IN THE HON’BLE COURT OF MS.

TWINKLE WADHWA, ADJ, TIS

HAZARI COURT, DELHI

SUIT NO._______ OF 2022

IN THE MATTER OF:

SH. KAMAL KUMAR NARULA …PLAINTIFF

VERSUS

SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS

REJOINDER TO THE WRITTEN STATEMENT FILED ON BEHALF OF

DEFENDANTS.

REPLY TO THE PRELIMINARY OBJECTIONS

1. That the contents of para no.1 of the PO are

wrong, false and hence denied. It is

submitted that the plaintiff has good prima

facie case in his favour.

2. That the contents of para no.2 of the PO are

wrong, false and hence denied. It is

submitted that the plaintiff has good prima

facie case in his favour.

3. That the contents of para no.3 of the PO are

wrong, false and hence denied. It is

submitted that the plaintiff has good prima

facie case in his favour and plaintiff is the

owner of the suit property as plaintiff had

purchased the suit property from his own

funds. It is further submitted that the

plaintiff has every right and title to file

and institute the present suit against the

defendants. It is submitted that the

plaintiff has filed the present suit on

arising valid cause of action in his favour,

suit is very much within limitation and the

plaintiff has affixed the proper court fee.

4. That the contents of para no.4 of the P.O.

are wrong, false and hence denied. It is

submitted that the plaintiff has filed the

present suit on arising valid cause of action

in his favour, suit is very much within

 limitation and the plaintiff has affixed the

proper court fee. It is further submitted

that the plaintiff has filed the legal and

valid site plan.

5. That the contents of para no.5 of the P.O.

are wrong, false and hence denied. It is

submitted that the plaintiff has filed the

present suit on arising valid cause of action

in his favour.

6. That the contents of para no.6 of the PO are

wrong and denied. It is specifically denied

that the plaintiff has no cause of action to

file and maintain the present suit. It is

submitted that the plaintiff has stated true

and material facts in the plaint and nothing

material has been concealed from the hon’ble

court. It is submitted that the plaintiff has

every cause of action to file the present

suit against the defendants.

7. That the contents of para no.7 of the P.O.

are wrong, false and hence denied. It is

submitted that the plaintiff has filed the

present suit on the basis of true facts and

has not concealed or suppressed any material

facts from this Hon’ble Court. It is

submitted that the defendants are misguiding

this Hon’ble court by mentioning unnecessary

and false and vague averments.

8. That the contents of para no.8 of the PO are

wrong and denied. It is specifically denied

that the plaintiff has no cause of action to

file and maintain the present suit. It is

submitted that the plaintiff has stated true

and material facts in the plaint and nothing

material has been concealed from the hon’ble

court. It is submitted that the plaintiff has

every cause of action to file the present

suit against the defendants.

9. That the contents of para no.9 of the PO are

wrong and denied. It is submitted that the

plaintiff has stated true and material facts

in the plaint and nothing material has been

concealed from the hon’ble court. It is

submitted that the defendant again and again

mentioning the same averments in all the para

which shows that defendant has nothing to

explain to the plaint of the plaintiff.

10. That the contents of para no.10 of the PO are

wrong and denied. It is submitted that the

plaintiff has stated true and material facts

in the plaint and nothing material has been

concealed from the hon’ble court. It is

submitted that the plaintiff has every cause

of action to file the present suit against

the defendants.

11. That the contents of para no.11 of the PO are

wrong and denied. It is specifically denied

 that the mother Smt. Chanchal Rani has ever

purchased any property from her own funds as

she was a house wife throughout her life. It

is submitted that the plaintiff has stated

true and material facts in the plaint and

nothing material has been concealed from the

hon’ble court on the contrary the defendants

are making false and imaginary averments in

the para under reply. It is submitted that

the plaintiff has every cause of action to

file the present suit against the defendants.

12. That the contents of para no.12 of the PO are

wrong and denied. It is submitted that the

suit property is belongs to the plaintiff and

the sharing of the same cannot be allowed

under any circumstances. It is submitted that

the plaintiff has stated true and material

facts in the plaint and nothing material has

been concealed from the hon’ble court. It is

 submitted that the plaintiff has every cause

of action to file the present suit against

the defendants.

