Name- Devvrath ANAND

16010224033

2016-21

WRITTEN STATEMENT
IN THE COURT OF THE CIVIL JUDGE :

SAKET COURT,NEW DELHI

O.S. No. of 20020

Mr.Naresh Singh,
S/o Kunwar singh Aged 46 Years
Occ: Buissnessman
R/o.New Delhi Plaintiff

Vs

Mrs Geeta,
D/O Ram lal, Aged 36 Years,

Occ; Houseife
R/o. New Delhi Defendant No.1

Mr Rajesh Lal,
S/o Jamna lal, Aged 36 Years,

Occ: Employee
R/o. New Delhi Defendant No.2

JOINT WRITTEN STATEMENT FILED BY THE DEFENDANT

 1. It is submitted that the defendant has gone through the averments made in the plaint and
affidavit filed in support of the plaint. The averments, which are not specifically
admitted, are denied. The Plaintiff is put to strict proof of the same. Most of the
averments are not correct and false and the suit is not maintainable.
2. In reply to Para 5 of the plaint, it is submitted that the Defendant No.1 and her Son,
Defendant No.2 are the only legal heirs of Late Shri Jamna Lal and no sale of the first
floor of the property and no WILL in respect of the first floor in favour of Plantiff and
applied for conversion of lease hold rights into freehold.
Hence, it is prayed that this Hon’ble Court may be pleased to dismiss the suit with costs.

Counsel for the Defendant Defendant

Verification

I, Mrs Geeta, D/o Ram lal aged about 36 years, Occ: Housewife, do hereby declare that the
facts stated in paras 1 to 7 are true and correct to the best of my knowledge, information and
belief and I believe the same to be true and correct. Hence, verified on this the day of 21st
February, 2020 at New Delhi.

Defendant No.1

Verification

I, Mr Rajesh lal, S/o Jamna lal aged about 36 years, Occ: Employee, do hereby declare that
the facts stated in paras 1 to 7 are true and correct to the best of my knowledge, information
and belief and I believe the same to be true and correct. Hence, verified on this the day of 21
February, 2020 at New Delhi.

Defendant No.2