District Shahadara

Please Tick
Case Information Format Civil
Criminal
S.No. Plaintiff/ Petitioner/ Complainant/ Appellant/ Decree Holder ETC. (Please fill up all
relevant Fields ( ) fields are mandatory
1 Name Of The Complainant Ms. Rama
2 W/O. Late Shri Sandeep,
3 Address H. No.10850. Gali Phool Wali Manakpura Karol Bagh,
Central Delhi-110005,
Presently Reside At: H.No.23 Naveen Palace, Jhoddha
Road, Kali Pau, Near Nasha Mukti Kendriya Wali Gali,
Najafgarh, New Delhi
4 Aadhar Card No. 2612 2658 0576 Pin Code - 110005
5 Gender Female Nationality Indian
6 Date of Birth 03.07.1999 Age 25 Years
7 Mobile No 8800703814 Email:
8 Act/ section Suit for declaration of title
9 Valuation of suit Court Fee ascertained/
Court Fee paid/ deposited
10 Police Station
11 FIR No. & Year (in criminal matters only)

S. No. Defendant/accused/respondent/judgement debtor etc

(Please fill up the relevant fields)
1 Name Of The Accused Ms. Anita Devi
2 W/O. Late Sh. Ishwar Dass
3 Address H.No. 10850, Phoolwali Gali, East Park Road, Manakpura,
Karolbagh, Delhi-110005
4 Aadhar No.
5 Gender Female Nationality Indian
6 Date of Birth
7 Mobile No.

S.No Advocate for Complainant

1 Name of Adv. Gajendra Singh Bar Regn. No D/3850/2013
Advocate
2 Address S. N. 7, Abdul Kalam Block, Thc, Delhi-110054

3 Mob.No. 9654391517 Email [email protected]

Submitted by:

Adv. Gajendra Singh (D/3850/2013)

Counsel for complainant
Extra Party Information

1 Name Of Extra Party Mr. Anoop

2 S/O, Late Sh. Ishwar Dass
3 Address H.No. 10850, Phoolwali Gali, East Park Road,
Manakpura, Karolbagh, Delhi-110005
4 Aadhar Card No.
5 Date of birth/ age
6 Mobile No Email:

1 Name Of Extra Party Ms. Deepika

2 D/O Late Sh. Ishwar Dass
3 Address H.No. 10850, Phoolwali Gali, East Park Road, Manakpura,
Karol Bagh, Delhi-110005
4 Aadhar Card No.
5 Date of birth/ age
6 Mobile No Email:
IN THE COURT OF DISTRICT AND SESSION JUDGE, CENTRAL
DISTRICT, TIS HAZRI COURTS, NEW DELHI
Suit No. __________ of 2024

IN THE MATTER OF:

MS. RAMA PLAINTIFF

VESUS
MS. ANITA DEVI AND ORS.
DEFENDANTS

INDEX

S.NO PARTICULARS PAGE NO

1. MEMO OF PARTIES 1
2. SUIT FOR DECLARATION ALONG 2-3
SUPPORTIVE AFFIDAVIT
3. APPLICATION FOR INTERIM INJUNCTION
4. LIST OF DOCUMENTS
5. VAKALATNAME

THROUGH

MR. GAJENDRA SINGH (D/3850/2013)

MR. RAVI KUMAR (D/2039/2013)
ADVOCATES FOR THE PLAINTIFF
S. N. 7, ABDUL KALAM BLOCK,
TIS HAZARI COURTS, DELHI-110054
PLACE: NEW DELHI CONT: 9654391517, 9910430702
DATE: 27/ 08/2024 EMAIL: [email protected]
IN THE COURT OF DISTRICT AND SESSION JUDGE, CENTRAL
DISTRICT, TIS HAZRI COURTS, NEW DELHI
Suit No. __________ of 2024

MEMO OF PARTIES

IN THE MATTER OF:

MS. RAMA
W/O LATE SHRI SANDEEP,
R/0, H. NO.10850. GALI PHOOL WALI
MANAKPURA KAROL BAGH,
CENTRAL DELHI-110005,

PRESENTLY RESIDE AT:

