COMPLAINT

IN THE COURT OF THE JUDICIAL FIRST CLASS MAGISTRATE,

BEGUSARAI

C.C. NO. 13 OF 2012

Miss. Lepcha kohli, D/o. Foolgenia Devi, Student, aged about 21 year studying in III
Year Batch, B.Tech., S.V. Engg, College, BEGUSARAI,

Residing at S.V. Women Hostel, BEGUSARAI,

Permanent resident of 43/790, K.S. Road, Trumpet, Parwal District.

Within jurisdiction of East Police Station, Bainagan. ……... Complainant

Mr. Johan sehan, S/o. Sachin Johan, Hindu, aged about 26 years 4th Year, B.Tech
student, residing at Men’s Hostel, S.V. Engg. College,

Permanent address 7/90, T. Nagar, Trumpet, Parwal District,

Within Jurisdiction of East Police Station, Bainagan. …….. Accused

COMPLAINT FILED ON BEHALF OF THE COMPLAINANT U/Sec 200 Cr. P.C.

1) The complaint submits that she is studying III Year B.Tech., in S.V. Engineering
College, BEGUSARAI, she knew the accused well.
2) The complaint submits that the accused had been behind her for last 6 months, but
she never cared him. He wrote a love letter to her and she admonished him, then
one day he pulled her upper saree in the class room and on her report he
suspended college for a month. This happened on 01.05.2012.
3) The complainant submits that on 12.05.2012, she came to BEGUSARAI Bus
Station along her friends Yogi, Anitha, Valli to bid forewell to the hockey team of
her college going to Muzaffarpur in Tirumala Express. She came out of the station
and went to the Bus Station at about 8.00 pm along with her friends, she found the
accused near auto stand.
4) The complaint submits that, while she was bargaining auto the accused came
there and abused her that, she was responsible for his suspension from the college,
tried to grab her right hand. When she protested he immediately stabbed on her
left and right cheeks and also on her back with his fists, she cried loudly and the
auto rickshaw drivers and passengers handed over him to police constable near
 the Bus Station. But he did not take the accused to police station that it was a non-
cognizable offence. Hence thus complaint was made directly.

The complaint therefore prays that the honourable court may be pleased to take
cognizance of the offence U/sec 323 IPC and punish him according to law.

xxxxxxxx xxxxxx

Advocate for complainant Complainant

 APPLICATION FOR BAIL

IN THE COURT OF THE FIRST CLASS MAGISTRATE,

AURANGABAD

M. shahakar ……… Petitioner

Vs.

State ……. Respondent

PETITION FILED ON BEHALF OF THE PETITIONER ACCUSED UNDER SEC. 409

OF IPC

May it please your honor

On behalf the above name accused, I beg to apply for his release on bail on
following reasons:

1. The accused was arrested on 05.11.2011 by the Muradabad Police on a charge

U/Sec 409 I.P.C. the main complaint against him being that he being the V.A.O.
of Meruru village and as such being a public servant failed to maintain and show
accounts for a sum of Rs. 3,000/- to the Government Treasury.
2. Though offence is non-bailable taking into consideration the fact that, the amount
involved is only Rs. 3000/- it is highly probable that there must be some honest
mistake on the part of the accused for no one would think of misappropriating
such a small amount as Three Thousands.
3. The accused is a respectable old man of 60 and is certainly not going to abscond.
Moreover his family is resident in the village for over 40 years. His pensions and
provident fund all came to more than Rs. 7000/- and the missed amount will be
compensate by the accused soon.

Due notice of this applications is given to the Police.

PRAYER

Therefore, pray that the said accused may be granted bail and released from the
policy custody where he is for the last 45 days.

XXXXXX

A. MilishaMishra

Advocate for accused

 CRIMINAL APPEAL AND REVISION MEMORANDUM OF APPEAL

IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE AT

BEGUSARAI

CRIMINAL APPEAL NO: 101 OF 2010

For the following among grounds the Appellant here in begs to prefer this appeal
against the judgment dated 29/7/2010 of judicial Magistrate, F.C., MURMURWA in
criminal case No: 101 of 2010, convicting the appellant U/Sec 411 I.P.C and sentencing
him to U/go, 6 months R.I. and to pay a fine of Rs. 300/-

GROUNDS

1. That the conviction is bad in law.

2. That the Judgment of the lower court offends Sec. 367 of the Cr.P.C.
3. That the learned magistrate should have inferred from the conduct of your
petitioner deposed to by the investigating officer that he was absolutely straight
forward in his dealings. The conduct of your petitioner as has been deposited to
by P.Ws. No. 52 and 4 would hardly be consistent with his guilty knowledge.
4. That the learned Magistrate should have taken into accent the representation made
to him by the alleged thief.
5. That the learned Magistrate should have bellered that the articles were purchased
bonafide for proper market price and inferred from that the absence of any guilty
knowledge of your petitioner.
6. That the articles sold were common articles of everyday use to be found in
possession of people of even modest means.
7. That the learned Magistrate should have disbelieved the evidence of P.W.s No: 56
and 7 who identified the parker pen and the Wallet alleged to belong to Sri Anand
and should have hold that they were ordinary, common articles incapable of
identification in the absence of any special mark or name.
8. That the learned Magistrate should have believed the defence witnesses who
disposed to having seen the articles sold to the appellant some five months prior
to the incident.
9. That the Lower Court ought to have given the benefit of responsible doubt to the
appellant and acquitted him.
PRAYER

In the circumstances stated above, the petitioner prays that your honour may be
pleased to admit the appeal, call for the record.

Release your petitioner pending disposal of the appeal on bail and after hearing
the case, set aside the order of conviction and sentence or pass such other order as the
ends of Justice may call for and your petitioner, as in duty bound, shall ever pray.
 REVISION APPLICATION

IN THE HIGH COURT OF JUDICATURE AT PATNA

CRIMINAL REVISIONAL JURISDICTION

In the matter of an application U/Sec. 439, Cr. P.C.

Rajasekhara Rai, residing at Nacharam, Patna …….. Petitioner/ Accused

Vs.

The State of Bihar …. Respondent

In the matter of a Revision from the order of conviction passed U/Sec 324, I.P.C.
on 30.01.2010 by the learned presidency magistrate sixth court, Patna.

To His lordship the Chief Justice and the Puisne Judge of the said honourable
court.

THE HUMBLE PETITION OF THE ABOVE NAMED PETITIONER MOST

RESPECTFULLY SHEWETH

In the matter of an application U/sec. 439, Cr. P.C. Rajasekhar Rai, residing at Nacharam,
Patna ………. Petitioner / Accused

Vs.

The state of Bihar …………. Respondent

In the matter of a Revision from the order of conviction passed U/sec 324, I.P.C. on
30.01.2010 by the learned presidency magistrate sixth Court, Patna.

To

His lordship the Chief Justice and the … judge of the said honourable Court.

THE HUMBLE PETITION OF THE ABOVE NAMED PETITIONER MOST

RESPECTFULLY SHEWETH

That the learned president Magistrate convicted the applicant and one Mukesh Rai
under the mentioned section and sentenced him to undergo Vigorous imprisonment for a
period of four month and to pay a five of Rs.100 or in default to undergo further R.I. for
15 days.

Being aggrieved by the aforesaid order, your petitioner begs to more the
honourable court in its Revisional Jurisdiction on the following.
Grounds

1. That the order of the lower court is against law.

2. That the learned presidency magistrate erect in believing the complaints who were
interested witness.
3. That the learned presidency magistrate was wrong in dis-believing the two
respectable and independent witnesses examined on behalf of the defence.
4. The learned magistrate has erred in not complying with the mandatory provisions
of the Cr. P.C. whereby an opportunity to explain away the circumstances
appearing against them was refused.
5. The learned magistrate has not maintained a full record of the evidence and hence
certain admissions by the prosecution given in their cross examination are not
available.

Prayer

The petitioner therefore prays that your lordship may be graciously pleased to call
for the record of the case and issue a rule upon the presidency.

Magistrate, sixth court and upon the opposite party to show cause why the aforesaid,
order complained of should not be vacated and to release the petitioner on bail pending
the disposal of this revision applications and your lordships may be pleased to pass such
other order or orders as the circumstances of the case demand.

And your petitioner, as in duty bound, shall ever pray.

 MEMORANDUM OF WRIT PETITION WRIT OF HEBEAS CORPUS

UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

IN THE COURT OF JUDICATURE OF BIHAR AT PATNA

W.P. No. 115 OF2014

Between:

Mr. Y. Koteswar Rai,

S/o. Sri M.N. Rai,

Aged 40 years,

R/o. Patna. …..Petitioner

AND

1) Govt. of Bihar Rep. by its Secretary for Home, Patna.

2) The Director General of Police, State of Bihar, Patna.

3) The Supdt. Of Police, Arwal District, Bihar. …. Respondents

Address for service on the above named petitioners is that of their Counsel M/s.
Ram & Co., Advocates, High Court of Bihar, Vengal Rai Nagar, Patna-04.

For the reasons stated in the accompanying affidavit, it is prayed that this
Hon’ble Court may be pleased to issue a writ of Habeas Corpus or any other appropriate
writ or order or direction to the respondents directing them to forthwith set the petitioner
at liberty who has been illegally detained by the Patna Police respondents No. 3 and pass
such other order or orders as this Hon’ble Court may deem fit and proper in the
circumstances of the case.

Place: Patna Counsel for Petitioner.

Date: XXXXX
 MODEL FIR

(First Information Report)

(Under Section 145 & 157 Cr.P.C.)

