IN THE HON’BLE COURT OF SHRI NARESH KUMAR LAKA

LD.DISTRICT JUDGE: CENTRAL : TIS HAZARI COURT

DELHI.
SUIT NO.CS-DJ/1302/2022
IN RE:

SANJAY KUMAR BANSAL & ORS. … PLAINTIFFS

VERSUS
MUKESH BILLA … DEFENDANT

DOH :

WRITTEN STATEMENT ON BEHALF OF THE

DEFENDANT WITH COUNTER CLAIM

RESPECTFULLY SHOWETH:

PRELIMINARY OBJECTIONS:

1. THAT the suit as filed and framed is legally not

maintainable and the same is gross abuse and misuse of
process of law and has been filed by the plaintiffs with
ulterior motives and designs, therefore, the suit deserves
to be dismissed with heavy costs.

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2. THAT the suit is without any cause of action and no

cause of action has arisen in favour of the plaintiffs and
 against the answering defendant and the suit is liable to
be dismissed under Order VII Rule 11 CPC.

3. THAT the suit is legally barred and hit by the provisions

of Section 34 of the Specific Relief Act. Section 34 of
the Specific Relief Act, provides :
“34. Discretion of court as to declaration of status or
right.—
Any person entitled to any legal character, or to any
right as to any property, may institute a suit against
any person denying, or interested to deny, his title to
such character or right, and the court may in its
discretion make therein a declaration that he is so
entitled, and the plaintiff need not in such suit ask for
any further relief: Provided that no court shall make
any such declaration where the plaintiff, being able to
seek further relief than a mere declaration of title,
omits to do so. 14 Explanation.—A trustee of property
is a “person interested to deny” a title adverse to the
title of some one who is not inexistence, and for
whom, if in existence, he would be a trustee.”

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4. THAT the suit as filed by the plaintiffs is legally barred

and hit by the provisions of Article 27 of the Limitation
 Act,1963, which provides the period of 12 years for
recovery of possession and admittedly, the defendant is in
lawful physical possession of the suit property in question
since after his birth in the year 1965, while the suit has
been filed in the year 2022 by the plaintiffs on the basis
of forged, fabricated, illegal and invalid documents,
having no legality or sustainability. Admittedly, over a
period of 05 decades have elapsed and now the present
false and frivolous suit for recovery of possession etc has
been filed, with cooked up story and allegations. Hence,
the suit is barred by limitation and deserves to be
dismissed outrightly.

5. THAT the present suit as filed by the plaintiffs is also

legally not maintainable as the plaintiffs have got no
locus standi to file the present suit. The suit is thus
barred by the landmark judgment of the Hon’ble Supreme
Court in in “Anathula Sudhakar vs. P.Buchi Reddy (dead)
by LRs & Ors.” (2008) 4 SCC 594, as admittedly the
plaintiffs are neither the owner nor in possession of the
suit property or even any portion of the property
no.1051,1052,1053, Main Bazar, Pahar Ganj, New Delhi.
The plaintiffs have to seek decree of declaration and
possession while they have

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 wrongly filed the present suit and as such the suit is not
maintainable. Thus the present suit is liable to be
dismissed outrightly.

6. THAT the mischief and unscrupulous conduct of the

plaintiffs is clearly visible from the fact that the plaintiffs
have deliberately and mischievously filed a false and
frivolous suit with wrong and incorrect name of the
defendant. The plaintiffs have wrongly arrayed the name
of the defendant as “Mukesh Birla” in the title of the suit.
This has resulted into non-service of the summons/notice
as issued from this Hon’ble Court and the plaintiffs
succeeded in getting the exparte orders against the
defendant from this Hon’ble Court, on the basis of
material fraud as committed by the plaintiffs upon the
defendant and this Hon’ble Court. It is fortunate that the
defendant got knowledge when the case had reached the
stage of arguments and upon applications filed by the
defendant, this Hon’ble Court was pleased to set aside the
exparte orders and allowed the defendant to
defend/contest the suit on merits subject to heavy costs as
imposed by this Hon’ble Court. In this way, the
fraudulent and mischief acts and deeds as committed by
the plaintiffs were foiled and thwarted, but resulted into
unnecessary harassment and economic burden of costs of
Rs.15,000/-.

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7. THAT the plaintiffs have no locus standi to file the
present suit, as the plaintiffs are neither the owners nor
ever in physical possession of the suit property nor any
legal title and ownership conferred upon them on the
basis of the alleged documents, which itself have no legal
significance and enforceability in the eyes of law as the
Vendors of the alleged Sale Deeds themselves had no
legal right, title or interest over the suit property and were
not legally competent to pass on any right, title, or
interest and to execute any such alleged documents. The
defendant is in fact has already acquired the legal title
and ownership by way of inheritance after demise of his
mother and also by way of adverse possession. Hence,
the suit as filed by the plaintiffs is liable to be dismissed
outrightly.

8. THAT the plaintiffs have not come before this Hon’ble

Court with clean hands and have suppressed and
concealed the true material facts from this Hon’ble Court.
In this respect it is submitted that the defendant is the
exclusive owner in possession of the property bearing
no.1054, situated at Main Bazar, Pahar Ganj, New
Delhi.55 and there are three other properties bearing
No.1051, 1052, 1053 (which are suit property in the
present suit), and all four properties no.1051, 1052, 1053
 and 1054 are built together as one property, without any
partition wall or

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division. The said built up four properties no.1051, 1052,

1053 and 1054 are existing since a very long time and are
more specifically shown in the site plan annexed. The
said properties no.1051, 1052, 1053 and 1054 (hereinafter
referred to as the “subject properties”) built as one single
property are in lawful physical possession, use and
occupation and enjoyment of the defendant since many
decades, without any interference, obstruction or
objection from any one.

