IN THE HON’BLE COURT OF LD.

DISTRICT & SESSION

JUDGE, SOUTH EAST DISTRICT, SAKET DISTRICT
COURTS, NEW DELHI
CIVIL SUIT NO. ______ OF 2024

IN THE MATTER OF:

SATVINDER KAUR
GHALAN & ANR. …PLAINTIFF(S)

VERSUS

IQBAL SINGH
AND ORS. .…DEFENDANT(S)
INDEX

SI. No. Particulars Page Nos.

1. MEMO OF PARTIES

2. SUIT FOR DECLARATION,

POSSESSION, RECOVERY OF
DAMAGES, PERPETUAL
INJUNCTION AND MESNE PROFITS
FOR THE PROPERTY BEARING NO.
RZ-218-B GALI NO. 18,
TUGLAKABAD EXTENSION, NEW
DELHI - 110019 ON BEHALF OF THE
PLAINTIFF(S) ALONG WITH
SUPPORTING AFFIDAVIT.

3. APPLICATION UNDER ORDER

XXXIX RULE 1 & 2 READ WITH
SECTION 151 OF THE CODE OF CIVIL
PROCEDURE, 1908 FOR GRANT OF
AD-INTERIM PERPETUAL
 INJUNCTION ALONG WITH
SUPPORTING AFFIDAVIT.
4. APPLICATION UNDER SECTION 151
OF THE CODE OF CIVIL
PROCEDURE,1908 FOR SEEKING
EXEMPTION FROM FILING THE
REQUISITE COURT FEE FOR THE
GRANT OF RELIEF OF POSSESSION
5. LIST OF DOCUMENTS ALONG WITH
DOCUMENTS.
6. VAKALATNAMA

PLAINTIFF(S)

THROUGH
COUNSEL
H.S. THUKRAL/ KARAN S. THUKRAL
ADVOCATES
For THUKRAL LAW ASSOCIATES
A-1/22, LGF Paschim Vihar
New Delhi-110063
MOB : +91 9999009339
(E): [email protected]

HADLEIGH UK
DATE: 16.02.2024
 IN THE HON’BLE COURT OF LD. DISTRICT &
SESSION JUDGE, SOUTH EAST DISTRICT, SAKET
DISTRICT COURTS, NEW DELHI

CIVIL SUIT NO. ______ OF 2024

IN THE MATTER OF:

SATVINDER KAUR
GHALAN & ANR. …PLAINTIFF(S)

VERSUS

IQBAL SINGH
AND ORS. .…DEFENDANT(S)

MEMO OF PARTIES

1. SATVINDER KAUR GHALAN

D/O LATE CHAIN SINGH CHERA
R/O 39, CARFAX ROAD,
HAYES MIDDLESEX,
UB3 4RD, UK
(M):07939760145
EMAIL: [email protected]

2. RANDHIR SINGH CHERA

S/O LATE CHAIN SINGH CHERA
R/O 55 ST PAUL AVENUE,
SLOUGH BERKSHIRE,
SL2 5EX, UK
(M): 07776035732
EMAIL: [email protected]

… PLAINTIFF(S)
VERSUS
1. IQBAL SINGH
S/O INDER SINGH,
R/O H. NO. RZ124,
GALI NO-15
TUGHLAKABAD EXTENSION,
NEW DELHI-110019
2. ANIL SHARMA
S/O HIRA LAL SHARMA
R/O 3124 GALI NO 2
RANJEET NAGAR DELHI
ALSO, AT
H. NO. 98, KH 655,
GROUND FLOOR, BLK-F,
SUDARSHAN PARK,
KARAMPURA NEW DELHI-110015

3. SARITA PANDEY
W/O BAIKUNTH NATH PANDEY
R/O RZ-441-B GALI NO 15
TUGLAKABAD EXTN NEW DELHI 110019
(M): 9874865448
EMAIL: [email protected]

4. RAJEWSHARI
W/O SH PRAMOD KUMAR
R/O UNKNOWN

5. BAIKUNTH NATH PANDEY

S/O SURESH DUTT PANDEY
R/O RZ-441-B GALI NO 15
TUGLAKABAD EXTN NEW DELHI 110019
83565883963

6. RAJESH KUMAR
S/O RAM SURAT TRIGUNAYAT
R/O RZ 216 A GALI NO 18
TUGLAKABAD EXTN NEW DELHI 110019

…DEFENDANT(S)
 PLAINTIFF

THROUGH

COUNSELS
H.S. THUKRAL/ KARAN S. THUKRAL
ADVOCATES
For THUKRAL LAW ASSOCIATES
A-1/22, LGF Paschim Vihar
New Delhi-110063
MOB : +91 9999009339
E-mail : [email protected]

HADLEIGH UK
DATE: 16.02.2024
 IN THE HON’BLE COURT OF LD. DISTRICT &
SESSION JUDGE, SOUTH EAST DISTRICT, SAKET
DISTRICT COURTS, NEW DELHI
CIVIL SUIT NO. ______ OF 2024

IN THE MATTER OF:

SATVINDER KAUR
GHALAN & ANR. …PLAINTIFF(S)

VERSUS

IQBAL SINGH
AND ORS. …DEFENDANT(S)

SUIT FOR DECLARATION, POSSESSION, RECOVERY

OF DAMAGES, PERPETUAL INJUNCTION AND MESNE
PROFITS FOR THE PROPERTY BEARING NO. RZ-218/B
GALI NO. 18, TUGHLAKABAD EXTENSION, NEW
DELHI - 110019 ON BEHALF OF THE PLAINTIFF(S)
ALONG WITH THE SUPPORTING AFFIDAVIT

MOST RESPECTFULLY SHOWETH:

1. That the present suit is filed on behalf of the Plaintiff(s) for
Declaration, Possession, Perpetual Injunction, Recovery of
Damages and Mesne Profits for the immovable property
bearing No. RZ-218/B Gali No. 18 carved out of Khasra
no. 520 , situated at Tughlakabad Extension, New Delhi-
110019 admeasuring 60 sq. yds. i.e., 50 sq. metres ,
(hereinafter referred to as ‘Suit property’). The Suit property
is a self-acquired property of Late S. Chain Singh Chera and
the same is distinctly identifiable from the registered
municipal number.