1. BEGUSARAI District, Tiruchanoor Police, 2014, FIR No. 102, Date: 15-04-2014

2. (i) Act ………………………….. Sections : ……………………………

(ii) Act …………………………. Sections : ……………………………

(iii) Other Acts & Sections: ……………………………………………

3. (a) Occurrence of Office: March, 31st, Monday, Night between 10.30 to 11.00 pm

(b) Information received from B. Ajay Kumar and K. Naresh Babu at the Police
Station about 11.25 pm, 31st March, 2014.

(c) General Diary Reference Entry No(s): 42, Time: 11.30 pm 31st March, 2014.

4. Type of Information: Written/ Oral

5. (a) Place of Occurrence : Tiruchanoor Road, Near Mango Mandi, BEGUSARAI.

(b) Address: Srinivasapuram, Tiruchanoor Road, BEGUSARAI-517 503

BEGUSARAI Rural, Tiruchanoor Police Station Limits.

6. Complainant/ Informant

a) Name: B. Ajay Kumar,

b) Father’s Name: B.K. Rai
c) Date/ Year of Birth: 24-10-1994
d) Nationality: Indian
e) Passport No ………. Date of issue………… Place of issue ……….
f) Occupation: Business
g) Address: Telephone Colony, Srinivasa Puram, BEGUSARAI.

7. Details of known/ suspected/ unknown/ accused with full particulars. (Attach separate
sheet if necessary)

…………………………………………………………….

8. Physical features deformities and other details of the suspect:

……………………………………………………………………
9. Contents of the Complaint/ Statement of the complainant or informant (Attach separate
sheets, if required).

10. Action taken. Since the above report reveals commission of offence (s) u/S as
mentioned at Item No. 2

Registered the case and took up the investigation/ directed ……………… Rank
……………… to take up the investigation FIR read over to the Complainant/ Informant,
admitted to be correctly recorded and a copy given to the Complainant/ Informant free of
cost.

Signature of the Officer-in-charge Police Station

XXXXX

Tiruchanoor Police Station,

BEGUSARAI
 A COMPLAINT UNDER SECTION 138 BY A FIRM
IN THE COURT OF ADDITIONAL CHIEF METROPOLITAN MAGISTRTE GAYA
Complaint No 123/ 2016

Mr. Sriram Kumar, s/o Mr Mittal Kumar,

r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003
Through : Shri Mr. Shayam Kumar, s/o Mr Ram Kumar,
r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003 …..Complainant

Vs

1. Mr. Pawan Kuamr, s/o Mr Raman Kumar,

r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003
2. Mr. Pritam Kumar, s/o Mr Ritham Kumar,
r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003 …...Accusseds

LIST OF WITNESSES
1. Complainant
2. Manager/Officers/Clerk of the Bankers of the Accused
3. Manager/Officers/Clerk of the Bankers of the Complainant.

Muffassil Thana Gaya

30/10/2018 at 4.00 PM
Complaint under section 138 read with section 142 of the Negotiable Instruments Act,
1881

That the complainant most respectfully submits as under:

1. The complainant is a partnership firm having their registered office at mentioned

in the title and the accused was purchasing goods from the complainant on credit bases.
 2. To fulfill the liability the accused had issued a cheque being No 2459 dated 25th
day of October, 2017 of Rs 1,00,000 ( Rupees One Lakhs only) drawn on 24th day of
October, 2017 towards part payment. The said cheque was presented by the complainant
in their bank on 28thday of October, 2017 for encashment, but the said cheque return
unpaid by the banker of the accused for the reason falsification of signature with the
Bank memo dated 29th day of October, 2017
3. The complainant approach their lawyer who sent a legal notice dated 30th day of
October, 2017 under clause (b) of the proviso to section 138 of the Negotiable
Instruments Act, 1881 and demanded from the accused the amount of the dishonored
cheque. However, the said notice was refused to be accepted by the accused, means the
accused was aware about the contents of the letter.
4. That since the accused did not make any payment under the said cheque, despite
sending said legal notice, which was refused to be accepted, the complainant is left with
no alternative, but to file the present complaint under clause (b) of section 142 against the
accused for the offence committed by him under the provisions of the Negotiable
Instruments Act, 1881, resulting from the dishonor of the cheque.
5. The cause of action has arisen on account of the dishonor of the cheque dated 30th
day of October, 2017 for Rs 1,00,000 ( Rupees One Lakhs only) issued by the accused,
as indicated herein above.
6. That the cause of action has arisen within the jurisdiction of this Hon’ble Court
and the payment was also actually to be received at Gaya and hence this Hon’ble Court
has jurisdiction to try and adjudicate upon the present complaint. That the complaint is
being filed within limitation as prescribed under the law.
PRAYER
It is, therefore, most respectfully prayed that the present complaint be registered and
summons issued against the accused in accordance with law, who may tried and punished
in accordance with law.

Place- Gaya Sd-

Date- 30/10/2011 Mr. Sriram Kumar
 MEMORANDUM OF APPEAL TO SESSIONS COURT
IN THE COURT OF THE SESSIONS JUDGE AT PUNE
Criminal Appeal No 321/2003
Shri Sriram Prasad, s/o Sri Ram Kumar
Age 36 years, occupation - service,
Resident of Mehetre Vasti, Chikhali,
Taluka Haveli, District - Pune. …..Appellant

Vs

The State of Maharashtra .….Respondent

CRIMINAL APPEAL U/S 374 OF THE CODE OF CRIMINAL PROCEDURE 1973

The humble petition of the appellant above-mentioned, now in jail, most respectfully
showeth:

1. That the appellant was charged with and tried for the offence punishable u/s
304(A) of the Indian Penal Code and was sentenced to suffer SI for one month and also
to pay a fine of Rs. 500/- I/d to suffer further SI for seven days.
2. That the said order of punishment has been passed by the Hon'ble Judicial
Magistrate, First Class, Vadgaon Maval, in S.T.C.C. No. 1100/2000.
3. That the said judgment and order of punishment have been passed by the Hon'ble
Trial Court on 7.3.2003.
4. That the Hon'ble Trial Court was pleased to hold the appellant guilty for the said
offence u/s 304(A) of the Indian Penal Code. That the alleged incident took place in the
property bearing Gat No. 1426, Mehetre Vasti of the revenue village Chikhali, Taluka
Haveli, District Pune, where the appellant was constructing a new house for the residence
of his family, while the appellant himself is working in Mumbai, and he occasionally and
during holidays visits his family residing at the place where he has constructed a new
house.
5. That the said work of construction of the house was assigned to a contractor, and
the father of the appellant; who is old enough, used to visit and supervise the construction
work from time to time.
6. That the appellant being in regular service at Mumbai could not visit or supervise
or look after the construction activity of the said work, and had hardly paid any attention
to the same personally.
7. That the prosecution has examined in all eight witnesses, but no witness on behalf
of the accused was examined, and the appellant is so unfortunate that while recording the
statement of the accused u/s 313 of the Code of Criminal Procedure, despite an enquiry
made by the Hon'ble Lower Court as to whether he had to examine any defence witness,
the accused being totally ignorant and completely innocent did not avail of the
opportunity offered to him, and therefore, no witness on his behalf or at his instance
could be examined.
8. That the appellant respectfully submits that with a view to meeting the ends of
justice, there should have been, at least, one witness, i.e. the father of the accused-
appellant, who used to attend to and supervise the work of construction personally,
should have been examined on behalf of the defence, but this did not happen, and for the
same, the whole blame goes to none but the defence only.
9. That even though the said accident took place between 16.30 hours and 20.30
hours on 17.6.2000, the panchnama was drawn two days thereafter on 19.6.2000.

GROUNDS
1. That the Learned Lower Court has not followed proper procedure and this has
resulted into miscarriage of justice.
2. That the orders passed by the Learned Lower Court are violative of the principles
of justice, equity and good conscience.
3. That the orders passed by the Learned Lower Court are contrary to the provisions
of law and the principles of natural justice.
 4. That the Learned Lower Court has failed to consider the evidence on record in a
judicious manner.
5. That the findings arrived at by the Learned Lower Court are not supported by the
evidence on record.
6. That the necessary issues of law and the facts have not been framed and answered
by the Learned Lower Court,
7. That the Learned Trial Court ought to have acquitted the accused-appellant for the
benefit of doubt for the great many controversies committed in the evidence adduced by
almost all the prosecution witnesses.
PRAYER
It is most respectfully prayed that the appeal may be allowed and the conviction and
sentence passed may please be set aside
Place- Pune Sd-
Date- 27/12/ 2004 Shri Sriram Prasad
Or
Counsel for the appellant
 MEMORANDUM OF APPEAL TO HIGH COURT
IN THE HIGH COURT OF JUDICATURE AT MUMBAI
Criminal Appeal No……/2011
1. The Pune Institute of Engineering
& Technology, Shivajinagar,
Pune 411 005.
2. Dr. Ashok Anandrao Ghatol, Director,
Pune Institute of Engineering
& Technology, Shivajinagar,
Pune 411 005. …...Appellant
Vs
Shri Sriram Kumar, s/o Shri Mittal Kumar
age 35 years, occupation - service,
resident of 1200 Sadashiv Peth,
Pune 411 030. ….Respondant

CRIMINAL APPEAL U/S 374 OF THE CODE OF CRIMINAL PROCEDURE 1973

The appellants above-named submit this memo of appeal, praying to state as follows:

1. 1. That the respondent was appointed at the appellant institute as a

Lecturer in Mechanical Engineering, by an order dated and he took over the
charge on .
2. That the appointment of the respondent was on contractual basis for the
period of one year only.
3. That another appointment-letter was issued on__by which the respondent
was appointed for another two years on contractual basis, and as per this
appointment order, the respondent was requested to communicate the acceptance
of the said appointment before the end of June 200_
4. That the respondent, however, did not communicate his acceptance of the
said appointment order, and since the respondent did not do so, the services of the
respondent stood terminated
 5. That the respondent also informed the appellant institution that he was not
interested in the service and he was, therefore, leaving his job.
6. That, thereafter, the respondent filed an appeal No. PU/25/ 2003 before the
Presiding Officer, Pune University Tribunal, Pune, and the said Learned Tribunal
was pleased to allow the said appeal of the respondent, and it was further ordered
that the appellants should pay unto the respondent salary including all allowances
with effect from being aggrieved by and dissatisfied with the judgment and order,
dated passed in the appeal No. PU/25/2003, by the Learned Presiding Officer,
Pune University College Tribunal, Pune.
GROUNDS
1. That the Learned Lower Court has not followed the proper procedure, and
this has resulted into miscarriage of justice.
2. That the orders passed by the Learned Lower Court are violative of the
principles of justice, equity and good conscience.
3. That the orders passed by the Learned Lower Court are contrary to the
provisions of law and the principles of natural justice.
4. That the Learned Lower Court has failed to consider the evidence on
record in a judicious manner.
5. That the findings arrived by the Learned Lower Court are not supported by
the evidence on record.
6. That the necessary issues of law and fact have not been framed and
answered by the Learned Lower Court.

