IN THE COURT OF MS" VANDANA, ADJ, CENTRAL

TIS HAZARI
couRÏ DELHI

CS No. 1330 I 2023

IN E RO F:

Plaintiff
lnderjeet Kaur
Versus
.. Defendants
Harvinder Kaulr & Crs
INDEX

Farticulars Pages
S. no
\ u
1 Written statement on behalf of defendants \'-

With affidavits

2 List of Documents with documents \ã- Ltq'-YÐ

Through

Dated:

Kun ta
Advocate
7, Gandhi Market
Minto Road, New Delhi-1 10002
Ph. No. 9871028645
 IN THE HON'BLE COURT OF DISTRICT AND SESSION JUDGE,
CENTRAL, TIS HAZARI COURTS DELHI
Civil Suit No, 12023

IilI THE MATTER OF.-

INDERJEET KAI..,¡R ... PLANINTIFF

VERSUS
Harvinder Kaur &Crs
DEFENDANTS

WRITTEN STATEMENT ON BEHALF OF DEFENDANT hlo. 't & 2

MOST RESPECTFULLY SHOWETH

PRELI Ml NARY OBJ ECTIONS : -

1. That the plaintiff has not complied the last order passed by this

Hon'ble Court whereby the plaintiff was directed to supply the

complete set of the paper book to the defendants so that the

written statement can be filed, however, without prejudice to the

rights and contentions defendants is filing the written statement

with incomplete documents

2. That the present suit of the plaintiff is without any cause of action

and the same is liable to be rejected on this ground alone

3. That the present suit as framed by the plaintiff against the

defendants is not maintenance as there is no cause of action in

 the
favour of the plaintiff and against the defendant therefore

present suit is liable to be rejected under order 7 rule 11 cpc'

the
4. That the plaintiff has no locus standi to file the present suit as

father of the respondent had already executed the registered

wlLL whereby he has bequeath shop at ground floor and first

ground floor and
floor in favour of defendant No.2 and shop at the
of the
third floor in favour of the defendant No.1 and second floor

property was bequeath to the plaintiff. lt is important to mention

upon
that property has been partitioned and will has been acted
making
and all the parties are in their respective portion and also
The copy
the payment of the house tax of their portion separately'

of registered will and house tax receipt is attached herewith.

5. That the plaintiff has concealed the material fact from this Honble
will
court and has filed the present suit concealing the registened
the grab
executed by the father of the parties. That plaintiff under

of present suit has malafide intentlon to usurp the share of the

of
answering defendants who have inherited the same by virtue

the registered will. That plaintiff is irr habit of harassing and

father
threatening the defendants. That during the lifetime of the
of
plaintiff used to harass him as well for the property. That father
the
the answering defendant has filed criminal complaint against

plaintiff and has revealed in the said complaint about the will
 3
that the plaintiff has
executed by him. lt is important to mention

noright,title,orinterestinthepropertylocatedatShop'43'
GandhiMarket,MirDardRoad,NewDelhi-110002except
second floor of the same"

6" That the plaintiff has concealed

the material facts from this

lron,blecoudandhasnotcomewithcleanhands.Theitis
hid substantial fact
pertinent to mentioned that the plaintiff have
between all the legal hiers
that the property is already distributed

oflateHarbhajanSinghaSpertheregisteredWILLwhichis
son and daughters'
execute by the father in favour of their
plaintiff did not stop there; they
7. That the illegality on behalf of the
obstructed the respondent in
also threatened the respondent and
these threats and
the functioning of the shop. Pursuant to
obstructiontousetheproperty,therespondentshavefileda
complaintagainsttheplaintlffon2lstSeptember2023'
ptaintiff is based upon a
8. That the present suit filed by the

commercialdisputeaSthesuitpropertyisshopinthe
for commercial purpose
commercial area and the same is used

and is governed by the commercial

courts, commercial Division

andCommercialAppellateDivisionofHighCouttAct'2015,
thereforethepresentordinarysuitisnotmaintainable.
9. That the present suit as filed by the plaintiff is deficient in terms

of order 6 Rule 15(A) of Code of Civil Procedure herein referred

to as The Rule as amended by the Commercial Courts,

commercial Division and Commercial Appellate Division of High

Court Act, 2015, the Rule is reproduced herein

"''154. Verification of pleadings in a commercial dispute: -

(1) Notwithstanding anything contained in Rule 15, every

pleading in a commercial dispute shall be verified by an affidavit

in the manner and form prescribed in the Appendix to this

Schedule

(2) An affidavit under sub-rule (1) above shall be signed by the

party or by one of the parties to the proceedings, or by any other

persoi'r on behalf of such party or parties who is proved to the

satisfaction of the Court to be acquainted with the facts of the

case and who is duly authorized by such party or parties

(3)Where a pleadlng is arnended, the annendments must be

verified in the form and manner referred to in sub-rule (1) unless

the count orders othen¡¿ise

(4)whene a pleading is not verified in the manner provided under

sub-rule (1), the party shall not be permitted to rely on such

pleading as evidence or any of the matter set out therein

 L)

by a
(5)The court may strike out a pleading which is not verified
Appendix
statement of Truth, namely, the affidavit set out in the

to this Schedule-|"