9. THAT the aforesaid subject properties were previously in

lawful use and occupation of the defendant, and the
defendant born on 03.07.1965 and since then the
defendant has been residing and occupying the subject
properties. The father of the defendant died in the year
1993, while the mother of the defendant died in the year
2001. It is submitted that there are civic and other
amenities and the subject property are subject to payment
of the property/house tax. It is submitted that the
defendant has been regularly paying the property/house
tax as well as the electricity and water bills and further
the telephone bills installed/provided at the subject
property. The defendant has already filed voluminous
 record/documents of payment of electricity & water bills,
telephone bills and the property/house tax before this
Hon’ble Court. The

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defendant has also filed various complaints as made to

the police and other authorities. All the said documents
as filed by the defendant establish the lawful physical
possession of the subject property including suit
properties no.1051, 1052 and 1053, alongwith property
no.1054, since a long time and further that the amenities
of electricity, water, property tax, telephone connections
are installed in the name of the defendant. It also
establish that neither the plaintiffs nor any person(s) from
whom the plaintiffs allegedly purchased the properties
were ever been in possession. The claim of the plaintiffs
is solely on the basis of the alleged Sale Deeds, which
have no legal significance as the Vendors of the alleged
Sale Deed were not possessing any legal right and title
over the subject properties and were not legally
competent to pass over the title and execute the alleged
Sale Deeds.

10. THAT initially the aforesaid property no.1051, 1052 and

1053 was jointly owned by Shri Roshan Lal Kalra and
Smt.Lila Devi and they had sold and transferred the said
property in favour of Smt.Kesara Bai w/o late Shri
Govind Ram through a registered Sale Deed dated
19.05.1966. It is submitted that Smt.Kesara Bai was the
maternal grand mother (Naani) of the defendant. It is
further submitted

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that during her life time Smt.Kesara Bai had devised and
bequeathed the said property in favour of her daughter i.e.
mother of the defendant, namely Smt.Sumitra Devi wife
of late Shri Madan Lal Billa and executed a Will dated
28.07.1967. The maternal grand mother of the defendant
namely Smt.Kesara Bai however died on 01.07.1972 and
thus by virtue of the said Will dated 28.07.1967, the
defendant’s mother Smt.Sumitra Devi became the sole
and absolute legal owner of the property in question.
However, the defendant’s mother got the aforesaid Will
dated 28.07.1967 probated, in Probate Case No.132/1972,
under Sec.289 of Indian Succession Act. It is submitted
that since the defendant was born on 03.07.1965,
therefore, the defendant has been residing at the said
property since from his birth, earlier with his parents and
after their demise, the said property is in exclusive
possession of the defendant and the defendant has been
enjoying and occupying the said property being the
exclusive legal owner, by way of inheritance from his
 mother Smt.Sumitra Devi, who died intestate in the year
2001.

11. THAT after the demise of his mother, the defendant has
got transferred all installed connections in his name and

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has been regularly paying MTNL, water and electricity

bills alongwith property tax to the MCD, in his own
name.

12. THAT it is submitted that the defendant’s mother

Smt.Sumitra Devi w/o late Shri Madan Lal Billa died
intestate and during her life time she had never executed
any alleged Sale Deed dated 08.12.2000 and the alleged
Sale deed dated 08.12.2000 is only a piece of forged and
fabricated document. The defendant’s mother was an
infirm, old aged and seriously ill and bed ridden and she
was an illiterate lady and the thumb impressions on the
alleged sale deed are not of the defendant’s mother, rather
manouvered and procured. In fact the alleged sale deed is
a forged and fabricated document and did not confer any
legal right and title to the Vendee, namely Shri Gulshan
M.Billa or Gulshan Birla, as apparent from various
manipulated, forged and fabricated documents filed by
the plaintiffs, alongwith the present suit. The defendant’s
 mother Smt.Sumitra Devi always wanted that the said
property will be exclusively inherited and owned by the
defendant and she never intended or disclosed of either
executing any alleged sale deed or any other document
regarding the said property. The defendant’s mother
Smt.Sumitra Devi herself declared before the relatives
and other family members, neighbours that after her
demise,

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the said property shall be owned exclusively by the

defendant. It is further submitted that Shri Gulshan Billa
or Birla was residing separately along with his family at
Surat, Gujarat, and he or his family had never looked
after, and took care of the old ailing mother and it is the
defendant, who himself and his family maintained and
looked after the mother. It is further submitted that even
the consideration amount as mentioned in the said alleged
sale deed was never received by the defendant’s mother
and it is all the manipulation. As already submitted the
defendant’s mother was not capable to move out of the
bed or go outside.

13. THAT the said alleged Sale Deed dated 08.12.2000 is

forged and fabricated document and has no legal
significance. Even Shri Gulshan Billa or Birla never
 disclosed about any such alleged sale deed, nor he ever
visited and made any claim over the said property and
further after his demise, his family/LRs also never visited
or made any claim over the said property. The alleged
Sale Deed dated 08.12.2000 is therefore liable to be
declared as invalid, illegal, null and void.

14. THAT the mischief and frauds having been committed by

the plaintiffs alongwith sons of late Sh.Gulshan Billa, i.e.

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Vishal Birla and Anand Murti Birla, are apparent from

the forged, fabricated, tampered, illegal and invalid
documents. It is the case of the plaintiffs that they
allegedly purchased the said property from Vishal Birla
and Anand Murti Birla son of late Sh.Gulshan Rai Birla
through alleged sale deed dated 28.06.2021. It is further
the case of the plaintiffs that after the death of
Sh.Gulshan Rai Birla, his both sons Vishal Birla and
Anand Murti Birla became the owners of the said
property and therefore they executed the alleged sale
deed dated 28.06.2021. The Hon’ble Court may kindly
take into consideration that for the purpose of alleged sale
deed dated 28.06.2021 it was a legal mandatory
requirement to get the Surviving Member Certificate
from the concerned authority, but as per the documents
filed by the plaintiffs, the alleged Surviving Member
 Certificate was obtained on dated 21.07.2021, which
means that the alleged sale deed dated 28.06.2021 was
executed about a month prior to issuance of Surviving
member Certificate and in this way, it establish a fraud,
collusion and connivance of the plaintiffs, as well as said
Vishal Birla and Anand Murti Birla and the officials of
Sub Registrar for execution of alleged sale deed dated
28.06.2021 without fulfilment of mandatory requirement
of Surviving Member Certificate.

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15. THAT the Hon’ble Court may also kindly take into
consideration that the further mischief and fraud of the
plaintiffs alongwith said Vishal Birla and Anand Murti
Birla is apparent from the admitted fact on record that
late Sh.Gulshan M.Birla or Billa was a permanent
resident of Surat, Gujarat, but he died at Kharkari,
Uttarakhand. However, the alleged Surviving Member
certificate was obtained from SDM, Mayur Vihar, East
Distt. Delhi on 21.07.2021. As settled law, the Surviving
Member Certificate ought to have been issued by the
competent authority of the local area, where the deceased
ordinarily was residing which is at Surat, Gujarat and he
died in Uttarkhand, then how could the S.D.M. Mayur
Vihar East Distt. Delhi issued the said Surviving Member
 Certificate. It is nothing but a fraud upon the govt.
agencies and also upon this Hon’ble Court and the
defendant, as the forged, fabricated and manipulated
documents have been produced and filed before this
Hon’ble Court to mislead this Hon’ble Court and get
passed erroneous orders on the basis of fabricated
documents.