2. That Late Sh. S. Chain Singh Chera S/o Sh. Pratap Singh
Chera was the lawful and absolute owner of the Suit
 property. He purchased the said property from one Sh.
Tirath Ram S/o Sh. Hakim Chand.
3. The said transfer was effectuated vide the following
documents:

S No. Document Details

1. A General Power of Attorney, executed
between the first party i.e. Sh. Tirath Ram S/o
Sh Hakim Chand in favor of second party i.e.
Sh. S. Chain Singh Chera S/o. Sh. Pratap
Singh Chera. The General Power of Attorney
executed on stamp papers of Rs. 50 marked
with Serial No. 88766, issued by Sh. Sudhir
Kumar Jain, with License No. 326, at the
Court Tehsil Mehrauli, New Delhi 110030
dated 21.03.2003, duly Registered with
certificate (Section 60) issued by Registrar
V, New Delhi/Delhi, with Registration No.
2243 in Book 4, Vol. No. 1,890, on pages 70
to 73, on 28.03.2003, Friday is marked and
annexed hereto as ANNEXURE: A.
2 A Special Power of Attorney, executed
between First Party Sh. Tirath Ram S/o Sh.
Hakim Chand in favour of Second Party Sh.
S. Chain Singh Chera S/o Sh. Pratap Singh
Chera. The Special Power of Attorney is
executed on a Stamp paper of Rs. 20 marked
with Serial No. 88767, issued by Sh. Sudhir
Kumar Jain, with License No. 326, certified
at the Court Tehsil Mehrauli, New Delhi
 110030 dated 21.03.2003.
True copy of the said Special Power of
Attorney dated 21.03.2003 is annexed
herewith and marked as ANNEXURE:B.
3 An Indemnity Bond, executed between the
first Party Sh. Tirath Ram S/o Sh. Hakim
Chand in favour of Second Party Sh. S.
Chain Singh Chera S/o Sh. Pratap Singh
Chera. The Indemnity Bond is executed on a
Stamp paper of Rs. 100 marked with Serial
No. 88768, issued by Sh. Sudhir Kumar Jain
with License No. 326, and attested at the
Court Tehsil Mehrauli, New Delhi 110030
dated 21.03.2003. True copy of the aforesaid
Indemnity Bond dated 21.03.2003 is annexed
herewith and marked as ANNEXURE C.
4 An Agreement to Sell and Purchase executed
between the First Party Sh. Tirath Ram S/o
Sh. Hakim Chand in favour of the Second
Party Sh. S. Chain Singh Chera S/o Sh.
Pratap Singh Chera dated 28/03/2003 for a
consideration of INR. 50,000/- (Rupees Fifty
Thousand Only). The Agreement to Sell and
Purchase is executed on a Stamp paper of Rs.
50 marked with Serial No 88769 issued by
Sh. Sudhir Kumar Jain, Licence no 326 at
Court Tehsil, Mehrauli, New Delhi 110030
dated 21.03.2003. Possession letter along
with Affidavit executed on Stamp papers of
Rs. 10 marked with Serial No Serial No
 88770 From 326 Sh. Sudhir Kumar Jain,
licence no 326 Court Tehsil Mehrauli, New
Delhi 110030 dated 21.03.2003. True copy of
the Agreement to Sell and Purchase and
Possession letter along with Affidavit are
annexed herewith and marked as
ANNEXURE:D
5 A Registered WILL dated 28.03.2003,
executed by Tirath Ram in favour of Sh. S.
Chain Singh Chera, certified [Certificate
(60)] by the Registrar V, New Delhi/Delhi,
vide registration no. 1,815 in Book 3, Volume
1,091, on pages 190 to 191.True copy of the
A Registered WILL dated 28.03.2003 Friday.
The same is annexed herewith and marked as
ANNEXURE: E

4. That the Plaintiff no.1 and Plaintiff no.2 are law-abiding

citizens of the United Kingdom (hereinafter referred as
‘UK') with no criminal antecedents and are currently
residing at the address mentioned in the memo of parties.
True copy of the ID proofs of the Plaintiff no. 1 and
Plaintiff no. 2 are marked and annexed hereto as
Annexure: F and Annexure: G respectively.
5. That the Plaintiff(s) are the sons/daughters of Late Shri S.
Chain Singh Chera. Late Shri S. Chain Singh Chera who
passed away unexpectedly from a heart attack on
14/12/2008, did not leave behind any Will. He was
thereafter survived by the Plaintiff(s) and their mother,
who later on became his sole legal heirs and successors.
 True copy of the death certificate of Late S. Chain Singh
Chera is marked and annexed hereto as ANNEXURE: H.
6. That the share of Late S. Chain Singh Chera in respect of
the suit property devolved upon the legal heirs at the time
of his death in the following manner:

S. No. Name Relationship with Share

Late S. Chain
Singh Chera
1 Sh. Randhir Son 1/3rd
Singh Chera
2 Smt. Satvinder Daughter 1/3rd
Kaur Ghalan
3 Smt. Sushil Wife 1/3rd
Kaur

7. That subsequently, the mother of the Plaintiff(s), Smt.

Sushil Kaur Chera demised intestate on 15/10/2022. True
copy of death certificate Late Smt. Sushil Kaur Chera W/o
Late S. Chain Singh Chera is marked and annexed hereto
as ANNEXURE: I.

8. That after the demise of Plaintiff’s mother, the share of the

Plaintiff’s mother was subsequently inherited by the
remaining legal heirs i.e. the Plaintiff(s) in equal ratio.
Consequently, Plaintiff no. 1 and Plaintiff no. 2 became
joint owners of the suit property, each holding a 1/2
undivided share. Hence, the present shareholding status
qua the undivided share in the suit property of both the
 legal heirs who also tend to be the co-owners of the suit
property is enumerated hereinunder: -

S. Name Relationship with Share

No. Late S. Chain
Singh Chera and
Late Smt. Sushil
Kaur Chera
1 Sh. Randhir Son 1/2
Singh Chera