It is submitted that the suit filed by the plaintiff is

not in conformity

with the Rules and in light of sub-rule 4 and 5 of the

Rule the

suit must be struck off the record'

10. That as per section 27 of CPC read with order 5 rule 1 CPC'

the commercial court could have issued summon to the

defendant only when the suit was duly instituted' That

the suit

section
duly instituted has to be comply with the requirennent of
provides the
26 (2) CPC as amended by the Act of 2a15 which
6 rule
form and the manner of an affidavit required under order
is order 4
15 A that corresponding provisions of section 26 CPC

rule 1 CPC which deals in instittltion of the suit start with

the

heading "Suit to be commenced by plaint"' Further order

4 rule

deemed
1(3) CPC specifically provides that the plaint shall not be

to be duly instituted unless it complies with requirement specified

plaint
in sub-rule 1 and 2. That sub-rule 2 provides that every

shall comply with the rules contained in order 6 and 7 CPC'

ln

order to a suit to be "duly instituted" the affidavit in the form

and

Court
manner provided under order 6 rule 15 A of Commercial

Act is mandatory requirement to be filed as per the condition

I

inserted in clause 2 of section 26 CPC by adding proviso under

the Act of 2015.

11. That the heading of Rule 15(A) of order 6 states verification

of pleadings in commercial disputes and the Rule 1 of Rule 15(A)

start with "Non-obestante Clause" by providing that every

pleadings in the commercial disputes shall be verified by an

affidavit in the manner and the form prescribed in the appendix

to the schedule, in the present case plaint admittedly did not

contain the prescribed affidavit, therefore, the said suit cannot be

said to be "duly instituted", therefore the said suit is liable to be

dismissed.

12. That lt rs submitted that section 12Aof commercial coutrAct

provides pre-institution mediation and settlement. The same

provides that the suit under the Act cannot be executed without

exhausting of the remedy of pre-institution mediation in the

present case. The said mandatory provision l'ras not been

complied with. Tlrerefore the suit could not have been instituted

properly, therefore, the present suit is liable to be dismissed' That

no cogent reason has been given by the plaintiff as to why pre-

institution mediation has not been followed. That the present suit

is liable to be dismissed on this ground alone. That the present

 suit is bad in law and the same has been filed concealing the

above fact, therefore the same is liable to be rejected

13. That the suit of the plaintiff as framed is not maintainable

under section 41(i) of Specific Relief Act, as the plaintiff has

concealed the material facts from this Honble court and have no

night, title and interest in the suit property and conduct of the
plaintiff are apparent as stated above ,which disentitle them for

injunction, which is the disøetionary relief, therefore the present

suit is liable to be dismissed on this ground as well

14" That the present suit filed by the plaintiff is barred by law as

the plaintiff under the garb of the present suit is seeking the
partion of the leasehold property which is not maintainable.

15, That the plaintiff has no locus standi to file the present case

as suit property has already been partition by virtue of registered

will, therefore the present suit is liable to be dismissed as become

infructuous,

16. That the present suit filed by the plaintiff has not been properly

valued for the purposes of court fee and jurisdiction and proper

courl fee has not been paid. lt is submitted that the plaintiff has

filed the present suit for partition with consequential relief of

partition, therefore, the plaintiff is liable to pay the ad-valorem

courl fee as laid by Hon'ble Supreme Court of lndia in case titled

c}
as "suhrid singh @ sardool singh Vs. Randhir singh & ors'"

20rc (12) SCC 112.That the coutt fee is to be calcq.llated on ad-

valorem basis in accordance with section 7 (a) of the court Fees

'1953 extended to Delhi
Act added by Punjab Amendment Act,

vide notification dated 21.07 .1959. The same is reproduced

hereinabove:-

"Frovided further that in the suit coming under sub-clause (c) in

cases where the relief sought is with reference to any properfy
such valuation shatt not be less than the value of the
properfy
calculate d in the manner provided for by clause (v) of fhrs secf
ion'"

That as per clause (v), the suit shall be valued on the market value
fee
of the property and the court fee shall be paid ad-valorem court

on such value, however, in the present case, the suit has neither
paid' lt is
been properly valued nor the proper coutl fee has been
the
further innporlant to mention that the plaintiff has neither valued

relief of partition on the nnarket value nor the proper couft fee
has

payment of
been paid. That the plaintiff is also liable to nrake the
value
requisite court fees on the consequential rellef on the rnarket

of the propedY.

S REPLY

As to the para No.1 The content of this para is wrong and denied'
lt
1.
is submitted that the plaintiff is in habit of harassing the
defendants'
 ?
2 AS T0 The Para No. 2 & 3 The contents of this para, are a matter of
record and hence need no reply. however, everything and anything

which is beyond the knowledge and record is denied in totality.

