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BEFORE THE HONOURABLE SR CIVIL JUDGE COURT AT

DISTRICT COURT AHMEDABAD MIRZAPUR

SP CIVIL SUIT NO 359/2021

Plaintiff: Shri, Nasirhussein


Ahmedbhai Bagban,

Vs

Defendant: 1) Smt. Shamsadbanu


Nasirhussein Bagban,

2) Shri, Mohmmed Faisal


Nasirhussein Bagban,

3) Shri, Mohmmed Sahil


Nasirhussein Bagban,

4) Rizabanu Nasirhussein
Bagban

To,

Shri, A. S. Saiyed,
ADVOCATE Shri,
B 204, Sakar 7, Nehrubridge Corner,
Ashram Rd, Vishalpur, Ellisbridge,
Ahmedabad, Gujarat 380006

NOTICE OF PRODUCTION

I, the undersigned Advocate, G Y Pathan on


behalf of my client Shri, Nasirhussein Ahmedbhai
Bagban the plaintiff of the captioned suit being
Sp CS No 359/2021 do hereby through this Legal

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C-1116 | Siddhivinayak Towers | Nr. Kataria Automobiles | SG Highway | AHMEADBAD (GUJARAT) | INDIA
Mo : 9898582114 | email : AdvocateAhmedabad@gmail.com
“Notice of Production” and call upon defendants
and/or pleader/Advocate/Attorney of defendant
to produce the following amongst the other
documents as prescribed hereinbelow in this
Notice of production in the custody of either
defendants no. 1 to 4 (4 through her guardian
defendant no 1) as well as in your custody being
the their Attorney/Advocate on record before the
Honourable Court on to be produced on or before
next date of hearing of the present suit:

“LIST”

1) ORIGINAL SALE DEEDS OF:


i. District Sub District Ahmedabad,
Taluka Ahmedabad City (West), Mouje
Maktampura, Sim Block/Survey No. 76
paiki part no.2/2 sub plot no A-3 at
the side of sq. var. 715 in building
situated as "Italian Complex-2" ground
Floor shop no. 36 and 37.
ii. District Sub District Ahmedabad,
Taluka Ahmedabad City (West), Mouje
Maktampura, Sim situated as "Sankalit
Nagar" House No.A/152.
iii. District Sub Ahmedabad City (West),
Mouje Maktampura, Sim Survey No. 76/2
situated as "Rasula Park
Co.Op.Hou.So.ltd" House No.C/4.
iv. District Sub District Ahmedabad,
Taluka Ahmedabad City (West), Mouje
Maktampura, Sim situated as "Italian
Complex Part 2" First Floor, Shop No.
A/4/3.

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C-1116 | Siddhivinayak Towers | Nr. Kataria Automobiles | SG Highway | AHMEADBAD (GUJARAT) | INDIA
Mo : 9898582114 | email : AdvocateAhmedabad@gmail.com
v. District Sub District Ahmedabad,
Taluka Ahmedabad City (West), Mouje
Maktampura, Sim situated as "Italian
Complex Part 2" First Floor, Shop
A/4/2.
vi. District Sub District Ahmedabad.
Taluka Ahmedabad City (West), Mouje
Maktampura, Sim Survey No. 76/2.
situated as "Rasula Park
Co.Op.Hou.So.ltd" House No.6/2.
vii. District Sub District Ahmedabad,
Taluka Ahmedabad City (West), Mouje
Maktampura, Sim Survey No. 76/2
situated as "Rasula Park
Co.Op.Hou.So.ltd" House No.6/2(c).
viii. District Sub District Ahmedabad,
Taluka Ahmedabad City (West), Mouje
Maktampura, Sim Near Juhapura Cross
Road, Near Italian Complex Ahmedabad
"Farhan Owners Association” in
building situated "Silver Plaza"
ground Floor Shop No. 26.
ix. District Sub District Ahmedabad,
Taluka. Ahmedabad City (West), Mouje
Maktampura, Sim Near Juhapura Cross
Road, Near Italian Complex Ahmedabad
"Farhan Owners Association" in
building situated "Silver Plaza"
ground Floor Shop No. 25.
x. District Sub District Ahmedabad,
Taluka Vatva, Mouje Gyaspur, Sim
Block/Survey No. 103/1 paiki and
Survey No. 221p3 Paiki Sub Plot No.

