Scribd Logo
Upload

Welcome to Scribd!

  • 15 views

    Grey Matters Vs Sushil Reply of Applicaton

    Uploaded by

    raj

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Grey Matters Vs Sushil Reply of Applicaton

    Uploaded by

    raj
    15 views4 pages

    Original Title

    Grey Matters Vs Sushil reply of applicaton

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    15 views4 pages

    Grey Matters Vs Sushil Reply of Applicaton

    Uploaded by

    raj

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 4

    IN THE HON’BLE COURT OF SH.

    SIDDHANT ROYAL,
    LD. CIVIL JUDGE, (JUNIOR DIVISION), JAGADHRI
    ----
    CS/1812/2024

    Grey Matters English Academy --Plaintiff

    VERSUS

    Sushil Arora & Ors. ---Defendants

    SUIT FOR RECOVERY OF Rs.1,92,000/- ALONGWITH


    INTEREST @ 18% PER ANNUM UNDER ORDER XXXVII
    (37) OF THE CIVIL PROCEDURE CODE, 1908.

    REPLY TO THE APPLICATION FOR SEEKING


    LEAVE TO DEFEND FILED BY THE DEFENDANTS

    R/Sir
    The plaintiff/respondent most humbly and
    respectfully submits as under:-
    PRELIMINARY OBJECTIONS:-
    1. That the present application of the
    applicant/defendant is not maintainable.
    2. That the above mentioned reply is part and parcel to
    the application filed by the applicants/defendants.
    3. That the applicant/defendant has no legal grounds as
    whole of the ingredient of Order XXVII Rule 2 of CPC
    has been fulfilled by the plaintiff/respondent and the
    defendant has no locus standi to file the present
    application against respondent/plaintiff. The present
    application is only an abuse of process of law.
    4. That the full copy of the plaint along with annexures
    was itself received by the advocate of the defendant on
    2

    last date 17.07.2024 in the court itself, hence, their


    claim of non receiving is completely frivolous.
    5. That the defendant seeks to submit following
    preliminary objections each of which has been taken in
    alternative and is without prejudice to the other,
    nothing contents in the preliminary and in the reply on
    merits bellow may unless otherwise specifically
    admitted, be deemed to be direct and tacit admission
    of any allegation made by the defendant/applicant in
    the present application.
    ON MERITS:-
    1. That the contents of para No.1 of the application as
    stated are admitted being matter of record.
    2. That the contents of para No.2 of the application as
    stated are wrong and hence denied. As the copy of the
    whole plaint was itself received by the advocate of the
    defendant in the court itself on 17.07.2024. Moreover,
    there is no defence with the defendant, so that they can
    surpass requirement of Order XXXVII Rule 2 of CPC.
    The purpose and intent of the legislature was to provide
    summary suit specially in matters where the
    agreement is the core of the matter. The defendant did
    not have single iota of evidence to support their claim
    and the purpose fully application filed by them is mere
    eye wash just to derail the core purpose of above Order
    XXXVII Rule 2 CPC.
    3. That the contents of para No.3 of the application as
    stated are wrong and hence denied in toto.
    That the contents of prayer clause as stated are
    wrong and hence denied and in view of the above
    3

    mentioned facts and circumstances, the application of


    the applicant/defendant is not maintainable and is
    liable to be dismissed with heavy costs.
    It is, therefore, prayed that the present
    application of the applicant/defendant may kindly be
    dismissed with heavy costs in the light of above
    mentioned facts, in the interest of justice.

    Verification Respondent/plaintiff

    Verified that contents of reply Grey Matters English


    of the application are true and Academy, SCO-37-38,
    correct to best of our Sector17C, Chandigarh,
    knowledge and belief. represented through its
    authorized signatory Mr.
    Verified at Sonepat Devanshu Goel
    On
    Through Counsel
    4

    IN THE HON’BLE COURT OF SH. SIDDHANT ROYAL,


    LD. CIVIL JUDGE, (JUNIOR DIVISION), JAGADHRI
    ----
    CS/1812/2024

    Grey Matters English Academy --Plaintiff

    VERSUS

    Sushil Arora & Ors. ---Defendants

    SUIT FOR RECOVERY OF Rs.1,92,000/- ALONGWITH


    INTEREST @ 18% PER ANNUM UNDER ORDER XXXVII
    (37) OF THE CIVIL PROCEDURE CODE, 1908.

    Affidavit in support of Reply to the application for


    seeking leave to defend filed by the defendants

    I, Mr. Devanshu Goel, authorized signatory of Grey


    Matters English Academy, SCO-37-38, Sector17C,
    Chandigarh, do hereby solemnly affirm and declare as
    under:-
    1. That the deponent has filed the above noted reply to
    the application filed by the defendant, which is most likely
    to succeed on the grounds mentioned in the reply to the
    application and contents of the same are true and correct
    as per my knowledge, though the same are not being
    repeated here for the sake of brevity and to avoid
    repetition, which also may kindly be read as part and
    parcel of this affidavit.

    Deponent
    Verification: Verified that the contents of the above
    affidavit are true and correct to the best of my knowledge
    and belief. Nothing has been concealed therein.

    Verified at Jagadhri On:


    Deponent

    You might also like