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DPC ASSIGNMENT

TOPIC: WRITTEN STATEMENT WITH AFFIDAVIT

NAME: Sankalp Uniyal

COURSE: B.A. LL.B.
SEMESTER: 10
ENROLLMENT: A3211118152
SECTION: B
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IN THE COURT OF SENIOR CIVIL JUDGE ABC (District),
Delhi

SUIT NO. XYZ OF 2022

IN THE MATTER OF:

Mr. H.K. Gupta,

S/o Mr. M.K. Gupta,

R/o EFG, New Delhi

……Plaintiff

Versus
Mr. D.C. Aggarwal,

S/o Mr. C. Aggarwal,

R/o EFG, New Delhi

……Defendants
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Index

Topic Page Number

Memo of Parties 5

List of Dates 6

8
Written Statement

10
Prayer

11
Verification
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13
Affidavit

List of Documents 15

Vakalatnama 16
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SUIT NO. XYZ OF 2022

Memo of Parties

1. Mr. H.K. Gupta,

S/o Mr. M.K. Gupta,

Having their registered address at

EFG, New Delhi

Mobile No. 888888888 ……Plaintiff

Versus

2. Mr. D.C. Aggarwal,

S/o Mr. C. Aggarwal,

Having their registered address at

EFG, New Delhi

Mobile No. 999999999 ……Defendants

Date: Through: GHI Advocate

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List of Dates and Events

Date Event

Rent agreement drafted between Mr. D.C.

1.03.2020 Aggarwal and Mr. H.K. Gupta.

Defendant asks plantiff to vacate the let

1.04.2020 out property for landlords personal
habitation.

Dispute arises between Mr. D.C.

Aggarwal and Mr. H.K. Gupta over
1.04.2022 plantiff not agreeing to vacate premises
and seeking extended stay in let out
property.

Plantiff uses intimidation to scare

1.05.2022 defendant’s in laws and implicate
defendant into submission.
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IN THE COURT OF SENIOR CIVIL JUDGE ABC(District),

Delhi

SUIT NO. XYZ OF 2022

IN THE MATTER OF:

Mr. H.K. Gupta,

S/o Mr. M.K. Gupta,

R/o EFG, New Delhi

……Plaintiff

Versus

Mr. D.C. Aggarwal,

S/o Mr. C. Aggarwal,

R/o EFG, New Delhi

……Defendants
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WRITTEN STATEMENT UNDER ORDER VIII OF CPC,

SUIT FOR PERMANENT INJUNCTION

The above mentioned Defendant humbly submits as under:

1. That the contents of Para 1 are admitted;

2. That the contents of Para 2 are admitted;

3. That the contents of Para 3 are admitted;

4. That the contents of Para 4 are admitted;

5. That the contents of para 5 are denied. It was no where

mentioned in the lease that the rent money will never be
changed.

6. That the contents of para 6 are strongly denied, the goods lying/kept
in the premises are provided by the defendant and they are not
owned by the plaintiff.

7. That the contents of para 7 are denied too, as t plaintiff have never
paid rent on time, defendant has to always remind him for payment of
the rent and plaintiff has never cooperated with the defendant.

8. That the contents of para 8 are also denied as there were multiple
notices were given to the plaintiff in regard to the change in rent
and there was no breach of terms..

9. That the contents of para 9 are denied as the defendant is

causing no harm to the plaintiff.
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10. That the contents of para 10 are denied.

11. That the contents of para 11 are strongly denied; as these are false,
fictitious and frivolous. The plaintiff may be put to proof;

12. That the contents of para 11 are accepted to the extent that FIR was
lodged but it was filed upon baseless reasons and false allegations.

13. That the contents of para 13 are false as there is no reason to

provide such relief.

14. That the contents of para 14 are denied vehemently. These are just a
pack of lies and plaintiff is not entitled for any compensation as
plaintiff has not suffered any pecuniary loss. Plaintiff may be put to
proof.

15. Para 15 is legal and hence needs no reply, however the

jurisdiction of the court is admitted.

