IN THE HIGH COURT OF DELHI AT NEW DELHI

C.S.(OS) No. _____ of 2013

IN THE MATTER OF:

Mr. Manpreet Khurana

S/o Late Lt. Col. S.K.Khurana
R/o 65893, Canary wharf
Canton, MI-48188 (USA)

Also at:
H.No.A-2/96, Anand Niketan,
New Delhi-110057 ......Plaintiff

Versus

1. Smt. Dheeraj Kaur Khurana

W/o Late Lt. Col. S.K.Khurana
R/o House No.A-2/96, Anand Niketan,
New Delhi-110057

2. Ms. Simmi Khurana

D/o Late Lt. Col. S.K.Khurana
W/o Jasjeet Singh Marwaha
R/o, 4 Rajdoot Marg
Rajdoot bahwan
Chanakaya Puri
New Delhi-110021

3. Ms. Karamjit Oberoi

D/o Late Lt. Col. S.K.Khurana
W/o Siri Ballab Oberoi
R/o 143/9 Flat # D102
Kishan Garh, Anand kunj
New Delhi – 110070

Also At:
R/o Flat No. M-96, 76/1 Ward No. 9,
Heera Lal Building, Kishan Garh,
Anand kunj, New Delhi – 110070

4. Mrs. Harmeet K. Singh

D/o Late Lt. Col. S.K.Khurana
W/o Arvind Pal Singh
 R/o 2117 W 117 Street
York, KS 66211, USA

Also at:
H.No.A-2/96, Anand Niketan,
New Delhi-110057 ......Defendants

SUIT FOR DECLARATION, PARTITION, PERMANENT

INJUNCTION AND FOR RENDITION OF ACCOUNTS

MOST RESPECTFULLY SHOWETH:

1. That the Plaintiff and Defendant No. 1 to 4 are the

lawful and legal heirs and representatives of the

estate of Late Lt. Col. S.K.Khurana (Retd.). The

Defendant No.1 is the legally wedded wife of Late Lt.

Col. S.K.Khurana (Retd.) and out of the wedlock of

Late Lt. Col. S.K.Khurana (Retd.) and Defendant

No.1, there are only 04 (four) children, namely, the

Plaintiff and Defendants No. 2, 3 and 4.

2. That the ancestors of the Plaintiff and the Defendants

belonged to Pakistan and were wealthy and affluent

and owned and possessed a lot of movable and

immovable properties including cash, jewellery, gold,

bank deposits etc. Late Dr. Raja Singh was the father

of Late Lt. Col. S.K.Khurana (Retd.) and the

grandfather of the Plaintiff and the Defendant No.2 to

4.
3. That after the Partition of India, Late Dr. Raja Singh

moved from Pakistan to Dehradun and then

Chandigarh along with his 02 (two) daughters and 03

(three) sons. Late Dr. Raja Singh also brought some

movable ancestral funds and wealth in the form of

cash, etc. from Pakistan. The pedigree table of the

family of the Plaintiff and the Defendants is annexed

along with the present plaint as Annexure-A.

4. That after settling in Chandigarh, Late Dr. Raja Singh

had a successful practice in and around Chandigarh.

From the ancestral funds and wealth and out of his

own income, Late Dr. Raja Singh purchased land and

built a house in Sector-15, Chandigarh and bought

few acres of land in Bhrara and Rajokheri villages in

Haryana.

5. That Dr. Raja Singh expired in the year 1967 and

before his demise, he distributed his entire undivided

ancestral properties both movable as well as

immovable by virtue of a Will, to his 03 (three) sons,

namely, (i) Late Lt. Col. S.K.Khurana (Retd); (ii)

Brig. Dr. N.S. Khurana (Retd.); and (iii) Dr. B.S.

 Khurana and gave some cash to his 02 (two)

daughters.

6. That the above named sons of Late Dr. Raja Singh

sold the house in Sector-15, Chandigarh in the year

1968-69 for a total sale consideration of

Rs.1,05,000/- (Rupees One Lac Five Thousand Only).

