V A K A L A T N A M A

IN THE COURT OF THE HONBLE SUBORDINATE JUDGE OF KRISHNAGIRI

O.S. No. Of 2018

ICICI Bank Limited, Krishnagiri

Rep by its Authorised signatory
…. PLAINTIFF
-Vs-

1. Nandini Magalir Mandram,

1/184, Balingayakanohalli,
Krishnagiri 635 106

2.Rani M
1/184, Balingayakanohalli,
Krishnagiri 635 106

3.Ananthi A,
1/186/179, Balingayakanohalli,
Krishnagiri 635 106
...DEFENDANTS

We the undersigned do hereby appoint and retain

M/s The CK Legal Services,

S.C.KANNAN B.A.B.L.,
H.SEKARAN B.A.B.L.,
K.NIVEDHA B.A.B.L.,
Advocates,
G8 Saradha Kripa, Sivanandha Colony,
Coimbatore 641012

to act and plead for me / us in the above matter and on my / our

behalf to conduct and prosecute ( or defend ) the same and all
proceedings that may be taken in respect of any application connected
with the same or any decree or order passed therein and application
for receive money on my / our behalf in the said matter and in
applications for review, and to represent me / us and take all necessary
steps on my / our behalf in the above matter and also to compromise
the above matter on such terms and conditions as the said advocate
(s) may think just and proper in my / our interest. The said Advocate
(s) When he / they is / are unable to remain present for any reasons
will be entitled to give proxy to any Advocate (s) of his / their choice. I
/ We agree to rectify all acts done by the aforesaid Advocate (s) in
pursuance of this authority.
Dated this __________________ day of _________________ 2018

Executed before me on02.08.2014 at Krishnagiri

ADVOCATE
 IN THE COURT OF THE
HONBLE SUBORDINATE
JUDGE OF KRISHNAGIRI

O.S. No. Of 2018

ICICI Bank Limited,

Krishnagiri
Rep by its Authorised
signatory

…. PLAINTIFF
-Vs-

1. Nandini Magalir
Mandram,
2. Rani M
3. Ananthi A,

….DEFENDANTS

VAKALATNAMA
FOR PLAINTIFF

Accepted
 A/s:

M/s The CK Legal Services,

S.C.KANNAN B.A.B.L.,
H.SEKARAN B.A.B.L.,
K.NIVEDHA B.A.B.L.,
Advocates,
G8 Saradha Kripa,
Sivanandha Colony,
Coimbatore 641012
0422-4971199

IN THE COURT OF THE HONBLE SUBORDINATE JUDGE OF KRISHNAGIRI

O.S. No. Of 2018

ICICI Bank Limited, Krishnagiri

Rep by its Authorised signatory
…. PLAINTIFF
-Vs-
1. Nandini Magalir Mandram,
2. Rani M
3. Ananthi A,
….DEFENDANTS

PLAINT FILED UNDER ORDER VII RULE 1 OF CIVIL PROCEDURE CODE

1. PLAINTIFF:-

The Plaintiff is M/s. ICICI Bank Ltd, a Banking company, within

meaning of the provision of Banking Regulation Act, 1949 and incorporated
under companies Act 1956 having its registered office at Land Mark Race
Course Circle, Vadodara 390 007 represented by its Manager and
Authorised Signatory having its branch office at Krishnagiri.

The address for service off all notices and process on the Plaintiff is
that of his counsel M/s The CK Legal Services, S.C.KANNAN, H SEKARAN,
K.NIVEDHA, G8 Saradha Kripa, Sivanandha colony, Coimbatore 641012.
Phone: 04224971199.
2.DEFENDANTS:

1.Nandini Magalir Mandram, having its office at 1/184,

Balingayakanohalli,
Krishnagiri 635 106

2.Rani M, full age, residing at, 1/184, Balingayakanohalli, Krishnagiri

635 106

3.Ananthi A, full age, residing at 1/186/179, Balingayakanohalli,

Krishnagiri 635 106

The address for service of all notices and processes on the Defendant is
same as stated above.