3. AS T0 The Para No. 4 That the content of the said para are false
and frivolous hence denied in totality. lt is denied that the father of the

respondent only constructed first and ground floor of the suit propefty

and the plaintiff constructed second floor of her own fund, lt is

subrnitted that it is clearly nnentioned in the WlLl-, executed ln the

year 2016, that the second floor was given in favor of the plaintiff and

the third floor was given to the Respondent no.1, indicating that the

allocation of floors was already determined. This demonstrates that

the floor allocation was established, and the plaintiff is making false

assertions without any substantial proof. lt is submitted that the

second and third floor was constructed at the same time long back

and the said fact is establish from the photographs of the roof of the

property which show the construction is old. Needless to state that

third floor of the property was got constructed from the funds of

defendant No.1.

4. AS T0 The Para No. 5 That the content of the said para are false

and frivolous hence denied in totality. lt is denied that Shri late

Harbhajan singh died intestate on 18-03-2023, leaving behind the

Plaintiff and the Defendant's No.1 & 2 as their legal heir. lt is

 submitted that the father of the plaintiff and the respondent had

executed a will in favor of both parties. However, the plaintiff

expressed dissatisfaction with the will and began harassil'lg the

defendants.

4. AS T0 The para No. 6 That the content of the said para are false

and frivolous hence denied in totality. lt is denied that after the death

of the parents of the Plaintiff and defendant the suit property is

inherent by the plaintiff jointly as co-parceners and the defendant. it

is further denied that the third floor of the above said propefty as

earlier has joint possession on the above said property. it is denied

that the defendant no.1 is residing and have one shop run by the

defendant no.1 and has access to entrance and exit for all legal heirs.

It is denied that being a legal hire of the parents plaintiff is entitle to

equal share in the property. The father of parties has executed the
,will whereby deceased has bequeath the property to the atl thnee

children as stated above. lt is denied that plaintiff used to install Kiosk

selling aftificial jewellery with her brother. lt is submitted that the

plaintiff is in possessiol'l of second Floor of the suit property as per

the registered Will. lt is important to mention here that the plaintiff is

not in the joint possession of the third floor of the property. lt is

subrnitted that the plaintiff failed to show any documents that she was

ever in the joint possession of the property. lt is important to mention

 \\
pertains
here that entire documents placed on record by the plaintiff

to second floor of the property which she has inherited by the virtue

of the WILL.

5. AS T0 The Para No. 7 That the content of the said para are false

and frivolous hence denied in totality. lt is denied that the

plaintiff has

already conveyed her in:ention so many times to parlition the above

mentioned property bearing no. H.No' 43, Gandhi Market, Mir Dard

Road, New Delhi-110002. and finally on 3-10-2023 to the defendant

No.1 & 2, but the defendant have not pay heed to the request of the

plaintiff. lt is further denied that plaintiff want to seek the partition of

the property for legal rights of her share 1l3rd share in the above said

property by metes and bounds with the defendant so that one can

use the properly in her own way without any intervention. lt is

submitted that plaintiff has inherited only second Floor of the suit

property which she is enjoying and she further has no right, title or

interest in any portion of the suit property'

6. AS TO The Para No. I That the content of the said para are false

plaintiff is
and frivolous hence denied in totality. lt is denied that the

receiving continuous threats from the defendant and the Plaintiff

is

party
having apprehension that the defendant may create any third
property' It
interest in the suit property by selling of alienating the suit
that
is further denied that the plaintiff has revealed from the source
\
the defendant with rnalafied and bad intention is trying to dispossess

the plaintiff illegally and forcibly and wanted to sell the property as

mentioned above with the help of gundas and police personals. lt is

submitted that the plaintiff is trying to mislead the court by making

false averment without giving any substantial proof.

T . AS T0 The Para No. 9 That the content of the said para are false
and frivolous hence denied in totality. lt is denied that the plaintiff has

sent a legal notice dated 0611012023 through her counsel to the

defendant and the said legal notice has been duly served to the

defendant at their respective address. it is submitted that no legal

notice on behalf of plaintiff has been received by the defendant'

g. AS T0 The Para No. 10 That the content of the said para is false and

frivolous hence denied in totality. it is denied the act of defendant are

totally illegal unlawfully unwarranted and agalnst the ;[aw. lt is

subnritted that each defendant and plaintiff is in possession of the

property of his respective share as per the Will.

g. AS T0 The Para No. '11 That the content of the said para are false

and frivolous hence denied in totality. lt is denied that the plaintiff has

filed any complaint dated 17t10123 in the nearby police station but

no action has been taken so far. Rest of para is wrong and denied.

10. . AS T0 The Para No. 1 2- 13That the content of the said para are

false and frivolous hence denied in totality. it is submitted that the

 fr\
!-)
plaintiff is making false statement without any cause and substantive
paras and the
evidence. Detail reply has been given in the aforesaid

same may be read as part and parcel to the para under reply'

para are
11. AS T0 The para No. 14 That the content of the said
the
false and frivolous hence denied in totality. the plaintiff against

defendants ls not maintainable as there is no cause of

action in

the
favour of the plaintiff and against the defendant therefore

present suit is liabke to be rejected under order 7 rule 11 cpc'

12. AS T0 The Para No. 15 TO 17 That the content of

the said paraare

suit is not
false and frivolous hence denied in totality that the present
nor made
maintainable as the plaintiff neither valued the suit [properly
is liable
the payment of requisite court fees, therefore the present suit
plan
to be rejected on this ground alone. lt is submitted that the site
given in the
filed by the plaintiff is incorrect. Detail reply has been
parcel to the
aforesaid paras and the same may be read as part and

para under rePlY.