H.NO.23 NAVEEN PALACE,

JHODDHA ROAD, KALI PAU,
NEAR NASHA MUKTI
KENDRIYA WALI GALI
NAJAFGARH, NEW DELHI PLAINTIFF

VESUS
MS. ANITA DEVI
W/O. LATE SH. ISHWAR DASS
R/0 H.NO. 10850, PHOOLWALI GALI,
EAST PARK ROAD, MANAKPURA,
KAROLBAGH, DELHI-110005 DEFENDANT NO.1

MR. ANOOP
S/O. LATE SH. ISHWAR DASS
R/0 H.NO. 10850, PHOOLWALI GALI,
EAST PARK ROAD, MANAKPURA,
KAROLBAGH, DELHI-110005 DEFENDANT NO.2

MS. DEEPIKA
D/O. LATE SH. ISHWAR DASS
R/0 H.NO. 10850, PHOOLWALI GALI,
EAST PARK ROAD, MANAKPURA,
KAROLBAGH, DELHI-110005 DEFENDANT NO.3
 THROUGH

MR. GAJENDRA SINGH (D/3850/2013)

MR. RAVI KUMAR (D/2039/2013)
ADVOCATES FOR THE PLAINTIFF
S. N. 7, ABDUL KALAM BLOCK,
TIS HAZARI COURTS, DELHI-110054
PLACE: NEW DELHI CONT: 9654391517, 9910430702
DATE: 27/ 08/2024 EMAIL: [email protected]
IN THE COURT OF DISTRICT AND SESSION JUDGE, CENTRAL
DISTRICT, TIS HAZRI COURTS, NEW DELHI
Suit No. __________ of 2024

IN THE MATTER OF:

MS. RAMA
W/O LATE SHRI SANDEEP,
R/0, H. NO.10850. GALI PHOOL WALI
MANAKPURA KAROL BAGH,
CENTRAL DELHI ,

PRESENTLY RESIDE AT:

H.NO.23 NAVEEN PALACE,

JHODDHA ROAD, KALI PAU,
NEAR NASHA MUKTI
KENDRIYA WALI GALI
NAJAFGARH, NEW DELHI PLAINTIFF

VESUS
MS. ANITA DEVI
W/O. LATE SH. ISHWAR DASS
R/0 H.NO. 10850, PHOOLWALI GALI,
EAST PARK ROAD, MANAKPURA,
KAROLBAGH, DELHI-110005 DEFENDANT NO.1

MR. ANOOP
S/O. LATE SH. ISHWAR DASS
R/0 H.NO. 10850, PHOOLWALI GALI,
EAST PARK ROAD, MANAKPURA,
KAROLBAGH, DELHI-110005 DEFENDANT NO.2

MR. DEEPIKA
D/O. LATE SH. ISHWAR DASS
R/0 H.NO. 10850, PHOOLWALI GALI,
EAST PARK ROAD, MANAKPURA,
KAROLBAGH, DELHI-110005 DEFENDANT NO.3
 SUIT FOR DECLARATION OF TITLE

MOST RESPECTFYLL AND TRUELLY SHOWETH:

1. That the above-noted Plaintiff is the wife of the deceased, namely,

late Sh Sandeep and the Defendant No. 1, 2 and 3 are deceased’s
mother, brother and sister respectively.

2. That on 23.07.2015, the Plaintiff was married to deceased, namely,

late Mr. Sandeep S/o. late Sh. Ishwar Dass R/o. H.No. 10850,
Phoolwali Gali, East Park Road, Manakpura, Karol Bagh, Delhi-
110005 as per Hindu rites and ritual at House No 23, Naveen Place,
Kali Pyau, Near Nasha Mukti Kendra Wali Gali, Jharoda Road,
Najafgarh, New Delhi - 110043. The Marriage Card and photographs
of the marriage are annexed as ANNEXURE P-1 and ANNEXURE
P-2 respectively.

3. After marriage the Plaintiff went to her matrimonial home i.e.,

H.NO. 10850, Phoolwali Gali, East Park Road, Manakpura, Karol
Bagh, Delhi-110005, in vidai and lived there with her husband and
mother-in-law, sister-in-law, and brother-in-law.

4. Thereafter, Plaintiff’s husband name and her matrimonial home

address were added to the Aadhar Card of the Plaintiff, annexed as
ANNEXURE P-3, on the basis of her husband’s documents and
marriage.