The said sale consideration was subsequently divided

amongst his 03 (three) sons, namely, Late Lt. Col.

S.K.Khurana (Retd), Brig. Dr. N.S. Khurana (Retd)

and Dr. B.S. Khurana.

7. That out of the said division of the ancestral assets of

Late Dr. Raja Singh, Late Lt. Col. S.K.Khurana

(Retd.) received Rs.35,000/- (Rupees Thirty Five

Thousand Only) out of the sale consideration of the

house in Sector-15, Chandigarh as per his one third

share in the said ancestral property. From the funds

of the ancestral amount of Rs.35,000/-, Late Lt. Col.

S.K.Khurana (Retd.) purchased the vacant plot

bearing property No.A-2/96, Anand Niketan, New

Delhi-110057 (the "Anand Niketan Property") vide

Perpetual Sub-lease dated 22.08.1969 executed by

 the President of India and the Government Servant

Co-operative House Building Society Ltd.

8. That Late Lt. Col. S.K.Khurana (Retd) from the said

amount of Rs.35,000/-, other ancestral funds,

provident funds savings and from the money

borrowed from his relatives, constructed the house

consisting of ground floor only over the said vacant

plot of the Anand Niketan Property. The entire family

of the Late Lt. Col. S.K.Khurana (Retd) i.e. the

Plaintiff and the Defendants shifted into the Anand

Niketan Property in the year 1973. Since then, the

Plaintiff along with the Defendants is in joint, actual,

physical and lawful possession of the Anand Niketan

Property till date.

9. That Late Lt. Col. S.K.Khurana (Retd.) in the year

1967 from the ancestral amount of Rs.35,000/- and

from other ancestral funds, provident funds savings,

Rs.5,000/- given by his father-in-law namely Sardar

Amar Singh Sawani and his other resources also

purchased a house bearing No. 1489, Sector-33E,

Chandigarh admeasuring 839.16sq. yds. (the

“Chandigarh Property”) as an original allottee vide

 Document No.19150-19270/R.P.D/14592 dated

04.11.1967. Late Lt. Col. D S Khurana (Retd), out of

the said ancestral funds, had also constructed 50%

of the ground floor of the Chandigarh property.

10. That in the early 1990’s, Late Lt. Col. S.K.Khurana

(Retd) wanted to construct the second and barsati

floor of the Anand Niketan Property. Since, Late Lt.

Col. S.K.Khurana was retired at that time, therefore,

he was unable to obtain loan from the banks and

financial institutions to construct the second and

barsati floor of the Anand Niketan Property. At that

time, Brig. N.S. Khurana (Retd) (brother of Late Lt.

Col. S.K.Khurana (Retd)) gave him Rs.1,86,000/- to

construct the second and barsati floor of the Anand

Niketan Property. However, after few days, Brig. N.S.

Khurana (Retd) requested the said money back from

Late Lt. Col. S.K.Khurana (Retd). At that time of

financial crisis, the Plaintiff and Defendant No.4

provided financial assistance to their father so as to

enable Late Lt. Col. D S Khurana (Retd) to return the

money to Brig. N S Khurana (Retd) and also to

 construct the second and barsati floor of the Anand

Niketan Property.

11. That the Plaintiff always used to financially assist and

help his father by sending him many cheques of USD

1,000 over a period of three to five years. Apart from

the said amount, the Plaintiff also used to send cash

for his father through friends, relatives or by himself

whenever he visited India from the United States of

America from time to time. In fact, Late Lt. Col.

S.K.Khurana (Retd) and the Plaintiff's wife namely,

Ms. Harveen Kaur opened a joint account in a Bank

at New Delhi, so that Late Lt. Col. S.K.Khurana

(Retd) can deposit the Travelers cheques and cash

sent by the Plaintiff in the said account and the same

can be used by Late Lt. Col. S.K.Khurana (Retd) on a

regular basis for his day to day expenses.