CLAUSE ARE
IN VIEW OF THE ABOVE SUBMISSION THE PRAYER

CONTRAVERTED
i\
prayer clause is controverted. The same are denied being
above'
wrong, false in view of the submissions as stated

For the foregoing, it is most respectfully prayed that

this

the suit
Hon'ble court may graciously be pleased to dismiss

under reply as being an abuse of process of this

Hon'ble

Court'Thedismissalofsuitmayalsoaccompanyan
discourage
innposition of exemplary cost in an endeavour to

such frivolous and fragile litigation' Defendants

i ,
^ Á .l/
:H'-lYsi\*Åú Wu,t¿'z-

Delhl Through

Dated
n lra
Advocate
7, Gandhi Market
Minto Road, New Delhi-1 10002
Ph. No. 9871A28645
VE FI

verified at Delhi on this day of May, 2024 that the contents of

'1 la trZ of the reply on nnerits are tru¡e and correct

to my
paras no.
preliminary objections
knowledEe and those of Paras no 1 to 15 of the
and co¡'rect on the
and paras 13 to 17 af the reply on merits are true

basis of infor¡'nation received and believed to be

true' Last para is

prayer before this Hon'ble Court' ¡*¿

I ¿ ê il'/
V/dvt,ih,eÅÐ*f-el'w-
Defendants
 a#-
f\

INTHEcoURToFMS.VANDANA,ADJ,CENTRALTISHAZARI
COURT, DELHI

GS No. 1330 I 2023

IN TH MATTE RO F:

Plaintiff
lnderjeet Kaur
Versus
Defendants
Harvinder Kaur & Ors

ajan Singh r/o 1ST

New Delhi-11 0002,
Floo
doh
the above noted
1
he case and as such

has been drafted bY my

2. That the accomPanYing Written Statement
the same has been understoo d
counsel under mY instructi ons an d
and the same ts not
bymeinmYv ernacular whic h is correct the same may be read
but
repeated here in for the sake of brevitY
rt and Parcel o f this affidavit'
I
Þ.
qH \t

ä1.1'

a,t. Uì
.'t
ÄÊt. -i - Lt t
i,]
i{. j
tteg'*
:õiÙ6 Deponent
i - l" t \r r ".
o ''' ,'
.',1, - *: - i

4 that the contents of

Verified at Delþt,,9 opa rt of it is
a
bove affidavit a tt
and nothing il
i,.l+¡';'iii'Ìr¡ Ì l,v "$ nen t
,: ¡ i.: :; :,:r i: I
.i.: l, ; : r: Ì -lj

..:,:Ì!ij í )i:ri; ri Üaì',"'"

i i ;,rt ii: Lì, l-: ¿:rt;i,¿i i¡ S
g¡*
.¿..ét\ lf Êlìi;'
fr¡.'!t *,{€ {r'¡¡ç*
t..,':ll ].-
1

ffi
-- -r..r '.$ l.*
',ij:ì::-¡'-È'

p ð'{Á? ?fl";d \:i;ìisfu:

14 fz+
 Jk
IN THE GOURT OF MS. VANDANA, ADJ, CENTRAL
TIS HAZARI
couRÏ DELHI

CS No" 1330 I 2023

IN THE MATTER OF:

Plaintiff
lnderjeet Kaur
Versus
Defendants
Harvinder Kaur & Ors
AFFID AVIT

rlo 3-'d
l, Harvinder Kaur age 49yrs. d/o Lgte sh. Harbhajan singtr
Floor, Shop No.43, Canðnl Market, Mir Dard Road, New
Delhi-1''10002'
do hereby solemnly affirm and declare as under:
case and
1 . That the deponent is defendant no.1 in the above noted
is well conversant with the facts of the case and as
such
competent to swear the present affidavit'

2'ThattheaccompanyingWrittenstatementha s been drafted

bY rny
understood
counsel under my instructions and the sa me has been
is not
by me in mY vernacular which is correct an d the same
be read
repeated herein for the sa ke of brevity but the same may
art and parcel of this a ffidavit

,¡i ì
'!1" ËPl'
,.',r,r!
' '
^¿
i.;þì r' UI

l-.
l\e iL^..
.:
!\u
;r,:ih
'q.i I !iA
i*
Jiwri vá*u'þ¿*^e-
Deponent

ATIO ä I ru-4y 3û?d

Verified at Delhi on this day of MaY, 2024 that the contents of
b ve affidavit are' {çusr-âH
dnopa rt of it is
â m

"¡;t;iir"iî.Ë
Deponent
¡ç¡g¿!

