IN THE COURT OF SENIOR CIVIL JUDGE SOUTH

EASTSAKET COURT AT NEW DELHI

CIVIL SUIT NO. of 2024
IN THE MATTER OF:
AMIT BAJAJ …PLAINTIFF
VS
JOGINDER KUMAR …
DEFENDANT

INDEX
S.NO PARTICULARS PAGE NO
1. MEMO OF PARTY
2. CIVIL SUIT FOR RECOVERY ALONG WITH
AFFIDAVIT
3. LIST OF DOCUMENTS
4. VAKALATNAMA

Through
MRATYUNJAY SINGH

(Advocate)
HERMES LAW LLP
Mob No: +91
8004627113
Email:-
Adv.Mratyunjay@gmail.com
 IN THE COURT OF SENIOR CIVIL JUDGE SOUTH EAST
SAKET COURT AT NEW DELHI
CIVIL SUIT NO. of 2024
IN THE MATTER OF:
AMIT BAJAJ …PLAINTIFF
VS
JOGINDER KUMAR …
DEFENDANT
MEMO OF PARTY
AMIT BAJAJ S/O LT. SH. MOHAN LAL BAJAJ
R/O – 4/76, Shubhash Nagar ,New Delhi- 110027.
Presently at
Flat 7 willow House- 3 , Langdon Park Teddigton
London UK
Post Code:-TW11 9NZ …PLAINTIFF
VS
JOGINDER KUMAR S/O MR. SOHAN LAL
R/O- 10614 MANAK PURA
KAROL BAGH, NEW DELHI- 110005
Contact no:- +91 9773878758 …DEFENDANT

Through

MRATYUNJAY SINGH

(Advocate)
HERMES LAW LLP
 Mob No: +91
8004627113
Email:-
Adv.Mratyunjay@gmail.com

IN THE COURT OF SENIOR CIVIL JUDGE , SOUTH EAST ,

SAKET COURT AT NEW DELHI
CIVIL SUIT NO. of 2025
IN THE MATTER OF:
AMIT BAJAJ …
PLAINTIFF
VS
JOGINDER KUMAR …
DEFENDANT

SUIT FOR RECOVERY OF RS 1,75,000/- ( RUPEES ONE

LAKH SEVENTY FIVE THOUSAND ONLY) ALONGWITH
PENDELITE AND FUTURE INTEREST @ 18 % P.A.
MOST RESPECTFULLY SHOWETH:
1. That the plaintiff is the citizen of India and having a
permanent residence at ground floor 76, Block 4 Subhash
Nagar Delhi- 110027 and Plaintiff working and residing
presently at Flat 7 willow House- 3 Langdon Park Teddigton
London UK Post Code:-TW11 9NZ in UK along with his
family. Herein representing through Power of Attorney of
Mr Deepak Bali marked and annexed as Annexure ‘P1’.
2. That the plaintiff got married in the year somewhere 2009
and for his lively hoods he migrated to UK and took up the
 job in 2010 and was Regularly working there in UK but
used to Regularly Come to India and stay with his mother
and other family members.
3. That the Defendant i.e. Mr Joginder Kumar is a family
friend of the Plaintiff and is currently residing in 10614
MANAK PURA , KAROL BAGH, NEW DELHI 110005.
4. That in the year 2022 the Defendant was residing in
tenanted premises and also searching accommodation for
purchasing for his own family but due to shortage of funds
, the defendant was not able to purchase the property for
himself , therefore the defendant approached to the
plaintiff on telephone for providing some monetary help
and asked to pay Rs. 1,75,000/- as friendly loan for one
year and also undertake to pay interest @ 2% per month.
5. That considering the old friendly relation with the
Defendant , the plaintiff agreed to help the defendant for
purchasing for accommodation for his family and gave Rs
1,75,000/- (Rupees One lakh and Seventy Five thousand)
through his younger brother namely Mr Vinod Kumar,
which was to be repaid in 1 year by the Defendant.
6. The above said amount was given through the plaintiff’s
cousin brother Namely Mr. Vinod Kumar, who is currently
living in Amritsar Punjab.
7. That after 12 months in July 2023, the plaintiff
approached the Defendant for returning of the above said
amount advanced by the plaintiff to the Defendant, but
the Defendant started avoiding the plaintiff.
8. That the plaintiff tried several times approached to the
Defendant through mobile calls and messages, but the
Defendant deliberately avoided him and never pick call of
the plaintiff.
9. That at last in the month of August 2023, the Defendant
issued two cheques bearing no 813853 amounting to Rs
1,00,000/- and 813870 amounting to Rs 75,000/- both
dated 17th August 2023 drawn on Corporation bank,
Branch Address Corporation Bank Lajpat Nagar Branch
New Delhi 110024. Cheques issued by defendant is
Marked and Annexed as Annexure ‘P2’.
10. That The above said cheques were presented in the
plaintiff bank on 17.08.2023, and same was got returned
and bounced on the 23.08.2023 with the remark
“Clearance Stop”. Return Memo is marked and annexed as
Annexure ‘P3’.
11. That the Plaintiff immediately informed the
Defendant about the bouncing of the cheques issued by
the Defendant and to pay the cheque amount. The
Defendant asked for some more time to repay the amount.
12. That again in the month of September 2023, the
Plaintiff approached the Defendant through telephone
about the repayment of the amount, the Defendant plead
guilty and further seeks 6 months of time for the
repayment.
13. That since then the Plaintiff is regularly approaching
the Defendant for the payment and the Defendant is
deliberately and wilfully avoiding the Plaintiff.
14. That the plaintiff had sent a Legal Demand Notice
through his counsel to the defendant On 5.03.2025 and
same was delivered upon the defendant on 07.03.2025 ,
despite receiving of the said legal notice, neither the
defendant reply the said legal notice nor complied the
said legal notice. Copy of the legal demand notice is
marked and annexed as Annexure ‘P4’. copy of the track
report of the legal demand notice is marked and annexed
as Annexure ‘P5’.
15. That the plaintiff even sent the legal demand notice
through whatsapp of the defendant on 5 th March 2025.
Copy of the Screenshots are marked and annexed as
Annexure ‘P6’.
16. That the first cause of action arose on 04.06.2022 ,
when the defendant approached to the plaintiff for
financial assistance , the cause of action further arose on
05.07.2022 , when the plaintiff gave Rs.1,75,000/- to the
defendant , the cause of action further arose on
17.08.2023 , when the defendant issued two cheques in
favour of the plaintiff , the cause of action further arose on
23.08.2023 , when the above said cheques got bounced ,
the cause of action further arose on 05.03.2025 , when the
plaintiff issued legal demand notice through his counsel
and despite service of legal notice , the defendant neither
reply nor compile. The cause of action is continuing unless
and until the payment is not made by the defendant .
17. That this Hon’ble court has the jurisdiction to decide
the present suit as bank of the defendant is situated
 within the jurisdiction of this Hon’ble Court , hence this
court has territorial jurisdiction of this Hon’ble Court to
entertain the present suit.
18. That the present suit is well within the limitation.
19. That no other suit for recovery of the said amount is
filed / pending against the defendant in any court of India.
20. That the present suit is valued at 1,75,000/- (Rupees
One Lakh and Seventy Five Thousand Only). And the court
fee is paid thereon.

