Format of Application of Secondary Evidence in Property Recovery Suit
IN THE COURT OF SENIOR CIVIL JUDGE, _____
_____ Versus _____
SUIT FOR RECOVERY
APPLICATION FOR SECONDARY EVIDENCE
The applicant submits as under:-
That the _____ i.e. Defendant No. _____ is the son of borrower namely _____. The father of the defendant No. _____has been expired before filing the recovery suit. The defendant No. _____ inherited the immoveable property and _____ on dated _____. The original sale deed is not in our possession. The original sale deed of _____ which was registered on that day in the Sub Registrar, _____, this property is has been sold by the defendant No. _____ to _____ son of _____, resident of _____. The secondary evidence is necessary to prove the documents. The certified copy of sale Deed is attached herewith
It is, therefore, prayed that the application for secondary evidence may kindly be allowed.
Written Statement Reply- Format of Suit for Declaration & Partition
In the court of _____
In the matter of:-
_____ Versus _____
SUIT FOR DECLARATION & PARTITION
Written Statement on behalf of the Defendant No. _____
The defendant No.1 most respectfully submits as under: –
1- That the contents of Para No.1 of the plaint are correct and admitted.
2- That the Para No.2 of the plaint is also correct and admitted. It is correct that _____.
3- That the Para No.3 of the plaint is also correct and admitted.
4- That the Para No.4 of the plaint is also correct and admitted. It is submitted that _____.
5- That the Para No.5 of the plaint is a matter of record.
6- That in Para No. 6 of plaint it is submitted the defendant No.1 has no knowledge about the said _____.
7- That the Para No.7 of the plaint _____.
8- That the Para No.8 _____.
9- That the Para No.9 of the plaint is correct and admitted.
REPLY TO PRAYER
That in reply to the prayer Para it is submitted that if _____ defendant No.1 has no objection.
It is, therefore, prayed that the suit of the plaintiff may kindly be decreed as prayed for Defendant _____
_____ son of _____ resident of _____
Verified that the contents of the written statement are true to best of our knowledge and belief and nothing concealed therein.
I _________ son/daughter/wife of _________ resident of _________ do here by confirm that I/we have purchase _________ Electric Battery operated, model _________ vide VIN/Chassis no_________ from _________, _________ Dated _________
I do solemnly affirm I am a resident of _________ and have purchased the above mentioned _________ Electric Vehicle for the use in the territory of _________ only.
I was not charged the _________ amount from the Dealer and have also received the benefit of _________ % subsidy on the base price of the vehicle.
This is verified on this date _________ at _________, that above statement is true & correct to the best of my knowledge and beliefs and nothing in concealed therein.
Format of Stay Execution- Setting Aside the Ex-Parte order and Ex-Parte Decree
In the court of _____
Application for Setting Aside the Ex-Parte order dated _____ and Ex-Parte Decree dated _____
1- That the above noted case was fixed for _____ before this Hon’ble court and the counsel for the applicant/defendant appeared before this Hon’ble court. The Hon’ble court fixed the time for arguments at _____ hence the counsel went to attend other cases in the other courts. at about _____when the counsel came back to attend this Hon’ble court then he came to know that the above noted case was proceeded as ex-parte against the applicant/defendant. Thereafter on _____ this Hon’ble court passed an exparte decree in favour of the plaintiff and against the defendant.
2- That the applicant/defendant will suffer an irreparable loss and injury in case the above noted suit is not restored in its original form.
3- That the present application is well within the limitation.
It is, therefore, prayed that the exparte order dated _____ and ex-parte decree dated _____ may kindly be set aside in the interest of justice.
1- That the _____ of the plaint is correct and admitted
2- That the _____ of the plaint is correct and admitted
3- That the _____of the plaint is correct and admitted
4- That the _____of the plaint is correct and admitted
5- That the _____ of the plaint is legal
6- That the _____ of the plaint is not _____
It is therefore, prayed that the suit of the plaintiff may kindly be decreed as prayed for in the plaint
Verified that the contents of written statement are true and correct to best of my belief.
The Branch Manager,
_________ Bank Limited
Subject : Application for Issuance of Foreign Demand Draft / Foreign Outward Remittance
Currency & Amount
Beneficiary Name, Address & Account No. / IBAN
Beneficiary Bank Name, Address & SWIFT / Sort Code
Purpose of Remittance
Foreign Bank Charges
OUR / BEN / SHA
We would like to purchase / remit _______________________ as above. In this context, we declare that the captioned transaction does not involve and is not designed for the purpose of any contravention or evasion of the provision of the Foreign Exchange Management Act 1999 or any rule, regulations, notification, direction or order issued there under.
The required A2 form, duly filled in and necessary documentary evidence in support of the said purpose are enclosed.
We request you to debit my/ our EEFC / RFC Account No.__________________________ for _________________ and the balance amount to my/ our INR Account No. __________________ along with your charges.
The Branch Manager,
Subject: – Cash Remittance
As per telephonic conversation we are remitting rupees ___________/- through our designation _________(Name) signature is attested below. You are requested to credit our _______ Account through NEFT/RTGS /Issue a Bankers Cheque in favor of “_______ Bank” /credit our Branch Adjustment-_______ Account (for _______Bank Branch only) against this remittance.
For NEFT/RTGS- our Code is _______and our Account number is _______.
I, _____ SON OF _____ OF _____ Received a sum of _____/- (_____ only), as full and final payment from _____ SON OF _____ R/O _____, in respect of sale of _____ alongwith all the goods/items (Details of terms and conditions are mentioned in Agreement to sell dated _____ no. _____) in the present of following witnesses:-
I/We______________________R/o___________________________has/have received a sum of _________________/- (______________________ only) from _________________________ R/o_______________________________as part / advance payment / token money on account of sale of plot No. / House No.______________ out of the total sale consideration of ______________ (_________________________________ only). The detail of the payment already paid is given below:-
i) Advance payment
in the presence of following witnesses :-