PRAYER
It is most respectfully prayed that the appeal may be allowed and the conviction and
sentence passed may please be set aside
Place- Pune Sd-
Date- 27/12/ 2004 Dr. Ashok Anandrao Ghatol
Or
Counsel for the appellant
 CRIMINAL REVISION
BEFORE SESSIONS COURT UNDER SECTIONS 397 OF Cr.P.C.

IN THE COURT OF SESSIONS JUDGE AT PATNA

Criminal Revision No……of 2011
(Under Section 397 and 401 of Criminal Procedure Code)
District- Gaya

Mr. Pawan Kuamr, s/o Mr Raman Kumar,

r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003 ……Petitioner

Vs

Mr. Satish Kuamr, s/o Mr Pratish Kumar,

r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003 ..….Respondents

Revision against the order dated 25th of March, 2010 passed by the Special Judge (E. C.
Act) in Criminal Revision No. …… of 2011, in Satish Kumar Vs. Pratish Kumar and
others.

The Relief sought for by this Revision is that the Hon'ble Court may be pleased to allow
the Revision on quash the order dated 25th of March, 2010 passed by the Special Judge
(E.C. Act) in Criminal Revision No. ………. of 2011 with costs throughout and to pass
such other and further orders as it deems fit in the circumstances of the case.

The present Revision is being filed inter alia on the following

GROUNDS

1. Because while discharging the accused under Section 245 (2), Cr.P.C. it was not
mandatory for the trial Court to records evidence under Section 244 Cr.P.C. The view
taken by the Court below to the contrary is erroneous in law.
2. Because the alleged offence being non-cognizable and compoundable, the trial
Court could legally discharge the accused under Section 249, Cr.P.C. on complainants
failure to attend the court.
3. Because the present complaint was the second complaint and the complainant was
deliberately keeping herself absent from the Court on the dates fixed, showing the non-
seriousness of the respondent to pursue the matter.
4. Because the order of the court below is otherwise erroneous on facts and in law.
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble Court may be pleased
to allow the revision petition and set aside the conviction and sentence passed against the
petitioner aforesaid and in any case if the conviction is maintained, the sentence
imposedmay please be commuted as ay be deemed fit

Place- Gaya Sd-

Dated- 25/10/2011 Mr. Pawan Kumar
Sd-
Advocate
 CRIMINAL REVISION
BEFORE HIGH COURT UNDER SECTIONS 397 AND 401 OF Cr.P.C.

IN THE HIGH COURT OF JUDICATURE AT PATNA

Criminal Revision No……of 2011
(Under Section 397 and 401 of Criminal Procedure Code)
District- Gaya

Mr. Pawan Kuamr, s/o Mr Raman Kumar,

r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003 ……Petitioner

Vs

Mr. Satish Kuamr, s/o Mr Pratish Kumar,

r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003 ……Respondents

Revision against the order dated 25th of March, 2010 passed by the Special Judge (E. C.
Act) in Criminal Revision No. 354 of 2011, in Satish Kumar Vs. Pratish Kumar and
others.

The Relief sought for by this Revision is that the Hon'ble Court may be pleased to allow
the Revision on quash the order dated 25th of March, 2010 passed by the Special Judge
(E.C. Act) in Criminal Revision No. 354 of 2011 with costs throughout and to pass such
other and further orders as it deems fit in the circumstances of the case.

The present Revision is being filed inter alia on the following

GROUNDS

1. Because while discharging the accused under Section 245 (2), Cr.P.C. it was not
mandatory for the trial Court to records evidence under Section 244 Cr.P.C. The view
 taken by the Court below to the contrary is erroneous in law.
2. Because the alleged offence being non-cognizable and compoundable, the trial Court
could legally discharge the accused under Section 249, Cr.P.C. on complainants
failure to attend the court.
3. Because the present complaint was the second complaint and the complainant was
deliberately keeping herself absent from the Court on the dates fixed, showing the
non-seriousness of the respondent to pursue the matter.
4. Because the order of the court below is otherwise erroneous on facts and in law.
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble Court may be pleased
to allow the revision petition and set aside the conviction and sentence passed against the
petitioner aforesaid and in any case if the conviction is maintained, the sentence imposed
may please be commuted as may be deemed fit.

Place- Gaya Sd-

Dated- 25/10/2011 Mr. Pawan Kumar

Sd-
Advocate
 TRANSFER APPLICATION UNDER SECTION 408, CR.P.C.

BEFORE THE HON'BLE COURT OF SESSIONS JUDGE AT GAYA

Transfer case No
(Under Section 408 of Cr.P.C.)

On behalf of the accused/applicant;

Mr. Pawan Kuamr, s/o Mr Raman Kumar,
r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003 …..Accused/applicant
Vs

Mr.Raman Kuamr, s/o Mr Praanv Kumar,

r/o Jaiprakash Nagar, Lakhibag, Manpur, Gaya, Pin- 823003
…..Complaint/Opposite Party

To
The Hon'ble Judge of that aforesaid Court.
The humble applicant most humbly showeth as under:

1. That the opposite party has instituted a case No 2459 of 2011 Under Section 302
of I.P.C. Mr. Ram Kumar Vs Mr Pawan Kumar which is pending before the
honourable Magistrate Sri Venketesh Kumar for trial.
2. That in the aforesaid case the bail application of the applicant has been rejected
and consequently the applicant is in jail.
3. That the aforesaid case is at the stage of evidence since last 6 months.
4. That the aforesaid Megistrate has been absent since last 5 months.
5. That the aforesaid Magistrate has how been transferred to another court and no
other Magistrate has been posted in his place.
6. That the applicant apprehends that it shall take very long when a new officer takes
charge of the Court and the proceedings of the trial recommences.
 PRAYER

It is, therefore, most respectfully prayed that the Hon'ble Court may be pleased to transfer
the case No 2459 of 2011 under Section 302 I.P.C, Mr. Ram Kumar Vs Mr. Pawan
Kumar which is pending before the honourable Magistrate Sri Venketesh Kumar for
trial.to some other court of competent jurisdiction.

Place- Gaya Sd-

Date- 30/10/2018 Defence Advocate
 APPLICATION UNDER SECTION 125 ON BEHALF OF THE MINOR
BEFORE THE HON'BLE COURT OF GAYA
Case No. 211 of 2011
(Under Section 125, Cr.P.C.)

District- Gaya
Sri Rahul Kumar, minor S/o Vipul Kumar R/o Jaiprakash Nagar, lakhibag, Manpur, Gaya
through his next friend Sri Vipin Kumar S/o Nitin Kuamr R/o Jaiprakash Nagar,
lakhibag, Manpur, Gaya, Maternal Uncle, P.S Muffassil Thana, Gaya of the aforesaid Sri
Rahul Kumar ……Applicant
Vs
Sri Vipul Kuamr, S/o Nehul Kumar R/o Jaiprakash Nagar, lakhibag, Manpur, Gaya
……Opposite party

To
The Hon'ble Judge of the aforesaid Court.
The humble applicant most humbly showeth as under:

1. That the opposite party is the father of the applicant.

2. That Smt. Meera Kumari the mother of the applicant was married to the opposite
party on 27/12/2006 and out of the said wedlock, the applicant was born on27/12/2007
3. That at present the applicant is 5 years old and a minor and therefore the present
petition is being filed through the next friend of the applicant.
4. That on 25/5/2009 the opposite party threw out Smt. Meera Kumari and the
applicant of his house and refused to maintain and support the applicant and his mother.
5. That ever since then the applicant was living along with his mother at the house of
his aforesaid maternal uncle who was taking the care of both the applicant and his
mother.
6. That on 25/2/2011 the mother of the applicant died on account of the heart-attack.
7. That since last six months the financial position of the maternal uncle of the
applicant Sri Vipin Kumar has considerably deteriorated and he is unable to feed and
maintain the applicant.
8. That despite requests made by the maternal uncle of the applicant, the opposite
party refused to maintain the applicant.
9. That the opposite party is a man of influence. Besides holding the post of
Assistant Audit Officer in the Department and drawing a salary of Rs. 70, 000 (Rupees
Seventy Thousand Only). The oppositeparty also owns other immovable properties at
Gaya
10. That the opposite party is duty bound to support and maintain the applicant.

