IN THE HON’BLE COURT OF MS.
TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI
SUIT NO._______ OF 2022
IN THE MATTER OF:
SH. KAMAL KUMAR NARULA …PLAINTIFF
VERSUS
SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS
REJOINDER TO THE WRITTEN STATEMENT FILED ON BEHALF OF
DEFENDANTS.
REPLY TO THE PRELIMINARY OBJECTIONS
1. That the contents of para no.1 of the PO are
wrong, false and hence denied. It is
submitted that the plaintiff has good prima
facie case in his favour.
2. That the contents of para no.2 of the PO are
wrong, false and hence denied. It is
submitted that the plaintiff has good prima
facie case in his favour.
3. That the contents of para no.3 of the PO are
wrong, false and hence denied. It is
submitted that the plaintiff has good prima
facie case in his favour and plaintiff is the
owner of the suit property as plaintiff had
purchased the suit property from his own
funds. It is further submitted that the
plaintiff has every right and title to file
and institute the present suit against the
defendants. It is submitted that the
plaintiff has filed the present suit on
arising valid cause of action in his favour,
suit is very much within limitation and the
plaintiff has affixed the proper court fee.
4. That the contents of para no.4 of the P.O.
are wrong, false and hence denied. It is
submitted that the plaintiff has filed the
present suit on arising valid cause of action
in his favour, suit is very much within
limitation and the plaintiff has affixed the
proper court fee. It is further submitted
that the plaintiff has filed the legal and
valid site plan.
5. That the contents of para no.5 of the P.O.
are wrong, false and hence denied. It is
submitted that the plaintiff has filed the
present suit on arising valid cause of action
in his favour.
6. That the contents of para no.6 of the PO are
wrong and denied. It is specifically denied
that the plaintiff has no cause of action to
file and maintain the present suit. It is
submitted that the plaintiff has stated true
and material facts in the plaint and nothing
material has been concealed from the hon’ble
court. It is submitted that the plaintiff has
every cause of action to file the present
suit against the defendants.
7. That the contents of para no.7 of the P.O.
are wrong, false and hence denied. It is
submitted that the plaintiff has filed the
present suit on the basis of true facts and
has not concealed or suppressed any material
facts from this Hon’ble Court. It is
submitted that the defendants are misguiding
this Hon’ble court by mentioning unnecessary
and false and vague averments.
8. That the contents of para no.8 of the PO are
wrong and denied. It is specifically denied
that the plaintiff has no cause of action to
file and maintain the present suit. It is
submitted that the plaintiff has stated true
and material facts in the plaint and nothing
material has been concealed from the hon’ble
court. It is submitted that the plaintiff has
every cause of action to file the present
suit against the defendants.
9. That the contents of para no.9 of the PO are
wrong and denied. It is submitted that the
plaintiff has stated true and material facts
in the plaint and nothing material has been
concealed from the hon’ble court. It is
submitted that the defendant again and again
mentioning the same averments in all the para
which shows that defendant has nothing to
explain to the plaint of the plaintiff.
10. That the contents of para no.10 of the PO are
wrong and denied. It is submitted that the
plaintiff has stated true and material facts
in the plaint and nothing material has been
concealed from the hon’ble court. It is
submitted that the plaintiff has every cause
of action to file the present suit against
the defendants.
11. That the contents of para no.11 of the PO are
wrong and denied. It is specifically denied
that the mother Smt. Chanchal Rani has ever
purchased any property from her own funds as
she was a house wife throughout her life. It
is submitted that the plaintiff has stated
true and material facts in the plaint and
nothing material has been concealed from the
hon’ble court on the contrary the defendants
are making false and imaginary averments in
the para under reply. It is submitted that
the plaintiff has every cause of action to
file the present suit against the defendants.
