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ramesh vs naveen evidance

Sh. Ramesh Chand, the plaintiff, asserts ownership of a property in Delhi and claims that his son and daughter-in-law, the defendants, have disrespected and threatened him after being disowned. He details incidents of harassment and extortion, leading him to file a complaint with the police and seek legal action to prevent potential harm or dispossession. The plaintiff requests the court to acknowledge his claims and grant relief based on the evidence provided.

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31 views4 pages

ramesh vs naveen evidance

Sh. Ramesh Chand, the plaintiff, asserts ownership of a property in Delhi and claims that his son and daughter-in-law, the defendants, have disrespected and threatened him after being disowned. He details incidents of harassment and extortion, leading him to file a complaint with the police and seek legal action to prevent potential harm or dispossession. The plaintiff requests the court to acknowledge his claims and grant relief based on the evidence provided.

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abc29
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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IN THE COURT OF MS.

TWINKLE WADHWA, JUDGE


FAMILY COURT, SHAHDARA, KARKARDOOMA
COURTS, DELHI.
CIVIL SUIT. NO.33/2023

IN THE MATTER OF:-

SH. RAMESH CHAND … PLANTIFF


VERSUS
SH. NAVEEN KUMAR & ANR. … DEFENDANTS
D.O.H.: 07.11.2024
EX-PARTE EVIDENCE BY WAY OF AFFIDAVIT

I, Sh. Ramesh Chand S/o Sh. Satya Prakash, aged about 56


years, R/o H.No.336-A Gali no.12, Mandoli Village, Delhi-93, do
hereby solemnly affirm and declare as under:-

1. That the deponent is the Plaintiff in the above noted case and well
conversant with the facts of the case and competent to swear this
affidavit.
2. That the deponent is the owner and in possession of the built up
property bearing H. NO.336-A Gali No.12, Mandoli Village,
Delhi-110093, measuring 30 sq, yards (hereinafter called the suit
property). The suit property specifically shown in the attached site
plan.
3. That the defendant No.1 is the son and defendant No.2 is the
daughter-in-law of the deponent.
4. That the marriage of the defendants was solemnized on 17.04.2021
according Hindu rites and customs.
5. That the defendant No.1 & 2 being the natural son and daughter-in-
law of the deponent were allowed to live in the suit property.
6. That the deponent has performed all her social obligation as he has
spent the sufficient amount in nourishment of the defendant No.1
& 2.
7. That the deponent has built up the suit property from his own funds
and allowed the defendants to live and use the suit property but
since joining the company of the defendant No.1 the defendant
No.2 started created scene in the house and also the defendants
have started disregarding and neglecting the deponent and his
family members.
8. That as the defendants have disregarded and insulted the deponent
without any reason therefore the deponent having no option has
abdicated the defendant No.1 &2 from his moveable and
immovable properties vide public notice dated 16.05.2022
published in the newspaper Rashtriya Sahara, Delhi Edition.
9. That in order to extort the money from the deponent, the defendant
got made the phone call to the deponent on 06.06.2022 through
some unknown person and he demanded Rs.3 Lac from the
deponent otherwise he will kidnap the defendant No.1 and if the
deponent dare to call the police then he will kill the deponent and
his family members by shooting and said unknown person again
made phone call to the deponent on 08.06.2022 from phone
No.8084004373 and also threatened the deponent to kill his family
if give in Rs.1 Lac. In this regard the deponent informed the police
and also give written complaint to PS Harsh Vihar on 14.06.2022.
10. That on coming to know about the said disownment, the defendants
left the suit property on 31.07.2022 and started resided at C/o Sh.
Dharmpal R/o 180, Harijan Basti, Shiv Mandir Gali No.11,
Wazirabad, Delhi-110054. Later on, the deponent came to know
that the defendant NO.2 started living at her parental home.
11. That despite disownment, the defendant No.2 did not mend her
ways and she kept continuing her misbehavior with the deponent,
while vistiong the suit property either herself alone or with her
mother Smt. Ritu Gautam. In continuation of their such illegal acts,
the defendant No.2 alongwith her mother Smt. Ritu Gautam came
to the suit property on 02.08.2022, where the defendant No. 2 and
her abovenamed mother abused with the deponent and the
defendant No.2 threatened the deponent that “TUNE HAME IS
GHAR SE NIKALA HAI, MAIN TERA JINA HARAM KAR
DUNGI AUR TUJHE KISI JHUTHE CASE MAIN FASAKAR
JAIL BHIJWA DUNGI PHIR IS GHAR PAR HAMARA KABJA
HO JAYEGA, AUR TUJHSE JO HO KAR LENA.” Due to such
misbehaviour of the defendant No.2 and her mother, the deponent
lodged written complaint with SHO PS Harsh Vihar on 05.08.2022
against them.
12. That in view of the above facts and circumstances, the plaintiff has
every apprehension that the defendants at any time may dispossess
the plaintiff from the suit property forcibly and may cause any
harm to the life and property of the deponent while visiting the suit
property and if they will not restrain from doing so, the deponent
shall suffer with irreparable loss and injury, which cannot be
compensated in any manner.
13. That the acts of the defendants are illegal, hence the plaintiff has
left no other option but to approach this Hon’ble Court by filing the
present suit.

14. That the deponent relies upon the documents i.e. copy of
complaints are Ex.PW-1/1(colly); copy of news paper is Ex.PW-
1/2; copy of Adhar card is Ex.PW-1/3; copy of GPA is
Ex.PW1/4; copy of sale agreement is Ex.PW1/5; copy of Receipt
is Ex.PW-1/6; copy of possession letter is Ex.PW-1/7; copy of
will deed is Ex.PW-1/8; copy of Affidavit is Ex.PW-1/9; and site
plan is Ex.PW-1/10.
15. That the petition of the deponent is correct and kindly be
decreed/allowed as prayed for.

DEPONENT
VERIFICATION
th
Verified at Delhi on this day of August 2024 that the
contents of this affidavit are true to the best of my knowledge and
belief and nothing has been concealed therefrom.

DEPONENT

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