IN THE COURT OF LD.

CIVIL JUDGE, VIKASNAGAR COURT,

UTTARAKHAND

CIVIL ORIGINAL SUIT No. ___ of 2025

IN THE MATTER OF:

MR. GIREESH KUMAR

…Plaintiffs

Versus

ABHISHEK JAIN AND ORS. …Defendants

INDEX

S. NO. PARTICULARS PAGE NO.

1. Court Fee

2. Memo of Parties

3. Suit for Declaration and Mandatory and

Permanent Injunction on behalf of the
Plaintiffs alongwith affidavit.

4. Application under Order XXXIX Rule 1

and 2 read with Section 151 of the Code
of Civil Procedure, 1908 along with
affidavit.

5. Address Form

6. List of Documents

7. Vakalatnama
 `.

PLAINTIFFS

PLACE: Dehradun PREET PAL SINGH

DATED: ___.02.2025
Advocate for the Plaintiffs
286, TYAGI MARKET, PREMNAGAR,
DEHRADUN
Enroll No. D/989/2017
preetpals25@gmail.com/8743006062
IN THE COURT OF LD. CIVIL JUDGE, VIKASNAGAR COURT,
UTTARAKHAND

CIVIL ORIGINAL SUIT No. ___ of 2025

IN THE MATTER OF:

MR. GIREESH KUMAR

…Plaintiffs

Versus

ABHISHEK JAIN AND ORS. …Defendants

MEMO OF PARTIES

1. Mrs. Kusum Bansal,

W/o Mr. Lakhi Chand Bansal
WZ-572E, Naraina Village,
New Delhi-110028 …Plaintiff
No.1

2. Mr. Lakhi Chand Bansal,

S/o
WZ-572E, Naraina Village,
New Delhi-110028 …Plaintiff
No. 2

Versus

1. The HDFC Bank,

Through its Branch Manager,
Branch- Naraina Vihar, New Delhi. …Defendant
No.1

2. Anamika Bansal,
D/o Balram Bhati,
 Resident of H. No. 148-A,
Pocket VI, MIG Flats,
Mayur Vihar, Phase-III,
New Delhi-110096. …Defendant
No.2

Plaintiff No.1

Plaintiff No.2

Through

PLACE: PREET PAL SINGH

Dehradun
Advocate for the Plaintiffs
DATED:
___.02.2025 286, TYAGI MARKET, PREMNAGAR,
DEHRADUN
Enroll No. D/989/2017
preetpals25@gmail.com/8743006062
IN THE COURT OF LD. CIVIL JUDGE, KARKARDOOMA
COURT, EAST DISTRICT NEW DELHI.

CIVIL ORIGINAL SUIT No. ___ of 2024

Mr. Girish Kumar

S/o [Father’s Name],
Proprietor of M/s Pallavi Gas Agency,
R/o [Address], Dehradun, Uttarakhand
… Plaintiff

VERSUS

1. Geeta Nautiyal
R/o [Address]
… Defendant No. 1
2. Ankit Jain
R/o [Address]
… Defendant No. 2
3. Vaibhav [Surname]
R/o [Address]
… Defendant No. 3
4. Indian Oil Corporation Limited (IOCL)
Through its Regional Head,
R/o [Address]
… Defendant No. 4

SUIT FOR CANCELLATION OF SALE DEED AND INJUNCTION

Most Respectfully Showeth:

1. That the plaintiff, Mr. Girish Kumar, is the proprietor of M/s Pallavi Gas
Agency, which operates its business from the premises located at [address],
Dehradun, Uttarakhand. The plaintiff has been in continuous possession of the said
land, which includes a godown used for the purposes of the gas agency.
2. That the plaintiff entered into a financial transaction with Defendant No. 1,
Geeta Nautiyal, sometime in [year]. The transaction was meant to be a financial
arrangement, as represented by Defendant No. 1, and there was no intention to
execute a sale of the said property.
3. That Defendant No. 1 fraudulently misrepresented the financial transaction as a
sale deed. The plaintiff was led to believe that the transaction was purely financial in
nature. However, Defendant No. 1, through deceitful means, caused the plaintiff to
unwittingly execute what has now surfaced as a registered sale deed in favor of
Defendant No. 1.
4. That the plaintiff was never aware of the existence of the sale deed until recently,
when Defendants No. 2 and 3, Ankit Jain and Vaibhav, began to harass the plaintiff,
claiming ownership of the said property on the basis of a further sale deed executed
by Defendant No. 1 in their favor.
5. That the plaintiff has never been dispossessed of the said land and continues to
operate the gas agency on the disputed property. The possession of the land has
remained with the plaintiff, and no physical handover of the property was ever made
to Defendants No. 1, 2, or 3.
6. That upon complaints and harassment from Defendants No. 2 and 3, the plaintiff
came to know about the existence of the alleged sale deed, which was fraudulently
procured by Defendant No. 1. The plaintiff immediately raised objections and denies
any conscious execution of the said sale deed.
7. That Defendant No. 1 has committed fraud upon the plaintiff by concealing the
true nature of the transaction and causing the plaintiff to believe that it was a financial
arrangement, while fraudulently registering it as a sale deed.
 8. That the actions of Defendants No. 2 and 3, who claim to have purchased the
land from Defendant No. 1, are now causing undue harassment to the plaintiff by
asserting false ownership claims over the land.
9. That Defendants No. 2 and 3 are attempting to bypass judicial processes by
influencing Defendant No. 4, Indian Oil Corporation Limited (IOCL), to take
adverse actions against the plaintiff's gas agency, such as canceling the dealership or
terminating contracts, without due process.
10. That if IOCL takes any adverse actions against the plaintiff before the matter is
adjudicated, it will cause irreparable harm and financial losses to the plaintiff,
effectively rendering the suit infructuous. The plaintiff’s livelihood and business are
at stake, and any premature termination of the gas agency would violate the principles
of natural justice.
11. That the plaintiff submits that the sale deed was never consciously entered into,
and the fraudulent actions of Defendant No. 1 have created a cloud over the plaintiff’s
rightful ownership and possession of the disputed property.

PRAYER:

In view of the above, it is most respectfully prayed that this Hon’ble Court may be pleased to:

1. Declare the sale deed dated [date], allegedly executed between the plaintiff and
Defendant No. 1, as null and void, on the grounds of fraud, misrepresentation, and
lack of conscious consent.
2. Cancel the subsequent sale deed executed by Defendant No. 1 in favor of
Defendants No. 2 and 3, as the sale is based on a fraudulent transaction and cannot
confer any valid title to the defendants.
3. Grant an injunction restraining Defendants No. 2 and 3 from harassing the
plaintiff or claiming ownership of the disputed property, until the disposal of the
present suit.
4. Grant an injunction restraining Defendant No. 4, IOCL, from taking any
adverse action against the plaintiff's gas agency, including cancellation of the
dealership or termination of contracts, until the disposal of the present suit.
5. Pass any other orders that this Hon'ble Court deems fit and proper in the facts and
circumstances of the case.

Place:
Date:

IN THE MATTER OF:

Mrs. Kusum Bansal and Another …Plaintiffs

Versus

The HDFC Bank and Another …Defendants

SUIT FOR DECLARATION AND PERMANENT INJUNCTION

Most Respectfully Showeth:

1. That the Plaintiff is the owner and in possession of the suit

property i.e. all that land in Khata No. 27(Fasli 1410-1415)

bearing Khasra no. 460 Measuring 0.1150 Hect. (Declared non-

agriculture U/S-143 UPZA

2. That the Plaintiff is constrained to file the present suit against the

Defendants seeking declaration along with permanent and

mandatory injunction.

3. That the Defendant No. 1 is the bank of the Plaintiff, having its

registered office at HDFC Bank House, Senapati Bapat Marg,

Lower Parel, Mumbai. However, all the transactions were carried

out by the Plaintiffs and Defendant No.2 from its branch office,

situated at Naraina, New Delhi-110028.

4. That immediately after marriage, the Son of the Plaintiffs and the

Defendant No.2 started residing at the matrimonial house

situated at WZ-572E, Naraina Village, New Delhi-110028 and on

02.09.2013, a daughter namely Haridaya alias Seerat was born

out of their wedlock. It is submitted that out of love and concern,

the Plaintiffs proposed the Defendant No.2 for opening of a joint

ownership locker with the Defendant No.1 at its branch for

keeping pieces of jewellery and valuable articles.