16. THAT it is submitted that after succeeding in

manufacturing and fabricating the alleged sale deeds
dated 28.06.2021, the plaintiffs got the E-mutation of the
said property, on the basis of the fabricated documents. It
is

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further submitted that no death certificate of Sh.Gulshan

M.Birla is filed before this Hon’ble Court, though
mentioned in the list of documents. It is further
submitted that on the basis of forged death certificate of
Sh.Gulshan Rai Birla, the Jt./Dy.Assessor & Collector,
Anand Parbat, Karol Bagh Zone, Delhi, issued the E-
change/mutation of the said property, against application
No.2134 dated 09.06.2021 and it was not verified the sale
deed of recorded owner in favour of Vishal Birla and
Anand Murti Birla on dated 17.06.2021, thereby violating
the terms and conditions of the DMC Act.
17. THAT it is further submitted that even on the basis of
mutation in the record of the MCD, no ownership right is
conferred and accrued and the mutation of the property in
the record of the MCD is only for the purpose of payment
of property tax and the M.C.D. specifically mentions that
the mutation and payment of property tax does not give
any legal ownership right to the tax payer and the tax
payer could be simply occupier or even tenant. Thus the
alleged document of mutation is not a document of
ownership and title of the property and the alleged sale
deeds executed on the basis of alleged mutation of
property in the record of MCD are not legal and valid
document in the eyes of law. It is settled law that in case
any right of inheritance and
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ownership accrued to some legal heir after the demise of

the original owner, then the proper legal remedy as
provided under the Indian Succession Act has to be
adopted to get declaration of ownership and title of the
property and the claim of the plaintiffs that the alleged
named persons executed the alleged sale deeds simply on
the basis of alleged mutation have no legal significance in
the eyes of law.

18. THAT the plaintiffs have filed List of Documents

alongwith the present suit and as per S.No.5, a document
“copy of death certificate of Sh.Gulshan M.Birla” is
 alleged to have been filed at Page 40. However, at page
no.40, a copy of death certificate in the name of
Sh.Gulshan Rai Birla as issued by the Govt. of
Uttrakhand is filed and this death certificate is fabricated
and forged document and there are over-cutting in the
name of the deceased, which proved that the said alleged
document is forged and fabricated by the plaintiffs with
others.

19. THAT there are numerous other points of consideration,

which goes to the root of the case that the alleged
documents as filed along with the present suit by the
plaintiffs are forged, fabricated, maneuvered and
manipulation of the plaintiffs alongwith others. It is
submitted that the name of Sh.Gulshan M.Birla is

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mentioned contradictorily, as at some places &

documents it is mentioned as Sh.Gulshan M.Birla, while
on others it is mentioned as Gulshan Rai Birla or Gulshan
Rai Billa. It is submitted that as per alleged sale deed
dated 8.12.2000, the name of the Vendee is mentioned as
“GULSHAN M.BILLA”, while the alleged death
certificate issued by Govt. of Uttrakhand mentions
another name “Gulshan Rai Birla”. It is further submitted
that from the photocopy of the alleged sale deed dated
8.12.2000, it is visible that there are signatures in the
 name of Gulshan M.Birla and not Gulshan M.Billa. It is
further submitted that as per photocopy of E-change of
Name No.21340/Non transferable dated 17.6.2021 issued
by the Assessor & Collector, M.C.D. the name is
mentioned as Sh.Gulshan Rai Birla. It is further
submitted that as per Proforma for Mutation, of
Assessment & Collection Department, Sadar Paharganj
Zone of M.C.D. the name of the applicant is mentioned as
Sh.Gulshan M.Billa s/o late Madan Lal Billa. It is further
submitted that in the alleged sale deeds dated 28,06.2021,
it is mentioned as late Shri Gulshan Rai Birla and
Gulshan R.Birla.

20. THAT the Hon’ble Court may also kindly take into
consideration that the plaintiffs have filed the photocopy
of the alleged sale deed dated 08.12.2000, which appears

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to have been taken from the office of Asstt.Assessor &

Collector, M.C.D. and that goes to prove that the
plaintiffs have not been possessing the alleged original
sale deed or do not want to produce the original before
this Hon’ble Court and therefore, filed the photocopy of
alleged sale deed before this Hon’ble Court and there
appears to be mischief and malafide designs of the
plaintiffs. It is further submitted that the plaintiffs have
also not filed the chain of title documents, including the
 documents (sale deed) in the name of Sh.Roshan Lal
Kalra and Smt.Leela Devi, Will dated 28.07.1967
executed by Smt.Kesara Bai in favour of Smt.Sumitra
Devi, Probate order dated 22.05.1975.

21. THAT it is necessary to submit here that in the year 2002,

the defendant had handed over the entire original title
documents and record of the subject properties no.1051,
1052, 1053 and 1054 to the husband of his real sister
Dr.Suman (retd as Director Law, Delhi University)
namely Shri Satish Gupta, upon their advise to keep the
original title documents in safe custody. It is also
necessary to submit that during that period the defendant
was given favour by his sister and her husband for
admission at Sant Parmanand Hospital, Delhi, due to
major surgical procedure and there was life risk involved
and the

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defendant remained admitted at the said hospital for 15

days, therefore, under good faith and trust the defendant
had entrusted the entire original title documents of the
properties to his sister and her husband, upon their firm
promise and assurance to return the same to the defendant
upon his discharge or whenever he require the same.
However, after his discharge from the hospital, the
defendant on several occasions made request to Shri
 Satish Gupta and Dr.Suman for return of the original
documents, but they returned the documents of only
property no.1054, while the remaining original title
documents are with them till date. The defendant didn’t
take any legal recourse nor made any police complaint
due to said close relationship, while Satish Gupta
extended threats of dire consequences to the defendant.

