CASE INFORMATION FORMAT Ci

DISTRICT East Grimlnal

S. PLAINTIFF / PETITIONER/ COMPLIANTI APPELLANT /DECREE HOLDER ETC,
No. PLEASE FILL UP ALL THE RELEVANT FIELD &() FIELDS ARE MANDATORY)
1 Namo of the Plantiff / CGtthn Sheola
Complalnant /Etc.
2 Slo W/o D/o Lale Shoi lal 3rh
3 Address Plal no-G02 ; See5r-19 loct3
Aleshandham Apartmonts Delh?-1l0045

Aadhar Card No. 636 248|4241 |Pin Codo:

INDIAN
5 Gender Male JFemale Othor |Nationality |Other:
6 Date of Birth Ago S0
7 Mobile No. -122 88 940 e-mail:
Act/ Section
Court Fee Ascetained:
Valuation of Suit
Court Fee pald / Deposited:
10 Police Station In Criminal Matters only

11 F.I.R. No. & Year In Criminal Matters only

S. DEFENDANT IACCUSED/ RESPONDENT JUDGEMNET DEBATER ETC.

No. PLEASE FILL UP ALL THE RELEVANT FIELD &() FIELDS ARE MANDATORY)
Name of The os,
DEFENDANT /ACCUSEDs. Pevk? De
EtC.

2S/o Wlo Dlo

3 Address N-35 Erenion huudoa Po ad, HousenoB-o
Derigines (nk B-a/4
UAam
Seetr
Padesh
2
Aadhar Card No. Pin Code:
INDIAN
5 Gender Male Female other Nationality
Other:
6 Date of Birth Age
7 Mobile No. e-mail:
S ADVOCATE FOR PLAINTIFF/ COMPLAINANT / PETITIONER / DECRESS HOLDER ETC.
No.
1 Name of The Advocate
Enrl. No.
foonam kani 8gb
Dsek Caut aDs
Office / Chamber No. Chomber 02, Dasle
3 Mobile No. e-mail: G811 630q

sUBMTED BY .Samae.g.tht.galatk
PLAINTIFF /PETITIONER / DEFENDANT IACCUSED / OTHER/ ADvoATE
 IN THE HON'BLE COURT OF SH SOMITRA KUMAR,
LD ADJ, EAST DISTRICT, KARKARDOOMA COURTS,
DELHI

CIVIL SUIT NO, 238/2023

IN THE MATTER OF:
CHITRASHEELA ...PLAINTIFF

VERSUS

SMT DEVKI DEVI& ORS. ...DEFENDANTS

INDEX

SNO.PARTICULARS PAGES C,FEE

1. Arpcaton Behall o the
Aainit tor necesarg |-2
qmandment tn AbbicaSm

Amen ded Appicahn w/o

34 Rute e2 R S P C 3-6

At7dauit.

PLAINTIFF
NIEW DELHI
DATED: o1 ] o8| 2024 THROUGI
MS POONAMRANI SINGII
ADVOCATE:
POONAM RANI SINGH
End, No. Di9640r2021 Advocate
NeAha ChkSeaJrks New Dei75
Emal: advpoonamrsinghgmal. co
Mobilo. 9811116J09
 IN THE COURT OF SHRI
SUMITRAKUMAR,
DISTRICTJUDGE, EAST DISTRICT, KARKARDOOMA
COURTS, DELHI
CIVIL SUIT NO. 238 OF 2023
IN THE MATTER OF:
CHITRA SHEELA ...PLAINTIFF
VERSUS
SMT. DEVKIDEVI& ORS.
...DEFENDANTS
APPLICATION ON BEHALF OF PLAINTIFF FOR
NECESSERY AMENDMENT OF APPLICATION
U/O 39 RULE 1&2 R/W 151
CPC.

Most Respectfully Showeth:

1. That the present petition is
pending before this Hon'ble
Court and the same has been fixed for
today I.e.,
01.08.2024.

2. That it is pertinent to mention here that the plaint has been

amended the other properties to the plaint because of the
same the plaintiff wants to amend the para no. 5
of the
application and after amendment the Para no. 5 may kindly
be read as follows:
Para no.5 That as such the
plaintiff has a
strong apprehension that the defendants may sell the
suitproperties to any other third person on the basis
of false and fabricated documents, hence the
present
application before this Hon 'ble Court.
3. That similarly the plaintiff want to
amended
prayer clause of this application and after
 amendment the praycr clause may kindly be read
as follows;
It is, therefore, most respectfully prayed
that this Hon'ble Court may be pleased to grant an ex
parte injunction order in favour of the plaintiff and
against the defendants thereby directing the
defendants, their associates, agents, nominees,

attorneys, executors, administrators assignee's or any

other person on behalf of the defendants, restraining
them from selling, alienating, gifting, transferring,
morigaging and creating any third party interest in the
properties till the final decision of accompanying suit,
in the interest ofjustice.

Any other or further relief which this Hon 'ble

Court deems fit and proper be also granted in favour of
the plaintiff and against the defendants.

PRAYER:

It is therefore , most humbly prayed that this Hon'ble

Court may kindly be please do allow the present
application for necessary amendment in the application
in the interest of justice.