12. That the contents of para no.12 of the PO are
wrong and denied. It is submitted that the
suit property is belongs to the plaintiff and
the sharing of the same cannot be allowed
under any circumstances. It is submitted that
the plaintiff has stated true and material
facts in the plaint and nothing material has
been concealed from the hon’ble court. It is
submitted that the plaintiff has every cause
of action to file the present suit against
the defendants.
13. That the contents of para no.13 of the PO are
wrong and denied. It is specifically denied
that the suit of the plaintiff is not
maintainable and the same is hit by specific
relief act. It is submitted that the
plaintiff has stated true and material facts
in the plaint and nothing material has been
concealed from the hon’ble court. It is
submitted that the plaintiff has every cause
of action to file the present suit against
the defendants.
14. That the contents of para no.14 of the PO are
wrong and denied.
15. That the contents of para no.15 of the PO are
wrong and denied. It is specifically denied
that the suit of the plaintiff is hit by
provision of section 41(h) of specific relief
act. It is submitted that the plaintiff has
stated true and material facts in the plaint
and nothing material has been concealed from
the hon’ble court. It is submitted that the
plaintiff has every cause of action to file
the present suit against the defendants.
16. That the contents of para no.16 of the PO are
wrong and denied. It is specifically denied
that the plaintiff has no cause of action to
file and maintain the present suit. It is
submitted that the plaintiff has stated true
and material facts in the plaint and nothing
material has been concealed from the hon’ble
court. It is submitted that the plaintiff has
correctly valued the suit for the purpose of
jurisdiction and court fees and the plaintiff
has affixed the appropriate court fees on the
plaint.
17. That the contents of para no.17 of the PO are
wrong and denied. It is specifically denied
that the plaintiff has not made the parties
to the suit according to the law, the
plaintiff has correctly filed the suit
against all the defendants as all the
defendants are illegally occupying the suit
premises of the plaintiff.
REJOINDER TO WRITTEN STATEMENT
1. That the contents of para no.1 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity.
2. That the contents of para no.2 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
3. That the contents of para no.3 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
4. That the contents of para no.4 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
5. That the contents of para no.5 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
6. That the contents of para no.6 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
7. That the contents of para no.7 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
8. That the contents of para no.8 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
9. That the contents of para no.9 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
10. That the contents of para no.10 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity.
11. That the contents of para no.11 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity. Let The defendant may be put to strict
proof of the same.
12. That the contents of para no.12 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity.
13. That the contents of para no.13 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity.
14. That the contents of para no.14 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity.
15. That the contents of para no.15 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity.
16. That the contents of para no.16 of the W.S. are
wrong and denied and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity.
17. That the contents of para no.17 of the W.S.
needs no rejoinder and those of the plaint are
reaffirmed and reiterated to be correct which
are not being repeated herein for the sake of
brevity.
18-21. That the contents of para no.18-21 of the
W.S. needs no rejoinder and those of the
plaint are reaffirmed and reiterated to be
correct which are not being repeated herein
for the sake of brevity.
That the prayer clause of the defendants is
wrong and denied and that of the contents of
prayer clause of plaint is reaffirmed and
reiterated to be correct and the prayer of the
plaintiff may uphold in view of the facts
stated in the present rejoinder.
PRAYER
It is, thisefore, prayed that the suit of
plaintiff may be decreed as prayed for.
Delhi Plaintiff
Dated
Through
DARSHAN SINGH & ASSOCIATES
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI
SUIT NO._______ OF 2022
IN THE MATTER OF:
SH. KAMAL KUMAR NARULA …PLAINTIFF
VERSUS
SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS
AFFIDAVIT
I, KAMAL KUMAR NARULA S/O LT. SH. JANKI DASS
NARULA R/O L-56, ANDHA MUGHAL, PRATAP NAGAR, DELHI-
110007, do hiseby solemnly affirm and declare as
under:
1. That the deponent is the plaintiff in the above
noted matter and I am fully conversant with the
facts of the case.