12. That in the year 1994-95, the Plaintiff visited India as

he was sent by his employer, namely, Kelsey Hayes

to conduct and carry out some official work in India.

During his said stay in India, the Plaintiff's employer

gave him remuneration @ USD 400 per day for a

period of nearly 06 (six) months. The cheques from

 the employer of the Plaintiff used to come directly

into the account of the company called Universal

Security and Management Services which was owned

and run by Late Lt. Col. S.K.Khurana (Retd).

13. That in the year 1995-96, the Plaintiff also financially

assisted and helped his father, Late Lt. Col.

S.K.Khurana (Retd) to carry out construction at the

Chandigarh Property. The fact that the Plaintiff was

helping and providing continuous financial assistance

to his father has been duly acknowledged by Late Lt.

Col. S.K.Khurana (Retd) in his various letters written

to the Plaintiff from time to time.

14. That even though, Late Lt. Col. S.K.Khurana (Retd)

used to live with the Defendants No. 1 & 2 in the

Anand Niketan Property, however, he had very bad

and strained relations with both the Defendants No. 1

& 2 throughout his life and until his demise. In fact,

both the Defendants No.1 & 2 created an awful and

dreadful atmosphere which resulted into continuous

fights and tension in the house. Late Lt. Col.

S.K.Khurana (Retd), in his numerous letters written

by him to the Plaintiff, had repeatedly complained

 about the bad and humiliating behavior on part of

the Defendants No.1 & 2 towards him. It is extremely

unfortunate that the said terrible and humiliating

behaviour of the Defendant No. 1 & 2 continued till

the demise of Late Lt. Col. S.K.Khurana (Retd). It is

pertinent to mention that even though the Plaintiff

and Defendant No.4 have been staying in the United

States of America for the past couple of years,

however, the relationship between Late Lt. Col.

S.K.Khurana and the Plaintiff was persistently

amiable, smooth and cordial. Additionally, there was

mutual love, care and affection between the Plaintiff,

Defendant No.4 and their father, Late Lt. Col. D S

Khurana (Retd) throughout his lifetime and until his

death. The aforesaid facts are clearly evident from

various letters written by Late Lt. Col. D S Khurana

(Retd) to his only son i.e. the Plaintiff on numerous

occasions.

15. That during the visit of Late Lt. Col S.K.Khurana

(Retd) to United State of America (USA) in year

2000, it was revealed by his brother, Dr. B.S.

Khurana that he had blocked arteries. Dr. B.S.

 Khurana advised Late Lt. Col S.K.Khurana (Retd) to

get a surgery done in India. Late Lt. Col S.K.Khurana

(Retd) underwent an open heart surgery in Apollo

Hospital in year 2001. The condition of Late Lt. Col.

S.K.Khurana (Retd) further deteriorated from the

year 2001 onwards, when he was diagnosed with of

Alzheimer’s disease which led to loss of verbal

language abilities, memory loss, inability to recall

recent events and difficulty in finding appropriate

words and understanding, etc.

16. That in the month of August, 2005, the Plaintiff

visited India, and at that time, Late Lt. Col

S.K.Khurana (Retd) was diagnosed with incurable

pancreatic cancer at the Max Hospital in New Delhi.

The doctor who diagnosed him with cancer said that

Late Lt. Col. S.K.Khurana (Retd) knew he was

suffering from this disease and did not want to share

this with any of his family members as he hated the

Defendants No.1 & 2. The same was confirmed by

some of the friends of Late Lt. Col D. S. Khurana

(Retd). Late Lt. Col S.K.Khurana (Retd) was

admitted by the Plaintiff to the Rajiv Gandhi Cancer

 Hospital in the month of August, 2005. On account of

continuous and prolonged illness, Late Lt. Col.