qyvf w,{ø
W"-,."2-

æ
'ì
fl4-q-r ?ü?4 +.!fltR{ir
iwr+
 \k
r)
IN THE COURT OF MS. VANDANA, ADJ, CENTRAL
TIS HAZARI
COURT, DELHI

CS No" 1330 I 2023

IN TH MATTEB g F:

Flaintiff
lnderjeet Kaur
Versus
Defendants
l-{arvinder Kaur & Ors
LIST OF DOCLJMENTS

1 Copy of registered Wilì

2 Copy of complaint dated 13'07 '2A22
3 Copy of complaint date d 21 '09 '2023
4 Copy electricitY Bill
5 CopY of House tax receiPts
6 Copy of letter dated 14'05'2024
7 PhotograPhs

Dated
a ra
Advocate
7, Gandhi Market
Minto Road, f'lew Delhi-1 10002
Ph. No. 9871028645
 \ryILL

r&
kl i.

)P&ç
will is made at Delhi, on l" iS i?or¿ gy SH.
card no. 928214747734 S/O LATE KISITAN
S
MARKET, MIR DARD R.OAD NEW DELHI.11O

Life is short and god knows when it may come

to an end. At present ;* .p{í q,ouoo,
health and disposing mind. I fuily understand -14,
that what is right and wrong. I make
the
following WILL in order to avoid any litigation
and unpleasantness after my death.

WHEREAS I am absolute owner and in possession

of a built up property bearing no. 43,
G.AryDHr À{ARIgTr..MrR p4np ROAD,
rytn{To Bp-åp2 NE1V DELrr r-ttÐ002,,
fltting with electriciQr meter, water connectionrianitary -. :':1-N"r''ì"
fitting fixtures etc.

And whereas after my demise/death my above

said property shall be divided in following
manners between my foll owing legal
heirs/b enefi ciaries _ :

o one shop on Ground Floor, and Entire first

floor of the said property shall go to
in favour of my son MR. YASH pAt SINGH
s/o sH. TTaRBTIAJAN SINGIT
R/o H'No' 43, GANDHI MARKET, MIR DARD
ROAD NEw DELHI-
lßa02.
' Entire second floor of the said property shali
go to in favour qf my Daughter
SMT. INDER JEET KAUR W/O LATE HARVINDER
SINGH R/O I{.NO, 43,
cANDrrr MARKET, MrR DARD ROAD NEw DELHr-1r0002.
' one shop on Grou4d Floor, and Entire Third floor
of the said property shall go to
in favour of my'Daughter sMT. HARVINDER KAUR
wo sH. ser¡Norn
SINGH R/-o H.No. 43, GANDHI MARKET, MrR
DARD ROAD NEw
DELIII-I10002.
And I frirther declare that after my demise
the above said froperty roof lterracerights
shali go to in favour of my above said beneficiaries in joint
names and they shalt be fully
entitled to use the same commoniy 1

úlrj S----' #
 S No. 5307
Date 20/05/20t6 t4: i{,t24?
\ç\
Deed Narne Ì,¡/lL
- WILL
Land Detail
TehsiVSuh Tehsil Sub Registrar
Village/Ciry Minto
Building Type
Place (Segment)
Properfy Type

Property Address
f'
A¡ea of 0.00

Consideraûon Am ount 0.00R

Stamp Duty Paid 0.00 Rupees
Value ofRegi$ration Fee 500.00 ftupee5
Pasting Fee 100.00 Ruppes

This document of -ìr'\ilLl.

..... , ir \__,.

Fresented by: Sh/Smt. S/ó W/o ..'"'r R./O

H.ARtsHAIAN SINGH ,.,
_é3Gandhi Mkr Mir DardRoaej Delhi
in the cfüce of the Sub Regi$rar , Delhithis
betr.veen the.hours of
t:1,;.

"i.ì.1-r¡

Regiår¡suu Registrar
Sub Registrar lll
Signature ofPresenter
Delhi

Execution admifted by the sa #

HARBFIAJAN SINGH :i::.tii':

and Shri / Ms. . -",î'

NP
Who is/are idenrified by.shri/Smr/I(m, Vijay Kumar Road Delhi
and Slui ßmtl(m Manvinda R/oB 115 4

ür{aqgi"rai Wimessi. }V'ifness NIo. II is known to me.

C*$te,$rs of rl¡e dæurnent explained to

the conditions and admit them as
C€$iñed &æ tf¡e left (or Right, as the impression of the executant has my presence.

¡
V¡a,
v"ì
I
RegÉÊrar/Sub Registrar
Ðate2ît/051201G t6:37259 _J
ch^. Sub Registrar III
al=¿ DgirNew Delhi
flllu/ t
þ\ t_
vI/_7
 ç.

Tirey shall be fully entitled to transfer their above said

respective shares of the said
property in the record of MCD, DDA, L & Do or any
other eoncerned Aurhority, on the
basis of this "'WILL" or its certifu true copy.