5. That at the mutual agreements and consent between the parties,

the Plaintiffs along with the Defendant No.2 requested Defendant

No.1 to open joint ownership locker facilities in the name of

 Plaintiffs along with Defendant No.2 and the Defendant No.1 after

complete satisfaction opened a joint locker No. 72 at its branch

with complete access right to each of the joint owners.

6. That due to some misunderstanding and matrimonial discord

between the Defendant No.2 and her husband (Plaintiffs’ Son), the

relationship of marriage between them came to an end and after

rounds of deliberation and conciliations, on a

mutual settlement agreement was executed between the

Defendant No.2 and her husband (Plaintiffs’ Son) for dissolution

of marriage.

7. That on the mutual settlement agreement for

dissolution of marriage was executed at Delhi Mediation Centre,

Karkardooma Courts, Delhi and same was also been brought on

record in Case No. 18-V/14 (Anamika Bhati versus Rahul Bansal

and Others) and mediation case no. L-3622/15. It is submitted

that the Learned Karkardooma Court while passing an order dated

10.12.2015 has discussed the terms and conditions of the mutual

settlement agreement wherein at paragraph no.8, it has been

recorded that the parties (Plaintiffs and Defendant No.2) have

agreed to close the joint locker no. 72 at HDFC Bank Naraina

Vihar, District and also a joint account in Canara Bank, Naraiya

Vihar, Delhi and both the parties have agreed to cooperate with

each other in doing so.

8. That the mutual settlement agreement has also been brought on

record in a Criminal Misc. Case No. 4597 of 2016 (Rahul Bansal

and Others versus NCT of Delhi and Another) filed before the

Hon’ble High Court of Delhi and the Hon’ble High Court vide its

order 09.12.2016 after taking into consideration the mutual

agreement allowed the petition and quashed the criminal

proceedings pending against the Plaintiffs and his son (husband

of the Defendant No.2).

9. That 29.06.2019, the Plaintiff approached the Defendant No.1 for

closure of the Locker No. 72 operation at its branch on the ground

of dissolution of marriage as well as relationship with the

Defendant No.2 and the Defendant No.2 has also given

undertaking that she herself wants to close that particular joint

locker no.72 at the Bank. It is submitted that the Plaintiffs have

also apprised the Defendant No.1 about the mutual settlement

agreement executed between the Defendant No.2 and her

husband as well as the order dated 09.12.2016 passed by the

Hon’ble High Court of Delhi in Criminal Misc. Case No. 4597 of

2016 (Rahul Bansal and Others versus NCT of Delhi and Another).

10. That on 03.07.2019, the Defendant No.1 rejected the Plaintiffs’

application dated 29.06.2019 for closure on the ground that all

the three joint owner of the joint locker no. 72 has to be

personally present for closure of the joint locker. And in absence

 of any of the member of request for closure cannot be

entertained.

11. That the Plaintiff No.__ maintains a savings account bearing no.

20401930004796 at the Defendant No.1 branch and despite the

request for closure of the joint locker no. 72 in the light of the

mutual settlement agreement as well as order dated 09.12.2016

passed by the Delhi High Court, the Defendant No.1 is

continuously deducting charges against the maintenance of the

joint locker. It is submitted that since 29.09.2019, the Defendant

No.1 has deducted charges from the joint savings account of the

Plaintiffs on several dates and the details of the deduction dates

are being reproduced herein below for kind perusal of this

Learned Court:

12. That the Plaintiffs have also approached the Defendant No.2 for

honouring the terms of the mutual settlement dated ____ and to

make a statement before the Defendant No.1 as per deposition

made by her in paragraph no.8 of the order dated 10.12.2015

passed by the Learned Karkardooma Court in Mediation Case No.

L-3622/15 but all efforts of the Plaintiffs went in vain and till

today, Defendant No.2 has not approached neither the Plaintiffs

nor Defendant No.1 for closure of the joint locker no.72.

13. That unwarranted act of the Defendant No.1 is causing

unnecessary mental, physical and monetary loss. It is submitted

that the act of the Defendant No.1 is in clear defiance of the order

dated 09.12.2016 passed by the Delhi High Court and Defendant

No.2 is also not cooperating with the Plaintiffs in order to

approach the Defendant No.1 for closure of the joint locker no.72

operating at its Bank Branch.

