IN THE COURT OF SH.
NAVEEN KUMAR,-I, CIVIL JUDGE,
SENIOR DIVISION, FARIDABAD COURTS, HARYANA
CS NO.____________/2025
IN THE MATTER OF:
Sh. Rakesh Binjola … Plaintiff
Versus
Shri Umesh Chander Sinha & Ors. … Defendants
WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT no-1 &
2 TO THE SUIT FILED BY THE PLAINTIFF.
MOST RESPECTFULLY SHOWETH:
PRELIMINARY OBJECTIONS:
1. That the present suit is not maintainable and liable to be
dismissed as the plaintiff has not come with clean hands and
has suppressed the material facts of the case.
2. That the present suit is not maintainable and liable to be
dismissed as there is no cause of action arose to file the present
suit.
3. That the present suit is not maintainable and liable to be
dismissed as the present suit is abuse to process of law.
4. That the present suit is not maintainable and liable to be
dismissed for joinder and non-joinder of parties.
5. That the present suit is not maintainable and liable to be dismissed as the
plaintiff has cheated the answering defendant , therefore the defendant no-
2 has filed complaint against the plaintiff for committed the offence of
cheating with the answering defendant in fraudulent manner and has
grabbed the hardened amount. It is submitted that the plaintiff has
cheated the defendants firstly by preparing agreement to sell and
purchase instead of Loan Agreement by giving false assurances and
promised to the defendant No.1 as the said agreement to sell and
purchase has been prepared as formal agreement and there is no need to
use the same.
6. That the present suit is not maintainable and liable to be dismissed
because the defendant No.1 has sent legal notice to the plaintiff and his
partners.
7. That the present suit is not maintainable and liable to be dismissed as the
plaintiff has not affixed the proper and requisite court fees for trial and
entertain the present suit, hence present suit is liable to be dismissed, under
Order 7 Rule 11.
8. That the present suit is not maintainable and liable to be dismissed as the
present suit doesn’t contain the verification under Order 7, Rule 11 of the
Civil Procedure Code (CPC), as verification is a mandatory requirement
for the plaint to be legally valid. Under Order 6, Rule 15 of the CPC, every
plaint must be verified by the plaintiff or an authorized person in the
manner prescribed. If the plaint is not verified or improperly verified, the
court may reject the plaint on the grounds of non-compliance with this
procedural requirement.
PARAWISE REPLY:
1. That the contents of the para No.1 of the suit are wrong
hence denied specifically till producing the evidence.
2. That the contents of the para No.2 of the suit are wrong
hence denied specifically till producing the evidence.
3. That in reply to the para No.3 of the suit are wrong hence
denied specifically. It is submitted that the defendant No.1 is
the victim of the plaintiff , allegedly prepared the
agreement to sell and purchased instead of loan agreement.
4& 5. That in reply to para No.4 & 5 of the suit, the relative of
defendant was in need money, so the loan of Rs.25,00,000/-
has been taken from the plaintiff and his associate/partner,
since 2019 to 2020. It is specifically denied that the
defendants was need of money for house hold expenses,
since the wife of the defendant No.1 is Govt. officer of
Bihar Government. It is submitted that the wife of the
defendant No.1 never signed any document or agreement to
sell and purchase as alleged. The plaintiff and his associate
had given an amount of Rs.15,00,000/- (Rupees fifteen lakhs
)to the defendant No.1 as loan, which will be refundable.
6. That the contents of the para No.6 of the suit are matter of
record.
7. That the contents of the para No.7 of the suit are totally
wrong and hence denied. It is specifically wrong and denied
that the defendant No.1 assured the plaintiff to return the
money very soon which the plaintiff believed as he had very
good reputation in the society.
8. That the contents of the para No.8 of the suit are totally
wrong and hence denied.
9. That in reply to para No.9 of the suit, the defendant No.1
had taken loan of Rs.10,00,000/- from the plaintiff and his
associates for admission fees and expenses of his relative. It
is totally wrong and denied that the plaintiff denied to pay or
lend him any friendly loan and asked him to make payment
of due money which he took from the plaintiff.
10. That the contents of para No.10 of the suit are wrong and
hence denied. It is submitted that the defendant No.1 had
taken only Rs.25,00,000/- from the plaintiff and his
associates, which will be refundable. The defendant No.1
never demanded any other money from the plaintiff, so the
question of denied does not arise.
