CLINICALPAPER II- DRAFTING, PLEADING AND

CONVEYANCING

GROUP III

SUBMITTED BY

AISHWARYA R GEDDADA

Register No. BA0150004

SUBMITTED TO

Professor K. Govindarajan

Professor of Law, TNNLU

TAMIL NADU NATIONAL LAW UNIVERSITY

MAY 2019

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 DECLARATION

I do hereby declare that the assignment entitled “Drafting, Pleading and Conveyance”
submitted to the Tamil Nadu National Law School in fulfillment of the requirement of the
internal component is a record of the original work done by me under the supervision and
guidance of Prof. K. Govind Rajan and that the project submitted has not been formed on
the basis of any other project submitted by any other university or college.

Place: Tiruchirappalli

Date: 02/05/2019

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 ACKNOWLEDGEMENT

The contributions of the Group members with the help of Prof. K. Govindarajan have made
this possible. I would like to extend my appreciation especially to the following. My fellow
friends, for their continual support and encouragement throughout, Prof. K Govindarajan,
without his guidance, I would not be able to put the topic together. The experience has been
an interesting and rewarding one. I would also like to thank all those people who directly
or indirectly helped me throughout the project.

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 TABLE OF CONTENTS

CONVEYANCING
S. NO. NAME OF THE DEED PAGE
NO.

1. SALE DEED 3

2. MORTGAGE DEED 11

3. DEED OF LICENSE 17

4. DEED OF HIRE- PURCHASE 21

PLEADINGS
S.NO. NATURE OF PLEADINGS PAGE
NO.

1. SUIT ON A PROMISSORY NOTE 28

2. FILING OF A WRITTEN STATEMENT 32

3. SUIT FOR GOODS SOLD AND DELIVERED 34

4. SUIT AGAINST A COMMON CARRIER 37

5. APPLICATION FOR APPOINTMENT OF COMMISSIONER 41

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CONVEYANCING

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 SALE DEED

PROBLEM-1

Mukesh is the absolute owner of the house property worth Rs. 80 lakhs located at Adyar,
Chennai. He is interested in selling the property to any potential purchaser of property at
Chennai and with that in mind he approaches G. Gunasekaran. Both the parties agreed in
this regard. Render help to the parties by drafting an appropriate Sale Deed.

DEED OF SALE

N. Mukesh, s/o P. Natarajan, aged about 52 years, residing at No.15 MG Road, Adyar,
Chennai- 600020, hereinafter called the “VENDOR” (which term shall mean and include
all his legal heirs, executors, representatives, assigns etc.) of the ONE PART AND Thiru.
G. Gunasekaran, son of Thiru. K. Gandhi, aged about 45 years and residing at No.32, Rajaji
II Street, Nungambakkam, Chennai-600 090, hereinafter called the 'PURCHASER' (which
term shall mean and include all his legal heirs, executors, representatives, assigns etc. of
the OTHER PART.

Explanation 1: This part of the deed represents the Preamble part of the deed. In this part,
description of the deed, date of the deed and other particulars of the parties have been
stated in full.

WHEREAS the vendor is the absolute owner of the property consisting of a house property
covering an extent of 1 acre, bearing R.S. No.2625/23, located in Adyar, Chennai-600 020,
more fully described in the Schedule hereunder, him having acquired the same from Thiru.
P. Ramesh, by way of sale in the year 2004 and registered with the Sub-Registry at Adyar,
Chennai, evidenced by Sale Deed No.1420/04.

Explanation 2: This part of the deed is the introductory recital where the property for the
transfer is absolute which is ascertained by the tracing of the title.

WHEREAS, the vendor is desirous of disposing off by way of sale the property consisting
of a vacant land covering an extent of 1 acre, bearing R.S. No.2625/23, located in Adyar,

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Chennai-600 020, more fully described in Schedule hereunder, since the said house
property is no longer required for their use.

Explanation 3: This part of the deed conveys the intention of the transferor to transfer the
scheduled property to the transferee.

WHEREAS the purchaser having learnt that the vendor is desirous of disposing off by way
of sale their property consisting of house covering an extent of 1 acre, bearing R.S.
No.2625/23, located in Adyar, Chennai-600 020, more fully described in Schedule
hereunder, approaches the vendor with a view to purchasing the same.

Explanation 4: This part of the deed denotes the intention of the purchaser in purchasing
the scheduled property from the vendor.

WHEREAS, the vendor and purchaser having carried out negotiations for the Sale and
Purchase respectively of the property consisting of a house and covering an extent of 1
acre, bearing R.S. No.2625/23, located in Adyar, Chennai-600 020, more fully described
in the Schedule hereunder; the vendor having agreed to sell the property and the purchaser
having agreed to purchase the same for a total consideration of RS.80 lakhs.

Explanation 5: In this part of the deed, the parties of the deed have carried out negotiations
for the sale and the purchase of the scheduled property and also have fixed the
consideration that is to be paid to the vendor by the purchaser.

WHEREAS, in pursuance of the agreement arrived at between the Vendor and Purchaser
as regards sale and purchase respectively of the property, more fully described in the
Schedule hereunder, the purchaser having paid to the vendor a sum of Rs. 44 lakhs (Rupees
fortyfour lakhs only), being the advance amount, on 28th February, 2019, under an
agreement to sell was entered therefor.

Explanation 6: This part of the deed denotes the advance amount that has been paid to the
vendor by the purchaser which was agreed upon in an agreement to sell entered into prior.

NOW THIS DEED WITNESSES THAT IN CONSIDERATION OF the vendor having

agreed to sell and the purchaser of a house property, bearing R.S. No.2625/23, more fully

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described in Schedule hereunder, the Purchaser having paid an advance amount of
Rs.44,00,000/- on 28th February, 2019, when an agreement to sell was entered between the
parties; the purchaser having paid on the day of the execution of this deed, the balance sum
of Rs. 36,00,000/- (Rupees Thirty six lakhs only) to the vendor, which sum the vendor
acknowledges of having received; and thus, the total consideration of RS.80 lakhs having
been received by the vendor; the vendor does hereby convey unto the purchaser absolutely
all the title and interests in the Schedule mentioned property and further, the vendor also
delivering vacant possession of the said house property to the purchaser to enable the
purchaser to enjoy the said property absolutely and without any interruption of whatsoever
nature.

Explanation 7: This part of the deed is the testatum which denotes the consideration for
the property and the advance amount and also the nature of the transfer which is an
absolute transfer to the purchaser.

