IN THE HIGH COURT OF DELHI AT NEW DELHI

I.A. NO. ________ OF 2023

IN
O.A. NO. ________ OF 2023
IN
CS (OS) NO. 361 OF 2016
IN THE MATTER OF: -
MRS. JYOTSANA BHATIA …..PLAINTIFF
VERSUS
ARUN KHOSLA & ORS. .….DEFENDANTS
INDEX
S. NO. PARTICULARS PAGE NO.
1. URGENT APPLICATION
2. APPLICATION FOR CONDONATION
OF DELAY UNDER SECTION 5 OF
THE LIMITATION ACT
3. DOCUMENT 1
TRUE COPY OF THE LIST OF
DEFECTS RAISED BY THE
REGISTRY
4. PROOF OF SERVICE

APPELLANT
THROUGH

(PRAVEEN K SHARMA/SURBHI SHARMA/

SAMEERA RAI & SAHIL NAGPAL)
ADVOCATES FOR THE APPELLANT
A – 384, FIRST FLOOR,
DEFENCE COLONY,
NEW DELHI – 110024
MOB: 9999099325
EMAIL: law_sharma@yahoo.com
PLACE: NEW DELHI
DATE: 18.04.2023
 IN THE HIGH COURT OF DELHI AT NEW DELHI
I.A. NO. ________ OF 2023
IN
O.A. NO. ________ OF 2023
IN
CS (OS) NO. 361 OF 2016
IN THE MATTER OF: -
MRS. JYOTSANA BHATIA …..PLAINTIFF
VERSUS
ARUN KHOSLA & ORS. .….DEFENDANTS
URGENT APPLICATION
To,
The Registrar
Delhi High Court
New Delhi -110003

Dear Sir,
Will you kindly treat this accompanying application as an urgent
one in accordance with the High Court Rules.
The grounds for urgency are mentioned in the prayer.

APPELLANT
THROUGH

(PRAVEEN K SHARMA/SURBHI SHARMA/

SAMEERA RAI & SAHIL NAGPAL)
ADVOCATES FOR THE APPELLANT
A – 384, FIRST FLOOR,
DEFENCE COLONY,
NEW DELHI – 110024
MOB: 9999099325
EMAIL: law_sharma@yahoo.com
PLACE: NEW DELHI
DATE: 18.04.2023
 IN THE HIGH COURT OF DELHI AT NEW DELHI
I.A. NO. ________ OF 2023
IN
O.A. NO. ________ OF 2023
IN
CS (OS) NO. 361 OF 2016
IN THE MATTER OF: -
MRS. JYOTSANA BHATIA …..PLAINTIFF
VERSUS
ARUN KHOSLA & ORS. .….DEFENDANTS
APPLICATION FOR CONDONATION OF DELAY UNDER
SECTION 5 OF THE LIMITATION ACT
MOST RESPECTFULLY SHOWETH:
1. That the present Appeal arises out of the impugned Order
dated 13.03.2022 of the Ld. Joint Registrar in CS (OS) No.
361/2016 (“Impugned Order”), whereby the Ld. Joint
Registrar directed the Defendants to file fresh/proper
affidavit of admission and denial of the documents in respect
of said additional document/Jamabandi.
2. That the Appellant craves leave of this Hon’ble Court that
the contents of the Appeal may kindly be read as part and
parcel of the present application and the same are not
repeated herein for the sake of brevity.
3. That the stipulated period for filing the said Chamber Appeal
were to be expired on 28.03.2023. However, the Counsel for
the Appellant had filed the said Appeal on 28.03.2023 vide
Diary No. 581289/2023 which is within the limitation
period. That inadvertently, the Chamber Appeal was filed in
the category of fresh case instead of being filed in the
category of pending case. Thereafter, on 29.03.2023, the
defects were raised by the registry and it was requested to
 file the aforesaid Chamber Appeal in the category of pending
case in CS (OS) No. 361/2016 and the same was filed again
in the category of pending case on 15.04.2023 vide Diary
No. 649675/2023. That due to above said reasons and
circumstances, the present Chamber Appeal has been filed
with the delay of 17 days from the date of filing it in the
pending case section. However, there is no delay and the
present appeal is within limitation as the Chamber Appeal
was filed on 28.03.2023 in the category of fresh case but
later on has been filed in the category of pending case. True
copy of the List of Defects raised by the Registry is enclosed
herewith and marked as Document 1.
4. That the delay of 17 days is thus on account of reasons
beyond the control of the Appellant.
5. That the present application has been made bonafide and in
the interest of justice.
PRAYER
It is, therefore, prayed that this Hon’ble Court may
kindly be pleased to:
a) Condone the delay of 17 days in filing the present
Chamber Appeal for reasons stated hereinabove;
b) Pass any other or further order(s) as deemed fit and
proper in the facts and circumstances of the present
case.
AND FOR THIS ACT OF KINDNESS THE APPELLANT
SHALL EVER PRAY
 APPELLANT
THROUGH

(PRAVEEN K SHARMA/SURBHI SHARMA/

SAMEERA RAI & SAHIL NAGPAL)
ADVOCATES FOR THE APPELLANT
A – 384, FIRST FLOOR,
DEFENCE COLONY,
NEW DELHI – 110024
MOB: 9999099325
EMAIL: law_sharma@yahoo.com
PLACE: NEW DELHI
DATE: 18.04.2023
 IN THE HIGH COURT OF DELHI AT NEW DELHI
I.A. NO. ________ OF 2023
IN
O.A. NO. ________ OF 2023
IN
CS (OS) NO. 361 OF 2016
IN THE MATTER OF: -
MRS. JYOTSANA BHATIA …..PLAINTIFF
VERSUS
ARUN KHOSLA & ORS. .….DEFENDANTS
AFFIDAVIT
I, Sahil Nagpal, S/o Late Shri Gulshan Nagpal, aged about 28
years, having office at A – 384, First Floor, Defence Colony, New
Delhi – 110024, do hereby solemnly affirm and declare as under:
1. That I am the Counsel for the Appellant in the above noted
matter and as such well conversant with the facts and
circumstances of the present case and I am competent to
swear this affidavit.
2. That the accompanying Application has been drafted under
the instructions of the Appellant and the contents whereof
are true and correct to my knowledge. Nothing material has
been concealed therefrom.

DEPONENT
VERIFICATION: -
Verified at New Delhi on this __ day of April, 2023, that the
contents of the above affidavit are true and correct to my
knowledge. No part of it is false and nothing material has been
concealed therefrom.
DEPONENT