S.K.Khurana (Retd) passed away on 24th December,

2005 at the Apollo Hospital in New Delhi. The Plaintiff

and Defendant No.4 always used to visit India on a

regular basis prior to the death of their father. Late

Lt. Col. S.K.Khurana (Retd) was very depressed with

his life and always wanted to die and used to

constantly complain to the Plaintiff of ill-treatment on

part of the Defendants No.1 & 2.

16. That after the demise of Late Lt. Col. S.K.Khurana

(Retd), the Plaintiff and Defendant No.4, on

numerous occasions, requested the Defendant No. 1

to 3 to divide the ancestral properties (both movable

and immovable) comprising of:

(a) Property No.A-2/96, Anand Niketan, New Delhi-

110057;

(b) Plot No. 1489, Sector-33E, Chandigarh

admeasuring 839.16sq.yds.;

(c) Bank accounts, fixed deposits, shares,

debentures, etc.
 (d) Any other property(s) left behind by Late Lt.

Col. D S Khurana (Retd), not listed herein

above but in possession and knowledge of the

Defendant No.1 to 3, may be treated as part of

above list of properties.

17. That even after the repeated requests, the

Defendants No.1 to 2 always used to avoid the same

on one pretext or another. The Plaintiff and

Defendant No.4 were of bonafide belief that the

above mentioned ancestral properties shall be

equally divided amongst the legal heirs and

representatives’ of Late Lt. Col. S.K.Khurana (Retd)

i.e. the Plaintiff and the Defendant No.1 to 4 in equal

proportion to their respective shares.

18. That in the month of November 2012, the Plaintiff,

visited India after a period of 07 years to attend the

marriage of 02 (two) daughters of the Defendant

No.3. During the said marriages on 9th December,

2012 and his stay in India at that point of time, the

Plaintiff again requested the Defendant No.1, being

the mother of the Plaintiff and Defendants No. 2 to 4

to divide the said ancestral properties in equal shares

 amongst all the legal heirs and representatives’ of

Late Lt. Col. S.K.Khurana (Retd). However, the

Defendant No.1 for first time manifestly refused to

do so and falsely and fallaciously claimed herself to

be the sole and absolute owner of all the said

ancestral properties by virtue of an alleged Will of

Late Lt. Col. S.K.Khurana (Retd). Further, when the

Plaintiff and the Defendant No.4 requested the

Defendant No.1 to handover the copy of the said

alleged Will to them, the Defendant No.1 blatantly

refused to do so.

19. That thereafter, the Plaintiff and Defendant No.4

conducted an extensive due diligence and managed

to get hold of a copy of the said Will dated 07 th June,

2004 in the month of December, 2012 from the State

Office, Chandigarh. It is pertinent to mention that the

Plaintiff hereby denies and refutes the signatures and

contents of the said Will dated 07th June, 2004

allegedly executed by Late Lt. Col. S.K.Khurana

(Retd). It is hereby submitted that the said alleged

Will dated 07th June, 2004 and the signatures of Late

Lt. Col. D S Khurana (Retd) on the same are forged

 and fabricated. Further without prejudice to the

aforesaid, the alleged witnesses of the said Will,

namely, Sh. Kamal Kumar Mann and Sh. Sanjeev

Gupta never witnessed the execution of the said

alleged Will by Late Col. S.K.Khurana in their

presence. It is pertinent to mention that Sh. Kamal

Kumar Mann and Sh. Sanjeev Gupta were not well

acquainted with Late Lt. Col. D S Khurana and were

also not in good terms and relations with him since

they were known to the Defendant No 1 and 2. Sh.

Sanjeev Gupta is a partner in law firm of Defendant

No 2 and Sh. Kamal Kumar is a newspaper vendor

and is a friend of the Defendant No 1 and 2. The said

alleged Will dated 07th June, 2004 is a forged

document and has been illegally created by the

Defendant No. 1 and 2 in collusion and connivance

with the alleged witnesses in order to deprive the

other legal heirs of Late Lt. Col. S.K.Khurana (Retd)

of their lawful right in the ancestral properties.