11. That the contents of the para No.11 of the suit are totally
wrong, incorrect and hence denied in toto. It is specifically
wrong and denied that the defendant No.1 again approached
the plaintiff with the same request and offered the plaintiff
his vacant residential plot bearing No.45, Block-E,
measuring 200 sq. yards situated at residential colony known
as Dayal Bagh Colony village Lakkarpur, Faridabad,
Haryana, which he wanted to sell as he is the dire need of
money for his household, he offered the plaintiff to buy the
plot as by which he can get some money for his household.
It is submitted that the defendant No.1 has not approached
the plaintiff for further loan against his property and the
plaintiff has prepared the alleged agreement to sell and
purchased got signed from the defendant No.1 without
going through the contents of the same false assurance to
the defendant No.1 as the same has been prepared for
formal agreement against alleged loan of Rs.25,00,000/-
(Rupees twenty five lakhs only).
12. That the contents of the para No.12 of the suit are wrong
and hence vehemently denied. it is specifically denied that
the defendant No.1 requested the plaintiff to help him by
purchasing the plot, as he wants to save dealer commission
and this will also lead to his reputation getting tarnish and
that will be setback to his and his family reputation and kept
requesting plaintiff to help me by purchasing the plot which
the plaintiff denied but defendant No.1, kept on pressurizing
him to help him as a friend as he and his family need money
and they are in dire need of money.
13. That the contents of the para No.13 of the suit are totally
wrong and hence denied. It is specifically denied that after
lot of persuasion and request from defendant No.1 the
plaintiff agreed to help him in getting his plot sold to one of
his known friend Mr. Mahesh Kumar Saraf R/o 33-A,
Pocket B, SFS DDA Flats, Mayur Vihar, Phase III, New
Delhi. It is submitted that the defendant never sold his plot
bearing No.45, Block-E, measuring 200 sq. yards situated at
residential colony known as Dayal Bagh Colony village
Lakkarpur, Faridabad, Haryana and asked him if he is
interested to buy the plot.
14. That the contents of the para No.14 of the suit are totally
wrong and hence denied. It is specifically submitted no one
i.e. plaintiff and his associates ever visit to the suit property.
15. That the contents of the para No.15 of the suit are totally
wrong and hence denied. It is submitted that the plot bearing
No.45, Block-E, measuring 200 sq. yards situated at
residential colony known as Dayal Bagh Colony village
Lakkarpur, Faridabad, Haryana belongs to the defendant
No.1 and his wife, who is residing in Patna Bihar and never
signed the alleged agreement to sell, which has been
prepared the plaintiff in order to grab the plot of the
defendant No.1 and his wife since the said plot of land is
about five crores. It is submitted that the defendant No.1
has returned an amount of Rs.36,60,000/-(Rupees thirty six
lakhs, sixty thousand only) instead of Rs.25,00,000/-,
which has been taken by the defendant No.1 from the
plaintiff and his associates. It is submitted that the plaintiff
has hatched conspiracy with Ravinder Kumar Mishra got
signed of the defendant No.1 on the alleged agreement of
sale and purchase by giving false assurance and promises to
the defendant No.1.
16. That in reply the contents of the para no.16 of the suit, the
defendant No.1 has handed over the original sale deed of the
said plot bearing No.45, Block-E, measuring 200 sq. yards
situated at residential colony known as Dayal Bagh Colony
village Lakkarpur, Faridabad, Haryana to the plaintiff and
his associates for the purpose of security against the loan of
Rs.25,00,000/-(Rupees twenty five lakhs only) and after
returning the above said loan amount of Rs.25,00,000/-
(Rupees twenty five lakhs only) to the plaintiff and his
associates, the defendant No.1 demanded the original
document/ sale deed , but the plaintiff started tried to extort
the money from the innocent defendant No.1 being the
Advocate by profession the plaintiff has misused his
profession since Advocate, though the defendant has also
paid interest of Rs.11,60,000/-(Rupees eleven lakhs sixty
thousand only) against the loan of Rs.25,00,000/- (Rupees
twenty five lakhs). The plaintiff very well known that the
said property is joint property and therefore the plaintiff
forged the signature of the defendant No.2 in order to grab
the said plot. However the defendant No.2 was not present in
Delhi. The allegations levelled in this para are totally false
and concocted.