13. That the contents of para no.13 of the PO are

wrong and denied. It is specifically denied

that the suit of the plaintiff is not

maintainable and the same is hit by specific

relief act. It is submitted that the

plaintiff has stated true and material facts

in the plaint and nothing material has been

concealed from the hon’ble court. It is

submitted that the plaintiff has every cause

of action to file the present suit against

the defendants.

14. That the contents of para no.14 of the PO are

wrong and denied.

15. That the contents of para no.15 of the PO are

wrong and denied. It is specifically denied

 that the suit of the plaintiff is hit by

provision of section 41(h) of specific relief

act. It is submitted that the plaintiff has

stated true and material facts in the plaint

and nothing material has been concealed from

the hon’ble court. It is submitted that the

plaintiff has every cause of action to file

the present suit against the defendants.

16. That the contents of para no.16 of the PO are

wrong and denied. It is specifically denied

that the plaintiff has no cause of action to

file and maintain the present suit. It is

submitted that the plaintiff has stated true

and material facts in the plaint and nothing

material has been concealed from the hon’ble

court. It is submitted that the plaintiff has

correctly valued the suit for the purpose of

jurisdiction and court fees and the plaintiff

 has affixed the appropriate court fees on the

plaint.

17. That the contents of para no.17 of the PO are

wrong and denied. It is specifically denied

that the plaintiff has not made the parties

to the suit according to the law, the

plaintiff has correctly filed the suit

against all the defendants as all the

defendants are illegally occupying the suit

premises of the plaintiff.

REJOINDER TO WRITTEN STATEMENT

1. That the contents of para no.1 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity.

2. That the contents of para no.2 of the W.S. are

wrong and denied and those of the plaint are

 reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

3. That the contents of para no.3 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

4. That the contents of para no.4 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

5. That the contents of para no.5 of the W.S. are

wrong and denied and those of the plaint are

 reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

6. That the contents of para no.6 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

7. That the contents of para no.7 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

8. That the contents of para no.8 of the W.S. are

wrong and denied and those of the plaint are

 reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

9. That the contents of para no.9 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

10. That the contents of para no.10 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity.

11. That the contents of para no.11 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

 are not being repeated herein for the sake of

brevity. Let The defendant may be put to strict

proof of the same.

12. That the contents of para no.12 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity.

13. That the contents of para no.13 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity.

14. That the contents of para no.14 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity.
15. That the contents of para no.15 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity.

16. That the contents of para no.16 of the W.S. are

wrong and denied and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity.

17. That the contents of para no.17 of the W.S.

needs no rejoinder and those of the plaint are

reaffirmed and reiterated to be correct which

are not being repeated herein for the sake of

brevity.

18-21. That the contents of para no.18-21 of the

W.S. needs no rejoinder and those of the

plaint are reaffirmed and reiterated to be

 correct which are not being repeated herein

for the sake of brevity.

That the prayer clause of the defendants is

wrong and denied and that of the contents of

prayer clause of plaint is reaffirmed and

reiterated to be correct and the prayer of the

plaintiff may uphold in view of the facts

stated in the present rejoinder.

PRAYER

It is, thisefore, prayed that the suit of

plaintiff may be decreed as prayed for.

Delhi Plaintiff
Dated
Through

DARSHAN SINGH & ASSOCIATES

IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI

SUIT NO._______ OF 2022

IN THE MATTER OF:

SH. KAMAL KUMAR NARULA …PLAINTIFF

VERSUS

SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS

AFFIDAVIT

I, KAMAL KUMAR NARULA S/O LT. SH. JANKI DASS

NARULA R/O L-56, ANDHA MUGHAL, PRATAP NAGAR, DELHI-
110007, do hiseby solemnly affirm and declare as
under:

1. That the deponent is the plaintiff in the above

noted matter and I am fully conversant with the

facts of the case.