2 Smt. Satvinder Daughter 1/2

Kaur Ghalan

9. That at the time of filing this present Suit, the Plaintiff no.1
and Plaintiff no. 2 stand to be the only class-I legal heirs of
Late Sh. S. Chain Singh Chera. True copy of the Family
chart depicting Plaintiff(s) as legal heirs of Late Sh. S.
Chain Singh Chera in the Class-I category is marked and
annexed hereto as ANNEXURE: J.
10.That Late S. Chain Singh Chera was a respectable, law-
abiding and peace-loving citizen. He was considered to be a
generous person who was always ready to cater the needs of
those individuals who were in the help or some support and
assistance. Being such an altruistic person, he purchased the
Suit property from his hard-earned life savings and the same
was kept for charitable purposes.
11.That being a man of such high moral principles, Late Sh. S.
Chain Singh Chera (hereinafter referred to as ‘deceased’)
decided to operate a school for underprivileged children and
accordingly built a 3/4th storey building in the Suit property.
It is submitted that the costs towards such construction were
also paid from the deceased’s charitable funds. Soon after
the completion of the building, the said school started
functioning. True copy of photographs of the school built in
the Suit property is marked and annexed hereto as
ANNEXURE K (COLLY).
12.That the deceased purchased the Suit property on advice of
Defendant No.1 namely Mr. Iqbal Singh S/o Inder Singh
who resides at RZ 124, Gali No.15, Tughlakabad Extension,
Delhi-110019 which is adjacent to the Suit property. While
the school was being constructed, the deceased used to visit
India to ensure the smooth functioning of the School at the
Suit property, whereas the Defendant No.1 used to visit the
Suit property on regular basis as the school was a short walk
from his residence and he travelled all the way from his
home to the school on his own accord.
13.That Defendant No.1 regularly insisted the deceased and Lt.
Smt. Sushil Kaur, the mother of Plaintiff(s) to entrust him
with the responsibility of running the school (built in the
Suit property). Upon such repeated requests of Defendant
No.1 and keeping in mind the positive approach of
Defendant No.1 and his family towards contributing to this
noble cause, the deceased agreed to the same and gave the
charge of operating the school to Defendant No.1 and his
family. Subsequently, the Defendant No.1 and his family
took the responsibility of administrating as well as
 managing the related work of the school built at the suit
property.
14.That on several occasions, the Suit property in question was
also used as a base camp for providing cataract treatment.
The said camps were conducted under the guidance and
supervision of the deceased and his family in which the
Defendant No.1 also used to participate. Thus, in all such
ways, a fiduciary relationship was built between the
deceased, his family & Defendant No.1.
15.That during the Plaintiffs’ visit to India in January 2009,
Plaintiff(s) along with their then alive mother Smt. Sushil
Kaur visited the suit property and further met Defendant
No.1 and his family who expressed their grief towards the
demise of their father. At the same time, the Defendant No.1
insisted the Plaintiff(s) to not to sell the Suit property as he
exhibited his desire to continue running the school in the
same way as he had been in the previous years. Upon
several requests and assurances made by the Defendant
No.1, the Plaintiff(s) agreed to the same. The said decision
was taken keeping in view that they not only wanted to
preserve and utilize the charitable funds of the deceased but
also wanted to promote his noble initiatives. Further, it is
also to be noted that due to the paucity of time and lack of
knowledge, the Plaintiff(s) were unable to go through the
process of mutation of the Suit property at that time.
16.The Plaintiff(s) had placed considerable trust in Defendant
No. 1. Through his actions, Defendant No. 1 instilled in the
plaintiff(s) the belief that he is a reliable person who in their
absence in India can become the custodian of the suit
property, thereby gaining their confidence. Further, the
 plaintiff(s) were under the impression that the suit property
was secure and entrusted Defendant No. 1 with the freedom
to manage it and make independent decisions regarding its
maintenance.
17.That after entrusting the administration of the school
constructed on the suit property to Defendant No.1,
Defendant No.1 not only managed the school and took care
of the suit property, but also reassured the plaintiff(s) that he
was handling the property with great care. Additionally,
Defendant No.1 informed the plaintiff(s) about the
education of underprivileged children at the school.
Defendant No.1 operated under the confidence of the
plaintiff(s) and implemented their suggestions.
18.That Defendant No.1 continued to take charge of the Suit
property for all these years i.e., 2009-2021 until the
outbreak of Covid-19 pandemic. In or around April 2021,
whilst the world was battling with COVID-19, the
Defendant No.1 approached the Plaintiff(s)’ mother via
phone call and over that said call Defendant No.1 forced her
to sell the Suit property and further demanded transfer of
funds regularly to his account from the sale proceeds of the
of the suit property. At first, Planitiff(s)’ mother i.e. Late
Smt. Sushil Kaur Chera was surprised upon hearing
Defendant No.1's proposal to sell the suit property.
However, she promptly refused the idea, as she had no
intentions of selling the property built from her husband's
charitable funds. Moreover, as a retired individual without
any source of income, she was unable to provide financial
assistance to Defendant No.1.
19.That the Defendant No.1 later approached the Plaintiff no. 2
over calls with the same demand, however, those
unprecedented times made the Plaintiff No.1 & 2
completely helpless. Neither did the Plaintiff No.1 & 2
agree to the sale of the Suit property nor did they commit
any monthly transfers to be made to Defendant No.1.
20.That the Plaintiff(s) received frequent calls for the sale of
the Suit property only from Defendant No.1 and none of his
family members who in fact also looked after and managed
the Suit property. Gradually, the Defendant No.1 started
pressurizing and repeatedly called the Plaintiff(s)
demanding immediate sale of the Suit property even amidst
the pandemic. Defendant No.1 clearly stated to the
Plantiff(s) that he no longer wishes to manage/administer
the school built in the Suit property.
21.That the Plaintiff(s) having left with no other
alternative/recourse, decided to go for an evaluation of the
market price of the suit property, with an intent to sell off
the same only if the sale amount was accurate. It was further
agreed between the Plaintiff(s) that the sale of the Suit
property will be done only with a condition that the
proceeds from such sale would be utilized into Plaintiff(s)
other existing charitable projects within the region of
Punjab.
22.That when the plaintiff(s) informed their family in Punjab
(India) about the said decision, initially there was
disagreement. However, in order to avoid any conflict with
Defendant No.1 and with no other viable option, they
eventually reached a settlement. During their discussion, it
was agreed between the plaintiff(s) and their family that
 Defendant No.1 would be given Rs. 10,000/- (Rupees Ten
Thousand Only) to assist with his living expenses. It is
worth noting that Defendant No.1 accepted this amount but
also expressed his desire for an additional Rs. 10-15 lakhs
from the proceeds of the sale of the suit property.
23. That the Plaintiff(s) never intended to sell the Suit property,
as the same was constructed from the funds of the
deceased's charitable endeavours. The Plaintiff(s) had never
agreed to transfer any substantial amount from the sale of
the suit property to the Defendant No.1. Instead, it was only
due to the persistent insistence of Defendant No.1 that the
decision to sell the Suit property was considered.
24.That the Defendant No.1 kept on explicitly demanding
Rs.10-15 lakhs from the sale of the Suit property and further
insisted that this amount be transferred to him irrespective
of the fact that it was kept for charitable purposes. Even
though the Plaintiff(s) wanted to secure the deceased’s
charitable funds, however, Defendant No.1 kept on
pressurising and demanding monies from the Plaintiff(s).
Constrained from such unanticipated demands, the
Plaintiff(s) & their family agreed upon giving the Defendant
No.1 Rs.5,00,000/- (Rupees Five Lakhs Only) from the sale
of the Suit property.
25.That the Plaintiff(s) started looking for a real estate
agent/property dealer who could assist them with selling the
Suit property. Subsequently, Plaintiff No. 2 was introduced
to Mr. Monti Sheri; a real-estate developer (having contact
no. 7011452694) based in Delhi. It is stated that Mr. Monti
Sheri along with Defendant No. 2 namely Mr. Anil Sharma;
a property broker, visited the Suit property for its valuation.
 Thereafter, an offer of INR 42,00,000/- (Rupees Forty-Two
Lakhs Only) was made by Mr. Monti Sheri and Defendant
No.2, however the same was rejected by the Plaintiff(s)
since they found it to be undervalued.
26.That after rejecting the earlier offer, the plaintiff(s)
continued their search for another estate agent or property