They shall be fully entitled to transfer their above said respective

shares of the said
property by way of Sale, Gift, Mortgage, exchange,
lease, or other wise to any one in
any
manners' That they my above said beneficiary can use,
hold, and enjoy the said properry
in any mariner they likes.

And whereas in case my above said beneficiary shall dies earlier

me then their iegal
heir(s) shall become absolute owner of his ltheir/her respective
shares of the above said
property.

That in case I have executed any V/ILL earlier then

such v/ili shalt be treated as NULL
AND VOID from today.
That my other legal heirs shall have no right, claim,
title or interest of any nature
whatsoever in respect of my above said property,
if any one raise any claim objection,
demand, etc' in respect of rny of the said properties
or this "'ryILL', then such claims shall
be treated \TjLL Ar\*D VOID.

This is my last and final

WILL regarding aforesaid of the said property and if any other
V/ILL executed by me p.i9r to gxçc.ution of this ryILL shall be
treated as
cancelled./revoked.

And I have signed

and executed this Will with my own consent without
any outside
pressure and fulIpossession of sense in the following
witnesses:-
lVitnesses:- ì¡?
fW Cþ.rn*x,
'u
{)ßrvr'¡- f\ 5
l.viro.t-cr
s \, ,/ r'ì
s Ie {t. -nøri-\¿r^-ac\ f-4-çq)-,"-Vt
L¿--tôo-gd.tsa.-r^ q4- e{
þt.o 59-- ß, hir^+ o $_o

e.l-
TESTATOR.

r> n -L r/^-c-^- t
aJ¡
Reg. No. Reg. Year Book No"
285 2Aß-2817 t

Ist Party IInd Party Witness

ist Parfy HARBHAJAN SINGH

el.
"Ij¡-

IInd Parry- NP

Witness Vijay Kumar Paswan, Manvinder Sin$h

C ertificate (S eetibiii6û):
,1i-'.'ì;,li:i.'..i.*.'

No.285 in Book No.3 Vof'No 1.,51J j;.1:, .,ri,,,

Regisfration ,

on page 169 to 170 on this cÍate 2310512016 L0:47:114M day Monday

and ieft thumb impressions hasihave been taken in my presence.

Sub *C*,u.
Sub Registrar III
Date 271t5/2016 16:10:15 New Delhi/Delhi

Ë;IITIIII¡III tllil IIä

1.69214L128s
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To,
Dale:ffi

The SHO
l.P. Estate
New Delhi-110002

R TO PR ERTY R"
HA ENT DAU RS IND EET
Subject:

Respected Sir/Madam,

Harbhajan singh s/o sardar Bishan

lVith regard r worrd fike to acknowredge that r am sardar
SingrR/o43,GandhiMarket,MintoRoad,NewDethi-1-l0002.lamT6yearsoldretiredandill
person.lhavetwodaughterandoneson.MyelderdaughterlnderjeetKaurisharassingmeand
my will which she is refusing' She is
my'amily due to some property lssues I have also macle
and threatening and forcing us to change the
will'
also disturbing us in our business

property issues and take

I just request you to please intervene in this matter and resolve our
action against my elder daughter lnderjeet Kaur'

Please do the needful, I shall be highlrT obliged

Thanking You

MR. SARDAR HARBHAJAN SINGH

R/o 43, Gandhi Market, Minto Road,

Ne,¡,r Deïhi-i10002

Mob:9873345942

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lt

qt trhLsi* dL^,
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7\ r 2073
Date:Z1't SePternbe
To,

ThC SHG Ji

lP Estate, New Delhi-110002

o"ro"r;::. r a'n Harvinder

kaur with mv
to acknowredge that
regards, r wourd rike want to
Minto Road' New Delhi-110002'
Rlo 43, Gandhi Market,
brother yastrpar singh kaur and her son taranjeet
sister smt. inderjeet
against my erder
rodge a compraint work on 3'd floor' According
due to some construction
threatening us
singh as they are she sit on the ground floor
shop
but
for 2nd froor of the buirding,
to wi, she has a rights at'ow us to work freely
and
she doesn't
functioning of my brother.
and dislurb the shop

alwaYs threaten
us with her son
please do

Pleaseinterveneinthismatteranclsolveourproblemsassoonaspossible.
soon'
soon against her
take necessary action
will be responsible for her
happen to us ìn future' she
ff anything

ThankingYou,

ApPlicants
ApPlicants

ll

cVü ï þt{
YashPal
Hanvinder Kaur
 .
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Name MS HARVINDER KI\UR .
Eãii of Supply fCIr
Bìlliñg Adõress D/O SH HAíìSFiAJA¡J SI¡JGiI 43
G- GANDiì! iv/"RKET i','llRDARÛ
2.00 (kr^J) CA No. 1 51 798789
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Meter No. Unit tsilled,Consumption (Curreil) Billed Consumption (Frevious) Multiplication Cùnent Consumþtionffiia r¡q6;

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tsill of Supply for Electricity

'! .ne 1\lr. IL4RBIL{J-{\- SINGII Sancticned l-oací : 2,(10 ß\ï)
3illing.Àddress 43 F.T. GÀ\DHi \{ARKET a^-r-.,^+ n-*"^¡ t fift2-t ?oQç
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 MUNÐIPAL CCRPORATION OF DELFII
PROPERTY TAX REGEiPT NO: PT"934427
@
FINANCIA'L YEAR : 2023-2CI24

A sum of Fi:: 4¿:l , - i::cuR THSTJSAND stx HUNDRED AND îwENTy orur oulv) hos been received r,vith thonl<s frcm vr.lt'¡s.