TO HAVE AND TO HOLD the property by the purchaser absolutely and forever and
without any encumbrance of whatsoever nature.

Explanation 8: This part of the deed is the habendum which denotes the nature and effect
of the transfer and in this case it’s an absolute transfer free from any kind of encumbrances.

THAT the vendor and purchaser hereby mutually covenant as follows:

1. The vendor hereby assures the Purchaser that the property hereby sold to the Purchaser
is free from all encumbrances and that if any subsisting is found to be there, the same shall
be discharged at the expenses of the Vendor.

2. The Vendor hereby declares that in respect of the property sold by him to the Purchaser,
he shall pay all the taxes and other levies due on the property up to the date of execution
of this Sale Deed and that the Purchaser shall pay the taxes and dues falling due hereafter.

3. The Purchaser shall apply to the appropriate authorities and arrange to carry out the
change of name required in all the necessary records and for this purpose, the Vendor is
always in readiness to give consent and affix their signature.

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4. The Vendor hereby declares that he surrendered all the parent deeds connected with
the property and that no document is retained by him.

Explanation 9: This part of the deed contains the covenants which are detailed for the
enforcement of the deed.

IN WITNESS WHEREOF, the parties hereto have set their hands on this, the 7th day of
March, 2019.

Explanation 10: This part of the deed is the testimonium where the parties confirm the act
of the transfer through signatures affixed by the parties and two witnesses.

Dated at Adyar, this 7th day of March, 2019.

WITNESS

(1) Sd/- xxxxxxxxxxxx Sd/

xxxxxxxxxxxx

(R. Aditi Balaji, No. 10, OCD Apartments, (N. Mukesh)

Gopalapuram, Chennai 600054)

2) Sd/- xxxxxxxxxxxx Sd/-

xxxxxxxxxxxx

(K. Abilash, No. 12, PTSD Flats) (G. Ganesan)

Gopalapuram, Chennai 600054

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 SCHEDULE OF PROPERTY

All that piece and parcel of land including all trees and bushes covering covering an
extent of 1 acre, bearing R.S. No.2625/23, located in Adyar, Chennai-600 020, and
bounded on,

NORTH by 40 Feet Road leading to Chennai City

SOUTH - by a house Door No.17, bearing R.S. No. 2624/23 and belonging to N.
Muralidhar

WEST – by a house Door No.18, bearing R.S. No. 2624/23 and belonging to N. Rajeev
Rao, and having a right of entry to the property from this side.

EAST - by a 100 Feet Road leading to Thiru Murugan Kovil and situated within the
Registration and Sub-Registration District of Adyar.

Dated at Chennai, this the 7th day of March, 2019.

(Sd/-) xxxxxxxxxxx

N. Mukesh

Explanation 11: This part of the deed represents the Schedule and the detailed purpose
for identification of the property.

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 MORTGAGE DEED

PROBLEM-2

Mani is the absolute owner of a house property worth Rs. 80 Lakhs located at Tambaram,
Chennai. He is in need of Rs. 40 Lakhs for starting a business and thereof he is interested
in creating a Usufractory mortgage of house property. Kannan residing at Madurai is
willing to give Rs. 40 Lakhs with a condition that Mani offers his immovable Property as
a security and repay debt amount in 2 years. Both the parties agree in this regard and they
approach you to draft an appropriate usufractuary mortgage deed.

MORTGAGE DEED

This DEED OF MORTGAGE executed this, the 11th day of March, 2019 BETWEEN

M/S R. Mani, aged about 36, residing at No.25 Patullos Road, Chennai- 600002,
hereinafter called the “Mortgagor” (which term shall mean and include all their legal heirs,
executors, representatives, assigns etc.) of the ONE PART AND Thiru. S. Kannan, son of
Thiru. M. Raj, aged about 45 years and residing at No.50, I Cross Street Anna Nagar,
Tambaram, Chennai-600 090, hereinafter called the “Mortgagee” (which term shall mean
and include all his legal heirs executors, representatives, assigns etc. of the OTHER PART.

Explanation: This paragraph represents the preamble part of the deed containing date of
the deed, description of the deed, identity particulars of the respective parties. This is the
introductory as well as the most important part of the deed since the term with which the
parties are to be referred throughout the deed has been mentioned. This para also mentions
the people who will be considered as “Mortgagor” and also the people who is to be
considered as the “Mortgagee”.

WHEREAS the mortgagor is the absolute owner of the property consisting of house
covering an extent of 2.75 acres, bearing R.S. No.35645/85, located in Tambaram Village,
Chennai-600 090, more fully described in the Schedule hereunder, they having acquired
the same from Thiru. R. Kannan, by way of sale in the year 1992 and registered with the
Sub-Registry at Tambaram Village, Chennai, evidenced by Sale Deed No.2020/92.

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Explanation: This paragraph is the introductory recital wherein the type of property that
is being transferred from one party to the other is described. The paragraph contains the
details of the property stating the measuring value of the property as well as the precise
location.

WHEREAS, the mortgagor is desirous of mortgaging by way of an usufructuary mortgage

on the property consisting of house property covering an extent of 2.75 acres, bearing R.S.
No.35645/85, located in Tambaram Village, Chennai-600 090, more fully described in
Schedule hereunder.

Explanation: This paragraph declares that the mortgagor has been fulfilling his duties in
the capacity of the “Sole and Absolute owner” since he acquired the property.

WHEREAS, the mortgagor and mortgagee having carried out negotiations for the
usufructuary mortgage of the property consisting of house property and covering an extent
of 2.75 acres of land, bearing R.S. No.35645/85, located in Tambaram Village, Chennai-
600 090, more fully described in the Schedule hereunder; the mortgagor having agreed to
mortgage the property and the mortgagee having agreed to mortgage the same for a total
consideration of RS.40 lakhs.

Explanation: This paragraph declares that an agreement to mortgage is made between the
parties and states the amount advanced by the Mortgagee to the Mortgagor in course of
the agreement of simple mortgage.