broker. They even took help of family and friends, including
their uncle, Late Mr. Gurdev Singh, who was also a family
friend of Defendant No.1. Despite efforts to find another
agent for property valuation, the onset of the second wave
of the Covid-19 pandemic in India prevented the agent from
visiting the suit property. Despite being aware of these
circumstances, Defendant No.1 persistently called the
plaintiff(s), theree mother and even to Late Mr. Gurdev
Singh for the sale of the suit property. However, as no real
estate developer was found, the plaintiff(s) chose not to
answer Defendant No.1's repeated calls. The frequent calls
to the Plaintiff(s) mother caused significant distress,
especially considering her ongoing battle with stage 4 renal
failure, which necessitated dialysis three times a week to
sustain her life. Her deteriorating health prevented her from
personally addressing matters related to the property.
Despite Late Mr. Gurdev Singh's deteriorating health and
his explicit mention of his kidney failure, Defendant No.1
continued to pressure him. Late Mr. Gurdev Singh informed
Defendant No.1 about his health condition and his inability
to attend to Defendant No.1's repeated calls, but his requests
were ignored as Defendant No.1 continued to enquire
persistently.
27.That since the Plaintiff(s) weren’t able to find an alternate
real-estate agent/property dealer, they decided not to sell the
Suit property at that point of time and thought of selling it
once they themselves visit India. The said decision was
explicitly informed to Defendant No. 1. Further, the
Plaintiff(s) also requested him to continue with the basic
administration of the school at least till the time they visit
India.
28.That in March 2022, Mr. Gurdev Singh, who was the uncle
of Plaintiff No.1 & 2 and a family friend of Defendant No.1,
passed away. During this period, the plaintiff(s) were
shocked to learn that the suit property had already been
sold. The plaintiff(s) were stunned upon receiving this
information. While Defendant No.1 and his family visited
Punjab to pay their respects on Mr. Gurdev Singh's demise,
Plaintiff No.1 & 2's cousin, Ms. Jagdish Kaur, learned about
the sale of the suit property through Defendant No.1's wife,
Mrs. Narinder Kaur, who then informed the plaintiff(s).
29.That On 12/03/2022, the plaintiff(s) learned about the sale
of the suit property when Ms. Jagdish Kaur, a cousin of the
plaintiff(s), who randomly called Plaintiff No.1 and asked if
she had received the proceeds from the sale of the suit
property. Surprised by this statement, Plaintiff No.1
informed her cousin that since the suit property had never
been sold, there was no question of receiving proceeds.
However, upon confirming this information with Defendant
No.1, he revealed that the suit property had indeed been sold
and that he had not received any proceeds from the sale.
30. That when the Plaintiff(s) family at Punjab tried
confronting and inquiring from Defendant No.1 about the
 sale of the Suit property, it turned into a heated argument. It
is pertinent to mention that even the Defendant No.1’s
family including his wife and son namely Lucky Singh
questioned the Defendant No.1 with respect to such
frivolous transaction but the same was of no avail as
Defendant No.1 refused to answer and instead escaped the
premises.
31.That the plaintiff(s) were deeply shocked as they had no
prior knowledge or information regarding the fraudulent
sale of the suit property. However, upon consulting their
lawyers in India and verifying the information publicly
available on the DORIS website, they confirmed the validity
of the sale. Later, on 30/10/2023, the plaintiff(s) received a
certified copy of a forged/impugned sale deed from the sub-
registrar office. Upon examination of the sale deed, it
became apparent that an attempt to defraud the plaintiff(s)
and deprive them of their title rights to the suit property had
been made by the defendant(s), particularly Defendant No. 2
and 3.
32.That in pursuance of the sale deed, Defendant No. 2, Mr.
Anil Sharma, son of HIRA LAL Sharma, residing at 3124,
Gali no. 2, Ranjeet Nagar, Delhi, acted on behalf of the
Principal, identified as D-4, during the sale transaction. D-4,
claimed to be the owner of the suit property, appointed D-1
as her attorney through a General Power of Attorney (GPA),
purportedly registered with the Sub Registrar as Document
no. 9901 Additional Book - IV Volume no. 914 on pages 95
to 98, dated 05/12/2011. This sale deed was executed with
the "vendee," Ms. Sarita Pandey, wife of Baikunth Nath
Pandey, residing at RZ-441-B Gali no. 15, Tuglakabad Extn,
 New Delhi 110019, who is Defendant No. 3 in the case. The
transaction, alleged to be fraudulent, was witnessed by two
individuals identified as D-5 and D-6 in the ongoing suit.
The impugned sale deed Sale deed has been registered with
certificate (Section 60) issued by Registrar V New
Delhi/Delhi, with Registration No. 3,607 in Book 1, Vol.
No. 16,145, on pages 113 to 119, on 28.07.2021,
Wednesday. True Copy of the Sale deed dated 28.07.2021 is
marked and annexed hereto as ANNEXURE: L.
33.That the impugned sale deed qua the Suit property has been
deceitfully made by the Defendant(s). Defendant no. 2 has
granted authority by means of another impugned/forged
General Power of Attorney (GPA) executed between Anil
Sharma Defendant no. 2 and one Smt. Rajeshwari W/o Sh.
Pramod Kumar posing as owner of Suit property. The stated
impugned GPA is registered with the Sub Registrar as
Document no. 9901 Additional Book - IV Volume no. 914
on pages 95 to 98, dated 05/12/2011. A certified copy of the
said GPA is attempted to be secured vide RTI no
REVEN/R/2023/62033. That an appeal has been marked to
PIO for non-provision of certified copy of the impugned
GPA as registered with the Sub Registrar as Document no.
9901 Additional Book - IV Volume no. 914 on pages 95 to
98, dated 05/12/2011 to the SDM , New Delhi. True copy of
the Email to Government authority and the Appeal to RTI
are marked and annexed hereto as ANNEXURE M and N
respectively. True copy of Mutation records, SDMC Reg no
3607 dated 28.7.2021 and DORIS website showcasing the
transfer of Suit property by Defendant No.2 in favour of
 Defendant No.3 is marked and annexed hereto as
ANNEXURE :O (Colly).
34.That none of the plaintiffs, their deceased mother, had any
prior knowledge of the existence of any such GPA.
Moreover, neither the plaintiffs, their deceased mother, nor
their deceased father, have ever executed any document,
whether a General Power of Attorney, Special Power of
Attorney, Agreements to Sell, Wills, Gifts, or any such
conveyance documents in favor of any of the defendants
from the time of their acquisition of title to the property in
question until the filing of this lawsuit. All documents,
including the Sale Deed registered on 28/07/2021, and the
aforementioned GPA dated 05/12/2011, that have been used
to advance the defendants' purported claim to title, are
essentially forged and fabricated, executed with the sole
objective of unlawfully misappropriating the suit property
that rightfully belongs to the plaintiffs, who are the only
class-I legal heirs of the deceased father/owner of the Suit
Property.
35. That neither the Plaintiff(s) authorised any person on their
behalf by giving them a letter of authorization/authority, nor
they have relinquished their respective shares to anyone in
the Suit property. Hence, the said transaction entered into by
the Defendant No.1, Defendant No.2 and Defendant No. 3 is
a complete sham, fraudulent and deceitful transaction based
on forged documents. The sole motive of the Defendant No.
1 and 2 of defrauding the Plaintiff(s) of their rightful share
and causing a wrongful loss to them was fulfilled by selling
the Suit property through illicit means and by way of
misrepresentation.
36.That the Plaintiff(s) had placed their utmost trust in the
Defendant No.1 that he shall safeguard the Suit property in
the absence of the Plaintiff(s), however, the Defendant No.1
in collusion with Defendant No.2 and Defendant No. 3,
fraudulently transferred the property without seeking any
authority from the Plaintiff(s).
37.That the Plaintiff(s) have in the recent past i.e. in May 2022
tried confronting the facts with the Defendant No. 1 over the
phone, however he has been avoiding calls and shying away.
38.That as per the knowledge of the Plaintiff(s), the Suit
property has been fraudulently transferred for a sum of INR
90,00,000/- (Rupees Ninety Lakhs Only). It is also pertinent
to mention that the Defendant No. 3, despite being in
knowledge from the very beginning that the Plaintiff(s) are
the owners of the Suit property, entered into a fraudulent
transaction to defraud the Plaintiff(s) and usurp the Suit
Property illegally.
39.That the Plaintiff(s) have never administered their rights in
the Suit property to any person whosoever. The Defendant
No.1 had latently, with ulterior motives, taking advantage of
the Plaintiff’s absence, sold the Suit property to Defendant
No.3 in collusion with other Defendant(s) without giving
any information or knowledge to the Plaintiff(s).
40.That the Defendant(s) have committed serious fraud and
cheating by entering into a fraudulent transaction based on
forged and frivolous documents. The Plaintiff(s) have