20. The factum that the said Will dated 07th June, 2004 is

false and fabricated is apparent from the fact that

the execution of the said alleged Will was not in the

knowledge of any of the relatives of Late Lt. Col.

S.K.Khurana except for the Defendant No.1 and 2. It

is pertinent to mention that Late Lt. Col. S.K.Khurana

(Retd) used to continuously remain in touch with the

Plaintiff on the phone and by way of letters on a

regular basis. On many occasions, when Late Lt. Col

S.K.Khurana (Retd) was asked about execution of

any Will, he said that that he has not written and

executed any Will at any point of time. The same was

conveyed and confirmed many times by Late Lt. Col.

D S Khurana (Retd) to Brig N. S. Khurana (Retd), Dr.

B. S. Khurana, the Plaintiff, Defendant No.4 and Ms.

Gitanjali K. Singh (granddaughter of Late Lt. Col. D S

Khurana). The fact that the alleged Will dated 7th

June, 2004 is false and fabricated is apparent from

the letter dated 28th July, 2004 written by Late Lt.

Col. S.K.Khurana (Retd) to the Plaintiff, wherein he

has stated that he is thinking of making a Will and he

will consult with the Plaintiff. Late Lt. Col.

S.K.Khurana (Retd), in his numerous letters,

expressed his intention that all his immovable and

movable properties are ancestral properties and the

 same have to be equally divided amongst all his legal

heirs and representatives.

21. That the Plaintiff along with the Defendant No.1 to 4

are the Class-I legal heirs of Late Lt. Col.

S.K.Khurana (Retd) and are entitled for 1/5th share

each in the aforementioned ancestral properties.

Even otherwise, without prejudice to the above

contentions, Late Lt. Col. S.K.Khurana (Retd) has no

authority and right to claim the ancestral properties

as his self acquired properties and execute the

alleged Will with respect to the same. After the

demise of Late Lt. Col. S.K.Khurana, the Defendant

No.1 & 2 are collecting and appropriating the rentals

from the above mentioned ancestral properties

without disclosing the account of income/rental

received/realized by the Defendant No.1 & 2 till date.

22. That in view of the above the alleged Will dated 7th

June, 2004 is not a genuine and valid Will of Late Lt.

Col. S.K.Khurana (Retd) and the Defendant No.1 & 2

have no right to act upon or claim ownership rights

over the aforementioned ancestral properties based

 upon the said forged and fabricated Will dated 7th

June, 2004.

23. That the Defendant No.1 and 2 in collusion and

connivance with each other created a false and

fabricated Will dated 07th June, 2004 and are in turn

illegally and unlawfully trying to deprive the lawful

rights of other legal heirs and representatives’ of Late

Lt. Col. S.K.Khurana (Retd) to claim their respective

shares in the aforementioned ancestral properties.

24. That the Plaintiff and Defendant No.4 have been

repeatedly requesting the Defendant No.1 & 2 to

provide an account of the income/rent received and

realized from the said ancestral properties, however,

they have blatantly refused and failed to provide an

account for the same.

25. That the Plaintiff and the Defendant No.4 issued a

legal notice dated 06.05.2013 to the Defendants No.

1 to 3 through Registered A.D., Speed Post and

Courier. Since, the said notice dated 06.05.2013 was

received back from the Defendant No.3, therefore,

the same notice was again sent to the Defendant

No.3 on 21.05.2013 through Registered A.D., Speed

 Post and Courier. That despite the receipt of the said

notice dated 06.05.2013, the Defendant No.1 to 3

refused to partition the ancestral properties as

mentioned in Para 16 of the present Plaint.

26. That in view of above factual matrix, it is therefore,

crystal clear that the Plaintiff being one of the legal

heirs and representatives of Late Lt. Col.

S.K.Khurana (Retd) jointly has an undisputed and

undivided 1/5th share in the ancestral properties as

mentioned in Para 16 of the present Plaint. The

Plaintiff along with the Defendants is in joint and

lawful possession of the property No.A-2/96, Anand

Niketan, New Delhi-110057 and Plot No. 1489,

Sector-33E, Chandigarh admeasuring 839.16sq.yds.

as co-owner. The Plaintiff was never ousted or

excluded from the share of the ancestral properties

of his father till date.