17. That the contents of the para No.17 of the suit are wrong ,
hence denied as bundle of lie as the plaintiff had taken the
original sale deed of the said plot of land and thereafter the
prepared the alleged agreement for sale and purchase and
got the signature of the defendant No.1 by giving false
assurances to him. It is specifically denied that purposed
buyers jointly have denied for the proposed transaction. Rest
of the para are wrong and denied.
18. That the contents of the para No.18 of the suit are totally
wrong and hence denied. It is submitted that the plaintiff
has prepared the agreement of sale and purchase instead of
loan agreement with malafide and dishonest intention to
grab the plot of the defendant No.1 and 2 only paid
Rs.25,00,000/- as loan to the defendant No.1, which has
been returned i.e. Rs.25,00,000/- (Rupees twenty five
lakhs) alongwith Rs.11,60,000/-(Rupees eleven lakhs sixty
thousand only) to the plaintiff and his associate. The
copy of the payments given to the plaintiff and his
associates are annexed herewith.
19. That the contents of the para No.19 of the suit are totally
wrong and hence denied. It is wrong and denied that the
plaintiff and other buyer of the property has paid the
consideration as stated in the agreement to sell and purchase
deed and thereafter on various occasions requested for the
registration of the Sale deed.
20. That the contents of the para No.20 of the suit are totally
wrong and hence denied. It is wrong and denied the
defendant No.1 and defendant No.2 and 3 had some
malafide intentions and has always requested for some time
to get registration of documents and execution of contract
firstly by the excuse of Covid pandemic and thereafter by the
on-availability of defendant No.2 due to her job in Patna
Bihar.
21. That in reply to the para No.21, the defendant No.1 has
returned the loan amount to the plaintiff and his associate. It
is specifically denied that the plaintiff immediately
confronted the defendant No.1, who informed that he is
paying this amount as compensation for delay in execution
of the Sale deed.
22. That in reply to para No.22, the daughter of the defendant
No.1 has paid Rs.5,00,000/- against the loan of
Rs.25,00,000/- (Rupees twenty five lakhs). It is specifically
denied that the defendant No.1 is paying this amount as
compensation for delay in execution of the sale deed.
23. That in reply to para No.23, the daughter of the defendant
No.1 has paid Rs.5,00,000/- against the loan of
Rs.25,00,000/- (Rupees twenty five lakhs). It is specifically
denied that the defendant No.1 is paying this amount as
compensation for delay in execution of the sale deed. It is
submitted that since the plaintiff has received an amount of
Rs.5,00,000/- on 29.2.2024 from the daughter of defendant
No.1, therefore the question of unknown person on
31.3.2024 does not arise at all. The plaintiff has received
the payment against the loan, but the plaintiff have bad
intention to grab the amount of the defendants and also grab
the plot/property without paying any amount to the
defendant No.1 and 2 and grabbed the amount of
Rs.25,00,000/- (Rupees twenty five lakhs) and
Rs.11,60,000/-(Rupees eleven lakhs sixty thousand only)
i.e. 36,60,000/- as compensation in lieu of Rs.25,00,000/-
(Rupees twenty five lakhs) as loan alleged sale
consideration.
24. That the contents of the para No.24 of the suit are totally
wrong and hence denied. It is wrong and denied that on
31.5.2024 defendant No.2 and 3 called the plaintiff and
requested to meet him in person. It is wrong and denied that
the plaintiff denied to the request of the defendant No.2 and
3 and asked them to met at day time but due to pressure of
defendant No.2 he allowed the meeting at the place of work
of the wife of plaintiff. It is submitted that the plaintiff called
the defendant No.2 and 3 and arranged the meeting at
Balvant Rai Mehta Vidhya Bhawan, and on 1.6.2024 on
the specific invitation of the plaintiff, the defendant No.2
and 3 visited to the plaintiff at relevant place as fixed by the
plaintiff and the plaintiff refused to return the original sale
deed and demanded Rs.61,00,000/- from the defendant
No.2 and 3. It is submitted that the defendant No.1 is
suffering from cancer and is not able to meet with the
plaintiff. It is submitted that it is the plaintiff , who had
tried to grab the amount of Rs.11,60,000/-(Rupees eleven
lakhs sixty thousand only) as well as property of the
defendants. It is submitted that the plaintiff has false and
baseless allegations against the defendant No.2 and 3. the
defendant No.2 had given complaint against the plaintiff
for forged her signature.
