Eviction Compressed
Eviction Compressed
1
2. | COURTFEE                 POSSESSION, ARREAR
                                                 S OF RENT,
3    TSuIT FOR RECOVERY   OF
                                       ORY AND PERMAN
                                                       ENT
     MESNE PROFIT,  DAMA! GES, MANDAT
                                           AFFIDAVIT
          NC TI ON AL ON G WITH SUPPORTIVE
     INJU
    ANNEXURE A-1                                                      D
                     EE ME NT     OF    SA LE    Al ND PURCHASE AN
     COPY OF AGR                                              PLAINTIFE
             PO WE R OF   AT TO RN  EY ONTHEN AME OF
     SPECIAL
     ANNEXURE A-2
                          F ELECTRICITY BILL
     COPY OF RECEIPTO
     ANNEXURE A-3
                           D OF PLAINTIFF
     COPY OF ADHARCAR
     ANNEXURE A-4                                                       \ 11’4
                           CE IP T   OF   LE  GA L   NOTICE ALONG WITH
     COPY OF  POSTAL    RE
                          VERY STATUS
     SCREENSHOT OF DELI
     ANNEXURE A-5                                        AINST              ||3-20
              FIR U/S 40 5  ,  50 3 OF IPC REGISTERED AG
     COPY OF
                              GAUR
     DEFENDANT L.E POOJA
                                                                            \ 2
     VAKALATNAMA
Versus
   Pooja Gaur
   R/0 E-34-A, Upper Ground
   Floor, Backside,
   Vishwakarma Colony,
   New Delhi - 11004                                           ...Defendant
PETITIONER
                                    THROUGH
                                                                            TranSh o
                                                                    Himanshu Sharma
                                                       H-1206, Florida Apartment
                                    sector 82, Faridabad, Haryana - 121002
 Date: ____January 2025                                M: +91- 8802116924
Place: Delhi                            E:sharmahimanshu8802@gmail.com
                                                                                              (2)
         Limitation
                                                                when
                    of ac ti on ar os e fr om the from 19 March
         That cause
                                                       requested the
                                ed the Plaintiff and
        Defendant approach
                                                                   E-34A
                     le as e out the   sui t  property pearing no
        Plaintiff to                                                      w
                              or Ba ck si    de, Vi sh wakarma Colony, Ne
        Upper Ground Flo
        Delhi-110044
                                                                             the
                    he r ca us  e   of  ac ti on  arose on 5th may 2023
      ii.That fu rt
                               he r    hu sb an d  re qu es ted the Plaintiff to give
        defe  ndant an d
                                                                  erty
               st  6 mo nt h:  s'  fim e  to vacate the suit prop
        at lea
                                                                     sent many
                us e  of   ac ti o n  Fur the r arose when Plaintiff
          e ca
     iii.Th
                                                                             ng the
                   ce   via  his  co u   nse l  ag ain and again requesti
       legal noti
                                                                                 30
                      fo  pe ac  ef ul ly    va c  at e the suit property within
       Defendant
                                   ti ce   wa  s  se  nt on 7/ 09 /2 024.The Present
      days i.e last legal no
      suit is within the Limitation.
Prayer
                               Himanshu
                                                 gf,h oManSh U
                                                   Sharma/ Hemant Kumar Sharma
                                                                         (ADVOCATES)
                                                                    Mob No.8802116924
                                 Email: Sharmahimanshu8802@gmail.com
VERI
—— =AFI1I
       CATI
          VNON
Verified at New Delhi on           that the contents of para 1 to 12
are true and cormect to my knowledge and understanding
                                                           and
nothing material has been concealed therefrom.
                                DIsTRICT AND SESSIO
                                                    N JUDGE
               - SOUTH bigppcy
                               SAKET COURTS NEW DELHI
                       Civil suit No        /2025
    1. That | Chetan Prakash S/o R.C Singh Gaur R/o A-235 Dout
                                                               ie
      Storey Kalkaji South Delhi 110019 that | am the Petitioner in
       the accompanying to the suit for recovery of possession and
       arears of rent and well acquainted with the facts of the
       case.
     - That I have gone through the contents of the accompanying
       Petition, | reaffirm the contents of the present suit has been
       drafted by my counsel under my instruction and same are
       true to the best of my knowledge.