JFÌ 1,{!iìr¿LSTNGH toworcìs the poyment of tox for the Finoncjol Yeor 2023-2û24 os per the detoils
given
HARVTNDER F.:

below:

ProPert)"' 'JFií ) 08802611c0t3500

dópert', ie¡rll'n.,-.,'; PLOTi HOUSE/FLAT/ SHOP NO. 43 GF/FF/3RD FLoOR
FARM !-{OUSE NO.
SECTOR/PHASE NO. GANDHI MARKET

BLocK/PocKET/ LINE/sTRliET No, MIR DARD LANE MINTO ROAD

COLONY GANDHI MARKET AREA

. WARD DELHI GATE

,: ZONE CITY S.P. ZONE

LANDMARK
PAYMENT FOR PROPERTY iNX
UPIC REGISTERED WITH HARVTN DER i<AU R(9873345S42)
r:i, :.,.:,:..::i.,::. ..:i
Põllmenî MÕt{} MODE oNLiNE (elwHaeoyment)
: TRANSACTION ID t688635627863
PAYMENT DA-IE a6-Ð7-2023

generqted by the syst€m qrìd

*, f,loto : For ;i-ríor:ì1ctícr , ;;f qll concemêd trot the property tqx hqs b€en poid oNtlNE . the receipt hos been
lience røquir,'- n() :.'l:.. : 'e'

RECETPT PRlNTED ON: 61712023

A.s*{*4@ çrt
 MUNTCIPAI, COR.PORAT{ÛN OF' ÐET,E{T

ASSESSIVIENT s' COLLECTION DEPARTLffiNT

No Dues Certificate (N0C)

This is iû rertüV thâtUPIC No 088026110013500 havirg property adclress 43 GF/FFI3RÐ FLOOR"
GANDHI l\fiAf*-iT AREA, DELHI GATE, New Delhi, 110002 of Sh/Smt. HARVINDER. K¿.IIR, YASHPAL
SINGH Lurs 11¿.;¡ositerl/uprlated property tax rlues unde I SAIvIRIDDh SCHEME 2022-23 upto Financiâl
year 2122-20?3. No previous years lax remaiudue.

Note: 1 Til:; is subject to scrutiny by the dcpartmcnt fo:: ntis-declaration or wilfui suppress:on of
lir<:1.s.
2 It is a Computer generated certificate hence; ilot reqülre sigl.ralue
Dare:26-C3"1023
 ffi to.$ÇÐ
\trif iqio¿l Cc,:.)i.: :rf rr- ri

h,{{.råqiСpAL ÐoRPORATÍGN
ür ÞrLÍ-ãå
;

PROPERTY TAX RgÇÊtpT fi{e

; PT_6B4ZI4
FåîSA!{C,AL VEAR : 2ü?2_2ûZg

A sum of Rs ¡7051ì /- rijousA¡'rÐ ÁN,D FrFTy Nrilrä ÕNry)

{:-tt
";i'r;reN hos heen received wiih rhcnks f rorrr
Mr./Ms.
YA=¡'{PA's'N'31-t' lìAiii/iiirltii
¡.ó,iJR tow'rds the pûymènt
cf pi.cperiy îcx under sé.tu{Rr*Dhí sc¡-åËMË 2t2?_2a upro
the yec,r
2022-2O?'3 cs per ihe,Jei,:1is gíven
below:

Property UptC
cBEû2ôlr0ct35ûû
Property Address
PLCT/l-ioU s¡i rr¿ii ssop 43 GF/FF13RD FLocR
No.
FARil,/ HOUSE Na.

SECTORiPHASE tJo. GANDI-{I iI,Å.RKET

BLocK/PocKEr/ MIR DARD LA\ii MII.¡TO
i_tNE/STR¡ET hJo.
ROAD
COLONY
GANiDHI MARKET AREA
i.VARD
DELHJGATE
ZOI'JE
CITY S.P. ZOI\'E
LANDiVJARK

PAVMEi"¡T FCR
SAMRiDDHi/AI"4NESTY

Fgvnrenf \in¡* SERVICES

N4ODi
ONLIN.¡E
TRÂI\SACT¡Oî! ID 16798274226t6
Pé,YME¡\T D,qTã
26-03-2û23
*Acknowiedg,err *i";i : lr ís certlfied
thot th¡e:o,xpoyer sh./srnt./rm.y^S*pdå¡-
deposíted the Freper::y tax upto Fy2022-20es såstür{
"dagvlNÐëÊ KÅuF¿ hss
{ netlre snd cfter Fy 2tt.4} in r/o property mentioned
seif- ossessrn#nt hcsi* under Arnnesty cbove on
$cherne ilapz*zlv¡hich is subject te
declqrEtion o¡ suppr€'$sior¡ of fccts scr{"rtiny on sccourìt of mís-
snc flnorc$eqrqnce of audii.