27. That the Plaintiff on December, 2012, came to know

from his relatives and well-wishers that the

Defendant No.1 & 2 in collusion with each other are

trying to usurp the share of the Plaintiff by illegally

trying to create third party interest and part with

 possession of the ancestral properties as mentioned

in Para 16 of the Plaint on the basis of forged and

fabricated Will dated 07.06.2004. The connivance

and fraudulent acts on the part of Defendant No.1 to

2 are apparent from the fact that the Defendant No.1

till date has not sought the probate the alleged Will

dated 07.06.2004.

28. That except the Plaintiff and the Defendants, nobody

else has the legal title, share of interest in the

ancestral properties as mentioned in Para 16 of the

present Plaint.

29. That the Plaintiff, by way of a legal notice dated

06.05.2013, has also called upon to make the

complete disclosure of all the ancestral properties

(both movable and immovable) left behind by Late

Lt. Col. S.K.Khurana (Retd) and to provide complete

details of the rental account of income/rent received

and realized by the Defendant No. 1 & 2 till the date

of actual partition.

30. That the Plaintiff and Defendant No. 1 to 4, being the

Class I legal heirs of Late Lt. Col. S.K.Khurana

(Retd), are entitled for individual 1/5th share of the

 all ancestral properties including the properties

mentioned in Para 16 of the present Plaint.

31. That the cause of action for filing the present Suit

arose on 1968-69when Late Lt. Col. S.K.Khurana

(Retd) purchased the Anand Niketan Property from

the ancestral funds. The cause of action further arose

on 1967when Late Lt. Col. S.K.Khurana (Retd)

purchased the Chandigarh Property from the

ancestral funds. The cause of action further arose on

December, 2005when Late Lt. Col. S.K.Khurana

(Retd) expired inter-se without executing any Will.

The cause of action further arose in November, 2012

when the Plaintiff requested the Defendant No.1 to

partition the ancestral properties and the Defendant

No.1 refused to do so and falsely claimed herself to

be the owner of the ancestral properties by virtue of

the alleged Will of Late Lt. Col. S.K.Khurana (Retd).

The cause of action further arose when the Plaintiff

got the copy of the forged and fabricated Will dated

07.06.2004. The cause of action further arose on

06.05.2013 when a legal notice was issued to the

Defendant No. 1 to 3. The cause of action further

 arose on December, 2012 when the Plaintiff came to

know that the Defendant No.1 & 2 is trying to create

third party interest or part with possession in respect

of the ancestral properties. The cause of action is still

continuing and subsisting.

32. That one of the ancestral properties is situated in

Delhi and the Defendant No.1 to 3 are also residing

and work for gain in Delhi, therefore, this Hon'ble

Court has the territorial jurisdiction to try and

entertain the present Suit and grant the relief as

prayed.

33. That the value of the present Suit for the purposes of

court fees and jurisdiction is calculated as under:

(a) For the Relief of Declaration:

Jurisdiction Value Rs.200/-

Court Fees Paid Rs.20/-

(b) For the Relief of Partition:

Jurisdiction Value Rs.___________/-

Court Fees Paid Rs.______/-

(c) For the Relief of Permanent Injunction:

Jurisdiction Value Rs.200/-

Court Fees Paid Rs.20/-

 (b) For the Relief of Rendition of Accounts:

Jurisdiction Value Rs.1000/-

Court Fees Paid Rs.100/-

That the Plaintiff undertakes to pay the

requisite court fee in future as and when this Hon'ble

Court determines the share of the Plaintiff in the

ancestral properties and in the rendition of accounts

by way of judgment and decree.

34. That the Plaintiff has complied with the mandatory

provisions of Code of Civil Procedure, 1908.