PRAYER
It is, therefore, most respectfully prayed that the Hon'ble Court may be pleased to direct
the opposite party to pay a sum of Rs 15, 000 (Rupees Fifteen Thousands Only) per
month to the applicant as his maintenance allowance.
Place- Gaya Sd-
Dated- 25/10/2011 Advocate for the applicant
 IN THE COURT OF DISTRICT JUDGE BHAGALPUR

In re, A. B. Minor

A, B (add description and residence)................................Petitioner

Vs

C, D (add description and residence).............................Respondent

Petition of AB, now major under Section 41 of the Guardianship and Ward Act, 1890.

The petitioner states as under:

1. That the respondent was appointed as a guardian of the of the person and property
of the petitioner at Patna in case no. 284 of 2018.
2. That the petitioner has attained the age of 21 yrs. on October 28 th, 2018
(28.10.2018)
3. That the respondent has not delivered to the petitioner all the books of accounts,
title deeds, jewellery and other movable property belonging to the petitioner.
4. That the respondent be directed to render and submits accounts from...... (when
the last accounts were scrutinized and passed by the court) to the date of this
petition.
5. That the respondent be order to pay to the petitioner what shall on taking such
account, be found to have been due to him by the said guardian.
6. That the respondent be directed to deliver to the petitioner all property in his
possession or control belonging to the petitioner.
7. That the state bank are directed to allow the petitioner to operate on the Ramesh
account, hereto for maintained by the said Shri C, D and that the latter case to
have any authority to operate on the said account.
Place: PATNA

Dated: 30/10/2018 Sd- Sd-

Petitioner Advocate
Verification:

It is verified that the contents stated in Para no. 1- 5 are correct to my knowledge and
belief. Nothing has been concealed therein.

Place: Patna Sd-

Date: 30/10/2018 Petitioner

 PLAINT

In the court of the Civil Judge of Jamui

O.S. No 243/2018

Appu khote ……...…….. Plaintiff

Vs.

Kalu singh …….……. Defendant

Plaint filed on behalf of the plaintiff under order VII Rule-10 and long cause title.

(1) Plaintiff

Appu khote, S/o. Ramlal aged 45 years, business -…., residing at D.No. 240,
Chand Road, Lapataganj, within jurisdiction of this honourable court.

The address for services of notices etc. on the plaintiff is as stated above and
come of ……………… advocate, Jamui.

(2) Defendant

Kalu singh S/o. Krishna, 40 years, Hindu, Business, residing at D.No. 240, Chand
Road, lapata ganj within jurisdiction of honourable court.

The address for service of process etc. on the defendant as stated above.

(3) Defendant borrowed a sum of Rs. 25,000 on 26.02.2014 and is consideration there of
executed a promissory note the like sum in favour of the plaintiff, agreeing to pay interest
at 24% per annum.

(4) The plaintiff made several demands on the defendant for the repayment of the debt.
The plaintiff also caused a registered lawyer’s notice dated 04.01.2017 to be sent to the
defendant did not respond.

(5) The plaintiff submits that the defendant is not an agriculturist and he is not entitled to
the benefits under any of the debt relief of law.
(6) Cause of Action: For this suit arose on 26.02.2014 at Jamui, within the jurisdiction of
this honourable court.

(7) The plaintiff values this suit for the purpose of court fee and jurisdiction of 39,000/-
and pays a court fee of 1.666 under section 20 of A.P. Court fee and suits valuation Act.
(8) Particulars of Valuation

Principal borrowed 25,000

Interest 24% p.a from 26.02.2014 to 20.02.2017 14,000

39,000

Court fee paid there on relief 1,666

Prayer

(9) It is therefore, prayed that the honorable court may be pleaded to pass a judgment and
decree against the defendant and in favor of the plaintiff

(10) Directing the plaint defendant to pay the plaintiff the sum of Rs.39,000 on with
further interest at the contact rate till the date of realization.

(11) Awarding the plaintiff the cost of this suit and

(12) Passing such further or other order as the honorable court may deem Fit and proper
in the circumstance of the case.

xxxx xxxx

Advocate for the plaintiff Plaintiff

Verification

I the plaintiff, do hereby declare that the facts stated above true and correct to the
best of my knowledge, information and belief.
List of document filed

(1) Documents original promissory note executed by the defendant.

Special plaints in suit by a licensor against his licencee by a notice as per the
licence agreement.
 WRITTEN STATEMENT

IN THE CITY CIVIL COURT AT JAMUI

SUIT NO. XX OF 2018

C aged 32 years, Christian inhabitant residing at S.R. Nagar, Jamui …… Plaintiff

Vs

1) ‘A’ and

2) ‘B’ ….. Defendants

Defendant No: 1 above named states as follows:

1) Defendant No. 1 admits execution of the irrevocable indenture of settlement in favour

of defendant No. 2 and the plaintiff, but pleads that she was induced to do so by the
undue influence and misrepresentations, of defendant No. 2 and the plaintiff as follows.

(a) The defendant was several times threatened with life by the plaintiff and defendant
No.2

(b) On 9th April 2013, the plaintiff and defendant No. 2 B brought an alleged magician in
this defendant’s house and threatened this defendant that they would have black magic
performed by the magicians and thus kill this defendant. This defendant, being old,
submitted to this diction and executed the indenture of settlement accordingly.

(c) Defendant No. 2 and the plaintiff represented to defendant No. 1 that the deed was
one of the General power of Attorney, empowering the plaintiff and defendant No. 2 to
manage the property of defendant No.1.

(d) Defendant No. 2 and the plaintiff misrepresented to a D.No.1 that it was legally
necessary for defendant No.1 to executed a power of attorney and appoint ‘B’ and ‘C’ as
managers of defendant No. 1 property.

This defendant says that neither the possession nor the management of the property in
suit were handed over to the plaintiff or defendant No.2. The indenture of settlement was
times never acted upon as alleged. This, defendant therefore is still the full owner in
possession and management of the properties in suit.

The Defendant therefore prays and counter claims

That it may be declared that the said deed of settlement be declared null and void
as against her and that the same day by order of this honourable court be cancelled. This
suit be dismissed with cost.

Date:

‘A’

xxxxxx

Defendant No.1

VERIFICATION

I, defendant, do hereby declare that the facts stated above true and correct to the best of
my knowledge, information and belief.

xxxx xxxx

Advocate of defendant Defendant No. 1

 CIVIL SUIT

IN THE COURT OF SENIOR CIVIL JUDGE, JAMUI

SUIT NO: 202 OF 2012

Sri Shyam Duggal,

Business man Residing at D.No. 4/22

Bhoot Nagar, Bhulapur. ………. Plaintiff

Vs.

N. lepcha kakkar

Business man Residing at D.No. 3/88

Near Municipal Office, Jamui. ……Defendant

THE PLAINTIFF ABOVE NAMED STATES AS FOLLOWS:

(1) The plaintiff is the owner of flat No. 10, D.No. 4/22 on the second floor of a building
with lincence to run Furniture Business at Bhavani Nagar, Jamui. The said flat along with
its furniture fixtures and fittings is here after referred to was the said flat.

(2) On 1st January 2012 the plaintiff agreed to allow the defendant to use the said flat on
the terms and conditions in a licence agreement dated 01.01.2012 entered between the
plaintiff and the defendant here to annexed and marked exhibit ‘A’ is a copy of the said
agreement dated 01.01.2012.

(3) Clause 12 of the agreement provides as follows:

Notwithstanding anything contained herein either party here may terminate thus
agreement by giving to the other not less than 3 months previous notice in writing and
without giving any reason. Therefore

(4) Accordingly on 01-07-2012, the plaintiff informed the defendant by a registered

letters, that he was terminating the licence contained in the said licence agreement with
effect from 30.09.2012 and caused upon the defendant to vacate the said flat by the said
date, here to annexed and marked exhibit ‘B’ is a copy of the said letters dated
01.07.2012 addressed by the plaintiff to the defendant.

(5) On 01-10-2012, the plaintiff called upon the defendant, to vacate the said flat, the
defendant informed the plaintiff that he was not prepared to do so, under any
circumstances what so ever, thereafter, the plaintiff made repeated demands on the
defendant to vacate the said flat but the defendant failed and neglected to do so, and
continued to occupy it in unauthorized and illegal manner.

(6) The plaintiff further submits that the defendant has no paid to the plaintiff any
compensation for the illegal and unauthorized use of the said flat from the month of Oct,
2012, and thereafter. There is thus due payable by the defendant to the plaintiff a sum of
60,000 being the monthly compensation for occupation of the said flat at the agreed rate
of Rs. 5000/- per month from 01-10-2012, till the filling of the suit, as per particular
annexed here to and marked exhibit “e”.

(7) The plaintiff also submits that the defendant be ordered and decreed to pay to the
plaintiff compensation at the rate of 5000/- per month from 01.04.2012, till the date on
which the defendant hands over possession of the said flat to the plaintiff.

(8) The plaintiff further submits that it is just and that pending the hearing and final
disposal of the suit, the defendant, the member of his family and on his agents or servants
he restrained by an interior injunction and order of This honorable Court from dispersing
of or parting with the possession of, or any part thereof in favor of any person other than
the plaintiff. The plaintiff submits that if such relief is not granted to the plaintiff, grave
and irresponsible harm and loss and injury will be inflicted on the plaintiff.

(9) The said flat is situated in Bombay, the agreement dated 01.01.2012 entered into left
the plaintiff and the defendant being exhibit ‘A’ here to was entered into in A.P. the
defendant resides in and carries on business in A.P. This honourable court. Therefore has
jurisdiction to entertain, try and disperse of this said.
(10) The plaintiff values the relief claimed in the present suit for the purpose of court fees
and jurisdiction of Rs 4000

(11) The plaintiff will rely on documents a list where of is annexed here to ….