                                                                     ~    Rt i.}//
                                                          oo
                                                          (he
                                                                         Vo
                                                                DEPONENT
VERIFICATION
Verified at New Delhi on             that the contents of affidavit       L
are frue and cormect to my knowledge and understanding and
                                                                    _}4}‘
nothing material has been concealed therefrom.           o\ \}” ‘f////
                                                                DEPONENT
                                  INDIA NON JUDICIAL
e-Stamp
                              L    INDLITONBARSIS0RINT
                                   16-0ct-2021 0421 P
                                   IMPACC (IVI/ dIS40TON DELIY DL-OWH
                                   SUBIN.DLDUMOTOITOTORMO      11811 T
 Blurchased by                    CHETAN PHAKASH
Deserplion of Dacumant            At ABIC) Powa       r - (A
                                                 of whiomey
Property Descapson                 £ VA FLAT NO 002 ON UPPER GROUND FLOOR [BACK SIDE)
                                   KMASRA NO 33 SITUATED AT VIBMWAKATMA COLONY W8 ROAG
                                   NEW DELHI- 1 10044
Corsderason Pres Ry |              o
                                    (Zwio)
st Pany                            VINAY
Secona Pany                       CHETAN     PRAXASH
Swrp Dusy Pt By                    CHETAN PRAXASH
Sarmp Duty Ameniie |
                     COHHON     - BIKE    PARKING   m:n.rr! ON
        !EDOR      PARKING    AREA,   AND    EASEMENT    ATTACHED
           I.E.   RIGHT TO INSTALL T.V./DISH          ANTENA AND
  mo      WATER TANK       ON THE TOP OF TERRACE        RIGHT TO
  USE COMMON    PASSAGE AND STATRCASE       FOR APPROACH      FROM
       OTTOM        TO       TOP     OF     THE     BUILDING                   (hereinafter                called        the
 . demised Portion),                          part            of        Property   No.E-33/A  LAND
. MEASURING APPROX.                          92.44           SQ.     YDS.   (PROPERTY NO.E-33/A &
 E-34              TOTAL            MEASURING            AREA         190         SQ.     YDS.       BALANCE            LAND
  E-34         MEASURING                  97.56     SQ.            YDS.          USE  IN   COMMON   ROAD)
  IN     KHASRA              NO.303         SITUATED                      AT     VISHWAKARMA      COLONY,
 M.B.      ROAD,              NEW    DELHI-110044.
Vinad
                                         16 0CT 26
                       AGREEMENT             TO    SELL         AND     PURCHASE
AND
witnesses.
 PLACE:
 DATED:
 WITNESSES:
 T
 Signature  __ \
Name_
8/0-"
R/o
2%
signature ViulunSimo:
Name
S/o,
R/0
                                                                                  2y      and         authorize
                                                                                  jeeds         and         things
for         an                               f         and                              name      in
                                       ’              HE
 1DE                                              R               ’
                                                                                                                4
                                                                                                                                 P
                                                                                           \*   Date    0f      ~m“
 The facts leading to this complaint wre that L am a reputed teacher in the school and bound to be
retired atter the fined age. And for the sake of my decent life after the retirement 1 purchased
ONI:             BHK Property having address R/o E-         -, Upper Ground Floor, Backside. Vishwakarma
                                                                     19, my younger brother Mr.
 Colony. New  Delhi = 110044 ("Property 1. At the time of COVID
                                                                                        affection
                                              due o whicn | innocently under love and
 Dinesh Gaur ( *Brother™jgot serioushy (i
                                                                                        Gaur ie
                                             to him along with her wife Mrs. Pooja
 gave the possession of i PROPERTY
                                                charged ary rent from them.
 Accused. As covid heing a tough time | didn’t
                                                                                       interested
 Later after the few months when the situation got sorma: and there were some people
10 rent the Property from me and also 1 vas facing finarcial constraint due to which | asked my
brother to give me approprizte rent or vacate the Propery. Afier that ke gave me 4000rs as rent
amount for around 2 menths but be stopped giving rent {rom December 2022, And asked me 10
allow him some ume to pay the rent.
                                                                                                   make anyY PAYM               o
                                                                                                                     paymENt They, e .,
                              him  some mont hs    to  pay \   the   rent but e . didn’t*t ma
     « | herealler.       @ g
              herealler. ivin                                                                                                        .
                                                                                                    prope
                                                                             o | vacate ~ the the prop        rty. in September 2004
                                                                                                            erty
                                          her   to   pay    ol    the   rent
       multiple reminders         my Brot
                                                                               start looking           king       for new Tenant Annd
                                     will vacate  my ) property and T should                     o
              notiied me thati he
        e i notified                        a
                                                                     q
                                                             e ( Accustd)    didn’t.‘. This         P
                                                                                        This act implies her criminal
                                  my    property but   her wike
        after that he   vacated
                                     .                             have crimi
                                                     l. Thus shee have          ally breached my trust,
                                                                         criminnally
        IeNt 1o misuse my Property without my consen
    Henee, in view of the above. it is clear that the Accusec dishonestly retaining the possession of
   my       Property and i’ went there (o claim the possession then she (Aceused) will misuse the law
   whichis for the benefit of innocent people, 1o injure my                         eputation.