NOW THIS DEED WITNESSES THAT IN CONSIDERATION OF the mortgagor having

agreed to sell and the mortgagee of a house property, bearing R.S. No.35645/85, more fully
described in Schedule hereunder, the Mortgagee having paid an amount of Rs.40,00,000/-
on 11th March, 2019,when an agreement for usufructuary mortgage was entered between
the parties; the mortgagee having paid on the day of the execution of this deed, the sum of
Rs. 40,00,000/- to the mortgagor, which sum the mortgagor acknowledges of having
received; and thus, the total consideration of RS.40 lakhs having been received by the
mortgagor; the mortgagor does hereby convey unto the mortgagee absolutely all the title
and interests in the Schedule mentioned property and further, the mortgagor also delivering
vacant possession of the said property to the mortgagee to enable the mortgagee to enjoy

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the said property absolutely and without any interruption of whatsoever nature if the
mortgagor fails to repay the Rs. 40 lakhs amount back to the mortgagee within a period of
two years from the date of execution of this deed.

Explanation: This is the operative part since it states about the complete transfer of interest
on property between the Mortgagor and the Mortgagee. This part states about the amount
and interest to be paid by the Mortgagor to the Mortgagee with respect to the Mortgage
agreed between them. It declares the amount interest and due date on which the interest is
to be paid by the Mortgagor to the Mortgagee. This part also declares the alternative in
case of Mortgagor failing to pay the installment of interests. This part states about the
agreement of simple Mortgage being finalized between both the parties and as such it
constitute a valid legal transfer.

TO HAVE AND TO HOLD the property by the mortgagee for the period of two years.:

THAT the Mortgagor and Mortgagee hereby mutually covenants as follows:

1. In the event of the Mortgagor failing to pay the said principal sum with all interest and
other moneys when the same shall become due and payable under these presents, the
Mortgagee will become entitled to have the said scheduled property sold through any
competent court and to realize and receive the said mortgage amount out of the net sale
proceeds of the said scheduled property.

Explanation: This clause describes the alternative in the event of the Mortgagor failing to
pay the said principal sum with all interest and other moneys.

2. The Mortgagor shall be liable to pay and shall pay all the costs, charges and expenses
that the Mortgagee will incur for the protection of the mortgage security and for the
realisation of the mortgage amount and the same shall be deemed to form part of the
mortgage amount and the security there for as aforesaid.

Explanation: This clause explains the liability of the Mortgagor for the expense incurred
for the protection of the Mortgage Security and the nature of such amount being paid.

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3. During the pendency of the security hereby created and until repayment of the mortgage
amount, the Mortgagor will get insured and keep insured the buildings and structures
standing on the said land against loss and damages due to fire or any other accident in the
sum of at least Rs. 5,00,000/- With some Insurance Company of repute and pay all premium
n the insurance policy as and when it becomes due and payable in respect thereof to such
company and shall hand over the policy to the Mortgagee duly endorsed in his name as
assignee and in the event of the Mortgagor failing to do so or to pay the premium, the
Mortgagee will be entitled to insure the said buildings and structures and/or to pay the
premium thereon and the amount paid by the Mortgagee in respect thereof will be deemed
to form part of the mortgage amount.

Explanation: This clause explains about the liability of the Mortgagor to insure the
buildings and structures standing on the scheduled until repayment of the Mortgage
amount.

4. And it is further agreed that in the event of the said scheduled property being destroyed
or damaged by fire or any accident as aforesaid. The Mortgagee will be entitled to receive
the insurance claim under such policy to the exclusion of the Mortgagor and to appropriate
the same first towards all arrears of interest and then the principal amount or as any part
thereof as may be sufficient to pay the mortgage amount due and if any surplus remains
the same only will become payable to Mortgagor.

Explanation: This clause explains the entitlement of the Insured amount in the event of any
contingency.

IN WITNESS WHEREOF, the parties hereto have set their hands on this, the 11th day of
March , 2019.

Explanation: This paragraph represents the testimonium whereby it confirms their consent
to agreement by affixing the signature and the same has been attested by witnesses as
required by law.

Dated at Tambaram, this 11h day of March, 2019.

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WITNESS

(1) Sd/- xxxxxxxxxxxx Sd/

xxxxxxxxxxxx

(Name and Address)

(Mani)

2) Sd/- xxxxxxxxxxxx Sd/-

xxxxxxxxxxxx

(Name and Address) (Mani)

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 SCHEDULE OF PROPERTY

All that piece and parcel of land including all trees and bushes covering an extent of
house property to 3 acres, bearing R.S. No.35645/85, located in Tambaram Village,
Chennai-600 090, and bounded on,

NORTH by 100 Feet Road leading to Chennai City

SOUTH - by a house Door No.23, bearing R.S. No.1605/85 and belonging to N.

Murugesan

WEST – by a house Door No.24, bearing R.S. No.1609/85 and belonging to A. Ganesan,
and having a right of entry to the property from this side.

EAST - by a 40’ road leading to Murugan Temple and situated within the Registration
and Sub-Registration District of Tambaram.

Dated at Chennai, this the 11th day of March, 2019.

(Sd/-) xxxxxxxxxxx

(Mortgagor)

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 DEED OF LICENSE

PROBLEM-3

David is the owner of a grove consisting of 150 trees comprised in 8 acres of land in
maracana village, Torino District. Luiz, a carpenter, is in need of teak wood to be used in
manufacture of doors. David desires to permit Luiz to cut the teak woods grown in his land
and further desires that Luiz completes the task of felling the trees within a period of 50
days. In view of this arrangement between them, they approach you to draw up a License
Deed. Render help to the parties.

LICENSE DEED

This DEED OF LICENSE executed this, the 19th day of March, 2019 BETWEEN

Mr. David, aged about 46, residing at No.21 Maracana Village, Torino district Torino -
73848, hereinafter called the “LICENSOR” (which term shall mean and include all their
legal heirs, executors, representatives, assigns etc.) of the ONE PART AND Mr. Luiz, son
of Mr. Mariano, aged about 38 years and residing at No. 48 Naples Road Torino,
hereinafter called the 'Mortgagor' (which term shall mean and include all his legal heirs
executors, representatives, assigns etc. of the OTHER PART.

Explanation 1: This Part of the deed represents the preamble. In this part the description
of the deed, date of the deed and other details of the parties have been stated in full

WHEREAS the Licensor is the absolute owner of the property consisting of orchard
covering an extent of 3 acres, bearing R.S. No.1600/85, located in Maracana Village,
Torino District, more fully described in the Schedule hereunder, they having acquired the
same from Thiru. R. Kannan, by way of sale in the year 1992 and registered with the Sub-
Registry at Uttarkhand, Deharadun evidenced by Sale Deed No.2020/92.