The plaintiff therefore prays

(a) That the defendant be ordered and decreed to forthwith remove himself, along with
members of his family and servant and their belongings, from the flat, being flat No. 10
situated on the second floor of T.K. Road, Jamui and to handover possession thereof
along with its furniture fitting and fixtures to the plaintiff.

(b) That the defendant be ordered and decreed to pay to the plaintiff.

(i) The sum of Rs. 60,000 as per exhibit ‘C’ here to being the compensation for
the use and occupation of the said flat from 1-10-2012 to till date on which the flat is
vacated by the defendant.

(ii) A sum of Rs. 5000/- per month for the use and occupation of said flat from
01.04.2012 to till the date on which the flat is vacated by the defendant.

(c) That pending that hearing and final disposal of the suit, the defendant, members of his
family, his servants and agent be restrained by an interim order and injections of this
Honourable court from disposing of as parting with the possession of or excumbering or
otherwise dealing with the said flat, or any part thereof in favour of any person other than
the plaintiff.

(d) That pending the hearing and final disposal of the suit, the defendant be ordered by an
interim order of this honourable court to pay to the plaintiff the amount mentioned in
clauses (i) & (ii) of prayer (b) above.

(e) For the interior relief in terms of prayers (c) above.

(f) For cost of the suit, and

(g) For such further and other reliefs as the nature and circumstances of the case may
require.
Plaint draw by Sd/-

K. Shamboo Rai Plaintiff

Advocate P. Sri Rama Rai

 INTERLOCUTORY APPLICATION

IN THE COURT OF CIVIL JUDGE, JAMUI

I.A. No. of 2013

O.S. No. of 2013

B. Nachiketa …. Petitioners (Plaintiff)

M. Vasudeva Rai …. Respondent (Defendant)

Petition filed on behalf of the petitioner/ plaintiff under 0XXX VII Rule 5 of C.PC.

For the reasons stated in the accompanying Affidavit, it is prayed that, the
honourable court may be pleased to direct that the property described in the schedule
below be attached before judgment passing such further or other orders as circumstances
of the case.

SCHEDULE

In Arwal District, Sri Balaji Registration District, Jamui sub district Jamui town
within Jamui Municipality in ward No. 8, Town Survey [T.S.] No: 1447, where in D.No.
249, Bazaar Street a house with R.C.C. Roof with all doors, door frames, all fittings are
with electric service connection measuring 25 feet east, west and 40 feet north, south and
bounded on the east by the house of T. Rama Lakshmi on the south by Nalinibhai lane on
the west by the house of Bazaar Street.

Uttam Ravi

XXXXXXX

Advocate for the Petitioner/ Plaintiff

 ORIGINAL PETITION

In the Family Court Judge, Jamui

MARRIAGE O.P. No. 17/2011

Smt. Saraswathi ………. Petitioner

Vs.

S. Mohan Sharma ………. Respondent

Petition filed on behalf of the petitioner under Hindu Marriage Act.

Name of the Petitioner

Smt. Saraswathi, W/o S. Mohan Sharma, Hindu aged about 30 years house wife
residing at 17-6-93, Brahmin Street, Jamui.

The address of the petitioner for the service of notice etc. is as stated above and
also care of her counsel. Smt. V. Geetha, Advocate, Jamui.

Name of the Respondent: S. Mohan Sharma, S/o. Raja Sharma, Hindu aged about 32
years, Doctor by Profession, residing at 8-3-97, G.S. Mada Street, Jamui. The address of
the respondent for the service of notices etc. is as stated.

The petitioner submits that she is legally married wife of the respondent. This
marriage was celebrated in the year 2008 at Jamui. At the time of marriage the
petitioner’s parents gave 25 thulas of gold and Rs. 2,00,000/- in cash as dowry to the
respondent. The marriage was consummated immediately.

The petitioner submits that, she is the legally married wife of the respondent.
Their submits that respondent has started his nursing home at Sharma & Sharma colony
and gained good reputation and were happy for 2 years i.e., since 2011 his life started to
have ups and downs.

The petitioner submits that the respondent slowly cultivated the bad habits and
became share to alcohol and used to have ephedrine etc. So have slowly began to lose his
sexual potency and attach become a total impotent. When he has been taken to Appolo
Hospital, Madras, the doctors have concluded that he lost his potency because of
excessive narcotic drugs and alcohol. The respondent became frustrated in his life. He
gave up his practice slowly the petitioner sold her jewels to maintain the family. Her
parents also helped to some extent.

The petitioner submits that because of inferiority complex the respondent started
to suspect the character of the petitioner. He used to abuse her with vulgar and filthy
words that, she had illegal connections with others. He used to abuse her even, if beggar
stands infront of the house, as the beggar is awaiting for her. She tolerate all these mental
torture added to this the respondent used to put cigarettes on her breast thighs and other
private parts and burn them. He enjoys her screamings. Sometimes he gaged her mouth
with cloth and subject to her to physical cruelty.

The petitioner further submits that on 10.02.2011 he made her naked put the blade
on her left breast and applied chillies powder on the wound she cried loudly
apprehending danger and her neighbor and her mother-in-law came there and saved her
from the clutches of the respondent than on 11.02.2011 she came away to her parents
house. She apprehends danger to her parents’ house also. She apprehends danger to her
life in the hands of the respondent and it is impossible for her to live with such sadistic
husband. Hence the petition for judicial separation filed.

The cause of action for this petition for Judicial Separation arose on 01.02.2003
the date of marriage and also 10.02.2011 when she frightened of her life ran away to her
parents’ house continues de divindum with the jurisdiction of this honorable court.

The value of the petition for the purpose of court fee is of Rs. 500 Net and fixed
court fee of Rs. 10/- paid V/Sec of A.P.C.F. & S.V. Act.

The petitioner submits that no similar petitioner has been filled so far before any
court.
Prayer

The petitioner therefore prays that the honorable court may be pleased to pass an order
and decree.

a. Declare that the marriage has been dissolved by judicial separation.

b. Direct the respondent to pay cost of the petition. And pass such others and further
orders as it deem fit and proper in the circumstances of the case.

Advocate for petitioner Petitioner

VERIFICATION

I, the petitioner do here by declare that the facts state above are true and correct to the
best of my knowledge and belief and signed this verification on this the 25.02.2011 at
Jamui.

LIST OF DOCUMENTS

1) 01.02.2008 marriage invitation card.

2) Doctor prescription with wound certificate.

 AFFIDAVIT

IN THE FAMILY COURT AT JAMUI

NOTICE OF MOTION NO. 80 OF 2010

IN

MATRIMONIAL PETITION NO: 101 OF 2010

Sushmitha ……… Petitioner

Vs.

Goutham …… Respondent.

I sushmitha of Jamui, Hindu Indian inhabitant residing at T.K. Street, 4th Road,
Jamui do hereby solemnly affirm and say as follows.

1) I say that I was married to the respondent on 01.04.2004 at Jamui according to

traditional Hindu rites until 2010. I had cohabited with the respondent at Jamui
and had a son Rahul by the said marriage. The said Rahul is now 5 years of age.
2) I say that until November 2010, our matrimonial life was quite happy and
harmonions. Thereafter, the respondent took to heavy drinking and began to show
disgust, contempt and neglect towards me and towards the said Rahul.
3) I say that the respondent has physically assaulted me on several occasions and is
guilty of gross cruelty as more particularly stated in my petition. I further say that
the respondent is also guilty of desecrating me as stated more fully in the said
petition. I say that I have therefore prayed for a dissolution of the said marriage in
the said petition.
4) I say that I am a housewife with no independent source of income. I further say,
that the respondent is the Branch Manager of Indian Bank and is drawing a
monthly salary of 4000/-
5) I say that I am clearly attached to the said Rahul and fear physical, assaults on
him by the said respondent if his custody.
 6) I therefore submit that this notice of motion be made absolute with costs
Solemnly Affirmed at Jamui. Susmitha

This 2nd December, 2010 Before me

Registrar/ Superintendent

City Civil Court, Jamui.

Advocates for the petitioner

 WRIT PETITION

IN THE HIGH COURT OF DELHI AT NEW-DELHI

(WRIT JURISDICTION)

WRIT PETITION (CIVIL) NO. _252_OF 2016

IN THE MATTER OF :

S/o Suggan kumar R/o Devi sadan, near dujra bhatti, Buddha colony …PETITIONER

Vs.

Muncipal Corporation of Delhi, Through Its Commissioner …RESPONDENT

WRIT PETITION UNDER ARTICLE 226 OF CONSTITUTION OF INDIA FOR

ISSUANCE OF PREROGATIVE WRIT OF MANDAMUS OR ANY OTHER
APPROPRIATE WRIT

Respectfully showeth :

1. That the petitioner is a citizen of India residing at Devi sadan, near dujra bhatti,
Buddha colony.The respondent is Muncipal Corporation of Delhi having their office at
Town Hall, Chandni Chowk, Delhi.

BRIEF FACTS:-

2. That the petitioner is aggrieved by the illegal appointments of daily wage workers by
the M.C.D. office in defiance of Notification No. MCD/LF/01-103 dated 1.2.2014 which
requires the M.C.D. to appoint only those person as Daily wage worker who are below
the age of 30 years as an 01.10.2014. The said Notification was issued after it was duly
approved.