22. THAT since the defendant’s sister and her husband

avoided to return the original title documents of the
subject property, therefore, another sister of the defendant
namely Smt.Sulekha called a meeting at her residence,
with Dr.Suman as she replied in the meeting on dated
06.02.2024 at Gurugram in threatening way that after her
retirement from service in Delhi University and till date
she has good close relations with four Hon’ble Judges of

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Supreme Court, stating that they have not yet received

their share in the subject properties and if the defendant
wants back the original title documents, then he has to
give their share or otherwise they have made mutual
agreement with vendors and plaintiffs to sale indirectly to
two of your neighbours namely Tarlochan Singh and his
son Aman Singh. In this way a big conspiracy has been
hatched and executed by them in association with alleged
 persons/Vendors and the plaintiffs and implicated a
fictitious defendant named Mukesh Birla in the present
suit. The said neighbours even keeping ill relations with
the defendant and they had tried to demolish the wall and
tried to trespass into the property of the defendant in the
year 2018, therefore, the defendant had filed a civil suit
No.2377/2018 titled “Mukesh Billa vs. Trilochan Singh
& ors.” against the said neighbours and the same is
pending before the ld. Court of Shri Pranav Joshi, ASCJ,
Tis Hazari Court, Delhi, and now fixed for 25.10.2024.
Because of the open threats to the life of the defendant,
the defendant has already lodged several complaints with
the police and copies of the same are filed herewith.

23. THAT the plaintiffs under a deep criminal conspiracy

with other associates and accomplices, including the own
sisters

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of the defendant who wanted share or money from the

defendant, bent upon and adamant to somehow snatch
and grab the subject property from the defendant, on the
basis of forged, fabricated and manipulated documents.
Thus the present suit requires to be dismissed with heavy
exemplary costs.
24. THAT it is further submitted that in the alleged sale deed
dated 08.12.2000, the property no.1051,1052 and 1053
are mentioned as 130 sq yds, while in the alleged e-
change of name dated 17.6.2021 issued by the M.C.D. the
area of the property is mentioned as 78 sq.mtrs.
However, as per the alleged sale deeds dated 28.06.2021,
the plot area of the said property no.1051, 1052 and 1053,
it is mentioned as 108.693 sq.mtrs.

25. THAT there is a deep conspiracy hatched by the plaintiffs

alongwith others namely Vishal Birla and Anand Murti
Birla, who are strangers and unknown to the defendant
and they have colluded and connived to somehow grab
and usurp the subject property on the basis of forged,
fabricated and manipulated documents. The defendant
has never met the plaintiffs and the said other persons
named above in his life time. They never visited or made
any claim over the subject property at any point of time
and

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even Sh.Gulshan M.Billa or Gulshan Rai Birla or

Gulshan R.Billa etc also never visited or made any claim
over the subject property, which is in continuous,
uninterrupted physical possession, use and enjoyment of
the defendant and all the amenities installed/provided at
 the subject property are in the name of the defendant
since many decades.

26. THAT the story as perpetrated by the plaintiffs is highly

contradictory as in the present suit, the plaintiffs have
claimed of getting symbolic possession, while in the
alleged three sale deeds it has been alleged that the actual
vacant possession of the subject property was handed
over to the plaintiffs. This establish that the alleged three
sale deeds are illegal and invalid documents in the eyes of
law as the same are based upon concoction and
falsehood.

27. THAT the site plan as filed by the plaintiffs is wrong and
false and do not depict the property in question as
existing at the site. The defendant is filing the correct site
plan of the property alongwith the written statement.

28. THAT the suit has not been properly valued for the
purpose of court fees and jurisdiction. The plaintiffs have
valued the suit for recovery of possession at
Rs.70,00,000/- without substantiating with any Govt.
record, valuation,

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circle rate, or any market survey etc. The plaintiffs have

intentionally undervalued the suit to evade paying the
advalorem court fees. The Hon’ble Court may also
 kindly take into consideration that one hand the plaintiffs
have undervalued the suit property at Rs.70,00,000/-, but
on the other hand, falsely claiming the use and
occupation charges at Rs.50,000/- per month and this
itself proves the mischief acts and deeds of the plaintiffs.
Therefore the suit being not properly valued and no
proper advalorem court fees has been affixed, may kindly
be dismissed with exemplary costs.

REPLY ON MERITS:
1. THAT the contents of para no.1 of the plaint as stated are
vehemently and specifically wrong and denied as whole.
It is vehemently wrong and denied that the plaintiffs are
the owner of the property bearing no.1051-1053 (Old
No.1416-1418) measuring about 130 sq yds vide separate
three sale deeds as alleged. Each and every averment as
made out by the plaintiffs are false, frivolous,
misconceived, concoction and contrary to the facts and
based on forged, fabricated and manipulated documents.
As already submitted the plaintiffs are neither the owners
nor having any legal right, title, interest, claim or concern

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whatsoever of any nature with the subject properties

no.1051, 1052, and 1053, which are built as one property
alongwith property no.1054 and are existing since several
decades and in the lawful physical possession of the
defendant. The alleged sale deeds are manipulated,
fictitious, forged and fabricated by the plaintiffs with
conspiracy of alleged vendors, who themselves were
never been the owners or possession of the subject
property. As already submitted in the alleged sale deeds,
it is wrongly claimed that the property are measuring 78
sq.mtrs. It is further submitted that the plaintiffs and
vendors of alleged sale deeds are strangers to the
defendant. The site plan as filed by the plaintiffs is wrong
and not as per the factual position and structure at the
site, there is no dimension and measurement of the
existing property at the spot. As already submitted there
is one single property built over properties no.1051, 1052,
1053 and 1054. It is further submitted that the front side
of the property was reduced by the MCD in the year 2010
because of widening of the road and further that in the
year 2018, the two neighbours named above tried to
trespass and demolish and encroached area of 5’x24’
approx.. behind the back wall of the property, and for the
same, the defendant has lodged several complaints to the
police. Reference be made to the

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detailed preliminary objections in this context which are

not being reproduced herein for the sake of brevity.
2. THAT the contents of para no.2 of the plaint as stated are
vehemently and specifically wrong and denied as whole.
It is vehemently wrong and denied that the plaintiff no.1
is the owner of 30% share equivalent to 39 sq yds having
purchased the same by virtue of regd Sale Deed dated
28.6.2021 as alleged. Each and every averment as made
out by the plaintiffs are false, frivolous, misconceived,
concoction and contrary to the facts and based on forged,
fabricated and manipulated documents. The plaintiff no.1
is neither the owner nor ever in possession of the suit
property or any part thereof and the subject properties are
in lawful physical possession of the defendant since
several decades, as mentioned hereinabove. The alleged
sale deeds are illegal and invalid documents in the eyes of
law, therefore, the same are liable to be declared as null
and void. Reference be made to the detailed preliminary
objections and preceding paras in this context, which are
not being reproduced herein for the sake of brevity.