16. The plaintiff is not entitled for any relief. It is therefore prayed that
the suit may be dismissed with cost.
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PRAYER

It is hereby prayed before this honourable court to:

1. To dismiss the plaint on the grounds of false and incorrect information

given by the plantiff;

2. To dismiss any future cause of action which may arise out

of above mentioned dispute between the plantiff and the
defendant;

3. To pass orders restraining the plantiff from doing any damage to the
defendant’s let out property;

4. To pass orders of eviction against the plantiff to create space for the
defendant’s habitation;

5. To grant the cost of the suit in favour of the plantiff and against the
defendant;

6. To pass such other or further orders as this Honourable Court deems

fit and proper in the facts and circumstances of the suit.
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VERIFICATION:

Verified at Delhi on this … day of May 2022 that the contents of paras 1
to 16 of the plaint are true to my knowledge derived from the records of
the Defendant maintained in the ordinary course of its business, believed
to be true and last para is the humble prayer to this Hon’ble Court.

…Defendant
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IN THE COURT OF SENIOR CIVIL JUDGE ABC(District),

Delhi

SUIT NO. XYZ OF 2020

IN THE MATTER OF:

Mr. H.K. Gupta, S/o

MR. M.K. Gupta,

R/o EFG, New Delhi

……Plaintiff

Versus

Mr. D.C. Aggarwal,

S/o MR. C. Aggarwal,

R/o EFG, New Delhi

……Defendants
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AFFIDAVIT

I, D.C. Aggarwal S/O MR. C. Aggarwal, aged 50years, R/O EFG, New
Delhi, do hereby solemnly affirm and declare as under:-

1. That I am the defendant in the above-noted suit and fully conversant

with facts of the case and able to depose about the same.
2. That the accompanying suit/written statement has been drafted by my
counsel on my instructions and contents of the plaint have been read
over and explained to me in vernacular language and I have
understood the meaning and implications thereof and the facts stated
therein are correct.
3. That the contents of the suit are not being repeated here for the sake
of brevity and same shall be considered as part of this affidavit
also (Optional but you can also add the details of submissions to be
made before the court, to which deponent is testifying to be true to
his knowledge).

DEPONENT
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VERIFICATION:

Verified at New Delhi on this … day of May 2022, that contents of the
above affidavit are true and correct to my knowledge and nothing material
has been concealed therefrom.

DEPONENT
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LIST OF DOCUMENTS

Date, if any,
Signature of
which the
S. No. Description of Document Party or
documents
Pleader
bears

1 Annexure A-1:

2 Annexure A-2:

3 Annexure A-3:

4 Annexure A-4:

5 Annexure A-5

6 Vakalatnama
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VAKALATNAMA

IN THE COURT OF SENIOR CIVIL JUDGE ABC(District), Delhi

SUIT NO. XYZ OF 2020

IN THE MATTER OF:

Mr. H.K. Gupta, S/o

Mr. M.K. Gupta,

R/o EFG, New Delhi

……Plaintiff

Versus

Mr. D.C. Aggarwal,

S/o Mr. C. Aggarwal,

R/o EFG, New Delhi

……Defendants
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I, D.C. Aggarwal, do hereby appoint & retain Advocate TUV (hereinafter called as
“the Advocate”) to be my advocate in the said Suit. I authorize the Advocate to do
any or all of the following on my behalf:

a) To represent, act and appear for me

b) To conduct and prosecute (or defend) the same and all proceedings that may
be taken in respect of any application connected with the same or any
decree of order passed therein

c) To sign, file, verify, present, and receive all types of documents including
plaints, statements, pleadings, appeals, cross objections, petitions, applications,
revision, withdrawal, compromise or affidavits

d) To withdraw or compromise or submit to arbitration any differences or disputes

that may arise touching or in any manner relating to the said suit

e) To deposit, draw and receive money, cheques, cash and grant receipts thereof

f) To do all other acts and things as may be necessary or expedient, in the opinion
of the Advocate, to be done

I do hereby agree to ratify and confirm all acts done by the Advocate or her
substitute in the matter as my own acts, as if done by me to all intents and purposes.

Dated:

28 May 2022

Signature