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IN THE COURT OF CIVIL JUDGE (S.D.

),
VASANT VIHAR NAGAR,
Dehradhun.
Original Suit No. Of 2017

Shri Raj Kumar Saini S/o Shri Ramgopal Saini R/o B-1005, Parsvanath Green
Ville, Sector-48, Sohna Road, Dehradun.
...................Plaintiff

VS
Shri Anoop Sarma S/o Shri Krishnalal Sharma presently residing at Aashirwad
Enclave, Vasant Vihar, Dehradun
Defendant

SUIT FOR EJECTMENT


SIR,
The Plaintiff begs to submit as under:-

1. That the plaintiff is owner and in exclusive possession of the


following properties,
a. A piece of land in Kandoli, Dehradhun admeasuring
33 acres beside Cambridge High School.
b. A Gowdown in Prem Nagar, Dehradun measuring
60x40
c. Flat no. 07 in Aashirwad Inclave, Vasant vihar,
Dehradun
d. Flat no.45 near Vikas Mall, Vasant Vihar, Dehradun.
2. That, the plaintiff the owner of the Flat no.09, Ashirwad Enclave,
Vasant Vihar, Dehradun, enters into a lease agreement dated 26th
January 2015, with Defendant to give aforesaid Flat no.7 to Defendant
on lease @12000 per month. For the year February 2015 to February
2016.
3. That on the date on which the lease agreement was finalized
defendant paid Rs. 46,000 to plaintiff, 36,000 as advanced rent paid
for 3 months and 10,000 as security deposit.
4. At the end of February 2016, defendant insisted plaintiff to renew the
rent agreement, and plaintiff agreed upon it. And the lease agreement
was further renewed for another year that is for February 2016 to
February 2017.
5. That on 3rd March 2017 a notice was served to defendant by plaintiff
stating that, on 28 February 2017 the lease agreement has came to an
end and plaintiff is not willing to renew it further.
6. That Notice also state that, within 2 months from the date of the
notice, defendant is required to vacant the flat. On December 2017
there is Plaintiffs daughter marriage and he want the possession of
his house back to perform all the marriage functions and rituals.
7. After prior and repeated notices and intimation to the defendant,
defendant is not willing to vacant the house of the plaintiff.
8. That rent from March 2017 to August 2017 is also unpaid and interest
thereupon is also to be charged @ 8% p.a.
9. That, the rent to be paid for the month of March 2017 to August 2017
is 72,000 and on adding interest of 8% p.a the defendant is required to
pay 74,880 to the plaintiff.
10. That the property in suit is situated within the limits of this court and
hence this Ld. Court has the Jurisdiction to hear adjudicate and decide
this suit.
11. That for the purpose of payment of Court fees the suit is valued at Rs.
15,000/-. Relief claim in the present suit for Ejectment of defendant
from plaintiffs property, on which maximum prescribed court fees is
being paid.

Plaintiff prays a decree against the defendants for the following reliefs:-

A. Ejectment of defendant from plaintiffs property


B. For a recovery of unpaid rent of Rs. 74,880/- from the defendant.
C. Cost of suit
D. Any other relief in addition to or substitution thereof as the Ld.
Court may deem fit.
...................Plaintiff
I, Shri Raj Kumar Saini S/o Shri Ramgopal Saini R/o B-1005, Parsvanath Green
Ville, Sector-48, Sohna Road, Dehradun, plaintiff do hereby verify that the
contents of paras 1 to 11 of the plaint are partly true to the best of my knowledge &
belief and partly true to the information received from the documents and partly
true on the basis of legal advice received which I, believe to be true.
Verified at Dehradun on 03.09.2017.

Dated: 03.09.2017 Plaintiff


Dehradun
Presented by

Rachit Munjal
Advocate.
IN THE COURT OF CIVIL JUDGE (S.D.), VIKAS NAGAR
DEHRADUN
Original Suit No. Of 2017
Raj Kumar Saini Vs. Anoop Sharma

Affidavit Shri Raj Kumar Saini S/o Shri Ramgopal Saini R/o B-1005, Parsvanath
Green Ville, Sector-48, Sohna Road, Dehradun.
...................Deponent
I, the deponent above named do hereby solemnly affirm on oath as under:-

1. That the deponent is plaintiff in the above suit and as such is fully aware of the
facts deposed to below.

2. That the deponent has filed the present suit for permanent Ejectment of the
defendant, that the contents of the said suit may be read and understood as a part of
this affidavit which are not being repeated herewith for the sake of brevity.

3. That the deponent hereby verifies that contents made in the suit are correct & true.

4. That the suit of the deponent is liable to be allowed for reliefs claimed.
.Deponent
Verification
I, the deponent above named do hereby verifies that the contents of para 1 to 4 of
the above affidavit are true to the best of knowledge & belief. Nothing material has
been concealed herewith & no part of it is untrue.
Verified at Dehradun on ..
.Deponent