25. That the contents of the para No.25 of the suit are matter of
record.
26. That the contents of the para No.26 of the suit are wrong and
denied for want of knowledge.
27. That the contents of the para No.27of the suit are totally
wrong and denied. It is specifically denied that to the best of
the belief and knowledge of the plaintiff, the defendant No.2
herein has merely tried to shift her civil liability by filing
false, fabricated , frivolous and malicious complaint to the
office of investigating officer of Police Station CR Park. It
is submitted that the plaintiff is an advocate by profession
and has misused his professional conduct to mislead the
Hon’ble Court to grab the money as well as property of the
defendants. The plaintiff have levelled false and baseless
allegations against the defendants in preplanned manner to
grab the amount as well as property of the defendants. It is
submitted that the defendant No.1 never requested the
plaintiff therefore the question of allowing the defendant
No.1 by the plaintiff does not arise at all.
28. That the contents of the para No.28 of the suit are
specifically denied . The plaintiff have made false and
concocted story, in order to grab the property of the
defendant No.1 and 2 and escaped from the offence
committed by forged the signature of the defendant No.2
on the alleged agreement.
29. That in reply to para No.29 of the suit , it is submitted that
the defendant No.2 did not know the Ravinder Kumar
Mishra as she never met with him at the residence of the
plaintiff. It is submitted that defendant No.2 visited the
plaintiff and has demanded Sale Deed of the property
since the defendant No.1 is suffering Cancer , but the
plaintiff has acted in illegal manner with the defendant No.2
and 3. Rest of the para are wrong and hence denied.
30. That the contents of the para No.30 of the suit are totally
wrong and hence denied. It is wrong and denied defendant
No.2 and 3 and common friend Mr. Ravinder Kumar Mishra
approached the plaintiff on 01.06.2024 to pressurize not to
execute the sale agreement and return the original
documents associates with the sale agreement and further
pressurized the plaintiff not to take legal action against the
defendant No.1 and 2 regarding of the execution of sale
deed and fraud and criminal breach of trust and/or
execution of sale Deed done by the Defendant No.1 and 2. It
is further wrong and denied that she also offered plaintiff
money with compound interest from the date of the
agreement which was earlier also committed by the
defendant No.3 to hide the fraud and criminal breach of
trust of defendant No.1 and defendant No.2 and also to stop
plaintiff to take legal remedy to execute the sale agreement
signed by the defendant No.1 and 2 for the residential plot
bearing plot bearing No.45, Block-E, measuring 200 sq.
yards situated at residential colony known as Dayal Bagh
Colony village Lakkarpur, Faridabad, Haryana. It is
submitted that the plaintiff has forged the signature of the
defendant No.2 on the alleged agreement to sale and
purchase and has taken original Sale deed of the plot in
question and on 01.06.2024 the defendant No.1 and 2
visited to the plaintiff and demanded the original sale Deed
of the property, but the plaintiff started act illegally and
unlawfully with the defendant No.2 and 3 and has refused
to return the Sale Deed of the property in question.
31. That the contents of the para-No.31 of the suit are totally
wrong and hence denied. It is wrong and denied and
specifically. It is submitted that defendant No.2 had not
apprehended and threatened Plaintiff not to take legal action
and not pressurize to execute the alleged sale agreement
made by Defendant no.1and 2, who are the joint owner of
the property , Residential plot bearing no. 45, Block-E
measuring 200sq. yards, situated at residential colony known
as Dayal Bagh Colony, Village Lakarpur, Faridabad,
Haryana. It is specifically denied the defendant no. 2 offered
plaintiff to settle the issue of their fraud and criminal breach
of trust by taking the money from them and the compound
interest incurred from the date of the sale agreement till date
to restrain Plaintiff from execution of the sale deed. It is
further denied that Defendant no. 2 has also threatened that if
plaintiff will not take amount from Defendant No. 2 and will
not file the sale agreement and the original associated
documents then she will use her position as registrar to
implicate the plaintiff in some false case. It is also denied
that the plaintiff resisted her offer thereafter in aggression
furiously the Defendant No.2 has filed written false,
frivolous complaint on Letterhead of Nalanda Open
University sent through Email in office of Station House
Officer Police Station CR Park, New Delhi (as told by
Investigating Officer) against the plaintiff with malafide
intention to get plaintiff frame into some criminal offence
for that plaintiff should not take any legal recourse for
execution of the said agreement.