3.The Plaintiff submits that it is a Banking company, carrying on the

business of providing financial assistance to their prosperous customers in
various type of loan personal, housing, and vehicle, agricultural, self help
group micro company… etc. The Plaintiff introduced financial assistance to
the self help group for purpose of developing the rural areas and villages.

-2-
4.During the course of its business, the borrowers are the Defendant herein,
approached the Plaintiff for seeking financial facility to develop their self
help group activities.

5.The Plaintiff believing the statements, in pursuance of the application and

in consideration of the Bank/Plaintiff, having extended the loan facility to
the borrowers/defendant, hereby agreed, confirmed and undertake to repay
the availed loan facilities, all interest, commission, charger, taxes, duties,
levies cost, expenses and all other monies.

6.The Plaintiff states that after production of all the necessary documents,
the plaintiff and defendnants executed the loan bearing number
L9KRG00034571187 on 13.07.2016 and to be bonafide and believing the
statement, the Plaintiff sanctioned the said loan facilities to the Defendant
for a sum of Rs.6,25,000/- (Rupees Six Lakh Twenty Five only) amount
financed & disbursed under the said agreement, the said loan amount has
to be paid without any delay or default, whether previously demanded or not
on or before 24 months from the date of finance. If failed to pay the
installment regularly the defendants are jointly or severally liable to pay
interest, penalty, charges, late fee, expenses etc as agreed.

7.On the contrary, the defendants failed to repay the loan amount as
promised by the terms and conditions. Even after repeated demands made
by the Plaintiff to repay the pending amount but the Defendants simply
refused and evade repaying the same. Then, the Defendants had turned out
to be a chronic defaulter. The Defendant is still overdue to the extent of
Rs.4,89,819/- (Rupees Four Lakh Eighty Nine Thousand Eight Hundred
Nineteen only)

8.The Plaintiff states that as per regular course of business accounts a sum
of Rs. 4,89,819/- (Rupees Four Lakh Eighty Nine Thousand Eight Hundred
Nineteen only) is outstanding against the Defendant towards pending of
overdue amount, which the Defendants had failed and neglected to pay in
spite of the Plaintiff’s repeated demands. The Loan Recall Notice dated
19.02.2018 may be marked as ExA1; Account Statement may be marked as
ExA2; legal notice dated 17.06.2018 sent to the defendants may be marked
as ExA3; and the said Legal notice sent to the defendants were returned as
“Addressee Left” may be marked as ExA4;
 -3-
9.The Plaintiff states that the Defendant never bothered to repay the dues
and neglected to repay willfully with the ulterior motive. The Plaintiff reliably
understand that the borrower is not willing to pay the amount due as per
terms and conditions and trying to evade or escape from clutches of law.
The act of borrower amounts to absolutely breach of contract also.

10.The Cause of Action for the suit arose at Coimbatore within the
jurisdiction of this Hon’ble court where the loan agreement was executed at
Coimbatore.when and where the loan facility was sanctioned and disbursed
at Coimb atore on various dates when the defendant repaid some amount.
The Plaintiff restricted suit claim amount Rs. 4,89,819/- (Rupees Four Lakh
Eighty Nine Thousand Eight Hundred Nineteen only)

11.The suit is valued for the purpose of court fee and jurisdiction at Rs.
4,89,819/- (Rupees Four Lakh Eighty Nine Thousand Eight Hundred
Nineteen only) and pays the court fee to sum of Rs……….. /- under section
22 of Tamil Nadu Court Fees and suit Valuation Act.

12. The Defendant may be directed to produce all relevant documents

pertaining to the suit transaction at the time of trial. The Plaintiff therefore
prays that this Hon’ble Court may be pleased to pass a decree and judgment
directing the Defendant.

a) To pay the Plaintiff sum of Rs. 4,89,819/- (Rupees Four Lakh Eighty Nine
Thousand Eight Hundred Nineteen only) for Loan No:
L9KRG00034571187 with subsequent interest at 18% per annum from
the date of filing the suit till the date of realization;

b) To pay the Plaintiff costs of the suit and

c) To grant such other relief or reliefs as may be deemed fit and proper in
the circumstances of this case and thus render justice.