3. THAT the contents of para no.3 of the plaint as stated are

vehemently and specifically wrong and denied as whole.
It is vehemently wrong and denied that the plaintiff no.2
is

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the owner of 35% undivided share in the suit property on

the basis of alleged sale deed dated 28.06.2021 or that the
 plaintiff no.3 is the owner of 35% undivided share in the
suit property on the basis of alleged sale deed as alleged.
Each and every averment as made out by the plaintiffs are
false, frivolous, misconceived, concoction and contrary to
the facts and based on forged, fabricated and manipulated
documents. The plaintiffs no.2 and 3 are neither the
owners nor ever in possession of the suit property or any
part thereof and the subject properties are in lawful
physical possession of the defendant since several
decades, as mentioned hereinabove. The alleged sale
deeds are illegal and invalid documents in the eyes of
law, therefore, the same are liable to be declared as null
and void. Reference be made to the detailed preliminary
objections and preceding paras in this context, which are
not being reproduced herein for the sake of brevity.

4. THAT the contents of para no.4 of the plaint as stated are

vehemently and specifically wrong and denied as whole.
It is denied for want of knowledge that the plaintiff no.2
is the wife of plaintiff no.1 and plaintiff no.3 is the son of
plaintiff no.1. It is vehemently wrong and denied that the
plaintiffs are owners of the property in question by virtue
of the alleged sale deeds as alleged. Each and every

- 25 -

averment as made out by the plaintiffs are false,

frivolous, misconceived, concoction and contrary to the
 facts and based on forged, fabricated and manipulated
documents. The plaintiffs are neither the owners nor ever
in possession of the suit property or any part thereof and
the subject properties are in lawful physical possession of
the defendant since several decades, as mentioned
hereinabove. The alleged sale deeds are illegal and
invalid documents in the eyes of law, therefore, the same
are liable to be declared as null and void. Reference be
made to the detailed preliminary objections and preceding
paras in this context, which are not being reproduced
herein for the sake of brevity.

5. THAT the contents of para no.5 of the plaint as stated are

vehemently and specifically wrong and denied as whole.
It is vehemently wrong and denied that Smt.Sumitra Devi
w/o Shri Madan Lal Birla had sold the property to Shri
Gulshan M.Birla by virtue of Sale deed dated 08.12.2000
as alleged. Each and every averment as made out by the
plaintiffs are false, frivolous, misconceived, concoction
and contrary to the facts and based on forged, fabricated
and manipulated documents. It is not disputed that
Smt.Sumitra Devi was the mother of the defendant and
she died intestate, and she willed during her life time to
give

- 26 -
the said property in favour of the defendant and therefore
she openly declared before the family members, relatives
and others and thus the defendant has become the sole,
exclusive and absolute owner of the subject property and
has been enjoying and occupying the same with his own
independent right and capacity. As already submitted the
name of the father of the defendant was Shri Madan Lal
Billa and nor Sh.Madan Lal Birla, as wrongly and falsely
alleged by the plaintiffs. It is further submitted that the
plaintiffs have not filed the original sale deed dated
08.12.2000 before this Hon’ble Court, knowingly well
that they are not having the original sale deed and
secondly, the alleged sale deed dated 08.12.2000 is only a
fabricated, forged and manipulated document. The
Hon’ble Court may kindly take into consideration that the
plaintiffs have filed the photocopy of the alleged sale
deed as obtained from the office of the Assessor &
Collector, MCD House Tax Department. It is further
submitted that the plaintiffs have also not filed the chain
of title documents right from the initial owners of the said
property. As already submitted Smt.Sumitra Devi had
never executed any such alleged Sale Deed dated
08.12.2000 during her life time, as she was illiterate,
infirm and old aged widow lady and was bed ridden and
it does not bear the thumb signatures

- 27 -
 of Smt.Sumitra Devi. It is already submitted that on the
basis of the said alleged sale deed, the Vendee as named
i.e. Gulshan Rai Birla never visited the said property nor
claimed any ownership and title over the said property
nor asked the defendant for vacating the said property,
knowingly well that the defendant is the actual owner and
in possession of the said property. The alleged sale deed
is therefore liable to be declared and cancelled as null and
void. Reference be made to the detailed preliminary
objections and preceding paras in this context, which are
not being reproduced herein for the sake of brevity.

6. THAT the contents of para no.6 of the plaint as stated are

vehemently and specifically wrong and denied as whole.
It is vehemently wrong and denied that Shri Gulshan Rai
Birla, who expired on 17.11.2009 or that the suit property
devolved upon Vishal Birla and Anand Murti Birla being
the legal heirs of Gulshan Rai Birla or that they got the
property mutated in their name vide letter dated
17.6.2021 issued by NDMC as alleged. Each and every
averment as made out by the plaintiffs are false,
frivolous, misconceived, concoction and contrary to the
facts and based on forged, fabricated and manipulated
documents. As already submitted the demise of
Sh.Gulshan Rai Birla or Gulshan M.Billa or any other
name, as several
 - 28 -

contradictory names and documents have been produced

by the plaintiffs before this Hon’ble Court, is denied and
disputed as only manipulated, forged and fabricated
documents including the death certificate has been filed
on record by the plaintiffs. There is no legal and valid
document which could establish that the alleged persons
named Vishal Birla and Anand Murti Birla are the legal
heirs of Gulshan Rai Birla or that they were legally
having right of inheritance or claim over the said property
and were competent for mutation of the property in their
names. As already submitted when Gulshan Rai Birla or
Gulshan M.Birla or Gulshan M.Billa was not the legal
owner of the subject property on the basis of alleged sale
deed, the question of inheritance and then mutation of the
property by the above named persons Vishal Birla and
Anand Murti Birla. The alleged mutation was an act of
fraud having been committed by the plaintiffs and the
said persons, who all are strangers to the defendant. As
already submitted the M.C.D. allegedly got the mutation
of the property without verification and making any
enquiry at the subject property, neighbourhood etc
regarding the inheritance, possession etc of the said
property and even no document of inheritance or
acquiring any legal rights in the property was submitted
with the MCD by the above
 - 29 -

named persons Vishal Birla and Anand Murti Birla, and it

was only an act of fraud, collusion and connivance
among the said persons and the plaintiffs and the officials
of M.C.D. It may also be taken into consideration that as
stated in the para under reply Gulshan Rai Birla died on
17.11.2009, but the alleged mutation was got done on
17.06.2021 i.e. after about 12 years, without assigning
any reason. It is further submitted that the plaintiffs have
filed a photocopy of alleged Surviving Member
Certificate issued by the SDM, Mayur Vihar, Delhi, well
after the said mutation and the execution of alleged sale
deeds and this itself proves and establish the fraud and
mischief as having been committed by the plaintiffs
alongwith alleged vendors etc. Reference be made to the
detailed preliminary objections and preceding paras in
this context, which are not being reproduced herein for
the sake of brevity.

