has commenced construction activities on the
said property without obtaining necessary permissions and approvals
from the Municipal Corporation of Greater Mumbai and other concerned
authorities.
5. I state that the illegal construction being carried out by the Respondent
violates the Development Control Regulations for Greater Mumbai,
specifically provisions relating to Floor Space Index (FSI), setback
requirements, and structural safety norms.
6. I state that I have personally verified that the Respondent does not
possess valid permissions including Commencement Certificate from the
MCGM for the ongoing construction work.
7. I state that the illegal construction has already resulted in damage to my
adjoining property, including cracks in the wall and water seepage issues,
posing a serious threat to the structural integrity of my property.
8. I state that I have on multiple occasions, namely on 16,12,2024,
5/02/2025, and 4/03/2025, verbally requested the Respondent to cease the
illegal construction activities, but the Respondent has disregarded these
requests and continues with the construction.
9. I further state that I sent a written notice dated 25.03/2025 through my
advocate, demanding that the Respondent immediately halt the
construction activities, to which no response has been received.
10.I state that I have also filed complaints with the Municipal Corporation of
Greater Mumbai on 01/04/2025 regarding the illegal construction,
bearing complaint reference number 79777730IN
11.I state that despite the complaints, the construction continues unabated,
causing me continuous harm and damage.
12.I state that the balance of convenience lies in my favour as the
continuation of illegal construction will cause irreparable damage to my
property, whereas temporarily halting the construction until proper
13.I state that if the temporary injunction is not granted, I will suffer
irreparable loss and damage which cannot be compensated adequately in
terms of money.
14.I state that this application is made bona fide and in the interests of
justice.
15.I, therefore, pray that this Hon'ble Court may be pleased to grant
temporary injunction restraining the Respondent from carrying out or
continuing the illegal construction at the said property pending the final
disposal of the suit.
[Link] is stated hereinabove is true and correct to the best of my
knowledge, belief, and information, and I believe the same to be true.

Solemnly affirmed at Mumbai

This ___ day of April, 2025

DEPONENT
 VERIFICATION:
I, Ashish Singh, Adult Indian inhabitant residing residing at 302, Kadri Park
Society, Erla, S.V Road, Opp Kunal Motors, Mumbai-400056 the Deponent
above named, do hereby verify that the contents of paragraphs 1 to 16 of my
above affidavit are true and correct to the best of my knowledge and belief,
and no part of it is false, and nothing material has been concealed therefrom.

Verified at Mumbai on this ___ day of April, 2025.

DEPONENT
Q.6 Draft a Anticipatory Bail Application , in session Court of thane , for
offence under section 118, 109 Of Bharatiya Nyay Sanhita (BNS )
IN THE COURT OF SESSIONS JUDGE, THANE
CRIMINAL BAIL APPLICATION NO. _____ OF 2025
(U/S 438 OF THE CODE OF CRIMINAL PROCEDURE, 1973)

IN THE MATTER OF:

Rajesh Kumar Sharma, )
Age: 42 years, Occupation: Business, )
R/o: Flat No. 403, Shivneri Apartments, )
Wagle Estate, Thane (West) – 400604 )
...APPLICANT/ACCUSED
VERSUS
State of Maharashtra )
Through Police Station Wagle Estate, )
Thane (West) )
...RESPONDENT
FIR No.: 287/2025
U/S: 118, 109 of Bharatiya Nyay Sanhita, 2023
APPLICATION FOR ANTICIPATORY BAIL UNDER SECTION 438 OF
THE CODE OF CRIMINAL PROCEDURE, 1973

MOST RESPECTFULLY SHEWETH:

1. That the present application is being filed under Section 438 of Cr.P.C.,
seeking anticipatory bail in connection with FIR No. 287/2025 registered
at PS Wagle Estate under Sections 118 and 109 of BNS, 2023.
2. That the Applicant is a permanent resident of Thane with deep roots in
society, running "Sharma Electronics" at Naupada for 12 years with no
criminal antecedents.
3. That the Applicant has been falsely implicated in this case where it is
alleged that he threatened the Complainant (Mr. Vinod Gupta) to sell
property below market value.
4. That the Applicant and Complainant are involved in Civil Suit No.
432/2024 regarding Plot No. 78, Sector 5, Wagle Estate. The meeting on
29.03.2025 at Coffee House was a discussion for settlement with no
threats made.
5. That the Complainant, having a weak position in civil litigation, has filed
this false complaint to harass the Applicant.
6. That the alleged offenses under BNS are bailable with maximum
punishment of three years, and arrest would cause irreparable harm to
Applicant's reputation and business.
7. That the Applicant undertakes to cooperate with investigation, appear
when required, and not contact the Complainant directly or indirectly.
GROUNDS
a) False implication arising from civil dispute with no prima facie case.
b) FIR registered with malafide intent to pressure Applicant in ongoing civil
litigation.
c) Incident allegedly occurred in public place with CCTV coverage that would
disprove allegations.
d) Applicant has no criminal antecedents and strong community ties.
e) Offenses alleged are bailable with maximum punishment of three years.
f) No custodial interrogation required as all documents are available in civil
proceedings.
PRAYER
It is prayed that this Hon'ble Court may grant anticipatory bail to the Applicant
in connection with FIR No. 287/2025 under Sections 118 and 109 of BNS,
2023, on such terms as deemed fit.