32. That the contents of the para-No.32 of the suit are totally
wrong and hence denied. It is specifically submitted that the
loan agreement is forge and fabricated alleged document
agreement to sell made by the plaintiff and false assurance
was given to the defendant no. 1. That the defendants repay
the loan amount along with interest of the plaintiff and his
partners Rs. 36,60,000/-.
33. That the contents of the para-No.33 of the suit are totally
wrong and hence denied. It is specifically submitted that the
plaintiff took the original sell deed from the defendant
fraudulently for seeing the ownership of alleged sell
agreement and kept the same.
33A. That the defendant No. 1 & 2 execute the collaboration
agreement in the year of 2021 with Yogesh Gupta S/o Sudhir
Gupta R/o H.No. 983 Sector 14 Faridabad to construct the
property bearing No. 45, Block – E, measuring 200sq. yards
situated at residential colony known as Dayal Bagh Colony
village Lakkarpur, Faridabad, Haryana and the collaboration
builder construct the property from ground to fourth floor
before the filing of suit and the plaintiff mispleaded against
the suit property that it is vacant residential plot.
34. That the contents of the para-No.34 of the suit are matter on
record hence, needs no reply. It is specifically that the
defendant is suffering from illness. Therefore, he was unable
to do so.
35. That the contents of the para-No.35 of the suit are totally
wrong and hence denied. It is denied that there is no cause of
action arose against the defendants and in favour of plaintiff.
36. That the contents of the para-No.36 of the suit are matter on
record, hence, needs no reply. It is specifically submitted
that the court fees has not been mentioned in plaint.
36A. That the contents of the para-No.36A of the suit are totally
wrong and hence denied.
37. That the contents of the para-No.37 of the suit are matter on
record, hence, needs no reply.
38. That the contents of the para-No.38 of the suit are wrong and
denied .
REPLY TO THE PRAYER PARA: -
It is therefore most respectfully prayed that the present suit is false
frivolous and concocted and not maintainable in the eye of law, hence,
needs to be dismissed with heavy cost.
DEFENDANT
Through
Counsel
IN THE COURT OF SH. NAVEEN KUMAR,-I, CIVIL JUDGE,
SENIOR DIVISION, FARIDABAD COURTS, HARYANA
CS NO.____________/2025
IN THE MATTER OF:
Sh. Rakesh Binjola … Plaintiff
Versus
Shri Umesh Chander Sinha & Ors. … Defendants
P.S. ___________
AFFIDAVIT
I, Umesh Chandra Sinha, S/o Rewati Raman Prasad , aged about 70
years, residing at Flat No. 102, Sushma Apartment Rajender Nagar,
Road No 10, Patna 800016 (Bihar)., do hereby solemnly affirm and
state on oath as under:
1. That I am the Defendant No. 1 in the accompanying written
statement and well aware of all the relevant facts and
circumstances of the case and as such competent to depose this
affidavit.
2. That the contents of the accompanying complaint statement
may kindly be read as part and parcel of this affidavit as the
same have not been repeated herein for the sake of brevity.
3. That the accompanying complaint has been drafted by my
counsel on my instructions. The contents of the same have been
read over to me in my vernacular and the same have been
understood by me and the same are true and correct.
DEPONENT
Verification:
Verified at Delhi on this _____ day of Feb, 2025 that the contents of
my above affidavit are true and correct to the best of my knowledge
and belief and nothing material has been concealed there from.
DEPONENT
IN THE COURT OF SH. NAVEEN KUMAR,-I, CIVIL JUDGE,
SENIOR DIVISION, FARIDABAD COURTS, HARYANA
CS NO.____________/2025
IN THE MATTER OF:
Sh. Rakesh Binjola … Plaintiff
Versus
Shri Umesh Chander Sinha & Ors. … Defendants
P.S. ___________
AFFIDAVIT
I, Neelam Kumari, aged about 60years W/o Umesh Chand Sinha,
residing at Flat No. 102, Sushma Apartment Rajender Nagar, Road No
10, Patna 800016 (Bihar), do hereby solemnly affirm and state on oath
as under:
1. That I am the Defendant No. 2 in the accompanying written
statement and well aware of all the relevant facts and
circumstances of the case and as such competent to depose this
affidavit.