5. After marriage, the husband of the Plaintiff took loan from bank and
made her wife Plaintiff nominee in the said loan. The documents of
the said loan is annexed ANNEXURE P-4.
6. Therefore, the Plaintiff is the legally wedded wife of the deceased
who was working in Delhi police as constable vide belt no.5M PIS
NO.84060002 and was expired on 20.03.2018 intestate due to
pulmonary koch’s and sepsis with shock. The death certificate dated
03.05.2018 is annexed as ANNEXURE P-5.

7. After the death of her husband the Plaintiff wrote a letter dated
04.04.2018, annexed as ANNEXURE P-6, to the Dy. Commissioner
of Police North West District Delhi as regards her recruitment in
Delhi Police in place of her husband on compensatory ground. The
office of the Dy. Commissioner of Police vide it’s letter/reply dated
04.06.2018, annexed as ANNEXURE P-7, sought succession
certificate to proceed further and in compliance of the same the
Plaintiff filed an application u/s 372 of the Indian Succession Act
1925 to get Succession Certificate in the Hon’ble Court of Sh
Dheeraj Mor ACJ/ CCJ/ ARC Dwarka Courts New Delhi bearing
case no. Succ. Court/ 53/ 2018 titled as Rama vs The State and Ors.,
annexed as ANNEXURE P-8, however, the same was withdrawn by
the Plaintiff after came into knowledge the fact that the Respondent
also filed another application u/s 372 of the Indian Succession Act
1925 to get Succession Certificate in the Tis Hazari Courts, New
Delhi bearing case no. Succ. Court/ 67/ 2018, annexed as
ANNEXURE P-9, which is pending for adjudication and wherein
the Plaintiff filed its objection.

8. It is pertinent to mention that above-noted facts, annexed documents,

evidences and incidences clearly established that the Plaintiff is
legally wedded wife of the deceased, namely, late Sh. Sandeep and
therefore, legally entitled for all benefits and right arise from the job
and in the property of the her husband.
9. That the Plaintiff is the legally wedded wife of late Sh. Sandeep and
has the right over the property of her husband. The Plaintiff being the
legally wedded wife of the deceased is entitled for all the benefit
which was or will be given by the govt. as per rule and is entitled to
receive the family emoluments, death benefits and pension including
job. The Plaintiff is also entitled for seeking interim as well as
permanent injunction restraining the Defendants from disbursing the
entire amount of death benefits and emoluments and ancestral or
private property belongs to the Plaintiff’s husband.

10.That the cause of action arose on 23.07.2015 when the marriage of

Plaintiff with Late Sh. Sandeep was solemnised and the Plaintiff
went her matrimonial home in vidai. The cause of action again arise
on 20.03.2018 when the husband of the Plaintiff was expired. The
cause of action further arose on 15.05.2018 when the Plaintiff filed
the application bearing no. Succ Court/ 53/ 2018 to get succession
certificate in the Dwarka Court and the cause of action also arose on
25.04.2019 when the plaintiff withdrawn the same. The cause of
action further arose on 14.05.2018 when the Defendant also filed the
application bearing no. Succ Court/ 67/2018 to get succession
certificate. The cause of action also arose when they went to
mediation to settle the matter. The cause of action arose on each and
every date when the Plaintiff demanded to be legitimate wife of the
late Sh. Sandeep and the same were denied by the Defendant. The
cause of action also arose on each date of hearing of above-noted
case. The case of action will continue whenever the Plaintiff would
be denied to be legitimate and lawful wife of late Sh. Sandeep by the
Defendant.
 11.That the suit has been properly valued for the purpose of pecuniary
jurisdiction and court fee as follows:

a) for the purpose of declaration of wife is Rs. 300/-

b) and for the consequential relief is the court of Rs. ______ has
been affixed on the plaint and the Plaintiff undertake to file
other court fees as and when this Hon’ble Court would order.

12.No other suit/ case has been filed in other court seeking same relief.

13.That this Hon’ble Court has the jurisdiction to try and entertain the
present case as the above-noted address of the deceased comes
within the territorial jurisdiction of this Hon’ble Court.

PRAYER

In the light of the above-mentioned facts and circumstances it is most

respectfully prayed that this Hon’ble Court may be pleased to pass an order
(s) of:

a) Declaration that plaintiff is legally wedded wife of the

deceased, namely, late Sh. Sandeep

b) Declaration that plaintiff is entitle all the benefit which was

given by the government and is entitled to receive the family
emoluments, death benefits and pension including job and
entitled for the property of her husband.

c) Declaration that the Plaintiff is also entitled for seeking

interim as well permanent injunction restraining the
 Defendants from disbursing the entire amount of death
benefits and emoluments and property of her husband.

d) Staying the adjudication of the application under section 372

of the Indian Evidence Act, 1925.

e) Any other order as it deems fit in favour of the Plaintiff in

the interest of justice.