2. That the accompanying rejoinder has been drafted
by my counsel on my direction and as per my
instructions and read over the contents before me
in vernacular language and I understood the same
and which is correct as per my knowledge and the
same may be read as part and parcel of this
affidavit and the same are not repeated hise for
the sake of brevity.
DEPONENT
VERIFICATION: -
Verified at Delhi on this ____ day of , 2022,
that the contents of this affidavit are true and
correct to the best of my knowledge and belief and
nothing has been concealed therefrom.
DEPONENT
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI
SUIT NO._______ OF 2022
IN THE MATTER OF:
SH. KAMAL KUMAR NARULA …PLAINTIFF
VERSUS
SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS
REPLY TO THE APPLICATION U/O VII RULE 11 READ WITH
SECTION 151 OF CPC FILED ON BEHALF OF DEFENDANTS.
MOST RESPECTFULLY SHOWETH:
ON MERITS
1. That the contents of para no.1 of the application
require no comments except to the mentioning of false
and vague suit.
2. That the contents of the para no.2 of the
application are false, vague, fabricated, wrong and
incorrect hence denied in toto.
3. That the contents of the para no.3 of the
application are false, wrong and incorrect hence
denied. It is submitted that the plaintiff has filed
the present suit very much within the limitation.
4. That the contents of the para no.4 of the
application are false, wrong and incorrect hence
denied. It is submitted that the plaintiff has filed
the present suit with his every right to do and the
suit is very much maintainable.
5. That the contents of the para no.5 of the
application are wrong, false and incorrect hence
denied in toto.
6. That the contents of para no.6 of the
application are wrong, false and incorrect and hence
denied. It is submitted that the plaintiff is having
every cause of action to file and institute the
present suit against the defendants.
7. That the contents of the para no.7 of the
application are false, wrong and incorrect hence
denied in toto. It is submitted that the plaintiff
has come before this Hon’ble court with clean hands
and nothing has been concealed from this Hon’ble
court by the plaintiff.
8. That the contents of the para no.8 of the
application are false, wrong and incorrect hence
denied in toto. It is submitted that the defendants
have unnecessarily concocted the false story and
mentioned under the para under reply.
9. That the contents of the para no.9 of the
application are false, wrong and incorrect hence
denied in toto.
10. That the contents of the para no.10 of the
application are false, wrong and incorrect hence
denied in toto.
11. That the contents of the para no.11 of the
application are false, wrong and incorrect hence
denied in toto.
12. That the contents of the para no.7 of the
application are false, wrong and incorrect hence
denied in toto.
13. That the contents of the para no.7 of the
application are false, wrong and incorrect hence
denied in toto.
14. That the contents of the para no.14 of the
application are false, wrong and incorrect hence
denied in toto. It is submitted that the suit of the
plaintiff is not hit by section 31 of specific relief
act.
15. That the contents of the para no.15 of the
application are false, wrong and incorrect hence
denied in toto. It is submitted that the suit of the
plaintiff is not hit by section 41(h) of specific
relief act.
16. That the contents of the para no.16 of the
application are false, wrong and incorrect hence
denied in toto. It is submitted that the plaintiff
has correctly valued the suit for the purpose of
jurisdiction and court fees and appropriate court
fees has been affixed by the plaintiff on the plaint
17. That the contents of the para no.17 of the
application are false, wrong and incorrect hence
denied in toto. It is submitted that the plaintiff
has filed the present suit against the bonafide
defendants.
18. That the contents of the para no.18 of the
application are false, wrong and incorrect hence
denied in toto.
That the last para is a prayer to this
Hon’ble court which is absolutely illegal, arbitrary,
malafide and cannot be allowed under any
circumstances.
PRAYER
It is, therefore, most respectfully prayed that
the application of the defendants is liable to be
dismissed with compensatory cost.