7. THAT the contents of para no.7 of the plaint as stated are

vehemently and specifically wrong and denied as whole.
It is vehemently wrong and denied that the alleged
persons named Vishal Birla and Anand Murti Birla sold
the suit property by virtue of alleged sale deeds to the
plaintiffs on 28.6.2021 as alleged. Each and every
averment as made out by the plaintiffs are false,
frivolous, misconceived,

- 30 -

concoction and contrary to the facts and based on forged,

fabricated and manipulated documents. As already
submitted the alleged sale deeds are only forged,
fabricated, manipulated, illegal and invalid documents
and the alleged persons Vishal Birla and Anand Murti
Birla were neither owners nor legally competent to
execute the alleged sale deeds. It is further submitted that
even on the basis of mutation in the record of the MCD,
no ownership right is conferred and accrued and the
mutation of the property in the record of the MCD is only
for the purpose of payment of property tax and the
M.C.D. specifically mentions that the mutation and
payment of property tax does not give any legal
ownership right to the tax payer and the tax payer could
be simply occupier or even tenant. Thus the alleged
document of mutation is not a document of ownership
and title of the property and the alleged sale deeds
executed on the basis of alleged mutation of property in
the record of MCD are not legal and valid document in
the eyes of law. It is settled law that in case any right of
inheritance and ownership accrued to some legal heir
after the demise of the original owner, then the proper
 legal remedy as provided under the Indian Succession
Act has to be adopted to get declaration of ownership and
title of the property and the claim of the plaintiffs that the
alleged

- 31 -

named persons executed the alleged sale deeds simply on

the basis of alleged mutation have no legal significance in
the eyes of law. Reference be made to the detailed
preliminary objections in this context, which are not
being reproduced herein for the sake of brevity.

8. THAT the contents of para no.8 of the plaint as stated are

vehemently and specifically wrong and denied as whole.
It is vehemently wrong and denied that at the time of
purchasing the suit property the symbolic possession of
the suit property was handed over to the plaintiffs by the
erstwhile owner or that the defendant is the real uncle of
the alleged persons Vishal Birla and Anand Murti Birla as
alleged. Each and every averment as made out by the
plaintiffs are false, frivolous, misconceived, concoction
and contrary to the facts and based on forged, fabricated
and manipulated documents. It is not disputed that the
defendant has been residing and occupying the suit
property since 1965 i.e. from the time of his birth and has
acquired full complete ownership right and title after the
demise of his mother in the year 2001. It is further
 submitted that the alleged persons Vishal Birla and
Anand Murti Birla are unknown and strangers to the
defendant. It is further submitted that in the alleged sale
deeds, it has been fraudulently alleged that the actual
physical

- 32 -

possession of the property was handed over to the

plaintiffs, but herein the plaintiffs have alleged of
handing over of symbolic possession. As a mater of fact
no kind of possession either actual physical or the
symbolic possession was ever handed and the property is
right from the beginning in the actual physical possession
of the defendant. Amazingly, when neither Gulshan Rai
Birla (or whatever his name) was ever in possession of
the property, then the question of his inheritance by the
alleged persons Vishal Birla and Anand Murti Birla
arose, and they were in capable to handover either actual
physical possession or symbolic possession to the
plaintiffs. Reference be made to the detailed preliminary
objections in this context, which are not being reproduced
herein for the sake of brevity.

9. THAT the contents of para no.9 of the plaint as stated are

vehemently and specifically wrong and denied as whole.
It is vehemently wrong and denied that after purchasing
the suit property by the plaintiffs by virtue of alleged sale
deeds dated 28.6.2021, or that the defendant was ever a
licensee or that the defendant requested the plaintiffs to
allow him to occupy the suit property as a licensee for a
period of one year as alleged. Each and every averment
as made out by the plaintiffs are false, frivolous,

- 33 -

misconceived, concoction and contrary to the facts and

based on forged, fabricated and manipulated documents.
The story as perpetrated by the plaintiffs is devoid of
truth, merit and substance and wrong to their own
knowledge, as because the plaintiffs never visited or
made any request to the defendant. Moreover, the
plaintiffs are neither owners nor having any legal right,
title or interest over the said property. The contention of
the plaintiffs of creation of license is fake and fictitious,
as because the defendant is the actual and absolute owner
and in possession of the said property with his own
independent right and capacity and there was never any
occasion for license. It is further submitted that the
plaintiffs have failed to mention as to by whom and when
the alleged license was created to the defendant.
Moreover, the license of a property is created generally in
close relationship or close friendly relations and not
between strangers and unknown persons. The Hon’ble
Court may also kindly take into consideration that the
 plaintiffs have not mentioned any specific date, month
and year of alleged request nor the mode of alleged
request, because it is a cock and bull story of the
plaintiffs and product of their evil minds. Reference be
made to the detailed preliminary objections in this
context, which are not being reproduced herein for the
sake of brevity.

- 34 -

10. THAT the contents of para no.10 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that the
defendant at the time of purchasing the suit property by
the plaintiffs by virtue of sale deeds had assured the
plaintiffs to vacate the suit property after expiry of one
year as alleged. Each and every averment as made out by
the plaintiffs are false, frivolous, misconceived,
concoction and contrary to the facts and based on forged,
fabricated and manipulated documents. The story is
highly absurd lies, bundle of concoction and product of
the own evil minds of the plaintiffs. The defendant got
knowledge of the fraud, mischief and other criminal acts
and offences only after coming to know of the present
suit filed by the plaintiffs. There was no question of any
assurance by the defendant to the plaintiffs to vacate the
suit property, who have no concern or connection with
the suit property which is legally owned and possessed by
 the defendant with his own independent right and
capacity. Reference be made to the detailed preliminary
objections in this context, which are not being reproduced
herein for the sake of brevity.