PLAINTIFF

THROUGH

MR. GAJENDRA SINGH (D/3850/2013)

MR. RAVI KUMAR (D/2039/2013)
ADVOCATES FOR THE PLAINTIFF
S. N. 7, ABDUL KALAM BLOCK,
TIS HAZARI COURTS, DELHI-110054
PLACE: NEW DELHI CONT: 9654391517, 9910430702
DATE: 27/ 08/ 2024 EMAIL: [email protected]

Verification:

Verified at New Delhi on this __________ day of _________, 2024 that the
contents of the plaint are true and correct to the best of my knowledge and
belief and noting has been concealed therefrom.

Plaintiff
IN THE COURT OF DISTRICT AND SESSION JUDGE, CENTRAL
DISTRICT, TIS HAZRI COURTS, NEW DELHI
Suit No. __________ of 2024

IN THE MATTER OF:

MS. RAMA PLAINTIFF

VESUS

MS. ANITA DEVI AND ORS.

DEFENDANTS

Affidavit

I, Rama W/o. Late Sh. Sandeep R/o. H. No. 10850, Gali Phool Wali,
Manakpura, Karol Bagh, Central, Delhi, New Delhi, Present address: H.
No. 23, Naveen Palace, Kali Pau, Near nasha Mukti Kendra Wali Gali,
Jharoda Road, Najafgarh, New Delhi; do hereby solemnly affirm and
declare as under:

1. That I am plaintiff in the present matter and as such I am well

conversant with the facts and circumstances of the present case and
fully competent to sign this plaint and Affidavit.
 2. That I also undertake that I have not filed any similar suit against the
defendant and the accompanying plaint has been drafted by my
counsel under my instructions and read over to me in vernacular
language and the contents of the said plaint are not being repeated
herein for the sake of brevity. That the statements made herein are
true and correct to the best of my knowledge and belief.

Deponent

VERIFICATION:

Verified on this ___ day of _________, 2024 that the contents of

Para 1 and 2 of the above Affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed there from.

Deponent
IN THE COURT OF DISTRICT AND SESSION JUDGE, CENTRAL
DISTRICT, TIS HAZRI COURTS, NEW DELHI
Suit No. __________ of 2024

IN THE MATTER OF:

MS. RAMA PLAINTIFF

VESUS
MS. ANITA DEVI AND ORS.
DEFENDANTS

APPLICATION UNDER ORDER XXXIX RULE 1 AND 2 OF THE

CODE OF CIVIL PROCEDURE, 1908 TO GRANT THE INTERIM
INJUNCTION RESTRAINING THE DEFENDANTS
Most respectfully and truly showeth:

1. That the Plaintiff has filed suit for declaration of title along with
present application for the interim injunction. The contents of the suit
are not being repeated herein for the sake of brevity and same may
be read as part and parcel to the present application for interim
injunction.

2. That in the light of the facts and circumstances mentioned in the

plaint, the Plaintiff is seeking the interim injunction restraining the
Defendants from disbursing the entire amount of death benefits and
 emoluments and property of her husband. The Plaintiff is also
seeking the interim relief as staying the adjudication of the
application filed under section 372 of the Indian Evidence Act, 1925.

3. That the Plaintiff has made the prima facie case in her fovour and the
balance of convenience is also titled in the favour of the Plaintiff and
therefor the Plaintiff is entitled to interim relief in its favour in the
interest of justice restraining defendant.

PRAYER

In the light of the above-mentioned facts and circumstances it is most

respectfully prayed that this Hon’ble Court may be pleased to pass:

a) Ex-parte ad-interim injunction restraining the Defendants

from taking any benefit given by the govt. as per rule and to
receive the family emoluments, death benefits and pension
including job and from the property of her husband and also
disbursing the entire amount of death benefits and
emoluments and property of her husband.

b) Ex-parte ad-interim injunction staying the adjudication of

the application under section 372 of the Indian Evidence Act,
1925 bearing case no..Succ Court/ 67/2018 to get succession
certificate pending in the Tis Hazari Court.