Dated at Krishnagiri on day of July 2018

PLAINTIFF COUNSEL FOR
PLAINTIFF

VERIFICATION

I,___________, Manager and Authorised signatory of M/s. ICICI Bank

Limited, and the Plaintiff above mentioned do hereby verify that the
statements made by me in above paragraphs are true to the best of my
knowledge, belief and information.

Verified at krishnagiri on th
day of July 2018

PLAINTIFF
-4-

LIST OF DOCUMENTS FILED UNDER ORDER VII RULE 14 [1] OF C.P.C

S.No Date Description of Document Parties Status

1 16.09.2017 Loan Recall Notice Plaintiff and Office copy
Defendant
2 17.06.2018 Legal Notice Plaintiff and Office copy
Defendant
3 13.07.2018 Legal notice send to the Defendant Original
defendants was returned as
Addressee Left

Dated at krishnagiri on th
day of July 2018

COUNSEL FOR PLAINTIFF

STATEMENTS OF ADDRESS FURNISHED UNDER ORDER VI RULE 14[A]

OF CIVIL PROCEDURE CODE
S. No. Rank of parties Address
Plaintiff ICICI Bank Limited, Coimbatore,Rep by its
1. Authorised signatory
Plaintiff Counsel Address :

M/s The CK Legal Services,

S.C.KANNAN B.A.B.L.,
H.SEKARAN B.A.B.L.,
K.NIVEDHA B.A.B.L.,
Advocates,
G8 Saradha Kripa, Sivanandha Colony,
Coimbatore 641012
0422-4971199
2. Defendant 1. Nandini Magalir Mandram,
1/184, Balingayakanohalli,
Krishnagiri 635 106

2. Rani M
1/184, Balingayakanohalli,
Krishnagiri 635 106

3. Ananthi A,
1/186/179, Balingayakanohalli,
Krishnagiri 635 106

PLAINTIFF COUNSEL FOR

PLAINTIFF

-5-

VALUATION REPORT FILED BY THE PLAINTIFF

Relief asked for Recovery of amount due

Sec and Sub Sec of the C F Act Sec 22 of C F Act

Market Value or Annual Rent Nil

Relief Valued at Rs.4,89,819/-

Court fees Paid at Rs. /-

COUNSEL FOR PLAINTIFF

VERIFICATION
I, __________, Manager and Authorized signatory of M/s. ICICI Bank Limited,
and the Plaintiff herein above hereby verified that the above mentioned
statements are true to the best of my knowledge, belief and information.

PLAINTIFF
 IN THE COURT OF THE
HONBLE SUBORDINATE JUDGE
OF KRISHNAGIRI

O.S. No. Of 2018

ICICI Bank Limited, Krishnagiri

Rep by its Authorised signatory

…. PLAINTIFF
-Vs-

1.Nandini Magalir Mandram,

2. Rani M
3. Ananthi A,
,
….DEFENDANTS

PLAINT FILED UNDER ORDER

VII RULE 1 OF CIVIL
PROCEDURE CODE

Pre-on:
Counsel for Plaintiff

M/s The CK Legal Services,

S.C.KANNAN B.A.B.L.,
H.SEKARAN B.A.B.L.,
K.NIVEDHA B.A.B.L.,
Advocates,
G8 Saradha Kripa,
Sivanandha Colony,
Coimbatore 641012
0422-4971199
 IN THE COURT OF THE
HONBLE SUBORDINATE JUDGE
OF KRISHNAGIRI

O.S. No. Of 2018

ICICI Bank Limited, Krishnagiri

Rep by its Authorised signatory

…. PLAINTIFF
-Vs-

1.Nandini Magalir
Mandram,
2. Rani M
3. Ananthi A,
….DEFENDA
NTS

Document. No.
Filed by plaintiff

Pre-on:
Counsel for Plaintiff

M/s The CK Legal Services,

S.C.KANNAN B.A.B.L.,
H.SEKARAN B.A.B.L.,
K.NIVEDHA B.A.B.L.,
Advocates,
G8 Saradha Kripa,
Sivanandha Colony,
Coimbatore 641012
0422-4971199