NEW DELHI PLAINTIFF

DATED: 01.08.2024

THROUGH
POONAMRANI SINGH
ADVOCATE

POONAM RANI SINGH

Enrl. No. DI9640/2021 Advocate
Ofice: 204,2nd Floor, Vardhman Bee Peo Paza, Plot No. 1,
Near Ashiwad Chowk. Sec -5, Dwarka New Delhi-75
Email : [email protected]
Mobile: 9811116309
 R2
04 02024

IN THE cOURT OF SN.SomiTRA KUmAR, LO. D.J , EAST

KARKARDOOMA cOURTS, NEW DELHI
CIVIL SUIT NO.38 OF 2023
IN THE MATTER OF: -

CHITRA SHEELA ...PLAINTIFF

VERSUS
SMT. DEVKI DEVI&& ORS . DEFENDANTS

AmeNDED APPLICATION UNDER ORDER 39 RULES 1 AND 2

READ WITH SECTION 151 CPC ON BEHALF OF THE

PLAINTIEF FOR GRANT OF EX-PARTE INTERIM

INJUNCTION

Most Respectfully showeth:

1. That the plaintiff has filed the suit for

Partition, Possession, and Peranent
Injunction, against the defendants and the
-same is filed for adjudication before this
Hon' ble Coçrt.

2.That the plaintiff CraVes leave of this

Hon'ble Court to read and treat the Contents
of the plaint as part thereof. as the same are
not being reproduced herein for the sake of
brevity.
3.That despite several reguests and receipt of
the said many legal notice, the defendants
neither partitioned the propertynor handed
Over the possession of the share to the
plaintiff.
4. That the plaintiff many times
contacted/met With the Defendants to
partition the abovesaid suit property by
metes and bounds but Defendants paid no
 attention to the requests of plaintiff and
deferred the requests of plaintiff on one
pretext Or the other and no satisfactory
answer has ever been given by any of the
abovesaid defendants regarding the
partition of the aforesaid properties by
metes and bounds and also de fendant no. 2
is not ready to partition the suit
property and threatenthe plaintiff
stating that YEH PROPERTY MERE BAAP KI HAI
AUR MAI ISKA EK BHI HISSA KISI KO NAHI
DUNGA AUR ISKO BECHKAR DIKHAUNGA AUR TUM
MERA KUCH NAHI BIGAAD PAOGAY POLICE AUR
NETAON SE MERE ACHI JAAN PEHCHAAN HAIN AUR
PROPERTY KAI SAARE KAAGACH MERE PAAS HAI
DEKHTA HOON TUM KAISE HISSA MAANGTAY HO

5. That as such the plaintiff has a strong

apprehension that the defendants may sell the
Suit properties to any other third person On
the basis of false and fabricated documents,
hence the present application before this
Hon'ble Court.

6.That if the defendants succeed in his ill

notive then the plaintiff shall suffer
irreparable loss and injury which cannot be
compensated in terms of money.

7.That the balance of convenience 1ies in

favour of the plaintiff and against the
efendants.
8,That the present suit is a fit matter where
the interím injunctíon prayed for should be
granted in the interest of justice and good
conscience.
PRAYER :
It iS, therefore, most respectfully prayed
that this Hon' ble Court may be pleased to
grant an ex-parte injuniction ord r in favour
of the plaintiff and against the defendants
thereby directing the defendantS, their
associates, agents, nominees, attorneysS,
executors, administrators assignees Or any
other person On behalf of the de fendants ,
restraining them from selling, alienating,
gifting, trns ferring, mortgaging and creating
any third party interest in the proper tits til1
the final decision of accompanying suit, in
the interest of justice.
Any other Or further relief which this
Hon' ble Court deems fit and proper be also
granted in favour of the plaintiff and against
the defendants.

PLAINTIFF
NEW DELHI
THROUGH
DATED: -0.08.2024
POONAM RANI SINGH
ADVOCATE

POONAM
Enrl. No.
RANI SINGH
DI9640/2021
Ofice: 204.2nd Floo, Var-nan Bee As
Advocale
Near Ashiwad Chowk. Sec.-5, Dwarks, Plaza,
New
Pict No. 1.
Email: advpconamrsingh Delhi-75
[email protected]
Mobile: 9811116309
 IN THE COURT OF SH.SoMLTRAKUMAR, LO. DISTRICT JUPGE)
EAST, KARKARDOOMA COURTS, NEW DELHI
CIVIL SUIT NO. OF 2023
IN THE MATTER OF:
CHITRA SHEELA ..PLAINTIFF
VERSUS
SMT. DEVKI DEVI& ORS ..DEFENDANTS
AFFIDAVIT

I, Smt.Chitra Sheela, D/o Late Lal singh, R/O

Flat. No -602, Sector -19, Pocket 3, Akshardham
Apartments, Dwarka, Delhi 110075, do hereby
solemnly affirm and declare as under:
1. That I the
am Plaintiff in the above
noted Case and as such am well
Conversant with the facts and
circumstances of the case and Competent
to swear affidavit.
2. That the contents of accompanying
APPLICATION UNDER ORDER 39 RULES 1 AND 2
identify 1 tne READ WITH SECTION 151 CPC have been

has drafted by my
instructions and the same have been read
Counsel under my

|)
and explained to me in my vernacular
language and I Say that the Same are
In
my true and COrrect
the best of my to

ne t wh knowledge and belief. The Contents of

pres nce. the same may kindly be read as part and

parcel to this affidavit
have not been repeated
sake of brevity.
as the Same
herein for the

DEPONENT
Khe
Seal r IFICATION:
Verified at New Delhi On ULAay of
Per Ap 2024 that the contents of my above

Warka KaCourts,O
31 NASM R
vit are true and Correct to the best of
ledge and belief and no part of it is

-N20e6w Delhi Se alhd nothing material has been COncealed

m.
GERTIFIED
Shri/Snt./K
NENY

DEPOENT
idenaino. t i e t e
eh
has soby
New De! which
O:e lthe are
that the contents ai

- 6 JUL 2024
raac &
have tbeen
rue and correct
knowiouge
Amissionet
F|TA SHARMA