2. That the contents of the accompanying complaint statement
may kindly be read as part and parcel of this affidavit as the
same have not been repeated herein for the sake of brevity.
3. That the accompanying complaint has been drafted by my
counsel on my instructions. The contents of the same have been
read over to me in my vernacular and the same have been
understood by me and the same are true and correct.
DEPONENT
Verification:
Verified at Delhi on this _____ day of Feb, 2024 that the contents of
my above affidavit are true and correct to the best of my knowledge
and belief and nothing material has been concealed there from.
DEPONENT
IN THE COURT OF SH. NAVEEN KUMAR,-I, CIVIL JUDGE,
SENIOR DIVISION, FARIDABAD COURTS, HARYANA
CS NO.____________/2025
IN THE MATTER OF:
Sh. Rakesh Binjola … Plaintiff
Versus
Shri Umesh Chander Sinha & Ors. … Defendants
P.S. ___________
AFFIDAVIT
I, Piyush Sinha, D/o Sh. Umesh Chand Sinha aged about 30 years,
residing at Flat No. 102, Sushma Apartment Rajender Nagar, Road No
10, Patna 800016 (Bihar)., do hereby solemnly affirm and state on
oath as under:
1. That I am the Defendant No. 3 in the accompanying in
the above named suit and well aware of all the
relevant facts and circumstances of the case and as such
competent to depose this affidavit.
2. That the accompanying written statement has been
drafted by my counsel on my instructions. The contents
of the same have been read over to me in my vernacular
and the same have been understood by me and the same
are true and correct.
3. That the contents of the accompanying complaint
statement may kindly be read as part and parcel of this
affidavit as the same have not been repeated herein for
the sake of brevity.
DEPONENT
Verification:
Verified at Delhi on this _____ day of Feb, 2024 that the contents of
my above affidavit are true and correct to the best of my knowledge
and belief and nothing material has been concealed there from.
DEPONENT
IN THE COURT OF SH. NAVEEN KUMAR,-I, CIVIL JUDGE,
SENIOR DIVISION, FARIDABAD COURTS, HARYANA
CS NO.____________/2025
IN THE MATTER OF:
Sh. Rakesh Binjola … Plaintiff
Versus
Shri Umesh Chander Sinha & Ors. … Defendants
P.S. ___________
REPLY OF URGENT APPLICATION UNDER ORDER 39 RULE 1
& 2 R/W SECTION 151 CPC ON BEHALF OF THE DEFENDANT
1 & 2 FOR EX-PARTE AD INTERIM INJUNCTION.
MOST RESPECTFULLY SHOWETH:
1. That the contents of the para-No.1 of the application is totally
wrong and hence denied. It is specifically submitted that the
plaintiff filed the suit for specific performance of contact alongwith
compensation for delay caused due to delebrate of the defendants
has lead to breach of contract terms and conditions. It is
specifically submitted that the suit is alleged as a forged and
fabricated agreement to sell.
2. That the contents of the para-No2 of the application is totally
wrong and hence denied. It is specifically submitted that the
defendant filed the complaint forged, false and fabricated loan
documents as alleged in sell agreement documents.
3. That the contents of the para-No3 of the application is totally
wrong and hence denied. It is specifically denied that the defendant
no. 2 is an influential person being Registrar of Nalanda Open
University has misused her powers/office stationary and authority
given by Nalanda Open University as a Government Servant/
Public Servant in complaints filed at Police Station CR Park, Delhi
is therefore having good contacts has already created and is still
creating forged, false, fabricated, furious documents of the suit
property and will run away from the hands of the law enforcement
agencies and Indian Judiciary by misusing her power/authority and
office stationery with the contacts available with her to avoid any
possible litigation caused by the acts of the defendants. It is
specifically submitted that the defendant no.2 used her personal
letterhead.
4. That the contents of the para-No4 of the application is totally
wrong and hence denied.
5. That the contents of the para-No5 of the application is totally
wrong and hence denied and liable to be dismissed as alleged loan/
agreement to sell is false documents and has the present ad interim
application be dismissed with heavy cost.
6. That the contents of the para-No6 of the application is totally
wrong and hence denied.