14. In light of the aforesaid facts and circumstances, the Plaintiffs

have been constrained to approach this Hon’ble Court by way of

the present application seeking a declaration that the Plaintiffs

may be declared as joint owner of locker no.72 maintained by the

Defendant No.1 in the light of the mutual settlement agreement

and through the present original suit, the Plaintiffs are also

praying for permanent and mandatory injunction against the

Defendant No.2 to honour the terms and conditions of the

mutual settlement agreement facilitating the Plaintiffs in closure

of the joint locker bearing no. 72 maintained by the Defendant

No.1.

15. It is further prayed that this Hon’ble Court may also pass

appropriate directions in the nature of permanent and mandatory

injunction against the Defendant No.1 to not to deduct any further

amount under the head of locker rental amount for joint locker

no.72 during the pendency of this original suit before this Hon’ble
 Court and/ or pass any other and further order(s) and direction(s)

which this Hon’ble Court may deem fit and proper.

16. The cause of action to file the present suit first arose _________

2015 when the Defendant No.2 consensually executed the mutual

settlement agreement and again cause of action arose on 29.06.2019

when Plaintiffs vide an application requested Defendant No.1 for

closure of joint locker no.72 and again the cause of action arose on

___________________when the Defendant No.2 refused to cooperate

the Plaintiffs in the light of undertaking deposed in a mutual

settlement agreement executed in Medication Case no. L3622/15

Delhi Mediation Centre, Karkardooma Courts, Delhi and finally, the

cause of action arose on _____________ when the Defendant No.1

arbitrarily deducted maintenance charges from the saving account

of the Plaintiffs.

17. That the cause of action has arisen at __________, Naraina, Delhi

as the Joint Locker No. 72 is maintained by the Defendant No.1

Bank Branch at Naraina and all the transaction also happened

within the territorial jurisdiction of this Hon’ble Court.

18. That present suit for the purpose of declaration and permanent

and mandatory injunction as is being prayed for herein, is being

valued at Rs. _______________/- on which court fees of Rs.

____________/- is being paid along with the plaint for the relief of
 declaration and permanent and mandatory injunction. The Plaintiffs

undertakes to pay further court fees if the aforementioned court fees

is found to be deficient as and when this Hon’ble Court directs.

19. That the present suit has been filed within the period of limitation.

20. That the Plaintiffs have not filed any other suit nor any other

suit/proceedings pending on the same cause of action, in any

other court of law nor any other suit is pending before any other

court of law in India.

21. The Plaintiffs crave the leave of this Hon’ble Court to place on

record any further documents or to make any further submissions

relating to the present dispute.

PRAYER

It is, therefore, in the view of the facts and circumstances, it

is expedient in the interest of justice that this Hon’ble Court may

be pleased to:

(i) Issue an order(s) or directions (s) in the nature of the decree

for DECLARATION that Plaintiff Nos. 1 and 2 may be

declared as joint owners of locker no.72 maintained by

 Defendant No.1 in the light of the mutual settlement

agreement

(ii) Issue an order(s) or directions (s) in the nature of decree

MANDATORY AND PERMANENT INJUNCTION against

Defendant No.2 to honour the terms and conditions of the

mutual settlement agreement facilitating the Plaintiffs in

closure of the joint locker bearing no. 72 maintained by the

Defendant No.1.

Special Cost together with such any other relief which this

Hon’ble court may deem fit and proper be also awarded in favour

of the plaintiff and against the defendants, in the interest of

justice.

PLAINTIFF NO.1

PLAINTIFF NO.2

THROUGH
PLACE: NEW DELHI BALDEV KUMAR SINGH
DATED: ___.03.2024 Advocate for the Plaintiffs
463, Ward 7, Sector 29, Noida,
Uttar Pradesh – 201301
Enroll No. D/3537/2014
baldevnlu@gmail.com/9999793692

VERIFICATION

Verified at New Delhi on ___ day of March, 2024, that the contents

of Paras 1 to ___ of the plaint are true and correct to my knowledge

while those of para __ to __ of the plaint are true upon information

received and believed to be true and correct. Last para is the

prayer clause before this Hon’ble Court.

PLAINTIFFS
 IN THE COURT OF LD. CIVIL JUDGE, KARKARDOOMA
COURT, EAST DISTRICT NEW DELHI.