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C-1116 | Siddhivinayak Towers | Nr. Kataria Automobiles | SG Highway | AHMEADBAD (GUJARAT) | INDIA
Mo : 9898582114 | email : AdvocateAhmedabad@gmail.com
28(c) Total Square Mtr 132.67 non-
agriculture land.
xi. District Sub District Ahmedabad,
Taluka Vatva, Mouje Gyaspur, Sim
Block/Survey No. 101/1 paiki, 101/3
paiki and Paiki 102 Sub Plot No. 20 to
29 in building situated "M.M. Karim
Block No. C Second Floor Flat No. C-
205.
xii. District Sub District Ahmedabad,
Taluka Ahmedabad City (West), Mouje
Maktampura, Sim situated as "Italian
Complex Part 2” First Floor, Shop
A/4/1
(Above mentioned properties will be
referred as disputed properties in the
plaint as well as injunction
application for the simplicity of
language.).
2) BANK STATEMENTS OF :
i. AXIS BANK
ii. CENTRAL BANK
iii. UNION BANK
3) ORIGINAL INSUARANCE POLICIES
i. LIC JIVAN SHRI
ii. LIC JIVAN ANAND
iii. MAX LIFE INSUARANCE
iv. BAJAJ ALLIANCE INSUARANCE
POLICY ORIGINAL
v. ICICI PRUDENTIAL ORIGINAL
POLICIY
4) ALL THE ORIGINAL RENT
AGREEMENTS WITH VARIOUS
TENANTS

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C-1116 | Siddhivinayak Towers | Nr. Kataria Automobiles | SG Highway | AHMEADBAD (GUJARAT) | INDIA
Mo : 9898582114 | email : AdvocateAhmedabad@gmail.com
5) PASSPORT OF PLAINTIFF
6) VISA OF PLAINTIFF
7) FLIGHT TICKETS OF PLAINTIFF
8) ORIGINAL DRIVING LICENSE OF
PLAINTIFF
1. It is pertinent to be noted on Dt.27/11/2021
and 28/11/2021 defendant No 2) Faisal
Nasirhussein Bagban and 1) respectively
arrived in Ahmedabad from ‘United States of
America’ in the morning by 5.00am and soon
thereafter have approached the residential
house of my client shri Nasirhussein
Ahmedbhai Bagban at: C/28, Rajdhana Society,
Behind H.P. Petrol Pump, Sarkhej Road,
Juhapura, Ahmedabad and knocked the door
however as per defendant’s contentions my
client have refused to open the same
consequently defendant no.2 along with no.1,
3 and 4 were compelled to stay at Hotel
Neelkanth at Paldi, Mahalaxmi Cross Road,
Ahmedabad. It is also contended by defendant
no.2 along with no.1, 3 and 4 have further
contended that on 30/11/2021 at the night my
client and plaintiff of the captioned suit
shri Nasirhussein Ahmedbhai Bagban have
visited the said Hotel Neelkanth and have
proposed to get the matter resolved through
verbal talks.
2. That, since thereafter, defendant no 2 have
filed the FIR against plaintiff and with
pursuant to the same plaintiff was arrested
by the Police from his home at the addressed
: C/28, Rajdhana Society, Behind H.P. Petrol
Pump, Sarkhej Road, Juhapura, Ahmedabad

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C-1116 | Siddhivinayak Towers | Nr. Kataria Automobiles | SG Highway | AHMEADBAD (GUJARAT) | INDIA
Mo : 9898582114 | email : AdvocateAhmedabad@gmail.com
whereby his all the original documents
including SALE DEEDS, PASSPORT, VISA,
INSUARANCE POLICIEs etc were kept in safe
custody, however due to aforesaid FIR he had
to left the house under the pressure of Police
since police have arrested the plaintiff.
3. That, taking the disadvantage of aforesaid
scenario, defendants have willfully removed
all the original documents as stated and asked
hereinabove being the LIST and hence, this
Legal Notice is addressed calling upon
defendants and their Advocate/pleader to
produce the documents on or before next date
of hearing of present suit, which documents
are essentially vital to decide the
controversy between the parties before this
Honourable Court.
4. It is your pious Legal duty to produce the
documents as demanded in this Legal Notice
for the smoother functioning of the
proceedings before the Honourable Court.
5. I hope that, defendant will act according to
the demands made in this Legal notice.

Date : 9/2/2023
Place: Ahmedabad ---------------------------------------
[ADVOCATE UNDER INSTRUCTIONS]

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C-1116 | Siddhivinayak Towers | Nr. Kataria Automobiles | SG Highway | AHMEADBAD (GUJARAT) | INDIA
Mo : 9898582114 | email : AdvocateAhmedabad@gmail.com

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