BEFORE THE LD DISTRICT JUDGE (CENTRAL)

TIS HAZARI,DELHI

IN THE MATTER OF

MOHD SALEEM …PLAINTIF

VERSUS

SAJID AJMAL AND ORS. …DEFENDANTS

REPLY ON BEHALF OF RESPONDENT SAJID JAMAL.

Preliminary Submission:

1. That the plaintiff has not come before this Hon’ble court with clean hands and has
conceal the material facts from this Hon’ble Court hence suit of plaintiff is liable to
dismiss.
2. That the plaintiff is no more owner of the property no 2433,Ground Floor,Gali Abdul
Qadir,Behind G.B Road,Delhi -110006 claimed in the suit as defendant no 1 is the
rightful owner of the property as per the sale deed dated 22.08.19. Hence no cause of
action arose in favour of plaintiff against the defendant no.1.Hnce suit is liable to be
dismissed.
3. That present plaint is instituted with malafide intention and on false and fabricated
ground to harass the respondent as no prima facie case is made out in favour of
plaintiff against the defendant. Hence the suit is liable to be dismissed.
PARA WISE REPLY:

1. That the contents of Para 1 need no reply.

 2. That the contents of para 2 are admitted
3. That the contents of Para 3 are false and hence denied .
4. That the contents of Para 4 is denied in toto.
5. That the contents of Para is denied in toto.
6. That the contents of Para 6 and 7 is false and baseless,and hence denied.
7. That contents of Para 8 is wrong and denied that the plaintiff had the actual
knowledge of sale deed and have received the consideration amount and signed the
deed without any pressure and with free will.
That the contents of Para 9 is related to defendant no 2, hence denied in toto
8. That the contents of Para 10 is baseless hence denied and need no reply.
9. That the contents of Para 12 is completely false and denied as the defendant no .1 has
not done any thing wrong and it is being opposed
10. That the contents of para 13 and 14 are the legal paras hence no need of reply. The
contents of the para 14 is only accepted only on the basis of legal aspects and the
other content have completely denied.
11. That the content of the para 15 to 17 are legal paras and hence need no reply.
12. That the prayer clause is strictly denied and opposing the same as the defendant no 1
is innocent.
Prayer

That the Respondent most respectfully prays the Hon’ble Court may be pleased to grant
following relief to the Respondent:

a) To pass an order rejecting the present complaint,

b) To impose cost on the complainant for instituting vexatious suit, and
c) To pass any such further order/direction as this Hon’ble Court may deem fit in the
interest of equity, justice and good conscience.

New Delhi

Dated Through

Counsel for the Respondent

Arvind Kumar
(Advocate)
 B-3, 1st Floor, Jangpura Extension,
New Delhi – 110014
Email- arvindkumar2003@gmail.com
Mob. 9868001254