IN THE HON’BLE COURT OF MS. RISHIKA SRIVASTAV, LD.

CJ. DELHI.

CASE NO. 1167OF 2021

IN THE MATTER OF:-

SAMEER BEG & ANR …PLAINTIFF

VERSUS
SHER SINGH …DEFENDANT
REJOINDER ON BEHALF OF DEFANDANT
SIR,
MOST RESPECTFULLY SHOWETH:

1. That the contents of Para No.1 of Reply to Application needs no

reply.

2. That the contents of Para No.2 of Reply to Application are

wrong, false and specifically denied. It is denied that the contents

of Para No.2 of Application are false. It is denied that the

allegations are false and vague. It is denied that there is no

mention as to what is the forgery. That the contents of Para No.2

of Application are reaffirmed and reiterated in reply to this Para

as the same has not been repeated for sake of brevity.

3. That the contents of Para No.3 of Reply to Application are

wrong, false and specifically denied. It is denied that the mother

of the plaintiffs late Smt. Huma Beg paid a sum of Rs. 2,00,000/-

as refundable security without interest and as the defendant failed

to fulfill his promise of putting Smt. Huma Beg in possession of

the tenanted premises he issued two cheques for Rs. 1,00,000/-

each as mentioned in the plaint toward the refund of the security

amount. It is further denied that there was no such loan

transaction between mother of plaintiffs and defendant. It is

further denied that the amount of Rs. 2,00,000/- has remained

outstanding till death of mother of the plaintiff. That the contents

of Para No.3 of Application are reaffirmed and reiterated in reply

to this Para as the same has not been repeated for sake of brevity.

4. That the contents of Para no. 4 of Reply to Application are wrong,

false and specifically denied. That the contents of Para No.4 of

Application are reaffirmed and reiterated in reply to this Para as

the same has not been repeated for sake of brevity.

5. That the contents of Para no.5 of Reply to Application are wrong,

false and specifically denied. It is denied that the documents in

 this regard are already on record. It is further denied that the

mother of the plaintiffs who gave Rs. 2,00,000/- to the defendant

and not to the plaintiff. That the contents of Para No.5 of

Application are reaffirmed and reiterated in reply to this Para as

the same has not been repeated for sake of brevity.

6. That the contents of Para no. 6 of Reply to Application are wrong,

false and specifically denied. It is denied that the allegations in

this Para are vague and false. That the contents of Para No.6 of

Application are reaffirmed and reiterated in reply to this Para as

the same has not been repeated for sake of brevity.

7. That the contents of Para no. 7 of Reply to Application are

wrong, false and specifically denied. It is denied that the

defendant was shocked as the defendant did not expect a fast

legal action by 20 year old plaintiffs. That the contents of Para

No.7 of Application are reaffirmed and reiterated in reply to this

Para as the same has not been repeated for sake of brevity.

8. That the contents of Para no. 8 of Reply to application are wrong,

false and specifically denied. That the contents of Para No.8 of

 Application are reaffirmed and reiterated in reply to this Para as

the same has not been repeated for sake of brevity.

9. That the contents of Para no. 9 of Reply to Application are

wrong, false and specifically denied. It is denied that the issuing

of cheques clearly prove that the same were issued by defendant

in discharge of liability. It is further denied that the defendant has

not denied issuing of cheques. It is denied that an agreement do

not require a dairy number or a revenue stamp to make it

admissible in evidence. That the contents of Para No.9 of

Application are reaffirmed and reiterated in reply to this Para as

the same has not been repeated for sake of brevity.

10. That the contents of Para no. 10 of Reply to Application are

wrong, false and specifically denied. It is denied that the

provision of Income Tax Act have no being of merits of the

present suit. That the contents of Para No. 10 of Application are

reaffirmed and reiterated in reply to this Para as the same has not

been repeated for sake of brevity.

11. That the contents of Para no. 11 of Reply to Application are

wrong, false and specifically denied. It is submitted that the

 Plaintiff himself has filed amended memo of parties showing the

correct address of Defendant. It is denied that the legal notice

beside being served on the correct address of Defendant was also

served on the whatsapp account of Defendant. That the contents

of Para No.11 of Detailed affidavit are reaffirmed and reiterated

in reply to this Para as the same has not been repeated for sake of

brevity. That the contents of para no. 12 of application are need

no reply.

12.That the contents of Para No.12 of Reply to Application are

wrong, false and specifically denied. That the contents of Para

No.12 of Detailed Affidavit are reaffirmed and reiterated in reply

to this Para as the same has not been repeated for sake of brevity.

13.That the contents of Para no. 13 of Reply to application are

wrong, false and specifically denied. It is denied that the

defendant is not entitled to the grant of leave to defend. That the

contents of Para No.12 of Detailed Affidavit are reaffirmed and

reiterated in reply to this Para as the same has not been repeated

for sake of brevity.

 That the prayer clause of Reply to Application is wrong, false and

specifically denied.

That the contents of Prayer Clause of Application are reaffirmed and

reiterated as the same has not been repeated here for sake of brevity.

DELHI
DATED
DEFENDANT
THROUGH

MOHIT BATRA AND SAKET GAKHAR

(ADVOCATES FOR DEFENDANT)
 IN THE HON’BLE COURT OF MS. RISHIKA SRIVASTAV, LD.
CJ. DELHI.

CASE NO. 1167OF 2021

IN THE MATTER OF:-

SAMEER BEG & ANR …PLAINTIFF

VERSUS
SHER SINGH …DEFENDANT
AFFIDAVIT

I, Sher Singh, S/o Sh. Mange Ram, R/o B-18-C, 3 rd Floor, Paschim Puri,
Old Slum Qtrs., Paschim Vihar, Delhi do hereby solemnly affirm and
declare as under:

1. That the Deponent is the Defendant in the abovementioned case and

is well conversant with the facts and circumstances of the case hence
competent to swear this affidavit.

2. That the Accompanying Rejoinder has been drafted by my counsel

on my instructions and the contents of same has been read over to
me in my vernacular language and I have understood the same and
the same are true and correct.

DEPONENT

VERIFICATION:

Verified at Delhi on this day of August 2022, that the contents of

my above affidavit are true and correct and nothing material has been
concealed thereof.

DEPONENT