  Sincerely.
                               )
                                                    :
                            ‘x‘h}\'wl\
                ] LLL:""" ’
            \
          To
          daa v
     2 CHETAN PRAKASH
     S A- 235 DOUBLE STOREY
     § KALKAJI
          Al
     o    South Deit
     §    Delhi 110018
MN500:
               | Y= g
                 CHETAN PRAKASH
                 R - amo o i AR
                 Father . R C. SINGH GAUR
                F=n faf2 /008 : 29/111971
                %/ Male
                                                                                                                                 P
                                                                                           \*   Date    0f      ~m“
 The facts leading to this complaint wre that L am a reputed teacher in the school and bound to be
retired atter the fined age. And for the sake of my decent life after the retirement 1 purchased
ONI:             BHK Property having address R/o E-         -, Upper Ground Floor, Backside. Vishwakarma
                                                                     19, my younger brother Mr.
 Colony. New  Delhi = 110044 ("Property 1. At the time of COVID
                                                                                        affection
                                              due o whicn | innocently under love and
 Dinesh Gaur ( *Brother™jgot serioushy (i
                                                                                        Gaur ie
                                             to him along with her wife Mrs. Pooja
 gave the possession of i PROPERTY
                                                charged ary rent from them.
 Accused. As covid heing a tough time | didn’t
                                                                                       interested
 Later after the few months when the situation got sorma: and there were some people
10 rent the Property from me and also 1 vas facing finarcial constraint due to which | asked my
brother to give me approprizte rent or vacate the Propery. Afier that ke gave me 4000rs as rent
amount for around 2 menths but be stopped giving rent {rom December 2022, And asked me 10
allow him some ume to pay the rent.
                                                                                                   make anyY PAYM               o
                                                                                                                     paymENt They, e .,
                              him  some mont hs    to  pay \   the   rent but e . didn’t*t ma
     « | herealler.       @ g
              herealler. ivin                                                                                                        .
                                                                                                    prope
                                                                             o | vacate ~ the the prop        rty. in September 2004
                                                                                                            erty
                                          her   to   pay    ol    the   rent
       multiple reminders         my Brot
                                                                               start looking           king       for new Tenant Annd
                                     will vacate  my ) property and T should                     o
              notiied me thati he
        e i notified                        a
                                                                     q
                                                             e ( Accustd)    didn’t.‘. This         P
                                                                                        This act implies her criminal
                                  my    property but   her wike
        after that he   vacated
                                     .                             have crimi
                                                     l. Thus shee have          ally breached my trust,
                                                                         criminnally
        IeNt 1o misuse my Property without my consen
    Henee, in view of the above. it is clear that the Accusec dishonestly retaining the possession of
   my       Property and i’ went there (o claim the possession then she (Aceused) will misuse the law
   whichis for the benefit of innocent people, 1o injure my                         eputation.
  Sincerely.
                               )
                                                    :
                            ‘x‘h}\'wl\
                ] LLL:""" ’
            \
       andwillinformtheAdvocate for appearance whenthe caseis called.                        te responsible for the result of
               ‘and I\e undersigned do hereby agree not to hold the advocate of his substitu       e which he shall receive
                                                                   colrt                shall be of the Advocat
       the said case.The adjournment costs whenever ordered by the
       andretainfor himself.
                                                                     of tthe whole or part of the fee agreed by me/us to be
                 And I'We undersigned do hereby agree that in the even
                                                                                       prosecution of the said case until the
       paid to the advocate remainin~ unpaid he shall be entitied 1o withdraw from the
      samispsldu          p.Tht    mufile   l’mly  fermm    ufllnd   lbovu   coun.   UWe   hereby agree that once the fee Is
                                                                                                                prolongs for
      paid,VWe will not be entitled for the refund of the same in any case whatsoever and if the case
      more than 3yea      the rs              be l
                              original fee shal  paid again by me/us
                INWITHNES         WHERE OF | /We do hereunto setmy/our hand to these presents the contents of which have
                                                                                    aihekan PyaRabh
                                                              1 identfy the Signaturs/Thumb Impression of the Below Mention
                                                                                                                            ed Perscn,
      \-Qlfr&‘\&w"
                                                                                     Who Has been Sighed in my presence. The Chiert.
              dvocate
                            Hemant—