CIVIL ORIGINAL SUIT No. ___ of 2018

IN THE MATTER OF:

Mrs. Kusum Bansal and Another …Plaintiffs

Versus

The HDFC Bank and Another …Defendants

AFFIDAVIT

I, Kusum Bansal W/o Lakhi Chand Bansal, aged about ______ years

old, R/o WZ-572E, Naraina Village, New Delhi-110028, do hereby

solemnly affirm and declare as under:

1. That I am Plaintiff No.1 in the present Suit and I am well conversant

with the facts of the case.

2. That the accompanying Suit with the present affidavit has been

drafted by my counsel under my instructions and I affirm that the

reply of facts made therein are true and correct to the best of my

knowledge derived from the official records maintained by me in its

ordinary course of business.

DEPONENT

VERIFICATION

I, the Deponent hereinabove, do hereby verify and state that the

contents of the present Affidavit are true and correct to the best of my
knowledge. No part of it is false and nothing material has been

concealed therefrom.

Verified at New Delhi on this ___ day of March, 2024.

DEPONENT
 IN THE COURT OF LD. CIVIL JUDGE, KARKARDOOMA
COURT, EAST DISTRICT NEW DELHI.

CIVIL ORIGINAL SUIT No. ___ of 20

IN THE MATTER OF:

Mrs. Kusum Bansal and Another …Plaintiffs

Versus

The HDFC Bank and Another …Defendants

AFFIDAVIT

I, Lakhi Chand Bansal S/o , aged about ______

years old, R/o WZ-572E, Naraina Village, New Delhi-110028, do

hereby solemnly affirm and declare as under:

1. That I am Plaintiff No.2 in the present Suit and I am well conversant

with the facts of the case.

2. That the accompanying Suit with the present affidavit has been

drafted by my counsel under my instructions and I affirm that the

reply of facts made therein are true and correct to the best of my

knowledge derived from the official records maintained by me in its

ordinary course of business.

DEPONENT

VERIFICATION
I, the Deponent hereinabove, do hereby verify and state that the

contents of the present Affidavit are true and correct to the best of my

knowledge. No part of it is false and nothing material has been

concealed therefrom.

Verified at New Delhi on this ___ day of March, 2024.

DEPONENT
 IN THE COURT OF LD. CIVIL JUDGE, KARKARDOOMA
COURT, EAST DISTRICT NEW DELHI.

CIVIL ORIGINAL SUIT No. ___ of 2018

IN THE MATTER OF:

Mrs. Kusum Bansal and Another …Plaintiffs

Versus

The HDFC Bank and Another …Defendants

APPLICATION ON BEHALF OF PLAINTIFF UNDER ORDER

XXXIX RULE 1 AND 2 READ WITH SECTION 151 OF THE
CODE OF CIVIL PROCEDURE, 1908 FOR THE GRANT OF AN
EX-PARTE AD INTERIM INJUNCTION AGAINST DEFENDANT
NO.1.

MOST RESPECTFULLY SHOWETH:

1. That the Plaintiffs/Applicants have filed the above-mentioned suit

before this Hon’ble court for Declaration and Permanent and

Mandatory Injunction against the Defendant and same is pending

before this Hon’ble Court for adjudication.

2. That the contents of the said suit kindly be read as part of the

present application as well, as the contents of the same have not

reproduced herein for the sake of brevity.

3. That the Defendant No.1 is in clear disobedience of the order dated

09.12.2016 passed by the Hon’ble High Court of Delhi in Criminal

Misc. Case No. 4597 of 2016 (Rahul Bansal and Others versus

NCT of Delhi and Another) and the Plaintiffs vide an application

 dated 29.06.2019 also informed the Defendant No.1 to not to

deduct any amount from the saving account number

20401930004796 of the Plaintiff No.___ against the maintenance

charges of Joint Locker No.72. Thus, the continuous deduction

made by the Defendant No. 1 from the saving account no.

20401930004796 of the Plaintiff No.___ is wholly illegal and the

same is bad in the eyes of law in the view of the facts and

circumstances mentioned in the plaint. The plaintiffs are old aged

ailing citizen of the country.

4. That in case an ex-parte ad interim injunction as prayed for is not

granted in favour of the Plaintiffs and against the Defendant No.1,

the Plaintiffs would suffer irreparable loss and injury which

cannot be compensated in terms of money and the very purpose

of filing the present suit would be defeated.