11. THAT the contents of para no.11 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that there was
ever any

- 35 -

request and persuasion by the defendant or that the

defendant was the uncle of the alleged persons Vishal
Birla and Anand Murti Birla or that they were the family
friends of the plaintiffs or that the plaintiffs allowed the
defendant to use and occupy the suit property as a
licensee for period of one year commencing from
28.6.2021 as alleged. Each and every averment as made
out by the plaintiffs are false, frivolous, misconceived,
concoction and contrary to the facts and based on forged,
fabricated and manipulated documents. The story as
made out by the plaintiffs is bogus, having no legal and
factual support and content and therefore may kindly be
rejected at the threshold. As already submitted the
plaintiffs and the alleged persons Vishal Birla and Anand
Murti Birla are strangers to the defendant, and there are
no relationship of the defendant either with the plaintiffs
 or with alleged persons and therefore, the claim of
alleged license is simply concoction and wrong to the
own knowledge of the plaintiffs. The defendant has been
occupying and using the suit property since inception
being the owner thereof with his own independent right
and capacity. Reference be made to the detailed
preliminary objections and preceding paras in this
context, which are not being reproduced herein for the
sake of brevity.

- 36 -

12. THAT the contents of para no.12 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that the status
of the defendant in respect of the suit property always
remained as a licensee or that defendant was having no
right, title or interest in the suit property of any nature as
alleged. Each and every averment as made out by the
plaintiffs are false, frivolous, misconceived, concoction
and contrary to the facts and based on forged, fabricated
and manipulated documents. The story as made out by
the plaintiffs is only repetition of fabricated averments
and reference be made to the detailed preliminary
objections and preceding paras in this context, which are
not being reproduced herein for the sake of brevity.
13. THAT the contents of para no.13 of the plaint as stated
are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that after
expiry of one year in the month of July,2022, the
plaintiffs requested the defendant to vacate the suit
property or that the defendant was allowed to occupy the
suit property for a period of one year which expired in the
month of June,2022 or that the defendant started avoiding
the issue as alleged. Each and every averment as made
out by the plaintiffs are false, frivolous, misconceived,
concoction and contrary to the

- 37 -

facts and based on forged, fabricated and manipulated

documents. As already submitted no license was ever
created or existed and the question of expiry of any
alleged period or making any request by the plaintiffs to
the defendant to vacate the suit property. The defendant
himself is the actual and absolute owner in possession of
the suit property and the plaintiffs have no locus standi to
disturb the possession and ownership rights of the
defendant. Reference be made to the detailed preliminary
objections and preceding paras in this context, which are
not being reproduced herein for the sake of brevity.

14. THAT the contents of para no.14 of the plaint as stated

are vehemently and specifically wrong and denied as
 whole. It is vehemently wrong and denied that there was
ever any request and persuasion by the plaintiffs or that
the status of the defendant was a licensee or that he was
having no right, title or interest in the suit property as
alleged. Each and every averment as made out by the
plaintiffs are false, frivolous, misconceived, concoction
and contrary to the facts and based on forged, fabricated
and manipulated documents. The story is simply
repetition and reference be made to the detailed
preliminary objections and preceding paras in this
context, which are not being reproduced herein for the
sake of brevity.

- 38 -

15. THAT the contents of para no.15 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that any effort
was made by the plaintiffs or that any notice was served
to the defendant or that the license was revoked etc as
alleged. Each and every averment as made out by the
plaintiffs are false, frivolous, misconceived, concoction
and contrary to the facts and based on forged, fabricated
and manipulated documents. There was never any
occasion for any effort request etc by the plaintiffs to the
defendant. No such alleged notice was ever served or
reached to the defendant. The question of revocation
does not arise when no license was ever created or
 existed. The defendant himself is the lawful occupant in
possession of the subject property with his own
independent right and capacity. Reference be made to the
detailed preliminary objections in this context, which are
not being reproduced herein for the sake of brevity.

16. THAT the contents of para no.16 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that the
alleged legal notice was served upon the defendant as
alleged. Each and every averment as made out by the
plaintiffs are false, frivolous, misconceived, concoction
and contrary to the

- 39 -

facts and based on forged, fabricated and manipulated

documents. Reference be made to the detailed
preliminary objections and preceding paras in this
context, which are not being reproduced herein for the
sake of brevity.

17. THAT the contents of para no.17 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that the
defendant is liable to pay use and occupation charges as
alleged. Each and every averment as made out by the
plaintiffs are false, frivolous, misconceived, concoction
 and contrary to the facts and based on forged, fabricated
and manipulated documents. No such alleged legal
notice was ever served upon the defendant and the
alleged legal notice has no legal enforceability as the
plaintiffs were/are having any legal right to issue any
such alleged legal notice. The defendant is occupying the
suit property with his own independent right and capacity
and there is no question of its vacation or paying any use
and occupation charges and it is all fanciful and flimsy
claim of the plaintiffs for use and occupation charges.
Reference be made to the detailed preliminary objections
in this context, which are not being reproduced herein for
the sake of brevity.

- 40 -

18. THAT the contents of para no.18 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that the status
of the defendant in the suit property is of unauthorised
occupant or that the defendant has no right to use and
occupy the suit property or that there was any permission
to occupy the suit property as alleged. Each and every
averment as made out by the plaintiffs are false,
frivolous, misconceived, concoction and contrary to the
facts and based on forged, fabricated and manipulated
 documents. As per the own admission of the plaintiffs,
the suit property has been in use and occupation of the
defendant since prior to the alleged sale deeds dated
28.06.2021, and no where in the alleged sale deeds it is
mentioned that the subject property is in occupation of
the defendant in the capacity of licensee and there is no
document whatsoever to establish and support that any
license or permission was created and existed in favour of
the defendant. Such story of alleged license by the
plaintiffs is only fiction and imagination and is legally not
sustainable. The defendant admittedly has been
occupying the suit property since many decades, and has
independent right and capacity and the plaintiffs have no
legal right to disturb the possession and legal rights of the
defendant. Reference be made to the detailed preliminary
objections and preceding paras in this context,

- 41 -

which are not being reproduced herein for the sake of

brevity.