REPLY TO THE PRAYER PARA: -
It is therefore most respectfully prayed that the present application is
false frivolous and concocted and not maintainable in the eye of law,
hence, needs to be dismissed with heavy cost.
DEFENDANT
Through
Counsel
IN THE COURT OF SH. NAVEEN KUMAR,-I, CIVIL JUDGE,
SENIOR DIVISION, FARIDABAD COURTS, HARYANA
CS NO.____________/2025
IN THE MATTER OF:
Sh. Rakesh Binjola … Plaintiff
Versus
Shri Umesh Chander Sinha & Ors. … Defendants
P.S. ___________
AFFIDAVIT
I, Umesh Chandra Sinha, S/o Rewati Raman Prasad & Smt Neelam
Kumari, aged about 70 years, residing at Flat No. 102, Sushma
Apartment Rajender Nagar, Road No 10, Patna 800016 (Bihar)., do
hereby solemnly affirm and state on oath as under:
4. That I am the Defendant No. 1 in the accompanying
application and well aware of all the relevant facts and
circumstances of the case and as such competent to depose this
affidavit.
5. That the contents of the accompanying complaint statement
may kindly be read as part and parcel of this affidavit as the
same have not been repeated herein for the sake of brevity.
6. That the accompanying complaint has been drafted by my
counsel on my instructions. The contents of the same have been
read over to me in my vernacular and the same have been
understood by me and the same are true and correct.
DEPONENT
Verification:
Verified at Delhi on this _____ day of Feb, 2024 that the contents of
my above affidavit are true and correct to the best of my knowledge
and belief and nothing material has been concealed there from.
DEPONENT
IN THE COURT OF SH. NAVEEN KUMAR,-I, CIVIL JUDGE,
SENIOR DIVISION, FARIDABAD COURTS, HARYANA
CS NO.____________/2025
IN THE MATTER OF:
Sh. Rakesh Binjola … Plaintiff
Versus
Shri Umesh Chander Sinha & Ors. … Defendants
P.S. ___________
AFFIDAVIT
I, Neelam Kumari, aged about 60years W/o Umesh Chand Sinha,
residing at Flat No. 102, Sushma Apartment Rajender Nagar, Road No
10, Patna 800016 (Bihar), do hereby solemnly affirm and state on oath
as under:
4. That I am the Defendant No. 3 in the accompanying
application and well aware of all the relevant facts and
circumstances of the case and as such competent to depose this
affidavit.
5. That the contents of the accompanying complaint statement
may kindly be read as part and parcel of this affidavit as the
same have not been repeated herein for the sake of brevity.
6. That the accompanying complaint has been drafted by my
counsel on my instructions. The contents of the same have been
read over to me in my vernacular and the same have been
understood by me and the same are true and correct.
DEPONENT
Verification:
Verified at Delhi on this _____ day of Feb, 2024 that the contents of
my above affidavit are true and correct to the best of my knowledge
and belief and nothing material has been concealed there from.
DEPONENT
IN THE COURT OF SH. NAVEEN KUMAR,-I, CIVIL JUDGE,
SENIOR DIVISION, FARIDABAD COURTS, HARYANA
CS NO.____________/2025
IN THE MATTER OF:
Sh. Rakesh Binjola … Plaintiff
Versus
Shri Umesh Chander Sinha & Ors. … Defendants
P.S. ___________
AFFIDAVIT
I, Piyush Sinha, D/o Sh. Umesh Chand Sinha aged about 30 years,
residing at Flat No. 102, Sushma Apartment Rajender Nagar, Road No
10, Patna 800016 (Bihar)., do hereby solemnly affirm and state on
oath as under:
1. That I am the Defendant No. 3 in the accompanying application
and well aware of all the relevant facts and circumstances of the
case and as such competent to depose this affidavit.
2. That the contents of the accompanying complaint statement may
kindly be read as part and parcel of this affidavit as the same have
not been repeated herein for the sake of brevity.
3. That the accompanying complaint has been drafted by my counsel
on my instructions. The contents of the same have been read over
to me in my vernacular and the same have been understood by me
and the same are true and correct.
DEPONENT
Verification:
Verified at Delhi on this _____ day of Feb, 2024 that the contents of
my above affidavit are true and correct to the best of my knowledge
and belief and nothing material has been concealed there from.
DEPONENT