WHEREAS, the Licensor is desirous of giving the right to the use of orchards by way of
licensing the property consisting of groves covering an extent of 2.66 acres and 50 trees,
bearing R.S. No.1600/85, located in Maracana village, Torino district, more fully described
in Schedule hereunder, since the said property is no longer required for their use.

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WHEREAS the Licensee having learnt that the Licensor is desirous of licensing their
property consisting of orchard covering an extent of 3 acres, bearing R.S. No.1600/85,
located in Maracana Village, Torino District, more fully described in the Schedule
hereunder, approaches the Licensor with a view to licensing the same.

WHEREAS, the Licensor and Licensee having carried out negotiations for the Licensing
of the property consisting of an orchard and covering an extent of 2.66 acres of land,
bearing R.S. No.1600/85, located in Maracana Village, Torino District, more fully
described in the Schedule hereunder; the Licensor having agreed to license the property
and the Licensee having agreed to the same for a total consideration of RS 6,70,000/-.

WHEREAS, in pursuance of the agreement arrived at between the Licensor and Licensee
as regards licensing and purchase respectively of the property, more fully described in the
Schedule hereunder, the Licensee having paid to the Licensor a sum of Rs.3 lakhs (Rupees
three lakhs only), being the advance amount, on 14th March, 2019, under an agreement to
license was entered therefor.

NOW THIS DEED WITNESSES THAT IN CONSIDERATION OF the Licensor having

agreed to License an orchard, bearing R.S. No.1660/85, more fully described in Schedule
hereunder, the Licensee having paid an advance amount of Rs.3,00,000/- on 30th June,
2019,when an agreement to license was entered between the parties; the Licensee having
paid on the day of the execution of this deed, the balance sum of Rs. 6,70,000/- to the
Licensor, which sum the Licensor acknowledges of having received; and thus, the total
consideration of having been received by the Licensor; the

TO HAVE AND TO utilise the property by the Licensor for a period of 50 days without
any encumbrance of whatsoever nature.

THAT the Licensor and Licensee hereby mutually covenant as follows:

1. The Licensor hereby assures the Licensee that the property licensed to the Licensee is
free from all encumbrances and that if any subsisting is found to be there, the same shall
be discharged at the expenses of the Licensor.

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2. The Licensor hereby declares that in respect of the property licensed to the licensee, he
shall pay all the taxes and other levies due on the property up to the date of execution of
this Licensing Deed and that the Licensee shall pay the taxes and dues falling due hereafter.

3. The Licensee shall not cause any damage to the scheduled property licensed to him nor
use it for any other purpose than the purpose stated in the licensing deed. If so, then the
licensing deed stands terminated.

4. The Licensee should hand over the licensed property mentioned in the schedule
hereunder on the day of completion of the term of license without any damage to the
property mentioned in the schedule.

Explanation – This clause includes the restrictive covenants placed on the licensee

IN WITNESS WHEREOF, the parties hereto have set their hands on this, the 3rd day of
March, 2019.

Explanation: This part of the deed deals with the Testimonium part of the deed, and
portrays act of transfer which is done between the parties to the sale deed. It is confirmed
by both the witnesses affixed along with signature

Dated at Tambaram, this 19th day of March, 2019.

WITNESS

(1) Sd/- xxxxxxxxxxxx Sd/

xxxxxxxxxxxx

(Gianluca Vialli) (David)

2) Sd/- xxxxxxxxxxxx Sd/-

xxxxxxxxxxxx

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(Francesco Totti) (Luiz)

SCHEDULE OF PROPERTY

All that piece and parcel of land including all trees and bushes covering an extent of
vacant land to 2.66 acres, bearing R.S. No.1600/85, located in Maracana Village, Torino
District, and bounded on,

NORTH by 100 Feet Road leading to Naples express way

SOUTH - by a house Door No.23, bearing R.S. No.1605/85 and belonging to Antonio
Conte

WEST – by a house Door No.24, bearing R.S. No.1609/85 and belonging to Alberto
Aquilani, and having a right of entry to the property from this side.

EAST - by a 40’ road leading to Basils Cathedral and situated within the Registration and
Sub-Registration District of Maracana.

Dated at Torino, this the 3rd day of March, 2019.

(Sd/-) xxxxxxxxxxx

(Licensor)

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 HIRE-PURCHASE AGREEMENT

PROBLEM-4

Rahul hires a washing machine from Bajaj Electronics, a sole proprietary concern, for a
period of 2 years, during which rent will be paid by Rahul, monthly. However, Rahul while
making the last payment of Hire- Charge, also exercises an option to purchase the said
machine taken on hire for which Balaji Electronics agrees. Draft a Hire- Purchase
agreement for the same.

This AGREEMENT OF HIRE-PURCHASE made at Chennai this 15th day of March

2019 BETWEEN

Mr. G. Rahul S/o Mr. Bhashyam, resident of Flat No. 10, Pragati, Chennai 600034
(hereinafter called “the owners”) of the ONE PART and Balaji Electronics, registered
office at Flat No. 112, Nagar Bhaavi, Chennai 600026 (hereinafter called “the hirer”) of
the OTHER PART.1

WHEREAS the owner is the absolute owner of the Washing Machine, and runs an
electronic shop for the sole purpose of letting it our to people desirous to hire.2

WHERAS, the hirer has approached the owner to let the said machine on hire to him, to
which the owner has agreed for enjoyment possession of the said machine.3

WHEREAS the owner has further assured the hirer that he shall have the right to sell the
said machine at the time the property is to pass and the said machine is free from any charge
or encumbrances in favor of any third party at the time when the property is to pass.4

1
This Part of the deed represents the preamble. In this part the description of the deed, date of the deed and
other details of the parties have been stated in full
2
This part represents the business of the owner and why he is letting the machine out
3
This part of the deed represent the intention of the hirer to hier the machine
4
This part reiterates the ownership of the owner

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WHEREAS the hirer has inspected the said Washing Machine and is satisfied about the
same and considers it fit for the purposes for which he requires the same.

NOW IT IS AGREED BETWEEN THE PARTIES AS FOLLOWS:5

1. The owner will let and the hirer will take on hire the Washing Machine.

2. The owner has delivered the said machine to the hirer and allowed the hirer to use the
said machine in the usual manner.

3. In consideration of the delivery of the said machine to the hirer, the latter has paid in
advance a sum of Rs. 3000 as first installment on the hire (the receipt whereof the owner
hereby acknowledges) and will punctually pay to the owner at his place the sum of Rs.4,000
every calendar month by way of rent for the hire of the said machine, the first payment to
be made on the 1st day of January and each subsequent payment on the 1st day of every
succeeding month.

