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District- Purba Medinipur

In the Court of Ld. Civil Judge (Senior Division), 1 st Court, Contai
Title Suit No- 132/2019

Amitava Das ………….Plaintiff.

-Versus-
Amiya Ranjan Das & Others ……..…….Defendants

Written Objection on behalf of defendant no-1 to 3

against an application under Order 39 Rule 7 CPC filed
by the plaintiff on 07/04/2021

The defendants named above begs to say and submit as

follows-

1) That the application under reply is not maintainable in

its present form and prayer.

2) That the application under reply is otherwise bad in law.

3) That the plaintiff cannot get any reliefs as prayed for.

4) That the application under reply is barred by limitation.

5) That owing to the principles of estoppel, waiver and

acquiescence the instant application under reply is liable
to be rejected.

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6) That it is denied that the defendants no-1/2/3 are now

trying to start raising pucca construction over the (A) suit
properties illegally by violating solemn order of injuction
and also by violating the WB Gram Panchayat Act &
Administration Rules by engaging huge number of
labours & for such a purpose they have accumulated
huge building materials over the suit properties.
7) That the defendant no-1 to 3 submits that the plaintiff

filed the instant application under reply in order to collect

evidence in this suit which can be found from the points sought

to be inspected and as such the application under reply is liable

to be rejected.

8) That barring the matters of record all other allegations of

the application under reply which are not specifically
denied are deemed to be denied and there are other
submissions which will be urged at the time of hearing.

It is prayed that Your Honour would be pleased to reject

the application under reply with exemplary costs.

Affidavit on behalf of Plaintiff

I, Amiya Ranjan Das, aged about years, Son of Late Bibhupada Das, by faith-
Hindu, by occupation- Retired from Service , residing at Flat No-NEIII,14/7 Paresh
Mazumder Road ,P.O-Haltu, P.S-KAsba, Kolkata-700078 do hereby solemnly affirm
and declare as follows:- 

1) That I am the defendant no-1 of this case am well conversant with the facts and
circumstances of this case. Hence I am competent to swear this affidavit.

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2) That the written objection has been drafted under my instructions and the contents
of the written objection contained herein, except the legal averments contained herein,
are true and correct to the best of my knowledge, information & belief. The legal
averments contained herein are true and correct on the basis of legal advice, received
by me and believed by me to be true and correct. The contents of this written objection
may kindly be read as part of this affidavit.

4) That I further solemnly affirm and declare that no part of it is false and nothing
material has been concealed therefrom.

Verification
Prepared in my chamber
The statement made hereinabove are true to the
best of my knowledge & belief and I have
understood the same and contents of the same
are true to my knowledge and belief and no part
Advocate of it is false and no material facts have been
concealed therefrom.
Dated-

……..………………….………………
Deponent

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