E n
ry

tr

!
NotB : For infornìcti*n of cri concerned that
the propeny tËÐ{ hcs been prid
quire no signsüJre. oNLrhJF ihe receipt hcs been genercted
by the system cnd hence

R[cÈtrT PR¡NTÊÞ
r¡{: 26/3/20?3
 ffi
faJrL
tur€Ð
Vt:,,tìtì""i Cc::.r-.: .:, ..^ ,,,

h4UNEC|F&L CORFöRATíçr\i ;
tF. ÞäLÉ-8t
PROPERTY TÅX RFCEIPT
I{Ç ; PT*684274
FËfd,ENCit\L VËAR ; A\ZZ*Z}ZS
A sum of Rs ¡70511 /- 'is:vir'lrreN ït-{ousAND,A¡{Ð ruFry r{¡NE oNrv) hcs been receive¡J w¡th
thanks f rorn Mr.f Ms.
YA.í{PÂLsl¡{Gl-{' tjAiii/inr}ãiì
towords the pûyn.ent cf pr-cperiy
l É'iJR
îax under sÅtudR¡DDhí s*,F{EtuiË ztzz_zSrrpto rhe yeor
2A22-Zû29 cs per the;,Jei,::¡is given below:

Froparty UptC
388û251r0c1350û
Property Addi*.sç
P!_oTlHCrj Sii rr¿ri sHop 43 GF/FF/3RD FLOOR
No.
FARM HOUSE Na.
sËcroRiPFrASE No.
GANDI-{I iüÉ.RKET
BLCIcK/POCKET/
IIIR DARD i-AN' M¡I\ITO
ilNE/STR¡tT I,Jo. ROAD
coLoNy GAI,IDHI MARKET ê.REA
WARD
DELHIGATE
7ôNrtr
CITY S.P. ZO¡JE
iANDfviARK
PAYIITNT FOR
SAMRIDDH¡/AIIhJESTY
Fcny'merrt Modi+ SERViCES
\4ODE
oNLif.¡E
TR.4NSÅCTIÛï\J ,D
167e82V4228t6
PAYMFhJT DAIi 26-t3-2t23
* nckr¡ow¡edç;err ei:i; rÈ !s cerrffed thot the tcxpoyer sh./srnt./ir¡ri.v¿s*pn¡-
deposited the Frop*r:.''tcx .tpto sgh*çX ,_,raËvr*-g.Eg KAU&
hss
FY zoa?-2tzs neråre
self- ossessmsnt br:si:; uncer Årnnesty { *Ào àr*, Fy 2tt4} in r/o property
nrentloned nbove on
scl'reme zez?-zsrn¡hích ;s subieci
declorstion or suppr€r,qs¡on of fccts t* scrurtir.ly orì üccoLJnt of r:.¡is-
cni frnsåc,e*¡ran¡ce of ar:dít.

t ñ
ry
r$

t
l¿otÊ : For ¡nform,ftiûn oÍ
oi¡ ¿:ancerned thot
trl.,l the
rne pr,
Propert-y tax hss been pâíd
¡uire no signoture. ch'¡LiNE, the receípt hcs been generoted
by the system ond hance

RFCi¡Pr PRTNTËD CI¡j ì

2S/3/2r?3
Subject: nequestfõiÞeimisiíón to Carry out Repairs on 3rd Floor - eroperty of l-ate Harbajàn Singh

Date: 13 May 2024

To,

The Municipal Corporation of Delhi (MCD) Office,

q=I
Deputy Commissioner,

G?ound floor, Old Hindu College NigamBhawan,

1 4 trAy :¡t124

Kashmere Gate, Delhi-LL0006

Er¿riøq
s:l{{ e'rã

Dear Sir/Madam,

I am writing to seek your assistance in resolving a dispute concerning the repair work being conducted on the 3rd
floor of the property with UPIC lD 088026110013500. My name is Harvinder Kaur, and I am currently overseeing the
repair work on the property. I have a track record of timely property tax payments and compliance with MCD
regulations.

The property in question was or¡¡ned by our late father, Harbajan Singh, who has passed away. As his children, my
sister lnderjeet Kaur, our brother Yashpal, and I are jointly responsible for the rnaintenance and upkeep of the
property.

I have initiated necessary repair work on the 3rd floor to ensure the safety and structural integrity of the building.
However, my sister, lnderjeet Kaur, who resides on the 2nd floor, has raised objections and halted the repair work.

I kindly request the MCD office to intervene in thís matter and grant permission for the repair work to continue on
the 3rd floor of the property owned by our late father, Harbajan Singh. lt is essential to address these maintenance
issues promptly to prevent any further deterioration of the propefi.

Thank you for your cooperation and assistance in resolving this issue

Yours sincerely,

Harvinder Kaur
 ¡

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