4. During the continuance of hiring, the hirer shall-

(i) Not sell, assign, pledge, mortgage, underlet, lend or part with the possession of the said
machine and not allow the said machine to be used by anybody else or kept or detained or
run for the use of any other person.

(ii) Not take the said machine out of the city of Chennai unless he has obtained permission
in writing from the owner in that behalf and if the owner grants permission subject to
certain terms and conditions, the hirer shall abide by all the terms and conditions imposed
in respect of such permission.

(iii) Pay all license duties, fees, registration and other charges taxes, payable in respect of
the said machine and keep the said machine in a good repair condition and working order
and will permit the owner and persons authorized by him to have access to the said machine
for the purpose of inspecting the condition thereof. In case the hirer fails or neglects to
cause the said machine to be repaired or kept in a proper state of repair, the owner shall be
entitled but shall not be bound to do, so, to seize or cause the said machine to be seized and

5
This part enlists the agreement entered hitherto by the parties

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to get the same repaired and to keep the said machine in his custody till the hirer pays the
bills for repair of the said machine.

(iv) Keep the said machine insured and kept insured so long as the hiring shall continue in
the joint names of the owner and the hirer against all risks and the hirer shall pay all the
premiums payable to the insurance company. On the hirer becoming the owner of the said
machine under the terms of this agreement, the owner will transfer to the hirer the benefit
of any insurance policy then current relating to the said machine.

(v) Make good to the owner all damages to the said machine (fair wear and tear excepted)
and pay the owner the full value of the said machine in the event of its total loss.

(vi) Indemnify the owner against claims by third parties arising by accident caused by the
said machine until the said machine is returned to the owner or purchased by the hirer in
terms of this agreement.

(vii) Not use or permit or suffer the said machine to be used in contravention of any law
for the time being in force.

4. If the hirer shall duly observe and performs all the conditions herein contained and on
his part to be observed and performed and shall pay to the owner the sum specified in
clause 3 hereof, together with all other sums if any payable by him to the owner under the
provisions of this Agreement, then the hiring shall come to an end and the said machine
shall become the property of the hirer and the owner will assign and make over all his rights
and interest in the same to the hirer, but the hirer shall have the option of purchasing the
said machine at the time of payment of last hire charge by paying in one lump sum the
balance. Untill all such payments as aforesaid have been made, the said machine shall
remain the property of the owner.

5. The hirer may at any time terminate the hiring by returning the said machine at his own
cost and risk to the owner at his place of address for the time being.

6. If the hirer shall make default in payment of any monthly sum payable hereunder for 5
days after the same have become due or shall fail to observe or perform any of the terms
and conditions of this agreement, the owner may without prejudice to his claim for arrears

Page | 23
of hire or damages (if any) for breach of this agreement forthwith terminate the hiring
without notice and retake physical possession of the said machine himself or through his
agents or servants and the hirer shall not object to the retaking of possession of the said
machine by the owner or his agents or servants and/or by written notice to the hirer
determine this agreement and the hiring hereby constituted. On such termination, the hirer
shall immediately return the said machine to the owner at his place of address for the time
being and the hirer shall pay the owner a sum of Rs. 6000 every month until the said
machine is returned to the owner.

7. No neglect, delay or indulgence on the part of the owner in enforcing any terms or
conditions of this agreement shall prejudice the rights of the owner hereunder.

8. The agreement is personal to the hirer and the rights of the hirer shall not be assignable
or chargeable by him in favor of third party.

9. In the event of the hiring being determined by the hirer or by the owner under clause 6
hereof, the hirer shall forthwith return the said machine to the owner at the hirer’s expense.
The determination of the hiring as aforesaid shall not affect or prejudice any claim the
owner may have against the hirer for arrears of hire payments or for damages for breach of
this agreement or his right to enforce such claim by action or otherwise.

10. The agreement shall determine if the hirer commits any act of bankruptcy or makes any
arrangement with his creditors or on presentation of a petition in the court for adjudicating
the hirer as an insolvent or on the appointment of a receiver of the properties of the hirer
or if an application is made by any creditor or other person against the hirer for the
attachment of the said machine.

11. The parties hereby admit that this agreement has been fully explained to them and they
have understood the meaning of all the clauses of this agreement and they have signed this
agreement with full understanding of the obligations herein.

Page | 24
IN WITNESS WHEREOF, the parties have hereunto set and subscribed their hands on
the date and year above mentioned6:

Dated at Chennai on this day the 15th day of March 2019

WITNESS

(1) Sd/-xxxxxxxxx Sd/-xxxxxxxxx

(Mr Vadivel (Owner)
Residing at No. 45,
Shanti Colony, Chennai - 28)

(2) Sd/-xxxxxxxxx Sd/-xxxxxxxxx

(Ms Subhikshha, (Hirer)

Residing at No.12,

Rajaji Avenue, Chennai - 9)

6
This part of the deed deals with the Testimonium part of the deed, and portrays act of transfer which is
done between the parties to the sale deed. It is confirmed by both the witnesses affixed along with signature

Page | 25
 SCHEDULE OF PROPERTY

The details of the Washing Machine under hire-purchase are as follows:

Brand IFB

Model Diva Marine SZ

Capacity 7 Kilograms

Maximum Rotational Speed 800 RPM

Installation Type Free-Standing

Form Factor Front-Loading

Colour Silver

Control Console Fully Automatic

Wattage 930 Watts

Door Material Plastic

Material Metal

Included Components Washing Machine

Batteries Included No

Batteries Required No

Dated at Chennai on the 15th day of March 2019

(S/d-) xxxxxxxxxxx
(Owner)

Page | 26
PLEADING

Page | 27
 SUIT ON PROMISSORY NOTE

PROBLEM 1

S. Jana, son of Krishnan, residing at Dorr No. 249, Netaji Road, Tirupati, borrowed a sum
of Rs. 50, 000/- on 02.04.2015 from G. Srinivas, Son of Raman, residing at Door No. 247,
Netaji Road, Tirupati, agreeing to repay the sum with 24% percent per annum and
executed a Promissory note therefor. K. Damodar and M. Sundar stood as attesting
witnesses. Jana did not repay any amount either towards Principal or interest and hence
G. Srinivas raised a demand from S. Jana through his advocate on 01.02.2018 and even
thereafter the borrower did not make any payment. Hence, G. Srinivas approaches you to
draft a plaint for the recovery of the amount due to him.