3. That the petitioner is of 27 yrs of age and was working as a daily wage worker, when
on 1.12.2014 his services were terminated without notice/prior intimation. The Petitioner
during his service worked to the satisfaction of his superiors. The respondent has
appointed Sh. Ompal, Sh. Ram and Smt Maya in defiance of the said notification
M.C.D./LF/01-/03 at 01.02.2014 as all the three person namely Om Pal, Sh. Ram and
Smt. Maya are more than 30 years of age as on 01.10.2014. The about named persons
were appointed in utter disregard of Notification. The respondent, however, removed the
petitioner from service although petitioner met the requirements.. That the Petitioner
made representation to the respondent vide letter dated 1.12.2014, 2.1.2015 and also met
the commissioner personally and apprised them of his grievance, however nothing
materialized.

4. That in spite of oral and written representations the respondent have not cared to act
and are maintaining stoic silence on the whole issue.

5. That the petitioners have thus approached the Hon’ble court on amongst others the
following grounds

GROUNDS:

(a) Because the action of the respondent is contrary to law and good conscience.

(b) Because the action of the respondent is arbitrary, unreasonable, irrational and
unconstitutional.

(c) Because respondent have no right to play with the career of the petitioner.

(d) Because the petitioner was removed from job inspite of the fact that he was below age
and fulfilled all requirements.

(e) Because respondent appointed. Sh. Ompal, Sh. Ram and Smt. Maya despite their
being overage and not meeting requirements of Notification No. MCD/LF/01-103 dated
1.2.2014.

(f) Because the action of the respondent is bad in law

(g) That the Petitioner craves, leave of this Honorable Court to add, amend, alter the
grounds raised in this petition.

6. That the cause of action in present case arose on 1.2.2014 when the respondent brought
out the Notification No. MCD/LF/01-103 dated 1.2.2014., it further arise when on
1.12.2014 the petitioner was removed from job inspite of the fact that he was below age
and fulfilled all requirements, it further arose when respondent appointed. Sh. Ompal, Sh.
Ram and Smt Maya despite their being overage and not meeting requirements of
Notification No. MCD/LF/01-103 dated 1.2.2014, it further arose when representations
were made to respondent orally and in writing on 1.12.2014, and 2.1.2015. The cause of
action further arose when respondent did not act inspite of the fact having brought to their
notice. The cause of action is continuing one.

7. That the Petitioner has no other alternative efficacious remedy except to approach this
Hon’ble Court by way of this writ petition

8. That the petitioner has not filed any other similar writ petition either before this
Hon’ble Court or before the Supreme Court of India.

9. That there has been no undue delay in filing of this petition.

10. That the honorable court has territorial jurisdiction to entertain the writ petition.

11. That the requisite court fee of Rs. 50/- has been affixed on this petition.

PRAYER :

The petitioner most humbly prays that this Hon’ble Court may be pleased to :-

(a) Issue appropriate writ in the nature of mandamus or any other appropriate writ
directing the Respondents to cancel the illegal appointment made in disregard of
Notification No. MCD/LF/01-103 dated 1.2.2003 : and

(b) Issue necessary directions to appointment of petitioner and

(c) Issue any other further order/orders or direction/directions as this Hon‟ble Court may
deem fit and appropriate on the facts and the circumstances of this case.

FOR THIS ACT OF KINDNESS THE PETITIONER ABOVENAMED SHALL EVER

PRAY.
Delhi PETITIONER
Date_______ THROUGH ADVOCATE
 GIFT-DEED

1. This deed of gift made at Nasik on 25th day of 20010 between Shri Ram Kumar,
s/o Ram Swaroop, aged about 70 years, occupation-pensioner, resident of 75
Kothrud, Nasik 411 038, hereinafter called the donor, of the one part and Shri
Shyamal Prasad, s/o Shri Somesh Kumar, aged of 25 years, occupation - service,
resident of 150 Kothrud, Nasik 411 038, hereinafter called the donee, of the other
part.

2. Whereas the property bearing Plot No. 75, out of Survey No. 50, of the revenue
village Kothrud, Taluka Haveli, District Nasik, described in further details in the
schedule hereunder, is owned and possessed by the present donor; and whereas
the done is a grandson, i.e. daughter's son of the donor; and whereas the donor
bears natural love and affection for the donee; and whereas out of such natural
love and affection, the donor has decided to make a gift of the said property unto
the donee; and whereas the donee is ready and willing to accept the gift of the said
property, if made out by the donor;

3. Now, this deed witnesses as follows:

1) The donor out of his natural love and affection for the donee does make a gift of
the property bearing Plot No. 75, out of Survey No. 50. of the revenue village
Kothrud, Taluka Haveli, District Nasik, described in further details in the
schedule hereunder, unto the donee TO HAVE AND TO HOLD the same
absolutely and FOR EVER as the owner thereof.

2) That the donee does hereby accept the said gift made out to him by the donor.

3) That the donee shall get his name entered in the record of rights in respect of the
said property.

4) That the donor does hereby declare and confirm that he, the donor, shall not have
any right, title or interest in or over the said property or any thereof.
 5) That the donor does hereby assure unto the donee that he, the donor, has a clean
and clear title to the said property, and the same is free from encumbrances, and
also that the said property is neither a subject-matter of any pending litigation, nor
that of acquisition or requisition proceedings.

6) That the donor also assures unto the donee that all the taxes, cesses, charges and
assessments payable in respect of he said property have been duly paid out by the
donor up to date, and those accruing and becoming hereafter shall be borne out by
the donee.

7) That all the expenses of stamp duty and registration have been borne out by the
donor alone.

THE SCHEDULE OF THE PROPERTY ABOVE REFERRED TO:

All that piece and parcel of land situate within the Registration Division & District Nasik,
Sub-Division & Taluka Haveli, within the local limits of the Nasik Municipal
Corporation, revenue village Kothrud, bearing Plot No. 75, out of Survey No. 50,
admeasuring 3,500 sqft or thereabouts, and bounded by as follows :

On or towards the East-Plot No. 16, on or towards the South- Plot No. 18, on or towards
the West-Public Road, and on or towards the North-Nullah.

In witness whereof the parties hereto have signed hereunder at Nasik the date first above
mentioned.

1. Sh Ram Kumar, s/o Sitaram Kumar, r/o ABC Complex, Nasik Sd/-

2. Sh Raju Kumar, s/o Suresh Kumar, r/o XYZ Complex, Nasik Shri Ram Kumar

Sd/-

Shri Shyamal Prasad

 PROMISSORY NOTE

On demand I, AMIT KUMAR, S/o Mahesh Thakur, R/o- 13/4, Ashok Nagar R. N. 3,
P.O- Kankerbagh, P.S- Kankerbagh, Dist.- Patna, jointly and severally promise to pay to
Mr. GAURAV KUMAR, S/o Rohan Singh, R/o JT Prof. Colony, P.O & P.S- Jamui,
Dist.- Jamui, or order the sum of Indian Rupees 1 Lakh (1,00,000) only with interest at
the rate of 12% (Twelve per cent) p.a. until repayment for value received.

PLACE: PATNA

DATE: October 24th, 2018 Revenue Stamp Signature

RECEIPT

Received from Mr. GAURAV SINGH, S/o- Rohan Singh, R/o- JT Prof. Colony, P.O &
P.S- Jamui, Dist.- Jamui, the sum of Indian Rupees 1 Lakh (1,00,000) only as loan under
promissory note dated October 24th, 2018 executed by one.

xxx xxx xxx

WITNESS RECEIVE STAMP SIGNATURE (S)

 GENERAL POWER OF ATTORNEY

Known all men by these present that, I PARUL KUMARI, daughter of GUTHAN
KUMAR, residing at DB-20, Biswas Apartment, Sant Nagar, Burari, East Delhi, District-
East Delhi, do hereby appoint nominate and empower Mr. ANANT SINGH, son of Mr.
PRABHAKAR SINGH, residing at Parur, Burari, East Delhi, as my lawfully attorney in
India, since I intended to purchase, sale, or to lease immovable or movable properties in
India, for which I am unable to attend in person on account of my job in USA, I do
hereby authorize the above named attorney to do the following for me and in my name on
my behalf execute all or any of the acts and things namely:-

1. To purchase, sale, or to lease or let it out to collect rents there from any moveable
or immovable properties in India.
2. To negotiate and enter into agreement or sale the above properties and enter into
settlement.
3. To receive the payment and issue receipt for the related transactions.
4. To make payment for the purchase of property to appear before the concerned
sub-registrar or registrar, sign any declaration and the endorsement for the
purpose of registration.
5. To develop or construct the building over the land and to apply for the utilities,
live electricity, water etc.
6. To open bank account, operate bank account transactions and issue cheques.
7. To open and operate the bank account for purchase and sale of shares and stocks.
8. To apply and obtain loans from bank or financial institution and create mortgage.
9. To appear before the local bodies and competent authorities to effect mutation of
names in revenue, municipal and electricity board.
10. To keep a true and correct account of all income and expenditure to me annually.
11. Generally to do other lawfull acts or thing that are necessary to purchase of
immovable property in any name.
12. To appear in all central and state government officers, to appear in all civil and
criminal court to act in the courts as applicant, petitioner, plaintiff, defendant or
respondent to appoint advocate to sign Vakilnama.
 13. I do hereby agree that all acts, deeds and things that are lawfully done by the
above said attorney (ANANT SINGH) shall be construed as acts, deed, things
done by me and I undertake to ratify and confirm all and whatsoever that my said
attorney shall lawfully do and cause to be donr for me by virtue of the power
hereby given.
14. IN WITNESS WHERE OF, I PARUL KUMARI have said my hand here unto on
this 23rd day of OCTOBER, 2018(23/10/18)

WITNESSS
 WILL WITH LEGACIES FOR CHILDREN

This is the last will and testament of me, Mr Shyamal Kumar, s/o Mr Ram Swaroop, r/o
Jaiprakash Nagar, Lakhibag, Manpur, Gaya, 823003 on 21st day of November, 2018. This
will be operative with effect from my death. I hereby revoke all wills and codicils by me
heretofore made.