Place: Thane
Date: 04.04.2025

ADVOCATE FOR THE APPLICANT

Adv. Sakshi Singh
MAH/8291/2025
Advocate Bombay High Court
904A,Sunteck Grandeur,
Near Andheri Subway
Andheri West
Mumbai-400056
Mob:8291608893
Email:Singh2002sakshiii@[Link]

VERIFICATION
I, Rajesh Kumar Sharma,Adult Indian Inhabitant aged ____ years residing at
Flat No. 403, Shivneri Apartments,Wagle Estate, Thane (West) – 400604 verify
that the contents of this application are true and correct to my knowledge and
belief.
Verified at Thane on this 4th day of April, 2025.

APPLICANT
Mr. Rajesh Kumar Sharma
Q.7 Draft of Application to bail

IN THE COURT OF J.M.F.C, AT THANE

Case No.______/2025
State of Maharashtra )
Through Wagle Estate )
Police Station. )
… Complainant
v/s
Avinash Deshmukh )
… Accused
APPLICATION FOR BAIL U/S 478/480 OF THE BNSS 2023
MAY IT PLEASE YOUR HONOUR-
It is most respectfully submitted on behalf of accused as under:
1. That the above named accused is arrested by the police in connection
with FIR No. 319/2025 of Police Station Wagle Estate, Thane for the
alleged offences punishable under Section 78(2) (Rash driving or riding
on a public way) and Section 79 (Causing hurt by act endangering life or
personal safety of others) of the Bharatiya Nyay Sanhita, 2023.
2. That this Hon'ble Court is pleased to grant MCR to the accused on
03.04.2025.
3. That the accused is an innocent person and has not committed any
offence and is falsely implicated in the alleged offence.
4. That the offences are Bailable in nature.
5. That the accused is a permanent resident of Flat No. 205, Ganesh
Heights, Pokhran Road No. 2, Thane (W) - 400601 for the last 8 years
and has deep roots in society.
6. That there is no prima facie case against the above accused as the alleged
accident was a mere mishap without any criminal intent.
7. That the offences allegedly committed by the accused are triable by
JMFC.
8. That the accused is ready and will easily be available to face the trial if
released on bail.
9. That there is no likelihood of tampering with prosecution witnesses if
released on bail.
[Link] the accused if released on bail is not likely to abscond.
[Link] the accused is ready to abide by any condition imposed by this
Hon'ble Court.
[Link] the accused is the only earning member of his family consisting of
his wife and two school-going children aged 8 and 12 years.
[Link] the offenses alleged by the accused are not punishable with death or
imprisonment of life.
[Link] the accused is ready to furnish reasonable surety to the satisfaction
of this Hon'ble Court.
[Link] no bail application is pending in any court of law except the present
one.
[Link] no recovery is to be made.
[Link] the accused is a 42-year-old software engineer with no previous
criminal record.
[Link] the accused has already cooperated with the investigation and has
provided all necessary documents including driving license, vehicle
registration, and insurance papers.
 [Link] is therefore prayed that the accused kindly may be released on bail on
reasonable surety/or his Personal Bond in the interest of justice and
equity.
FOR THIS ACT OF KINDNESS AND MERCY THE ACCUSED AS IN
DUTY BOUND SHALL EVER PRAY.

Filed in court
Thane
04/04/2025

Advocate for Accused

Adv. Sakshi singh
MAH/8991/2025
904A,Sunteck Grandeur,
Near Andheri Subway
Andheri West
Mumbai-400056
Mob:8291608893
Email:Singh2002sakshiii@[Link]
Q.8 Different types of bail under BNSS 2023
1. Regular Bail
This is the standard bail granted to someone who is already arrested and in
custody
 Can be applied for after being arrested for any offense
 For bailable offenses, it's granted as a matter of right
 For non-bailable offenses, it's granted at the court's discretion based on
factors like crime severity, evidence strength, and flight risk

 Anticipatory Bail

 Allows a person to seek bail in anticipation of arrest

 Must demonstrate reasonable belief of potential arrest for a non-bailable
offense
 Can only be granted by Sessions Court or High Court
 Court may impose conditions like cooperation with investigation
 Protection remains active until trial conclusion unless specified otherwise
 Default Bail
 Also called "statutory bail" or "compulsory bail"
 Granted when investigation isn't completed within prescribed timeframes:
 60 days for offenses punishable up to 10 years
 90 days for offenses punishable beyond 10 years
 This is a right, not discretionary, if the investigation period expires
without a chargesheet
2. Interim Bail
 Temporary bail granted for a limited period
 Usually for urgent personal circumstances (medical emergencies, family
crisis)
 Person must surrender after the specified period unless extended
3. Bail for Bailable Offenses
 Automatic right to bail
 Even the officer-in-charge of a police station can grant it
 Court cannot refuse bail in these cases
 Might require sureties or personal bond
4. Bail for Non-Bailable Offenses
 At the court's discretion
 More stringent conditions may be imposed
 Can be refused for serious offenses, especially those punishable with
death or life imprisonment
 Court considers factors like criminal history, nature of evidence, and
possibility of influencing witnesses
5. Bail with or without Surety/Personal Bond
 Surety Bail: Requires one or more persons to guarantee the accused's
appearance
 Personal Bond: Accused promises to appear without needing guarantors
 Cash Bail: Deposit of money with the court as security