2. That the accompanying rejoinder has been drafted

by my counsel on my direction and as per my

instructions and read over the contents before me

in vernacular language and I understood the same

 and which is correct as per my knowledge and the

same may be read as part and parcel of this

affidavit and the same are not repeated hise for

the sake of brevity.

DEPONENT

VERIFICATION: -

Verified at Delhi on this ____ day of , 2022,

that the contents of this affidavit are true and
correct to the best of my knowledge and belief and
nothing has been concealed therefrom.

DEPONENT
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI

SUIT NO._______ OF 2022

IN THE MATTER OF:

SH. KAMAL KUMAR NARULA …PLAINTIFF

VERSUS

SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS

REPLY TO THE APPLICATION U/O VII RULE 11 READ WITH

SECTION 151 OF CPC FILED ON BEHALF OF DEFENDANTS.

MOST RESPECTFULLY SHOWETH:

ON MERITS

1. That the contents of para no.1 of the application

require no comments except to the mentioning of false

and vague suit.

2. That the contents of the para no.2 of the

application are false, vague, fabricated, wrong and

incorrect hence denied in toto.

3. That the contents of the para no.3 of the

application are false, wrong and incorrect hence

denied. It is submitted that the plaintiff has filed

the present suit very much within the limitation.

4. That the contents of the para no.4 of the

application are false, wrong and incorrect hence

denied. It is submitted that the plaintiff has filed

the present suit with his every right to do and the

suit is very much maintainable.

5. That the contents of the para no.5 of the

application are wrong, false and incorrect hence

denied in toto.

6. That the contents of para no.6 of the

application are wrong, false and incorrect and hence

denied. It is submitted that the plaintiff is having

every cause of action to file and institute the

present suit against the defendants.

7. That the contents of the para no.7 of the

application are false, wrong and incorrect hence

denied in toto. It is submitted that the plaintiff

has come before this Hon’ble court with clean hands

and nothing has been concealed from this Hon’ble

court by the plaintiff.

8. That the contents of the para no.8 of the

application are false, wrong and incorrect hence

denied in toto. It is submitted that the defendants

have unnecessarily concocted the false story and

mentioned under the para under reply.

9. That the contents of the para no.9 of the

application are false, wrong and incorrect hence

denied in toto.

10. That the contents of the para no.10 of the

application are false, wrong and incorrect hence

denied in toto.
11. That the contents of the para no.11 of the

application are false, wrong and incorrect hence

denied in toto.

12. That the contents of the para no.7 of the

application are false, wrong and incorrect hence

denied in toto.

13. That the contents of the para no.7 of the

application are false, wrong and incorrect hence

denied in toto.

14. That the contents of the para no.14 of the

application are false, wrong and incorrect hence

denied in toto. It is submitted that the suit of the

plaintiff is not hit by section 31 of specific relief

act.

15. That the contents of the para no.15 of the

application are false, wrong and incorrect hence

denied in toto. It is submitted that the suit of the

plaintiff is not hit by section 41(h) of specific

relief act.

16. That the contents of the para no.16 of the

application are false, wrong and incorrect hence

denied in toto. It is submitted that the plaintiff

has correctly valued the suit for the purpose of

jurisdiction and court fees and appropriate court

fees has been affixed by the plaintiff on the plaint

17. That the contents of the para no.17 of the

application are false, wrong and incorrect hence

denied in toto. It is submitted that the plaintiff

has filed the present suit against the bonafide

defendants.

18. That the contents of the para no.18 of the

application are false, wrong and incorrect hence

denied in toto.

That the last para is a prayer to this

Hon’ble court which is absolutely illegal, arbitrary,

malafide and cannot be allowed under any

circumstances.

PRAYER

It is, therefore, most respectfully prayed that

the application of the defendants is liable to be

dismissed with compensatory cost.