Suit on a Promissory Note: Plaint

IN THE COURT OF SUB DISTRICT JUDGE AT TIRUPATI

O.S.NO. 012/2019

G. Srinivas Plaintiff

v.

S. Jana Defendant

PLAINT FILED UNDER ORDER VII RULE I OF THE CODE OF CIVIL

PROCEDURE

The Plaintiff, G. Srinivas, Son of Raman, is a business man, aged about 35 years, residing
at door 247,Netaji Road Tirupati, Andra Pradesh 530982.

The address of the plaintiff for service of all the notices and process is that of his advocate
Ms. Priya Venkatesan having office at A-21, 10th Cross, Netaji Road, Tirupati, Andra
Pradesh- 530994.

Page | 28
The Defendant, S. Jana, Son of Krishnan, aged about 30 years, is residing at door no. 249,
Netaji road, Tirupati, Andra Pradesh, 530982 which is also his address for service of all
notices and other processes from the court of Law.

1. The plaintiff alleges that the Defendant had borrowed money of Rs. 50 thousand
from the Plaintiff on 2nd April 2015 for his marriage expenses on the promise that
the said amount would be repaid within 3 years along with interest. The note was
executed with attesting witness Mr. K. Damodar and M. Sundar.
2. In consideration of the loan given by the Plaintiff, the defendant executed a
Promissory Note on the day of obtaining the loan amount. The plaintiff states that
the defendant has failed to repay the said amount of Rs. 50 thousand and the interest
of 24% per annum associated with it.
3. The plaintiff states that even after repeated reminders to the Defendant to repay the
loan money, the defendant did not respond to the reminder.
4. The plaintiff submits that even after a demand was raised by the plaintiff via his
advocate on 1.02.2018, the defendant did not make any payment. Therefore, as
according to Section 20, CPC, the case would squarely fall within the jurisdiction
of this Court.
5. The plaintiff submits that the plaintiff has approached this bench under the
limitation period as the plaintiff has approached the bench within 1 year of non-
repayment of promissory note.
6. The Plaintiff submits that the defendant is not an agriculturist and he is not entitled
to the benefits under any of the debt relief of law.
7. The cause of the action for this suit arose, in the city of Tirupati, on 1st March, 2018,
3 years from the date of execution of this promissory note, when the Defendant
defaulted in the payment of Rs.50 thousand along with interest as stated in the
Promissory Note.
8. The Plaintiff estimates the value of the reliefs sought by him at a sum of Rs. 30,000
for the purpose of court fees under the Andra Pradesh Court Fees and Suits
Valuation Act, 1956 and at the same amount for the purpose of jurisdiction.
9. The Plaintiff prays that this Honourable Court may be pleased to pass a decree in
favour of the plaintiff

Page | 29
 i. For the sum of Rs. 50,000 towards Principal and a sum of Rs.36, 000
towards interest totalling in all to Rs 86,000/-
ii. for further interest at the rate of 10% from the date of plaint till the date
of passing the Decree;
iii. for further interests from the date of Judgment and Decree till date of
realisation;
iv. for costs of the suit and
v. for such other reliefs as are deemed fit and proper in the interest of
justice and which may be prayed for hereafter.

Dated at Tiruchirappalli, this 2nd day of May, 2019

Advocate for Plaintiff Plaintiff

VERIFICATION

I, Aishwarya R Geddada, Daughter of G. Ravikhumar, aged about 22 years, do hereby

declare that the facts stated in paras 1 to 5 are true and correct to the best of my knowledge,
information and belief and I believe the same to be true and correct. Hence, verified on this
2nd day of May, 2019 at Tiruchirappalli.

Plaintiff

MEMO OF DOCUMENTS FILED

S.No. Date Item Description

1. 02.04.2015 Promissory Note- Drawn by defendant

Rs 50 thousand to plaintiff

Page | 30
VALUATION

1. Valuation for the purpose of jurisdiction and Court Fees

for relief (a) Principal amount ________________________
Interest from _____ to ____ ________________________
Total ________________________

2. Court Fees thereon under Chapter I & II, read with Schedule I,
Schedule II of the Tamil Nadu Court Fees and Suits Valuation Act, 1955
Court Fees paid under Andra Pradesh Court
Fees and Suits Valuation Act __________________

Dated at Tiruchirappalli, this 2nd Day of May 2019

Page | 31
 FILING OF WRITTEN STATEMENT

PROBLEM 2:

Based on the Plaint drawn for Problem No. 1, draft a Written Statement on behalf of S
Jana.

WRITTEN STATEMENTS

IN THE COURT OF SUB DISTRICT JUDGE AT TIRUPATI

O.S.NO. 012/2018

G. Srinivas
Plaintiff

v.

S. Jana Defendant

WRITTEN STATEMENT FILED BY THE DEFENDANT UNDER ORDER VIII

RULE I OF THE CODE OF CIVIL PROCEDURE [FAIR COPY]

1. It is submitted that the defendant has gone through the averments made in the plaint
and affidavit filed in support of the plaint. The averments, which are not specifically
admitted, are denied.
2. The plaintiff is put to strict proof of the same. Most of the averments are not correct
and false and the suit is not maintainable.
3. In reply to the averments made in para 1 of the Plaint, it is submitted that I have no
acquaintance with the plaintiff and did not approach him at any point of time for
hand loan to meet my marriage expenses and executed promissory note in favour
of the Plaintiff. I have sufficient means to support my family and take care of the
expenses. Hence there is no question of taking hand loan from the plaintiff and
execution of promissory note in favour of the plaintiff. It is submitted that since
there is no amount borrowed from the plaintiff and executed a promissory note, the
figures of outstanding stated in para therein is false and fabricated one.

Page | 32
 4. In reply to para 2 of the Plaint, it is submitted that since I have not approached him
for hand loan I have not received any reminder for the loan to be repaid. Hence the
allegations in the Plaint are denied.
5. In reply to para 3 of the Plaint, I agree to the fact that I am not an agriculturist since
I’m engaged in business and I deny to the fact that I am not entitled to any benefits
since I do not owe any debt to the Plaintiff.
6. It is submitted that I have never approached the plaintiff for any amount said to
have been borrowed be me and executed promissory note. Since we reside in the
adjacent street and due to rivalry between our two families regarding some disputes
relating to colony problems, the plaintiff has fabricated the promissory note and
filed the present suit alleging that I have borrowed a sum of Rs.50,000/- form the
plaintiff and executed a promissory note. The plaintiff is trying to mislead this
Hon’ble Court and made false allegations in the plaint.
7. The other allegations of the plaint which are note specifically admitted herein are
denied. The plaintiff is put to strict proof of the same.