19. THAT the contents of para no.19 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. The present suit is only abuse and misuse of
process of law and there is no legal remedy for a false
and frivolous suit based upon forged, fabricated and
manipulated documents. Reference be made to the
 detailed preliminary objections and preceding paras in
this context, which are not being reproduced herein for
the sake of brevity.

20. THAT the contents of para no.20 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. It is vehemently wrong and denied that any cause
of action arisen for the present suit on 28.6.2021 or that
the plaintiffs purchased the suit property by virtue of
alleged sale deeds or that the defendant requested the
plaintiffs to occupy the suit property for a period of one
year as a licensee as alleged. It is further vehemently
wrong and denied that any cause of action arose in the
month of July,2022 after expiry of one year or that the
plaintiffs approached the defendant to vacate the suit
property or that any cause of action arose on any other
date or that the plaintiffs approached the defendant to
vacate the suit property as

- 42 -

alleged. It is further vehemently wrong and denied that

any cause of action arose on 10.11.2022 or that any
alleged legal notice was served upon the defendant or that
any cause of action are continuing as alleged. Each and
every averment as made out by the plaintiffs are false,
frivolous, misconceived, concoction and contrary to the
facts and based on forged, fabricated and manipulated
 documents. No cause of action has ever arisen in favour
of the plaintiffs and against the defendant and the suit is
filed without any cause of action and all the dates and
occasions as made out are product of the own evil minds
of the plaintiffs. There is no question of vacating the suit
property by the defendant. Reference be made to the
detailed preliminary objections and preceding paras in
this context, which are not being reproduced herein for
the sake of brevity.

21. THAT the contents of para no.21 of the plaint as stated

are vehemently and specifically wrong and denied as
whole. As already submitted the suit has not been
properly valued for the purpose of court fees and
jurisdiction and is intentionally undervalued to evade the
liability to pay the court fees. Reference be made to the
detailed preliminary objections and preceding paras in
this context, which are not being reproduced herein for
the sake of brevity.

- 43 -

22. THAT the contents of para no.22 of the plaint as stated

are not denied to the extent that the territorial jurisdiction
of this Hon’ble Court and that the property is situated at
Pahar Ganj and the defendant is occupying the suit
property, rest as stated are vehemently and specifically
wrong and denied as whole. It is vehemently wrong and
 denied that any cause of action arose for the present suit
as alleged. In fact no cause of action has arisen for the
present suit and the suit is without any cause of action.
Reference be made to the detailed preliminary objections
and preceding paras in this context, which are not being
reproduced herein for the sake of brevity.

Prayer clause and sub clauses (a) to (d) are wrong and
hence denied and the plaintiffs are not entitled to any
relief.
It is, therefore, respectfully prayed that the suit of the
plaintiffs being legally not maintainable may kindly be
dismissed with special heavy costs.

Prayed accordingly,

- 44 -

DEFENDANT
THROUGH:
DELHI.
DATED: COUNSEL.
VERIFICATION:
Verified at Delhi on this day of October,
2024 that the contents of paras 1 to 19 of the reply on merits and
factual submissions in preliminary objections are true and correct
to my knowledge and those of paras 20 to 22 of the reply on merits
and legal submissions in preliminary objections are true upon
information received and believed to be correct. Rest is prayer to
this Hon’ble Court.

DEFENDANT

IN THE HON’BLE COURT OF SHRI NARESH KUMAR LAKA:

LD.DISTT.JUDGE: CENTRAL DISTT. TIS HAZARI COURT
DELHI.
SUIT NO.CS-DJ/1302/2022
IN RE:

SANJAY KUMAR BANSAL & ORS. … PLAINTIFFS

VERSUS
MUKESH BILLA … DEFENDANT

REPLY ON BEHALF OF THE DEFENDANT TO THE

APPLICATION UNDER ORDER 39 RULES 1 & 2
READ WITH SEC.151 CPC

RESPECTFULLY SHOWETH:
1. THAT the contents of para no.1 of the application are
matter of record so far as the plaintiffs have filed the false
and frivolous suit against the defendant. The
 accompanying written statement may kindly be read as
part and parcel of this reply, which is not being
reproduced herein for the sake of brevity.

2. THAT the contents of para no.2 of the application as

stated are absolutely wrong and hence denied. All the
allegations made in the para under reply are false,
frivolous and purely

- 2 -

concoction. The plaintiffs have no case what to talk of

good prima facie case.

3. THAT the contents of para no.3 of the application as

stated are absolutely wrong and hence denied. All the
allegations made in the para under reply are false,
frivolous and purely concoction. The balance of
convenience lies in favour of the defendant and against
the plaintiffs.

4. THAT the contents of para no.4 of the application as

stated are absolutely wrong and denied. The plaintiffs
themselves have no legal right, title and ownership and
possession qua the suit property and therefore, has no
locus standi to seek any relief. The defendant is lawfully
occupying the suit property with his own independent
right and capacity.
 Prayer clause is wrong and hence denied and the
plaintiffs are not entitled to any relief.

- 3 -

It is, therefore, respectfully prayed that the application

being legally not maintainable may kindly be dismissed
with special costs.

DEFENDANT
THROUGH:
DELHI.
DATED: COUNSEL.
IN THE HON’BLE COURT OF SHRI NARESH KUMAR LAKA:
LD.DISTT.JUDGE: CENTRAL DISTT. TIS HAZARI COURT
DELHI.
SUIT NO.CS-DJ/1302/2022
IN RE:

SANJAY KUMAR BANSAL & ORS. … PLAINTIFFS

VERSUS
MUKESH BILLA … DEFENDANT

AFFIDAVIT

Affidavit of Shri Mukesh Billa aged about 60 years son of late Shri
Madan Lal Billa resident of 1051,1052,1053 & 1054, Main Bazar,
Pahar Ganj, New Delhi.110055.
I, the above named deponent, do hereby solemnly affirm and
declare as under :

1. THAT I am the defendant and well conversant with the

facts of the case and competent to swear this affidavit.

2. THAT the contents of the accompanying written

statement are drafted under instructions by the counsel
and the same have been read over and explained to me in
vernacular and understood by me as correct.

- 2 -

3. THAT the contents of the accompanying written

statement are not being reproduced herein for the sake of
 brevity, which may kindly be read as part of this
affidavit.

DEPONENT.
VERIFICATION;
Verified at Delhi on this that the
contents of the above affidavit are true and correct to my
knowledge and no part of it is false or wrong.

DEPONENT.