Delhi PLAINTIFF
Dated Through
DARSHAN SINGH AND ASSOCIATES
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI

SUIT NO._______ OF 2022

IN THE MATTER OF:

SH. KAMAL KUMAR NARULA …PLAINTIFF

VERSUS

SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS

AFFIDAVIT

I, SH. KAMAL KUMAR NARULA S/O LT. SH. JANKI DASS

NARULA R/O L-56, ANDHA MUGHAL, PRATAP NAGAR, NEW
DELHI-110007, do hereby solemnly affirm and declare
as under:-

1. That I am the plaintiff in the above noted case

and well conversant with facts and circumstances
of the case and as such I am competent to swear
the affidavit.
2. That the reply to the application U/o 7 rule 11
read with section 151 of CPC has been drafted by
the counsel under my instructions which are
correct and the contents of the same may be read
as the part and parcel of this affidavit as same
 are not being repeated herein for the sake of
brevity.

DEPONENT
VERIFICATION: -

Verified at Delhi on this ____ day of __,

2022, that the contents of this affidavit are true
and correct to the best of my knowledge and belief
and nothing has been concealed therefrom.

DEPONENT
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI

SUIT NO._______ OF 2022

IN THE MATTER OF:

SH. KAMAL KUMAR NARULA …PLAINTIFF

VERSUS

SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS

REPLY TO THE APPLICATION U/O I RULE 10(2) READ WITH

SECTION 151 OF CPC FILED ON BEHALF OF DEFENDANTS FOR
DELETING THE DEFENDANTS NO.2 TO 4.

MOST RESPECTFULLY SHOWETH:

ON MERITS

1. That the contents of para no.1 of the application

require no comments except to the mentioning of false

and vague suit.

2. That the contents of the para no.2 of the

application are false, vague, fabricated, wrong and

incorrect hence denied in toto. It is submitted that

the defendants are in illegal possession of the suit

property hence all the defendants are necessary party

to the suit.

3. That the contents of the para no.3 of the

application are false, wrong and incorrect hence

denied. Let the defendants put to the strict proof of

the same.

4. That the contents of the para no.4 of the

application are false, wrong and incorrect hence

denied.

5. That the contents of the para no.5 of the

application are wrong, false and incorrect hence

denied in toto.

That the last para is a prayer to this

Hon’ble court which is absolutely illegal, arbitrary,

malafide and cannot be allowed under any

circumstances.
PRAYER

It is, therefore, most respectfully prayed that

the application of the defendants is liable to be

dismissed with compensatory cost.

Delhi PLAINTIFF
Dated Through
DARSHAN SINGH AND ASSOCIATES
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI

SUIT NO._______ OF 2022

IN THE MATTER OF:

SH. KAMAL KUMAR NARULA …PLAINTIFF

VERSUS

SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS

AFFIDAVIT

I, SH. KAMAL KUMAR NARULA S/O LT. SH. JANKI DASS

NARULA R/O L-56, ANDHA MUGHAL, PRATAP NAGAR, NEW
DELHI-110007, do hereby solemnly affirm and declare
as under:-

1. That I am the plaintiff in the above noted case

and well conversant with facts and circumstances
of the case and as such I am competent to swear
the affidavit.
2. That the reply to the application U/o I rule
10(2) read with section 151 of CPC has been
drafted by the counsel under my instructions
which are correct and the contents of the same
may be read as the part and parcel of this
 affidavit as same are not being repeated herein
for the sake of brevity.

DEPONENT
VERIFICATION: -

Verified at Delhi on this ____ day of __,

2022, that the contents of this affidavit are true
and correct to the best of my knowledge and belief
and nothing has been concealed therefrom.

DEPONENT
IN THE HON’BLE COURT OF MS. TWINKLE WADHWA, ADJ, TIS
HAZARI COURT, DELHI

SUIT NO._______ OF 2022

IN THE MATTER OF:

SH. KAMAL KUMAR NARULA …PLAINTIFF

VERSUS

SH. RAKESH KUMAR NARULA & ORS. …DEFENDANTS

INDEX

S.NO. PARTICULARS PAGES C.FEE

1. Rejoinder to the WS along with affidavit

2. Reply to application U/O 7 R11, along with

affidavit

3. Reply to application under order 1 rule

10( 2) along with affidavit

DELHI PLAINTIFF

DATED: THROUGH

DARSHAN SINGH & ASSOCIATES