Hence, it is prayed that this Hon’ble Court may be pleased to dismiss the suit with costs.

Counsel for the Defendant Defendant

VERIFICATION

I, S. Suman Gupta, daughter of Sumeet Gupta aged about 30 years, do hereby declare that
the facts stated in paras 1 to 6 are true and correct to the best of my knowledge, information
and belief and I believe the same to be true and correct. Hence, verified on this 2nd day of
May at Tirupati.

Defendant

Page | 33
 SUIT FOR GOODS SOLD AND DELIVERED

PROBLEM 3:

Arjun purchased a LC Led Plasma T.V Set from M/s Ganesh and Company (P) Ltd.
carrying on business in the sale of T.V Sets of different descriptions at 101, 5th Cross Street.
Thillai Nagar on 01.01. 2017 for Rs. 70,000/-. The company also delivered the same at the
residence of Arjun. Right from the time the T.V set was installed, it was not giving good
performance on account of defective picture tube. Arjun informed this to the company and
they also promised to replace the set within a week. But as no action was taken by the
Company in this regard, Arjun requests you to file an appropriate suit against the
Company, Draft a suitable plaint-

SUIT ON GOODS SOLD AND DELIVERED

IN THE DISTRICT COURT OF MUNSIF AT TIRUCHIRAPPALLI

O.S. NO: -- /2019

Sri. Arjun A.J : Plaintiffs

v/s

M/s Ganesh & Company (P) Ltd : Defendants

PLAINT INSTITUTED UNDER ORDER VII RULE 1 OF THE CODE OF CIVIL

PROCEDURE

The Plaintiff Mr. Arjun A.J son of Mr. A Jayan, Hindu, aged about 37 years and residing
at Keytra House, K.K Nagar, Trichy-620007.

The Address of the Plaintiff for service of all Notices and other processes from this Court
of Law is that of his Advocate Ms. Priya Venkatesan, having her office at No. 102, KVR
Complex, Thennur Road, Trichy.

Page | 34
The Defendant. M/S Ganesh & Company (P) Ltd having its registered office at 101, 5th
cross street, Thillai Nagar Trichy – 620014, which is also the address for service of all
summons and other notices from this Court of Law.

1. The Plaintiff submits that on the 1st November 2017, the plaintiff had approached
M/S Ganesh & Company (P) Ltd, run by the defendant for purchasing a LC Led
Plasma T.V set for the plaintiff’s personal use.
2. That the defendant had recommended a SAMSUNG LC Led Plasma T.V set to the
plaintiff which had a MRP of Rs.70,000 and a guarantee period of 3 years.
3. That at the time of purchasing the LC Led Plasma T.V Set, the dealer had assured
the Plaintiff free after-sale service for a period of two year and in case the set is met
with any other damage beyond repair, a guarantee to replace the set with any other
model or the same model itself.
4. The defendant company had delivered the T.V set to the residence of the Plaintiff
on the 7th November 2017.
5. That from the time of installation of the T.V set, the T.V set was not giving good
performance and the plaintiff was also experiencing trouble with the T.V set on
account of its defective picture tube.
6. That when the plaintiff approached the defendant’s company for replacing the T.V
set, the company promised to replace the T.V set within a week’s time. However,
even after a week’s time, no action was taken by the company in this regard.
7. The defendant company has failed to replace the said T.V. set even after the
stipulated time period.
8. The whole cause of action arose when the defendant company has failed to replace
the T.V. set as stipulated in the agreement at Trichy.
9. For the purpose of Court fee and jurisdiction the suit is valued at Rs. 70,000/- as
per Section 24 of The Tamil Nadu Court Fees and Suits Valuation Act and the
plaintiff pays the same.

The Plaintiff therefore prays for a Judgment and Decree against the Defendant

i. To reimburse the loss incurred by the plaintiff in buying the defective product

Page | 35
 ii. In the alternative to replace the delivered LC Led Plasma T.V Set with a new
one and additional services to be provided for the new good.
iii. For Costs of the suit
iv. For such other reliefs which the Plaintiff is entitled and which this Court deems
to be fit and proper in the interest of justice.

Signature Signature

(Advocate) (Plaintiff)

VERIFICATION

I, Arjun A.J, the Plaintiff above named, do hereby verify and state that the
allegations/averments set out in paras 1 to 4 are based on information, what has been stated
in paras 4 to 7 is based on knowledge and what has been stated in para 8 is based on belief
and that the same is true.

(Signature of the plaintiff)

(Signature of the Advocate)

Page | 36
 SUIT AGAINST A COMMON CARRIER

PROBLEM 4:

Farooq, a wholesale dealer in Paulson Butter at Bombay, is carrying on a business at 3-

D, Munroe Bagh in Colaba Highway, Colaba, Mumbai. H econsigned on 01.04.2016, 20
kilos of butter in 20 sealed tins to Soli Coyaji, son of pestonji Coyaji, residing at Malabar
Hill, Mumbai. The consignment was sent through M/s Mahavir Transports (P) Ltd.,
Mumbai. The Transport Company delivered on 08.04.2016 only 10 tins and there was a
shortfall in the delivery which is of the value of Rs. 40,000/-. As the transport company did
not trace out the remaining tins and delivered the same to the consignee, the consignee
now intends to file a suit against the transport company for the recovery of the value of tins
short supplied. Draft a suitable Plaint.

SUIT FOR COMPENSATION AGAINST COMMON CARRIER

IN THE CITY CIVIL COURT AT MUMBAI

O.S.No.293/2017

Farooq

S/O, Ismail, aged 34 years

Paulson Butter Company Pvt Ltd.

3-D, Monroe Bagh

Colaba Highway,

Mumbai – 25
………………………………………………………………………....Plaintiff

Vs.