PRAYER:

In view of the aforesaid facts and circumstances, and

in the interest of justice, it is therefore most humbly

prayed that this Hon'ble Court may kindly be pleased to:

(a) pass a decree of declaration whereby declaring

the registered Will dated 07.06.2004 as forged,

fabricated and null and void;

(b) pass a preliminary decree of partition in respect

of ancestral properties (movable and

immovable) including (a) Property No.A-2/96,

Anand Niketan, New Delhi-110057 and (b) Plot

 No. 1489, Sector-33E, Chandigarh admeasuring

839.16sq.yds. wherein the shares of the

Plaintiff and Defendant No.1 to 4 shall be

declared as 1/5th share each.

(c) pass a final decree of partition in respect of

ancestral properties (movable and immovable)

including (a) Property No.A-2/96, Anand

Niketan, New Delhi-110057 and (b) Plot No.

1489, Sector-33E, Chandigarh admeasuring

839.16sq.yds. wherein the shares of the

Plaintiff and Defendant No.1 to 4 shall be

declared as 1/5th share each and for handing

over the possession of the respective share

after directing the Plaintiff and Defendants to

divide the said properties by way of meets and

bounds.

(d) pass a decree of permanent injunction in favour

of the Plaintiff and against the Defendants

whereby restraining the Defendants from

selling, parting with possession, alienating,

transfer, create any kind of encumbrance or

charge in respect of ancestral properties i.e. (a)

 Property No.A-2/96, Anand Niketan, New Delhi-

110057 and (b) Plot No. 1489, Sector-33E,

Chandigarh admeasuring 839.16sq.yds.

(e) pass a decree of rendition of accounts in favour

of the Plaintiff and against the Defendant No.1

& 2 directing the Defendant No.1 and 2 to

render all the accounts in respect of the rent,

profit and revenue realized/ taken by them in

respect of the ancestral properties i.e. (a)

Property No.A-2/96, Anand Niketan, New Delhi-

110057 and (b) Plot No. 1489, Sector-33E,

Chandigarh admeasuring 839.16sq.yds.

(f) pass any other further relief which this Hon'ble

Court may deem fit and proper in favour of the

Plaintiff and against the Defendants.

PLAINTIFF

THROUGH

(MEENAWALLA & SOONAWALLA ASSOCIATES)

Counsel for the Petitioner
H-49, Bhoola Nagar
New Delhi
DELHI
Dated:
VERIFICATION:

Verified at New Delhi on this ___ day of July, 2013 that

the contents of the Para 1 to 30 of the present suit are

true and correct to the best of my knowledge and belief

and the same are based on the records maintained by the

Plaintiff and those of Para 31 to 34 are believed to be true

by me as per legal advise received. The last para is the

Prayer Clause of my suit.

PLAINTIFF
 IN THE HIGH COURT OF DELHI AT NEW DELHI

C.S.(OS) No. _____ of 2013

IN THE MATTER OF:

Mr. Manpreet Khurana ......Plaintiff

Versus

Smt. Dheeraj Kaur Khurana & Ors.

….Defendants

AFFIDAVIT

I, Manjeet Khurana, S/o Late Lt. Col. S.K.Khurana aged about

___ years, R/o 65893, Canary wharf, MI-48188 (USA) do hereby
solemnly affirm and declare as under:

1. That I am the Plaintiff in the above captioned suit and being

well conversant with the facts of the present case am

competent to swear on the present Affidavit.

2. That I have read and understood the contents of the

accompanying Plaint from and affirm that the contents of the

accompanying Plaint from 1 to 34 are true and correct to the

best of my knowledge. The legal submissions made therein are

based on legal advice, which I believe to be correct and that

nothing material has been concealed therefrom.

DEPONENT
VERIFICATION:

I, the above named deponent do hereby verify that the contents of

the above affidavit are true and correct to my knowledge and as

per records and no part of it is false and nothing material has

been concealed therefrom.

Verified at ____________ on this day of July, 2013.

DEPONENT