PRAYER
Now, that the plaintiff prays and claims that this Hon’ble Court
may be pleased to:-
a) Pass a decree for Rs 1,75,000/- (Rupees One Lakh Seventy
Five Thousand Only) in favor of the plaintiff and against
the defendant.
b) Pendent elite and further interest @ 18% p.a. till
realization of the amount in full.
c) Cost of the suit be allowed to the plaintiff.
d) Any other relief which this Hon’ble Court deems fit may
also be granted to the plaintiff.

…
Plaintiff
VERIFICATION: -
I the above named Plaintiff do hereby verify that the contents
of Para __ to __ and the contents of paragraphs __ to ___ are
true to my knowledge while the contents of para __ to __ are
true to the information and believed to be true.
Verified at new Delhi on this day ___ of March 2025.

Deponent

IN THE COURT OF SENIOR CIVIL JUDGE SOUTH

EASTSAKET COURT AT NEW DELHI
CIVIL SUIT NO. of 2025
IN THE MATTER OF:
AMIT BAJAJ …
PLAINTIFF
VS
JOGINDER KUMAR …
DEFENDANT
AFFIDAVIT
I,_Deepak Bali S/o Devi Dutt Bali R/o A-207 Nand Ram Park
Uttam Nagar 110059 age about 29 years Power of Attorney
holder of Mr. AMIT BAJAJ, S/o Mohan Lal Bajaj, ground floor 76,
Block 4 Subhash Nagar Delhi- 110027, do hereby solemnly
affirm and declare as under: -
1. That I am the Plaintiff in the aforesaid matter in the above
noted suit and well conversant with the facts of the case
and as such, am competent to swear this affidavit on oath.
2. That the contents of paragraphs 1 to __ are true to my
knowledge while the contents of para __ to ___ are true to
the information and believed to be true to the information.
3. The annexures enclose along with suit are true copies of
the respected originals.
 DEPONENT
VERIFICATION: -
Verified at New Delhi on this ___ day of March 2025 that
the contents of the above affidavit are true and correct to the
best of my knowledge and nothing has been suppressed or
concealed.

DEPONEN
T

IN THE COURT OF SENIOR CIVIL JUDGE SOUTH

EASTSAKET COURT AT NEW DELHI
CIVIL SUIT NO. of 2025
IN THE MATTER OF:
AMIT BAJAJ …
PLAINTIFF
VS
JOGINDER KUMAR …
DEFENDANT
LIST OF DOCUMENTS
1. Power of Attorney Executed in favor of Sh. Deepak Bali by
the Plaintiff Mr. Amit Bajaj Authorized as a Representative
along with letter of authorization .
2. Original Cheque bearing no 813853 and 813870
amounting to Rs 1,00,000/- and Rs 75,000/-.
3. Return Memo dated 23,08,2023.
4. Legal Notice Dated 5.03.2025.
5. Postal Receipt Dated ___ .03.2025
6. Postal Track Report dated __.03.2025 .
 7. Whats app Screenshots of Legal Demand Notice
8. Any other DOCUMENT shall also be produced with prior
permission of this Hon’ble Court.

Through

MRATYUNJAY SINGH

(Advocate)
HERMES LAW LLP
Mob No: +91
8004627113
Email:-
Adv.Mratyunjay@gmail.com