5. That the Plaintiffs/Applicants have prima-facie case in his favour

and balance of convenience is also in favour of the

plaintiffs/applicants.

PRAYER
 In view of the above facts and circumstance, it is, therefore,

most prayed that this Hon’ble Court may be pleased to pass an

ex-parte ad interim permanent and mandatory injunction in

favour of the Plaintiffs/ Applicants and against the Defendant

No.1, restraining the Defendant No.1 to make any deduction from

the saving account number 20401930004796 under the head of

maintenance charges of joint locker no.72, till the final disposal of

the accompanying suit property by the Hon’ble Court, in the

interest of justice.

Such other or further orders as this Hon’ble Court may deem

fit and proper in the facts and circumstances of the case be also

passed in the favour of the Plaintiff and against the Defendant to

meet the interest of justice.

PLAINTIFF NO.1

PLAINTIFF NO.2

THROUGH
PLACE: NEW DELHI BALDEV KUMAR SINGH
DATED: ___.03.2024 Advocate for the Plaintiffs
463, Ward 7, Sector 29, Noida,
Uttar Pradesh – 201301
Enroll No. D/3537/2014
baldevnlu@gmail.com/9999793692
 IN THE COURT OF LD. CIVIL JUDGE, KARKARDOOMA
COURT, EAST DISTRICT NEW DELHI.

CIVIL ORIGINAL SUIT No. ___ of 2018

IN THE MATTER OF:

Mrs. Kusum Bansal and Another …Plaintiffs

Versus

The HDFC Bank and Another …Defendants

AFFIDAVIT

I, Kusum Bansal W/o Lakhi Chand Bansal, aged about ______ years

old, R/o WZ-572E, Naraina Village, New Delhi-110028, do hereby

solemnly affirm and declare as under:

1. That I am Plaintiff No.1 in the present Application and I am well

conversant with the facts of the case.

2. That the accompanying Application with the present affidavit has

been drafted by my counsel under my instructions and I affirm that

the reply of facts made therein are true and correct to the best of my

knowledge derived from the official records maintained by me in its

ordinary course of business.

DEPONENT

VERIFICATION
I, the Deponent hereinabove, do hereby verify and state that the

contents of the present Affidavit are true and correct to the best of my

knowledge. No part of it is false and nothing material has been

concealed therefrom.

Verified at New Delhi on this ___ day of March, 2024.

DEPONENT
 IN THE COURT OF LD. CIVIL JUDGE, KARKARDOOMA
COURT, EAST DISTRICT NEW DELHI.

CIVIL ORIGINAL SUIT No. ___ of 2018

IN THE MATTER OF:

Mrs. Kusum Bansal and Another …Plaintiffs

Versus

The HDFC Bank and Another …Defendants

AFFIDAVIT

I, Lakhi Chand Bansal S/o , aged about ______

years old, R/o WZ-572E, Naraina Village, New Delhi-110028, do

hereby solemnly affirm and declare as under:

1. That I am Plaintiff No.2 in the present Suit and I am well conversant

with the facts of the case.

2. That the accompanying Suit with the present affidavit has been

drafted by my counsel under my instructions and I affirm that the

reply of facts made therein are true and correct to the best of my

knowledge derived from the official records maintained by me in its

ordinary course of business.

DEPONENT

VERIFICATION

I, the Deponent hereinabove, do hereby verify and state that the

contents of the present Affidavit are true and correct to the best of my
knowledge. No part of it is false and nothing material has been

concealed therefrom.

Verified at New Delhi on this ___ day of March, 2024.

DEPONENT
 IN THE COURT OF LD. CIVIL JUDGE, KARKARDOOMA
COURT, EAST DISTRICT NEW DELHI.

CIVIL ORIGINAL SUIT No. ___ of 2024

IN THE MATTER OF:

Mrs. Kusum Bansal and Another …Plaintiffs

Versus

The HDFC Bank and Another …Defendants

LIST OF DOCUMENTS

S. NO. PARTICULARS PAGE NO.

1.

2.

3.

4.

5.

6.

7.

PLACE: NEW DELHI BALDEV KUMAR SINGH

DATED: ___.03.2024 Advocate for the Plaintiffs
 463, Ward 7, Sector 29, Noida,
Uttar Pradesh – 201301
Enroll No. D/3537/2014
baldevnlu@gmail.com/9999793692