already initiated criminal proceedings against the
Defendant(s) for committing fraudulent acts and serious
offences under various legal provisions. True copy of Police
Complaint dated 09/08/2022 at Police Station Tughlakabad
 Extension, New Delhi-110019 against Defendant No.1-3 is
annexed herewith and marked as ANNEXURE:P.
41.That the fraudulent, malicious and capricious nature of
conduct of the Defendant(s) have caused grave injustice to
the Plaintiff(s) as well as to the deceased. Since the
Plaintiff(s) are the only legal heirs of the deceased, his
undivided share should have been inherited by the
Plaintiff(s). Further, the Defendant No.1 has breached the
trust and the very foundation of their fiduciary relationship
by fraudulently selling their rightful share in the Suit
property.
42. That the Defendant(s) cannot be allowed to prejudice the
rights of the Plaintiff(s) and does not have any rights to
appropriate any portion of the Suit property to himself/third
party out of no ownership without the consent of Plaintiff(s)
in the present matter.
43.That the sale transaction dated 28/07/2021 exhibit the
fraudulent act played by Defendant No.1 in active collusion
with Defendant No. 2 & Defendant No. 3. It is pertinent to
mention that the said sale deed executed w.r.t. the Suit
property is void ab initio and not binding on Plaintiff(s).
44.That in view of the above facts and circumstances, the
Plaintiff(s) have been deprived of their rightful share in the
Suit property as legal heirs. Such malicious, fraudulent and
capricious conduct on part of Defendant No.1 has caused
serious prejudice to the legal rights and legitimate claims of
the Plaintiff(s) in the Suit property.
45. That the Defendants(s) have exploited the situation in as
much as they have taken advantage of the fact that the
Plaintiff(s) reside permanently in the United Kingdom and
 further have no access and sources besides the Defendant
No.1 to look after the Suit property.
46.That the Defendant No.1 in connivance with Defendant No.
2 & Defendant No. 3 fraudulently sold the Suit property
without the consent of Plaintiff(s), thereby depriving the
Plaintiff(s) of their family share in the sale consideration. It
is submitted that the Defendant No.1-3 has at no point of
time had any title, right or interest to sell the Suit property.
Hence, the sale transaction dated 28/07/2021 executed by
Defendant No. 2 in favour of Defendant No.3 and sale deed
registered thereafter in the office of sub-registrar, is not only
null, void and inoperative but also invalid and
unenforceable in the eyes of law.
47.That it is a well-settled position of law that a person cannot
pass a better title than he has have (Nemo Dat Quod Not
Habet). However, the conduct on behalf of Defendant No.1-
3 showcases that they have failed to comply with it and
have rather violated the said principle of law. As a result, the
sale transaction dated 28/07/2021 as well as the sale deed
registered thereafter in the office of the Sub-Registrar is a
bogus, fabricated and a sham document which is invalid and
non-binding on the Plaintiff(s).
48.That the Defendant(s) have relied on a forged and fabricated
document while executing the sale of the Suit property and
have thus committed fraud on the Plaintiff(s). That such
conduct on part of Defendant(s) showcases that they have
even managed to influence the registering authority by
producing a false, fabricated and fraudulent document. Such
acts of Defendant No.1-3 are not only against the interest of
Plaintiff(s) but also against the interest of law and justice.
49.That the Plaintiff(s) have remained in constructive
possession of Suit property since the time the said property
had been purchased. Further, the Plaintiff(s) held no
knowledge of the sale deeds dated 28/07/2021 or the change
in mutation records as no notice was served on to the
Plaintiff(s). Rather, they were made aware only on
12/03/2022 through the Plaintiff No.1 & 2’s cousin.
50.That in view of the above iterated facts and circumstances,
the Plaintiff(s) have been fraudulently deprived of their 1/2
undivided share each in the Suit property as legal heirs of
the deceased. The sale of the Suit property to the Defendant
No.3 without the consent of the Plaintiff(s) being the legal
heirs and on account of fraudulent act on part of Defendant
No.1 & Defendant No.2 makes the whole transaction null
and void. It is submitted that the Plaintiff(s) have serious
apprehensions that the Defendant No.3 shall further alienate
her rights and transfer the Suit property in favour of a third
person, if not restrained immediately. Therefore, the
Plaintiff(s) have also sought a decree of ad-interim perpetual
injunction from transferring or alienating the suit -property
to any other person till the final adjudication of the present
suit.
51.That the Defendant No.1 could not have disposed of any
portion of the Suit property without seeking consent of the
Plaintiff(s). Further, Defendant No.1-3 held no right, title
and interest to use and occupy the Suit property against the
interest of Plaintiff(s). Thus, on account of such wilful
default of Defendant No.1-3, the Plaintiff(s) have no other
option left but to approach this Hon’ble Court for their
 grievances and safeguarding their legal rights over the Suit
property.
52.That the cause of action for filing the present suit first arose
on 14/12/2008 when S. Chain Singh Chera passed away
intestate leaving behind the Plaintiff(s) as his only legal
heirs. The cause of action further arose in January 2009
when the Plaintiff(s) visited the Suit property and met the
Defendant No.1 and his family and decided to continue with
Defendant No.1 as the custodian of the Suit property. The
cause of action further arose on all occasions between 2009-
2021 when Defendant No.1 communicated & kept updated
the Plaintiff(s) about all developments w.r.t. Suit property.
The cause of action further arose in April 2021 when the
Defendant No.1 approached the Late Smt. Sushil Kaur over
calls thereby demanding transfer of funds regularly to his
account and/or tried to force her to sell the Suit property to
which Late Smt. Sushil Kaur straightaway denied such sale.
The cause of action further arose when Defendant No.1 in
the year 2021 approached Plaintiff No.1 and Plaintiff No.2
for the sale of the Suit property and they denied the same.
The cause of action further arose on all occasions when
Defendant No.1 started creating pressure and repeatedly
called the Plaintiff(s) demanding immediate sale of the Suit
property. The cause of action further arose when the
Plaintiff(s) decided to sell the Suit property only with a
condition that the proceeds from such sale would be utilized
into Plaintiff(s)’s other existing charitable projects within
the region of Punjab. The cause of action further arose when
the Plaintiff(s) gave Rs. 10,000/- (Rupees Ten Thousand
Only) to Defendant No.1 whilst the Suit property was being
valued. The cause of action further arose on all occasions
when Defendant No.1 kept on explicitly demanding Rs.10-
15 lakhs from the sale of the Suit property and the
Plaintiff(s) denied the same. The cause of action further
arose when Mr. Monti Sheri along with Defendant No.2
namely Mr. Anil Sharma; real-estate agent and property
broker visited the Suit property for its valuation and made
an offer of Rs. 42,00,000/- (Rupees Forty-Two Lakhs Only)
which was rejected by the Plaintiff(s). The cause of action
further arose when the Plaintiff(s) informed the Defendant
No.1 that they would sell the Suit property once they’ll visit
India. The cause of action further arose on 12/03/2022 when
the Plaintiff(s) discovered about the sale of their Suit
property through Ms. Jagdish Kaur. The cause of action
further arose when Plaintiff(s)’s family at Punjab tried
confronting and inquiring from Defendant No.1 about the
sale of the Suit property but he failed to respond. The cause
of action further arose on 10/05/2022 when the Plaintiff(s)
as per the information publicly available on the DORIS
came to know that the Suit property has been fraudulently
sold by Defendant No.2 to Defendant No.3. The cause of
action arose when the Plaintiff(s) tried contacting the
Defendant No. 1 via calls but he failed to respond. The
cause of action additionally arose on 30/10/2023, when the
Plaintiff(s) became aware of a fraudulent sale upon
receiving a certified copy of a forged/impugned sale deed
dated 28/07/2021 from the Sub Registrar's office on the
aforementioned date. Upon scrutinizing the aforementioned
sale deed, it became evident that Defendant(s), particularly
Defendant no. 2 and 3, had orchestrated an endeavour to
 defraud the Plaintiff(s) with the aim of depriving them of
their rightful title to the subject property. The cause of
action is persistent and is still continuing as the Plaintiff
No.1 and Plaintiff No.2 stand to be fraudulently deprived of
their respective 1/2 undivided share each, at the hands of the
defendant(s).
53.That the Plaintiff(s) reserves their right to move an
appropriate application for amendment of the suit with due
permission of this Hon’ble Court or file additional
documents as and when they are disclosed; keeping into
account the facts mentioned in the relevant paras of the
plaint.
54.That the valuation of the present suit for the purposes of
court fee and jurisdiction is assessed as under:

a) For the relief of declaration, the suit is valued

tentatively at Rs. 1,35,00,000 (Rupees One Crore Thirty-
five lakhs only) being the market value of the Suit
property, the prescribed court fee of INR 20/- has been
paid. The Plaintiff (s) undertakes to pay the appropriate
court fee as and when the final decree is passed or when
directed by this Hon’ble Court.

b) For the relief of perpetual injunction, the suit is valued

at INR 200/- being the fixed jurisdictional value on which
the requisite court fee of INR 20/- has been paid.

c) For the relief of possession, the suit is valued at INR

______/- being the fixed jurisdictional value on which the
requisite court fee____ has been paid.

d) The valuation of future mesne profits/damages for

unauthorised sale of the respective share(s) of the
 Plaintiff(s) is fixed at 60/- on which court fee has been
paid. The Plaintiff further undertakes to pay the
appropriate court fee on future mesne profits/damages as
may be awarded by the Hon’ble Court at the time of
passing a decree of mesne profits/damages.

55.That this Hon’ble Court has territorial as well as pecuniary

jurisdiction to try and entertain the present suit as the Suit
property is situated within the local limits of the jurisdiction
of this Hon’ble Court at Delhi and the entire cause of action
has arisen at Delhi.
56.That the present suit is not commercial in nature and
Plaintiff(s) has not filed any other similar suit before any
court of law.

