IN THE HON’BLE COURT OF SH.

ARUN GOEL,
ADDITIONAL DISTRICT JUDGE, SHAHDARA,
KARKARDOOMA, DELHI
CS NO. 164 OF 2016

In the matter of:

SHRI JATINDER AGGARWAL …PLAINTIFF

VERSUS

SHRI RAJINDER KUMAR BABBAR …DEFENDANTS

APPLICATION UNDER ORDER 22 RULE 4 READ WITH SECTION

151 OF C.P.C FOR BRINGING THE LEGAL HEIRS OF SMT USHA
RANI, DEFENDANT NO. 2 ON RECORD
Sir,
The Plaintiff most respectfully submits as follows:-
1. That the above case is pending adjudication before this Hon’ble Court
and is now fixed for 17.05.2023.
2. That the Defendant No.2 in this case has expired. The plaintiff is not
Aware of the exact date of his death.
3. That he has left behind the following legal heirs:-
 S.NO Name & Address Relationship

1. SHRI RAJINDER KUMAR BABBAR HUSBAND

RESIDENT OF 198-C, POCKET-F,
DILSHAD GARDEN,
DELHI- 110095

2. KASHISHH BABBAR RESIDENT OF SON

198-C,POCKET-F,DILSHAD
GARDEN, DELHI- 110095

3. SHWETA BABBAR DAUGHTER

RESIDENT OF 198-C, POCKET-F,
DILSHAD GARDEN, DELHI- 110095

4. URVASHI BABBAR DAUGHTER

RESIDENT OF 198-C, POCKET-F,
DILSHAD GARDEN, DELHI- 110095

4. That the right to sue survives.

5. That the Plaintiff with his efforts has now been able to find out the same..
An affidavit in support is being attached with this application.

PRAYER
It is therefore, most respectfully and humbly prayed that in view of the facts and
circumstances mentioned above, this Hon’ble Court may kindly be pleased to:-
(i) Allow the present application and pass an order or direction to substitute
the legal heirs of deceased Defendant No. 2 Smt. Usha Rani as Defendant
No. 2 in the above suit bearing CS No. 164/2016.
(ii) Pass such other and further order or directions or any other relief in
favour of the plaintiff, which this Hon’ble Court may deem fit and proper
in the facts and circumstances of the case and in the interest of justice and
equity.
AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN DUTY
BOUND SHALL EVER PRAY.
PLAINTIFF

Though Counsel:

RAJIV DALAL/ SANJEEV SHARMA

Advocates for the Applicant
D&S Law Offices
B-10,2nd Floor, Jangpura Extension, New Delhi – 110014.
Chamber Ns. 139-142, B Block, Tis Hazari Courts, Delhi 110054
Mobile.: + 9810066196
E-mail: contact@dslawoffices.in, rajiv@dslawoffices.in

DELHI:
DATED:
 IN THE HON’BLE COURT OF SH. ARUN GOEL,
ADDITIONAL DISTRICT JUDGE, SHAHDARA,
KARKARDOOMA, DELHI
CS NO. 164 OF 2016

In the matter of:

SHRI JATINDER AGGARWAL …PLAINTIFF

VERSUS

SHRI RAJINDER KUMAR BABBAR …DEFENDANTS

AFFIDAVIT

I, Jatinder Aggarwal, Late Sh. Kirti Chand Aggarwal Resident of 4, Lancer

Road, Delhi - 110054, do hereby solemnly affirm and declare as under:-
1. That I am the Plaintiff in this case and therefore well conversant with the
facts and circumstances of the case, and thus, competent to swear this
affidavit.
2. That the accompanying Application Under Order 22 Rule 4 R/W Section
151 of C.P.C for bringing the Legal Heirs of Usha Rani, the Defendant
no. 2 on record has been drafted by my counsel on my instruction and the
 contents of the same have been read and understood by me and the same
are true to my knowledge.

DEP
ONENT

VERIFICATION :-

Verified at Delhi on this __ day of April, 2023 that the contents of this affidavit
are true to the best of my knowledge and belief and no part of it is false and
nothing has been concealed thereof.

DE
PONENT
 IN THE HON’BLE COURT OF SH. ARUN GOEL,
ADDITIONAL DISTRICT JUDGE, SHAHDARA,
KARKARDOOMA, DELHI
CS NO. 164 OF 2016

In the matter of:

SHRI JATINDER AGGARWAL …PLAINTIFF

VERSUS

SHRI RAJINDER KUMAR BABBAR …DEFENDANTS

INDEX
S NO. PARTICULARS PAGE NO.

1. Application under Order 22 Rule 4 read with section

151 of C.P.C for bringing the legal heirs of Smt Usha
Rani, Defendant No. 2 on record along with affidavit.

PLAINTIFF
Though Counsel:
 RAJIV DALAL/ SANJEEV SHARMA
Advocates for the Applicant
D&S Law Offices
nd
B-10,2 Floor, Jangpura Extension, New Delhi – 110014.
Chamber Ns. 139-142, B Block, Tis Hazari Courts, Delhi 110054
Mobile.: + 9810066196
E-mail: contact@dslawoffices.in, rajiv@dslawoffices.in

DELHI:
DATED: