IN THE HIGH COURT OF DELHI AT NEW DELHI

Civil Suit No….of ……

IN THE MATTER OF :

Daljeet kaur …… Plaintiff

Versus

Jasbir Singh & Ors. …… Defendant

Written Statement of the Respondent under Order 8 rule 1

(Or Written Statement on behalf of all the Respondent)

The respondent(s) respectfully state(s) as follows:-

1. Para no.1 of the plaint is admitted and needs no reply.

2. Para no.2 of the plaint is admitted and needs no reply.

3. Para no.3 of the plaint is admitted and needs no reply.

4. Para no.4 of the plaint is denied and is not admitted

because the defendant was not the illegal heir as stated in
the plaint by the plaintiff’s side, in fact defendant is the
legal heir and had been vested the exclusive right of the
property by the deceased father through will by way of
testamentary succession.

5. Para no.5 of the plaint is denied and is not admitted

because the property bearing no.42, gautam nagar, New
 Delhi- measuring 275 sq yards, consisting of ground, first
and second floor with terrace belongs to Sh. Jasbir singh
the defendant as the whole construction and acquisition of
plot was done by Sh. Jasbir Singh. Therefore as stated by
the plaintiff in the plaint that the said construction of the
building was done by her father is false. The deceased father
was a poor person who could not have afford to build his
own house.

6. Para no.6 of plaint is denied because the property belonged

to the son as his individual property earned by his own hard
work and money. Plaintiff does not have any share in the
property except some family settlements.

7. Para no.7 of plaint is denied because as per the plaintiffs

claim in the plaint the property belonged to the deceased
father which he acquired through his own efforts and money
because of which all the rent and other income arising out
of the disputed property will be divided but in reality the
defendant is not liable to entertain any such claims as the
property which is in dispute solely belongs to the defendant
which had been acquired by him through his own efforts
and money and has an exclusive right to enjoy the property
as well as any other incomes arising out of it as also he has
many evidences to show such as bills and taxes etc. and
therefore defendant will not be liable for anything.

8. Para no.8 of plaint is denied as plaintiff cannot ask for the

document of the property because the documents of the
said property belongs to the defendant and plaintiff has no
right to demand them as the rights of the said property is
vested in defendant through will.

9. Para no.9 of plaint is denied as similar to Para no.8.

10. Para no.10 of plaint is denied because the share of all the
plaintiff and defendants had already been settled and
 nothing more remains to be settled. The plaintiff was already
aware of the deceased father’s bank account number.

11. Para no.11 and 12 of the plaint is denied because the

defendant had not committed forgery on the cheques
operated the account of the deceased’s father and there shall
be no criminal proceeding against the defendant. Also the
plaintiff’s son meeting with the bank officials is under
suspicion. Also the defendant has not forged any documents
to grab any property.

12. Para no.13,14,15,16 of the plaint is denied because after the

demise of the father plaintiff and the defendant will not be
the joint owner of the property except the settlement of the
property. As we have already stated above that the defendant
has been vested exclusive right to the property. Further it
should be noted that the defendant is not trying to create
third party right in the property and also has not contacted
any property dealers.

13. Para no. 18 of the plaint is denied as the claims by the

plaintiff are false.

14. Para no. 19 of the plaint is denied as the reliefs claimed by

the plaintiff are vague.