PRAYER

In view of the aforesaid facts and circumstances, it is

therefore, most humbly prayed that this Hon’ble Court may
kindly be pleased to:
a) Pass a Decree of Declaration in favor of the Plaintiff(s)
and against the Defendant(s) thereby declaring that the
sale transaction dated 28/07/2021 executed by Defendant
No.2 in connivance with Defendant No.1 in favor of
Defendant No.3 and the said sale deed registered in the
Office of Sub-Registrar, as null and void and
unenforceable and invalid in law; and declare that the
same is not binding on the Plaintiffs;
b) Pass a Decree of Declaration in favor of the Plaintiff(s)
and against the Defendant(s) thereby declaring that that the
Plaintiffs are the rightful owners of the Suit property
having 1/2 undivided share each;
 c) Pass an order granting possession of the Suit property
bearing No. RZ-218-B Gali No. 18 Tughlakabad
Extension, New Delhi-110019 in favor of the Plaintiff(s)
and against the Defendant(s);
d) Pass a Decree of Perpetual Injunction in favor of the
Plaintiff(s) and against all the Defendant(s), their legal
heirs, agents, servants, attorneys, assignees, authorized
representatives or anybody acting on their behalf; from
selling, transferring, alienating, creating any third party
interest or encumbering and interfering with the peaceful
possession of the Plaintiff(s) in the Suit property;
e) Pass an order awarding recovery of damages and mesne
profits in favor of the Plaintiff(s) and against all the
Defendant(s) for using the Suit property in possession of
the Defendant(s) belonging to the Plaintiff(s);
f) Pass an order awarding the cost of the suit throughout in
favor of the Plaintiff(s) and against all the Defendant(s).

PLAINTIFF(S)

THROUGH

COUNSELS
H.S. THUKRAL/ KARAN S. THUKRAL
ADVOCATES
For THUKRAL LAW ASSOCIATES
A-1/22, LGF Paschim Vihar
New Delhi-110063
MOB : +91 9999009339
E-mail : [email protected]

DATE: 16.02.2024
IN THE HON’BLE COURT OF DISTRICT & SESSION JUDGE, SOUTH
EAST DISTRICT, SAKET DISTRICT COURTS, NEW DELHI

CIVIL SUIT NO. ______ OF 2024

IN THE MATTER OF:

SATVINDER KAUR GHALAN

& ANR.
…APPLICANT(S)

VERSUS

IQBAL SINGH AND ORS. …DEFENDANT(S)

APPLICATION UNDER ORDER XXXIX RULE 1 & 2

READ WITH SECTION 151 OF THE CODE OF CIVIL
PROCEDURE, 1908 FOR GRANT OF AD-INTERIM
PERPETUAL INJUNCTION ALONG WITH
SUPPORTING AFFIDAVIT

1. That the present suit is pending adjudication before this

Hon’ble Court; the contents of the same may kindly be
read as part and parcel of the present application as for the
sake of brevity, the same are not repeated herein.
2. That the above-noted suit has been filed by the
Applicants/Plaintiff(s) seeking relief of Decree of
Declaration, Possession, Perpetual Injunction, Recovery of
Damages and Mesne Profits in respect of the Suit property
bearing No. RZ-218-B Gali No. 18 Tughlakabad
Extension, New Delhi- 110019; primarily on the ground
that the Applicants/Plaintiff(s) being the legal heirs are the
rightful owners to the extent of 1/2 undivided share each in
the Suit property. However, the Defendant No.1 in
collusion with Defendant No.2 has sold the Suit property
to Defendant No.3 without having any authority from the
 Plaintiff(s). In this regard, the detailed averments are made
in the suit which may kindly be read as part and parcel of
the present application as for the sake of brevity, the same
are not repeated herein.
3. That the Applicants/Plaintiff(s) holds an imminent
apprehension that the Defendant No.3 is contemplating to
transfer, sell, part with, alienate and create any third-party
interest in respect of the suit property bearing No. RZ-218-
B Gali No. 18 Tughlakabad Extension, New Delhi-110019
with a view to defeat the lawful and legitimate claim and
interests of the Plaintiff(s) in the suit property.
4. That the Applicants/Plaintiff(s) has a strong prima facie in
their favor and strongly hopes to succeed in the same and
in case ad-interim injunction is nor granted against the
impleaded Defendant(s) forthwith is respect of the Suit
property, the Applicants/Plaintiff(s) shall suffer irreparable
loss and injury without any restitution therefrom.
5. That if the relief of ad-interim injunction is not granted in
favor of the Applicants/Plaintiff(s) against the
Defendant(s), the sole and primary purpose of the suit shall
get defeated, since after getting notice of the proceedings
initiated by the Applicants/Plaintiff(s), the Defendant(s)
shall expedite and advance his unlawful actions qua the
suit property.
6. That the Applicants/Plaintiff(s) have approached this
Hon’ble Court with clean hands and the balance of
convenience clearly lies in their favor.
7. The application is being moved bona-fide and in the
interest of justice.
 PRAYER
In the premises stated hereinabove, the Applicants/Plaintiff(s)
above named most respectfully pray that this Hon’ble Court may
kindly be pleased to:

a) Pass an ad-interim injunction in favor of the

Applicants/Plaintiff(s) and against the Defendant(s),
their heirs, assignees, successors, authorized
representatives, attorneys or anybody acting on their
behalf, thereby restraining them from selling,
alienating, transferring, parting with possession,
creating any third party interest or to encumber in any
manner the Suit property bearing No. RZ-218-B Gali
No. 18 Tughlakabad Extension, New Delhi- 110019;
during the pendency of the accompanying suit.
b) Pass any such other orders and further reliefs be
granted as a are necessary in the circumstances of the
case in favor of the Applicant(s)/Plaintiff(s)

PLAINTIFF(S)

THROUGH

COUNSELS
H.S. THUKRAL/ KARAN S. THUKRAL
ADVOCATES
For THUKRAL LAW ASSOCIATES
A-1/22, LGF Paschim Vihar
New Delhi-110063
MOB : +91 9999009339
E-mail : [email protected]
HADLEIGH UK
DATE: 16.02.2024
 IN THE HON’BLE COURT OF LD. DISTRICT &
SESSION JUDGE, SOUTH EAST DISTRICT, SAKET
DISTRICT COURTS, NEW DELHI
CIVIL SUIT NO. ______ OF 2024

IN THE MATTER OF:

SATVINDER KAUR
GHALAN & ANR. …PLAINTIFF(S)

VERSUS

IQBAL SINGH
AND ORS. .…DEFENDANT(S)