1. I hereby appoint CD of, etc., and EF of, etc., as the executors of my this will,
trustees of my estate and also the guardians of the person and property of my
minor children, GH and IJ, during the respective periods of their minority. In case
any one of the executors fails to obtain probate or act as trustee and guardian, the
other shall act as the sole executor, trustee and guardian.

2. I direct my said executors or executor and trustees or trustee to pay out of my

estate a sum of Rs. 1 lakh to X and a further sum of Rs.1 lakh to Y for their
absolute use and benefit and I hereby give, leave and bequeath the same unto and
in their favour absolutely. It is my further wish and desire that a sum of Rupees 1
lakh should be paid for the expenses of the marriage of MN of, etc., should I not
celebrate his or her marriage during my lifetime and I direct my said executors or
executor and trustees or trustee to pay the same accordingly on the occasion of his
or her marriage.

3. Subject to what are hereinbefore stated, my said executors or executor and

trustees or trustee shall, after defraying the costs, charges and expenses of
administration, hold and possess the entire estate, both movable and immovable,
in trust for my children for their maintenance and support until the youngest of
them shall attain the age of 21 years.

4. My said executors or executor and trustees or trustee shall be entitled to convert

the movables only into money which should be invested in the purchase of
Government securities or trustees securities or in loans against the first mortgage
of houses and lands or in any other good and sound investments with power to
draw interest, dividends, etc. to alter and vary the same at their discretion such
 investment or investments into other investment or investments of the same or
like nature, to be held upon trust as aforesaid.

5. My said executors or executor and trustees or trustee shall look after, manage and
keep and maintain in good repair and develop all my properties, and realise the
rents, profits and other income thereof.

6. I further direct that my said executors or executor and trustees or trustee shall
after paying all my just debts, testamentary and other expenses and the legacies
hereinbefore recited, and, after providing for the costs, charges and expenses of
the management and development of the said properties and for payment of the
revenue and taxes spend the surplus of the income for all the necessary expenses
for maintenance and education of my said children during their minority and on
my last child attaining the age 21 years shall divide the remaining property
equally among all my children, when and in such an event the trust hereunder
created shall come to an end.

7. Provided, however, they shall keep and maintain proper account of the estate and
file the same in court once in every six months and get the same audited and
passed.

Provided, however, further that in the event of acquisition or compulsory purchase of any
property, the said executors and trustees shall invest the proceeds in purchase of some
other suitable property or properties to be also held by them in trust as aforesaid.

IN WITNESS WHEREOF, I have hereunto set and subscribed my hand and signature the
day and year first above written in presence of witnesses;

1. Sh Ram Kumar, s/o Sitaram Kumar, r/o ABC Complex, Gaya Sd/-

2. Sh Raju Kumar, s/o Suresh Kumar, r/o XYZ Complex, Gaya Mr. Shyamal Kumar
 Usufructuary Mortgage

This deed of Usufructuary Mortgage executed on 28/9/2016. A (description) hereinafter

called the mortgagor to and in favour of B (description) hereinafter called the
usufructuary mortgagee, the terms mortgagor and the usufructuary mortgagee meaning
and including their respective heirs, executors, administrators, legal representatives and
assignees Witnesseth.

Whereas the mortgagor is the absolute owner of the property and the mortgagor is in
severe need of money due to marriage of his daughter. Therefore, the Mortgagee has
consented to give Rs. 2 lac to the Mortgagqr as a loan @ rate of 18% per annum.

Now this deed of usufructuary mortgage witnesseth that in consideration of the

premises and in further consideration of the sum of Rs 2 lakhs. (Rupees two lakhs only)
paid by the mortgagee to the mortgagor (as in the Form N o. 1) the receipt of which sum
in manna aforesaid the mortgagor doth hereby acknowledge, he, the mortgagor doth
hereby transfer, convey and assign as and any of Usufructuary Mortgage unto the
mortgagee all that the property more fully described in the schedule hereto subject to the
following terms and conditions.

The mortgagee is hereby authorized to receive the rents and profits accruing from
the mortgaged property and appropriate net income that is gross income less payment of
taxes and public dues charged on the property, towards payment of interest in the first
instance and the balance if any towards the principal, and to remain in such possession
and enjoyment until payment of the mortgage-money and on such discharge of the
mortgage the mortgagee shall deliver back possession of the mortgaged property to the
mortgagor in the same manner as the former was put in possession.

The mortgagor has this day delivered vacant possession of mortgaged

property/constructive possession of the same by directing the tenants to pay the rent
henceforth to the mortgagee.
 The mortgagor assures the mortgagee that the mortgaged property is not subject to
any encumbrance, attachment of any kind, charge, or lien subsisting on the same.

In witness whereof the mortgagor has set his hand and seal on the day and year
first above written and in the presence of witnesses :

1. Sh. Deepak sharma , s/o shri lakhan Sharma,

r/o sharma niwas, 200/D, phoolganj
2. Sh Tunmun choudhary , s/o shri Muntun Choudhary., Sd
r/o Choudhary gharana, 200/B, Phoolganj Mortgagor
Sd -
Mortgagee
 Mortgage by conditional sale

1. This Deed of Mortgage by Conditional Sale executed at 19 this day of september

2009 by A, son of Shri Jaggu Yadav , r/o Yadav niwas, B5, Sehanpur hereinafter
called the Mortgagor to and in favor of B, son of Shri sallu singh , r/o Mahendru
ghat, D56, Sehanpur, hereinafter called the Mortgagee, by conditional sale the
terms Mortgagor and Mortgagee meaning and including their respective heirs,
executors administrators, legal representatives and assignees witnesses.

2. Para 2 as in Form 1.
3. Now this Deed of Mortgage by Conditional, Sale witnesseth that in consideration
of and in further consideration of the sum of Rs. 4 lac (Rupees four lakhs only) paid by
the mortgagee to the mortgagor (as in Form No. 1) the receipt of which sum in manner
aforesaid the mortgagor doth hereby acknowledge, he the mortgagor doth hereby transfer,
convey and assign unto the mortgagee as and by way of mortgage by conditional sale the
property more fully described in the schedule hereto subject to the following terms and
conditions namely :

(i) The mortgagor has conveyed by way of conditional sale the property to the
mortgagee,. herein the schedule-mentioned property as security for repayment of
the money borrowed under this deed on condition that on the mortgagor paying
the sum secured herein to the mortgagee within a period of three years from this
date the mortgagee shall reconvey the said property to the mortgagor at the cost of
the mortgagor and that in the meantime the mortgagor shall pay interest at 18%
p.a. every month on or before the 10th of every succeeding month and on further
condition that in default of such payment Within the period stipulated herein, the
conditional sale shall ripen into an absolute one and the mortgagee shall enjoy
thereafter the said property absolutely and forever with all powers of alienation
free from any let or hindrance from the mortgagor or any one claiming under or
through him and simultaneously the right of the mortgagor to redeem shall stand
extinguished. The mortgagor doth assure the mortgagee that the property hereby
 secured under this mortgage by _conditional sale is not subject to any
encumbrance, lien, charge, attachment or any proceedings.

In witness whereof the mortgagor herein has set his hand and seal on the day and year
first above-written and in the presence of witnesses:

1. Sh, Jaggu Yadav , s/o shri johan yadav r/o Yadav niwas, B5, Sehanpur Sd-
2. Sh Appu khote, s/o sallu singh shri r/o Mahendru ghat, D56, Sehanpur Mortrage

Sd-
Mortgagee
 Simple Mortgage

1. This Deed of Simple Mortgage executed at this 25.day of August2009 by A. Son of

Shri Usman pasina, r/o. hereinafter called the mortgagor in favour of B, son of Shri
sambhu manjhi , r/o B5, near dujra bhatti, boring road hereinafter called the
Mortgagee the, terms mortgagor and Mortgagee meaning and including his respective
heirs, executors, administrators, legal representatives and assigns Witnesseth as follows :
‘

2. Whereas the mortgagor is the absolute owner of the property fully described in the
schedule hereto, whereas the mortgagor is in urgent need of funds (for celebrating his
daughter’s marriage/for discharging prior mortgage dated 29/10/2017. in favour of ...... ,
etc.), whereas the mortgagor approached the mortgagee for a loan of Rs. (Rupees
................... only), Whereas the mortgagee has consented to the same.

3 Now this Date of First Simple Mortgage witnesseth that in Wderation of the premises
and in further consideration of the sum of R5 ................ (Rupees ........... only) paid by the
mortgagee to the mortgagor as in Form No. 1) the receipt of which sum in manner
aforesaid the modgagor doth hereby acknowledge, he the mortgagor doth hereby transfer,
convey and assign unto the mortgagee as and by way of first Simple mortgage all the
property more fully described in the schedule hereto subject to the following terms and
conditions viz :

(i) To repay the principal sum on demand (on any period agreed to between the parties).

(ii) In the meanwhile to pay interest @ 18% pa.

(iii) In the event of the mortgagor failing to pay the amount due under the mortgage on
demand, the mortgagee shall have a right to sue for recovery of the said amount and if
'need be to have the property sold in the said proceeding for due realisation of the
mortgage dues.
(iv) During the subsistence of the mortgage the mortgagor shall pay all public dues and
taxes accruing due in respect of the schedule mentioned property and shall not allow the
same to be proceeded against for recovery of such dues and taxes. If the mortgagee were
to spend money to save the mortgage-property from being sold for recovery of said dues,
such monies shall be, deemed and treated as principal amount, and recovered as such.

