IN THE COURT OF ADDITIONAL CIVIL JUDGE (S

IN THE COURT OF ADDITIONAL CIVIL JUDGE (S.D.), MALOUTM/s. Madan Lal Varinder Kumar V/s. Bimla Devi etc.

Suit for RecoveryReply to Application to produce the Original Bahi & Khata

R/Sir,

It is submitted as under :-

Pre-Objections :-

1.

That application is not maintainable. Defendant is already admitted signature of Kundan Lal in the written statement and affidavit D.A.2.

That applicants have no cause of action to file the present application. They have filed the present application just to linger on the proceedings.

On-Merits :-1.

That para no. 1 of the application is correct regarding the pendency of the suit.

2.

That para no. 2 of the application is incorrect and denied.

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3.

That para no. 3 of the application is incorrect and denied. The entries of Bahi & Khata are genuine and the defendants have already admitted the Signatures of Kundan Lal on the sale deed and also in the account books.

It is, therefore, prayed that the application of the applicant may kindly be dismissed with costs.

Submitted By :-

M/s. Madan Lal Varinder Kumar through Prop. Varinder Kumar S/o Sh. Madan Lal R/o Malout, Tehsil Malout, Distt. Sri Muktsar Sahib.

Verification :-Verified that the contents of para no. 1 to 2 of the pre-objections and para no. 1 to 3 of the on-merits of the reply to application are true and correct to the best of my knowledge and belief and prayer is believed to be true.IN THE COURT OF ADDITIONAL CIVIL JUDGE (S.D.), MALOUT

Chandi Ram Sharma

V/s.

Ram GopalSuit for Declaration & Permanent InjunctionReply to Application for Setting aside exparte order dated R/Sir,

It is submitted as under :-

Pre-Objections :-

1.

That application is not maintainable. That the defendants no. 2 & 3 have filed their written statement and they have appointed their counsel accordingly. The Honble Court has also declared exparte on dated 09-03-2012 previously and the applicants have filed application to set-aside the said exparte order on dated 23-05-2012. The Court has set-aside that exparte order on the basis of Cost of Rs. 5000-00. But the defendants have again not cared about the present suit and was not appeared in the Honble Court and the Honble Court again passed exparte order dated against the defendants no. 2 & 3. -2-

2.

That the applicants have no cause of action to file the present application. The applicants intentionally not appeared in the Honble Court and they have filed the present application just to linger on the proceedings of the present suit.3.

That the applicants may kindly be estopped to file the present application on account of their own act and conduct.

4.

That the application of the applicants is time barred.On-Merits :-

1.

That para no. 1 of the application is correct.

2.

That para no. 2 of the application is correct.

3.

That para no. 3 of the application is correct.

4.

That para no. 4 of the application is incorrect and denied.

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5.

That para no. 5 of the application is incorrect and denied.

6.

That para no. 6 of the application is incorrect and denied.

7.

That para no. 7 of the application is incorrect and denied.

8.

That para no. 8 of the application is incorrect and denied.

It is, therefore, prayed that the application of the applicant may kindly be dismissed with costs.Submitted By :-

Chandi Ram Sharma Plaintiff

Through Counsel :-Verification :-

Verified that the contents of para no. 1 to 4 of the pre-objections and para no. 1 to 8 of the on-merits of the reply to application are true and correct to the best of my knowledge and belief and prayer is believed to be true.