APPLICATION UNDER SECTION 151 OF THE CODE OF

CIVIL PROCEDURE,1908 FOR SEEKING EXEMPTION
FROM FILING THE REQUISITE COURT FEE FOR THE
GRANT OF RELIEF OF POSSESSION
MOST RESPECFULLY SHOWETH:
1. That the present suit is pending adjudication before this
Hon’ble Court; the contents of the same may kindly be
read as part and parcel of the present application as for the
sake of brevity, the same are not repeated herein.
2. That the above-noted suit has been filed by the
Applicants/Plaintiff(s) seeking relief of Decree of
Declaration, Possession, Perpetual Injunction, Recovery of
Damages and Mesne Profits in respect of the Suit property
bearing No. RZ-218-B Gali No. 18 Tughlakabad
Extension, New Delhi- 110019; primarily on the ground
that the Applicants/Plaintiff(s) being the legal heirs are the
rightful owners to the extent of 1/2 undivided share each in
the Suit property. However, the Defendant No.1 in
collusion with Defendant No.2 has sold the Suit property
to Defendant No.3 without having any authority from the
 Plaintiff(s). In this regard, the detailed averments are made
in the suit which may kindly be read as part and parcel of
the present application as for the sake of brevity, the same
are not repeated herein.
3. That the Applicant(s)/Plaintiff(s) have filed the present
application as the nature of the relief sought in the present
suit is essential for the protection of the
Applicant(s)/Plaintiff(s) legal rights and interests in the
suit property. Granting possession of the property is
imperative to ensure the Applicant(s)/Plaintiff(s) continued
access to shelter and livelihood. Further, it is most
respectfully submitted that since the
Applicant(s)/Plaintiff(s) are permanently residing in the
United Kingdom, logistical challenges, including time
differences, hinder the proper valuation of the suit
property. Consequently, the necessary court fee for
obtaining possession relief cannot be accurately
determined.
4. That in light of the aforementioned circumstances, the
Applicant(s)/Plaintiff(s) earnestly request this Hon’ble
Court to consider the present application for exemption
from filing the court fee for the relief of possession.
5. That the Applicant(s)/Plaintiff(s) respectfully undertakes to
pay the appropriate court fee on relief of possession as
may be awarded by the Hon’ble Court at the time of
passing a decree of relief of possession.
PRAYER
In the premises stated hereinabove, the Applicants/Plaintiff(s)
above named most respectfully pray that this Hon’ble Court may
kindly be pleased to:
a) exempt the applicant(s)/plaintiff(s) from paying the
appropriate court fee for the relief of possession.
b) pass any such other orders and further reliefs be granted as
a are necessary in the circumstances of the case in favor of
the Applicant(s)/Plaintiff(s)

PLAINTIFF(S)

THROUGH

COUNSEL
H.S. THUKRAL/ KARAN S. THUKRAL
ADVOCATES
For THUKRAL LAW ASSOCIATES
A-1/22, LGF Paschim Vihar
New Delhi-110063
MOB : +91 9999009339
(E) : [email protected]
IN THE HON’BLE COURT OF LD. DISTRICT & SESSION
JUDGE, SOUTH EAST DISTRICT, SAKET DISTRICT
COURTS, NEW DELHI
CIVIL SUIT NO. ______ OF 2024

IN THE MATTER OF:

SATVINDER KAUR
GHALAN & ANR. …PLAINTIFF(S)

VERSUS

IQBAL SINGH
AND ORS. .…DEFENDANT(S)

LIST OF DOCUMENTS

S.NO PARTICULARS PAGES

1. ANNEXURE: A

General Power of Attorney duly registered

with the certificate (60) issued by Registrar
V New Delhi/Delhi, bearing registration no.
2,243 in Book 4, Vol. No. 1,890, on pages
70 to 73, on 28.03.2003 of the Suit property.

2. ANNEXURE: B

Special Power of Attorney having Stamp

papers of worth Rs. 20 marked with serial
no. 88767, issued by Sh. Sudhir Kumar
Jain, along with license No. 326, certified at
the Court Tehsil, Mehrauli, New Delhi
110030 dated 21.03.2003 of the Suit
property.
3 ANNEXURE :C

Indemnity bond having Stamp papers of

worth Rs. 100 marked with Serial No.
88768, issued by Sh. Sudhir Kumar Jain
along with license No. 326, and attested at
the Court Tehsil Mehrauli, New Delhi
110030 dated 21.03.2003 of the Suit
property

4 ANNEXURE:D

Agreement to sell and purchase having

Stamp papers of worth Rs 50 marked with
Serial No 88769 issued by Sh. Sudhir kumar
jain, licence no. 326 at Court Tehsil ,
Mehrauli, New Delhi 110030 dated
21.03.2003 and possession letter alongwith
affidavit having Stamp papers of worth Rs
10 marked with serial no. 88770 From 326
Sh. Sudhir kumar jain, license no. 326
Court Tehsil Mehrauli, new Delhi 110030
dated 21.03.2003 of the Suit property

5 ANNEXURE: E

Registered WILL dated 28.03.2003 friday,

executed by Tirath Ram in favour of Sh. S.
Chain Singh (Certificate (60) ) by the
Registrar V New Delhi/Delhi. Vide
registration number 1,815 in Book 3,
Volume 1,091, on pages 190 to 191 of the
Suit property
6 ANNEXURE: F & G

ID proofs of the Plaintiff no 1 and Plaintiff

no. 2.

7 ANNEXURE:H

Death certificate bearing entry no. 106

registered on 16/12/2008 of Late S. Chain
Singh Chera evincing DOD as 14/12/2008

8 ANNEXURE:I

Death certificate bearing entry no. 172

registered on 19/10/2022 of Late Smt Sushil
Kaur CHERA w/o Late S. Chain Singh
Chera evincing DOD as 15/10/2022

9 ANNEXURE: J

The Family chart of Plaintiff(s)

10 ANNEXURE: K (COLLY).
Photographs of the school built in the Suit
property.

11 ANNEXURE: L

certified copy of impugned Sale deed

Registered with certificate (Section 60)
issued by Registrar V New Delhi/Delhi,
with Registration No. 3,607 in Book 1, Vol.
No. 16,145, on pages 113 to 119, on
26.07.2021, of the Suit property.

12 ANNEXURE:M and N

computer printer generated copy of the

 Email to Government authority and the
Appeal to RTI.

13 ANNEXURE:O (Colly).

Mutation records SDMC Reg. no. 3607

dated 28.7.2021 and DORIS website
showcasing the transfer of Suit property by
Defendant No.2 in favour of Defendant
No.3.

14 ANNEXURE:P

Police Complaint dated 09/08/2022 at

Police Station Tughlakabad Extension, New
Delhi-110019 against Defendant No.1-3.

PLAINTIFF(S)

THROUGH

COUNSEL
H.S. THUKRAL/ KARAN S. THUKRAL
ADVOCATES
For THUKRAL LAW ASSOCIATES
A-1/22, LGF Paschim Vihar
New Delhi-110063
MOB : +91 9999009339
(E) : [email protected]