(iv) During the subsistence of the mortgage the mortgagor shall keep the property
mortgaged in good condition and shall not commit any act Which is destructive or
permanently injurious thereto as to cause the security to become insufficient.

The mortgagor doth assure the mortgagee that save the mortgage in favour of C to secure
a sum of Rs ......... under deed of First Simple Mortgage, dated ........ there are now no
other encumbrances subsisting on the mortgaged property.

The mortgagor doth also assure the mortgagee that he shall continue to pay the interest
due on the first mortgage without any default and shall not render any act, deed or thing
whereby the mortgaged property will become insufficient security.

witnesses :

1 Sh ......... , s/o shri ............. , r/o Sd

2 Sh ......... , s/o shri ............. , r/o Mortgagor

Sd
Mortgagee
 Lease Deed with an option to renew

This deed of lease made at 27 October of 2009 by and between A, son of Shri Sahdev
Mahto , resident of Lapata Ganj, 200/D and B, son of Shri Shyam Bhikari, resident is as
under :
Whereas the lessor is the absolute owner of the property more fully described in
the schedule, Whereas the lessee approached the lessor for lease of the said property to
the former, Whereas the lessor has consented to the same.
It is, hereby, mutually agreed to between the parties hereto as follows :
1. The property demised by the lessor to the lessee is the one tha is more fully
described in the Schedule hereto.
2. The tenancy is for a period of three years from this date (i.e.) from 27 october
2009 to 27 october 2012. The lessee is given the option to renew the lease for a
further period of three years provided he exercises his right to renew the lease
three months prior to expiry of the lease period herein and provided further that
on such renewal the lessee shall pay as monthly rent the present monthly rent
plus 20% increase thereon.
3. The monthly rent is Rs 9000 (Rupees nine thousand only) it does not include
charges or fees for amenities such as water, electricity, etc. The lessee shall,
himself, bear the charges or fees for such amenities.
4. The demised premises shall be used for residential/ non-
residential/manufacturing purposes only.
5. The lessee has paid this day to the lessor a sum of Rs 3000 . (Rupees three
thousand only) as security deposit. The same is refundable to the lessee on the
lessee’s vacating and surrendering vacant possession of the demised premises
subject to adjustment by the lessor as hereinafter stipulated. In the meantime, it
shall not carry any interest.
6. The monthly rent shall be paid on or before 5th of the month succeeding that for
which the same shall fall due on 5th of every succeeding month.
7. The lessee shall not sublet the demised premises or any part thereof without, the
written consent of the lessor.
8. The lessee shall not erect any permanent structure in the demised premises or any
part thereof without the written consent of the lessor.
9. The lessee is entitled to make his own arrangements for the additional electrical
fittings at his cost and responsibility and shall remove all such fittings at the time
of vacating the demised premises without causing any damage to the premise.
10. The lessee shall, at his cost carry out, minor repairs to, and colour/white wash,
the premises. The lessee should maintain the property in good condition and
shall, at the time of vacating the premises, hand over the same in the same
condition as it was at the time of letting subject to reasonable wear and tear.
11. The lessee should allow the lessor and or his agents, at all reasonable times
during the subsistence of the lease to enter upon the property and inspect the
condition thereof and give or leave notice of any defect in such condition and if
such defect is caused by any act or default on the part of the lessee, his servants
or agents, he is bound to make good the same within three months from date of
receipt of such notice by the lessor.
12. If the lessee becomes aware of any proceeding touching the demised property or
any encroachment he shall give with reasonable diligence notice thereof to the
lessor.
13. The lessee shall not put the demised property for any purpose other than that for
which it is leased.
14. In case the lessee were to commit breach of any of the covenants contained
herein, the lease shall stand determined irrespective of the period stipulated
herein, and the lessor will be entitled to re-enter the same.
15. The lessee shall vacate and surrender vacant possession of the demised premises
on the expiry of the period of lease.
16. If at the time of vacating the premises any damage is found to have been caused
to the premises the lessee shall bear such cost as to repair the damages and if the
lessee shall fail to do so, the lessor is entitled to have the repair carried out and
shall adjust such cost against the security deposit in his hands and refund the
balance subject to further adjustments against arrears of electricity charges, water
 charges and other public dues payable by the lessee touching the demised
premises.
17. The lessor shall pay the property tax and other taxes by virtue of possessing and
enjoying the property. In case the lessee were constrained to pay, he is entitled to
adjust such payments against the rents.
18. The lessor assures the lessee that the lessee shall enjoy the demised premises
without any interruption or interference by him or at his instance as long as the
lessee observes his obligations under this' deed of lease.
19. The term lessor shall mean and include his heirs, executors, administrators, legal
representatives and assignees while the term lessee will include only his wife and
son living as part of his family until his demise.
20. In other respects the Transfer of Property Act shall apply.

In witness whereof the lessor and the lessee set their respective hands and seals
on the day and year first above written and in the
presence of witnesses :

1. Shri, Chunnu Mahto s/o Sahdev Mahto, r/o. Lapata Ganj, 200/D
Sd_
2. Shri,Sanam Bhikari s/o Shyam Bhikari, r/o. Dariyapur, B5 Lessor
Sd-
Lessee
.
Draft Sale Deed

This deed of sale executed at ................ this day of............................

2009...... by Shri ......... , s/o......... Hindu/Jain/Mohammedan/Christian, residing
at............................................ hereinafter called the vendor to and 1n favour
of....................Son of................................ Hindu/Jain/ Mohammedan/Christian
residing at ............... hereinafter called the purchaser, the terms vendor and
Purchaser wherever the context so admits meaning and including their
Respective heirs, executors, legal representatives and assigns, witnesses as
follows.

Whereas the vendor is the absolute owner of the Schedule-mentioned

property,he having purchased the same under deed of sale, dated ...........registered as
document No .................... in the office of the Registrar of Assurances at
...................belonged to.................... under deed of sale dated... registered as document
No .................. in the office of the Registrar of Assurances, vendor being the sole heir to
the said.. ...........whereas the vendor has been in exclusive possession and
Enjoyment ever since then, whereas the purchaser has agreed to purchase
the same.

Now this deed of absolute sale witnesses that in consideration of the

Premises and in further consideration of the sum of Rs. ............... (Rs................)only, paid
by the purchaser to the vendor, in cash/under pay order no............. dated.................drawn
by.........................Bank and in favour of the vendor, at the time of execution of these
presents/at the time of registration of these presents before the Registering Officer/or paid
By the purchaser to the vendor in manner of the following ;

1. Rupees ......................... only) paid in advance on the date of agreement of sale.

Rs……(rupees…….only) paid at the time of execution of the sale deed in
cash/pay order ...... at the time of registration of these presents before the
Registering Office aggregating to Rs……(rupees…….. only)
2. The receipt of which sum in manner aforesaid the vendor doth hereby
acknowledge, he the vendor doth hereby grant transfer, convey and assign an and
by way of absolute sale unto the purchaser all that........................premises being
............. agricultural land-building site in........................,.house, ground and
premises bearing door No ................ more particularly described in the Schedule
hereto together with all right, title, estate, interest, property, claim and demand
into and upon the schedule mentioned property with all rights, waters, water
courses, ways, easements, advantages, privileges, opportunities belonging to or
 reputed to belong now or heretofore therewith or any part thereof, to have and to
hold the same unto and to the use of the purchaser absolutely and forever, free
from all encumbrances, charges, lien, trust,will, litigation lis pendens, attachment,
right or demand of any kind whatsoever.

The vendor has this day delivered vacant possession of the property more fully described
in the schedule hereto to the purchaser

The vendor doth covenant with the purchaser as follows :

1. The vendor is the sole person absolutely entntled to the property hereby
conveyed and has been in exclusive possession and enjoyment of the same and
that he has full power and authority to convey the same to the purchaser.
2. That property hereby conveyed shall be entered upon peaceably and quietly
enjoyed by the purchaser without any let or hindrance by the vendor or anyone
claiming under or through the vendor.
3. The purchaser shall henceforth collect the profit/income/rent from the schedule
mentioned property.
4. The vendor has paid all the public charges, rates and out In respect of the said
property till date.
5. The vendor had not dune or knowingly suffered or been a party or privy to any
act, deed or thing by reason where of the said property is charged or encumbered
or affected in estate, title or otherwise.
6. The vendor shall keep the purchaser indemnified against all claims, actions,
proceedings, demands, cost, damages and expenses whatsoever which the
purchaser may be put to by reason of any defect in title or breach by the vendor
of any of the covenants, assurances and representations contained herein.
7. The Vendor shall at all times at the request of, and at the cost of, the purchaser
execute and cause to be executed and registered and do all such acts, deeds and
things as may reasonably be required of him for further and better assuring the
schedule mentioned property or any part unto and to the use of the purchaser.
8. The vendor has no objection to the rights and liberties he had with Electricity
Board including Security deposits and interest accrued thereon being transferred
 and credited in favour of the purchaser; so too he has no objection to mutation in
the field record maintained by Revenue Department and in the assessmentnt
register maintained by municipality and other public department recognising the
purchaser as owner of the property hereby conveyed.

ln witness whereof the vendor has set his hand and seal on the day and year first above-
written and in the presence of witnesses :

1) Sh shyam lal , s/o mohan lal, r/o Buudha colony, B6, Patna Sd_
2) Sh Rohan verma, s/o Sohan Verma, r/o Buddha colony, B55,Patna seller
Sd-
purchaser