Delhi PLAINTIFF
Dated Through
DARSHAN SINGH AND ASSOCIATES
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI
SUIT NO._______ OF 2022
IN THE MATTER OF:
SH. KAMAL KUMAR NARULA …PLAINTIFF
VERSUS
SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS
AFFIDAVIT
I, SH. KAMAL KUMAR NARULA S/O LT. SH. JANKI DASS
NARULA R/O L-56, ANDHA MUGHAL, PRATAP NAGAR, NEW
DELHI-110007, do hereby solemnly affirm and declare
as under:-
1. That I am the plaintiff in the above noted case
and well conversant with facts and circumstances
of the case and as such I am competent to swear
the affidavit.
2. That the reply to the application U/o 7 rule 11
read with section 151 of CPC has been drafted by
the counsel under my instructions which are
correct and the contents of the same may be read
as the part and parcel of this affidavit as same
are not being repeated herein for the sake of
brevity.
DEPONENT
VERIFICATION: -
Verified at Delhi on this ____ day of __,
2022, that the contents of this affidavit are true
and correct to the best of my knowledge and belief
and nothing has been concealed therefrom.
DEPONENT
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI
SUIT NO._______ OF 2022
IN THE MATTER OF:
SH. KAMAL KUMAR NARULA …PLAINTIFF
VERSUS
SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS
REPLY TO THE APPLICATION U/O I RULE 10(2) READ WITH
SECTION 151 OF CPC FILED ON BEHALF OF DEFENDANTS FOR
DELETING THE DEFENDANTS NO.2 TO 4.
MOST RESPECTFULLY SHOWETH:
ON MERITS
1. That the contents of para no.1 of the application
require no comments except to the mentioning of false
and vague suit.
2. That the contents of the para no.2 of the
application are false, vague, fabricated, wrong and
incorrect hence denied in toto. It is submitted that
the defendants are in illegal possession of the suit
property hence all the defendants are necessary party
to the suit.
3. That the contents of the para no.3 of the
application are false, wrong and incorrect hence
denied. Let the defendants put to the strict proof of
the same.
4. That the contents of the para no.4 of the
application are false, wrong and incorrect hence
denied.
5. That the contents of the para no.5 of the
application are wrong, false and incorrect hence
denied in toto.
That the last para is a prayer to this
Hon’ble court which is absolutely illegal, arbitrary,
malafide and cannot be allowed under any
circumstances.
PRAYER
It is, therefore, most respectfully prayed that
the application of the defendants is liable to be
dismissed with compensatory cost.
Delhi PLAINTIFF
Dated Through
DARSHAN SINGH AND ASSOCIATES
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI
SUIT NO._______ OF 2022
IN THE MATTER OF:
SH. KAMAL KUMAR NARULA …PLAINTIFF
VERSUS
SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS
AFFIDAVIT
I, SH. KAMAL KUMAR NARULA S/O LT. SH. JANKI DASS
NARULA R/O L-56, ANDHA MUGHAL, PRATAP NAGAR, NEW
DELHI-110007, do hereby solemnly affirm and declare
as under:-
1. That I am the plaintiff in the above noted case
and well conversant with facts and circumstances
of the case and as such I am competent to swear
the affidavit.
2. That the reply to the application U/o I rule
10(2) read with section 151 of CPC has been
drafted by the counsel under my instructions
which are correct and the contents of the same
may be read as the part and parcel of this
affidavit as same are not being repeated herein
for the sake of brevity.
DEPONENT
VERIFICATION: -
Verified at Delhi on this ____ day of __,
2022, that the contents of this affidavit are true
and correct to the best of my knowledge and belief
and nothing has been concealed therefrom.
DEPONENT
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI
SUIT NO._______ OF 2022
IN THE MATTER OF:
SH. KAMAL KUMAR NARULA …PLAINTIFF
VERSUS
SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS
INDEX
S.NO. PARTICULARS PAGES C.FEE
1. Rejoinder to the WS along with affidavit
2. Reply to application U/O 7 R11, along with
affidavit
3. Reply to application under order 1 rule
10( 2) along with affidavit
DELHI PLAINTIFF
DATED: THROUGH
DARSHAN SINGH & ASSOCIATES