Plaintiff
 THROUGH

MR. GAJENDRA SINGH (D/3850/2013)

MR. RAVI KUMAR (D/2039/2013)
ADVOCATES FOR THE PLAINTIFF
S. N. 7, ABDUL KALAM BLOCK,
TIS HAZARI COURTS, DELHI-110054
PLACE: NEW DELHI CONT: 9654391517, 9910430702
DATE: 27/ 08/ 2024 EMAIL: [email protected]

Verification:

Verified at New Delhi on this __________ day of _________, 2024 that the
contents of the application are true and correct to the best of my knowledge
and belief and noting has been concealed therefrom.

Plaintiff
IN THE COURT OF DISTRICT AND SESSION JUDGE, CENTRAL
DISTRICT, TIS HAZRI COURTS, NEW DELHI
Suit No. __________ of 2024

IN THE MATTER OF:

MS. RAMA PLAINTIFF

VESUS
MS. ANITA DEVI AND ORS.
DEFENDANTS

Affidavit

I, Rama W/o. Late Sh. Sandeep R/o. H. No. 10850, Gali Phool Wali,
Manakpura, Karol Bagh, Central, Delhi, New Delhi, Present address: H.
No. 23, Naveen Palace, Kali Pau, Near nasha Mukti Kendra Wali Gali,
Jharoda Road, Najafgarh, New Delhi; do hereby solemnly affirm and
declare as under:

3. That I am plaintiff in the present matter and as such I am well

conversant with the facts and circumstances of the present case and
fully competent to sign this application and Affidavit.
 4. That I also undertake that I have not filed any similar suit against the
defendant and the accompanying application has been drafted by my
counsel under my instructions and read over to me in vernacular
language and the contents of the said application are not being
repeated herein for the sake of brevity. That the statements made
herein are true and correct to the best of my knowledge and belief.

Deponent

VERIFICATION:

Verified on this ___ day of _________, 2024 that the contents of

Para 1 and 2 of the above Affidavit are true and correct to the best of my
knowledge and belief and nothing material has been concealed there from.

Deponent
IN THE COURT OF DISTRICT AND SESSION JUDGE, CENTRAL
DISTRICT, TIS HAZRI COURTS, NEW DELHI
Suit No. __________ of 2024

IN THE MATTER OF:

MS. RAMA PLAINTIFF

VESUS
MS. ANITA DEVI AND ORS.
DEFENDANTS

LIST OF DOCUMENTS

S.NO PARTICULARS PAGE NO

1. The Marriage Card is annexed as ANNEXURE

P-1.

2. The photographs of the marriage are annexed as

ANNEXURE P-2 respectively.

3. The Aadhar Card of the Plaintiff is annexed as

ANNEXURE P-3

4. The documents of the loan is annexed

 ANNEXURE P-4.

5. The death certificate dated 03.05.2018 is

annexed as ANNEXURE P-5.

6. A letter dated 04.04.2018 written by the Plaintiff

to the Dy. Commissioner of Police North West
District Delhi as regards her recruitment in Delhi
Police in place of her husband on compensatory
ground is annexed as ANNEXURE P-6,.

7. A letter/ reply dated 04.06.2018, of the office of

the Dy. Commissioner of Police is annexed as
ANNEXURE P-7,

8. An application u/s 372 of the Indian Succession

Act 1925 to get Succession Certificate in the
Hon’ble Court of Sh Dheeraj Mor ACJ/ CCJ/
ARC Dwarka Courts New Delhi bearing case no.
Succ. Court/ 53/ 2018 titled as Rama vs The
State and Ors. Filed by the Plaintiff is annexed
as ANNEXURE P-8.

9. An application u/s 372 of the Indian Succession

Act 1925 filed by the respondent to get
Succession Certificate in the Tis Hazari Courts,
New Delhi bearing case no. Succ. Court/ 67/
2018 is annexed as ANNEXURE P-9.

THROUGH
 MR. GAJENDRA SINGH (D/3850/2013)
MR. RAVI KUMAR (D/2039/2013)
ADVOCATES FOR THE PLAINTIFF
S. N. 7, ABDUL KALAM BLOCK,
TIS HAZARI COURTS, DELHI-110054
PLACE: NEW DELHI CONT: 9654391517, 9910430702
DATE: 27/ 08/2024 EMAIL: [email protected]