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IN THE COURT OF SH. HARJEET SINGH JASPAL, CI(N), ROHINI COURTS, DELHI In Re: RAJ DEVI ves KAMAL SINGH ETC IN BEHALF OF DEFENDANTS NO. IIs respectfully submits as under : PRELIMINARY OBJECTIONS : 1. That the present suit is without any cause of action. No cause of action has been ever accrued in the favour of Plaintiff and against the answering defendants giving her right of filing of the present suit. 2. That the suit of the besides being an abi simply for harassing fulfill her illegal det site plan filed by the plaintiff is incorrect. It is respectfully submits that he defendants with their children are living in the property earing 76/206, T-Huts, Khasra No.206, Village Rajpura, hi, The said property no. 76/206 is allotted to the Gurmandi, Del brother of the defendant no.1 Chand Singh and the defendants and his brother were residing in the said property before the allotment of the same, being an unauthorized occupants. After the allotement of the said token by the government, the brother of the defendant no1.1 became the owner of the said jhuggi and Shere Asie fotion card) aadhor card and other documents in the n/ame of the defendants and his brother w.r.t. said property no. 76/206. The defendant is residing in the said jhuggi since past plaintiff is residing in separate and now she wants to grab the jhuggi 20-25 years and the jhuggi/property no. 80/49 of the defendants’s brother under the garb of present petition and the eviction petition, she filed earlier. It is further stated that it is the defendants who constructed the a tin shed room on their jhuggi and the same is in exclusive possession of the defendants and the plaintiff is having evil eye on the said room also. The plaintiff has no docu property of the injunction on the however it is denied that no interim relief is granted. The Hon‘ble High Court of Delhi, Rajiv Sahai Endlaw J, vide order dated 13/09/2017 granted stay over the impugned order of eviction and now the matter is listed for 22/03/2018. 6. That contents of Para no. 6 of the plaint are wrong and denied. it is denied that on 01/08/2017, the defendants suddenly purchase plastic tarpaulin and tin shed. It is denied that on that day, the defendants illegally constructed brick wall and tin shed room on tenanted premises during pendency of revision petition. it is denied that any call at 100 no. is made by the daughter of the plaintiff and the police came and they gave any warning to the defendants to remove illegal construction but not took any action. It is denied that the photographs filed by the plaintiff is showing illegal construction. It is respectfully submits that defendants made construction over the jhuggi no. 76/206, which belongs to the brother of the defendants no.1 and the photographs filed by the plaintiff showing the said property. 7. That contents of Para no. 7 of the plaint are not in the knowledge of the defendants and therefore not submitted that the said complaint therefore no action on the same is

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