M/S Mahaveer Transports Pvt Ltd

Page | 37
No 4, Near Ganesh Mandir,
Opp. Peninsula Hotel,
90 Feet Road, Sakinaka, Andheri(E),

Mumbai –
72…………….…………………………………………………………Defendant

PLAINT FILED UNDER ORDER VII RULE 1 OF CPC FOR COMPENSATION

AGAINST COMMON CARRIER

The Plaintiff above named submits as follows:

1. The plaintiff, Farooq, son of Ismail, aged about 34 years is a businessman who runs
Paulson Butter Company at Monroe Bagh, Colaba, Mumbai - 400025
2. The Address of the Plaintiff for service of all Notices and other processes from this
Court of Law is that of his Advocate Mr. A. Irani, B.A.,LL.B (Hons), having his
office at No. 25 Kagalnagar, P.O Bistupur, Mumbai- 831001
3. The Defendant, M/S Mahaveer Transports Ltd, No 4, Near Ganesh Mandir,
Opp. Peninsula Hotel, 90 Feet Road, Sakinaka, Andheri(E),Mumbai – 72, is also
the address for service of all summons and other notices from this Court of Law.
1. The plaintiff therefore states that the defendant had made a commitment to deliver
a package, containing 20 kilograms of butter in 20 sealed tins to Soli Coyaji, son of
Pestonji Coyaji , residing at No. 7/4 , Malabar Hills, Mumbai-400015. Upon
delivery of the same, it was found out that 10 sealed butter tins were missing.
Hence, Mahaveer Transports Pvt Ltd is liable to provide compensation for the
same.
2. The plaintiff states that the cause of action for this suit arose at Mumbai on
08/04/2016 when the plaintiff paid a consideration of Rs 40,000 for delivery of a
package containing 20 tins of butter to Soli Coyaji, son of Pestonji Coyaji , residing
at No. 7/4 , Malabar Hills, Mumbai-400015. The bill regarding the same was
furnished to the plaintiff in Mumbai. Upon delivery of the package on 08/04/2016,
it was discovered that 10 tins out of the 20 tins of butter consigned were missing,

Page | 38
 and to that effect, Mahaveer Transports (P) Ltd. has failed in meeting its
commitments promised to the plaintiff.
3. When this fact about the missing tins along with the bill for the transport of the 20
tins was furnished and inquired, the defendants did not provide proper answers to
the inquiries made by the plaintiffs and did not take any measures on its behalf to
locate the missing 10 tins of butter or provide any tangible proof of any such
measure for locating the missing consigned items.
4. The Plaintiff humbly states that this Hon’ble Court has jurisdiction to try the suit
as the whole cause of action arose at Mumbai and values the suit at Rs.40,000/- and
pays thereon a Court Fee of Rs. 4,000/- of the Bombay Court Fees Act.
5. The Plaintiff therefore humbly prays for a Judgment and Decree against the
Defendant from the Honourable Court:
v. In furnishing the 10 tins of butter, or compensation for the same amounting to
Rs. 40,000/-.
vi. Further compensation for mental harassment, loss of income suffered by the
plaintiffs which was suffered due to the non-delivery of the 10 tins of butter to
the buyer.
vii. Costs of the suit
viii. Other reliefs which the Plaintiff is entitled and which this Court deems to be
fit and proper in the interest of justice.

VERIFICATION

I, Farooq Ismail, the Plaintiff above named, do hereby verify and state that the
allegations/averments set out in Paras 1 to 5 are based on knowledge, what has been stated
in Para 6 is based on information and what has been stated in Para 7 is based on belief and
that the same is true.

Dated at Trichy this 13th day of April 2016.

Page | 39
 (Sd.)xxxxxxxx

Plaintiff

VALUATION
1. Valuation for the purpose of jurisdiction and Court Fees
for relief (a)Principal amount 40000
Interest from 01-04-2016 to 11-04-2016 0
Total 40000

2. Court Fees thereon under Section 22, 400

Dated at Trichy this 13th day of April 2016.

Page | 40
APPLICATION FOR THE APPOINTMENT OF AN ADVOCATE
COMMISSIONER

PROBLEM 5:

Lokesh had filed a Suit against Mahadev for demarcation of boundaries of his land since
Mahadev claims that boundary area belongs to him. In order to ascertain the said claim,
Lokesh intends to take out an application for the appointment of an Advocate
Commissioner to inspect the land and decide the issue. Draft a suitable Application and a
Petition for this purpose.

INTERLOCUTORY APPLICATION FOR THE APPOINTMENT OF

COMMISSIONER.

IN THE COURT OF THE MUNSIFF, TIRUCHIRAPPALLI

I. A. No. 183/2018 in O.S. No.164/2019

Lokesh. M Plaintiff

22, Vichitra Villa,

Preetam Colony,

Tiruchirappalli-620009

Versus

Mahadev. J

Door No. 12,

11th Cross Thillai Nagar,

Tiruchirappalli-620009 Defendant

Page | 41
 AFFIDAVIT FILED BY PLAINTIFF

I, Lokesh, son of Jagannathan, aged 33 years, residing at 22, Vichitra Villa, Preetam
Colony, Tiruchirappalli-620009 do hereby solemnly affim an state as follows:

1. I state that I am the plaintiff in the above case and I am well acquainted with the
facts of the case.

2. I state that the suit is for declaration of boundary to the property held by the plaintiff
to prevent the defendant from encroaching the plaint schedule property.

3. I state that it is highly necessary in the interest of justice that an order for the
appointment of a commissioner by the Honourable Court and a report is called for
in respect of the matters mentioned in the accompanying application for finding the
dimensions of the scheduled property.

4. I state that the local investigation and the report of the commissioner are highly
necessary for the purpose of elucidating the above matters and for ascertaining the
factum of position of the scheduled property; and for the smooth conduct of the
suit.

5. I state that if no commission is issued, it will cause serious and irreparable legal
injury and financial as well as emotional loss to the plaintiff

6. I state that the plaint schedule in the plaint may be taken and read as part of this
affidavit.

7. I state that in the circumstances of the case and in the interest of justice, it is fit and
proper that the prayer contained in the accompanying application be granted. The
facts stated above are true to the best of my knowledge, information and belief.

Solemnly affirmed by

On 24/04/2017

Page | 42
Advocate for the Petitioner/Defendant (Signature of the applicant)

Before me

S. Chandran

Advocate

SCHEDULE OF PROPERTY

All that piece and parcel of land including all trees and bushes covering an extent of vacant
land to 3 acres, bearing R.S no 200001/82 located in kattupattu village, Trichy 620008.

NORTH by a100 feet road leading to Trichy City.

SOUTH by a house Door No 23, bearing R.S no 20002/81, and belonging to Mahadev and
having a right of entry to the property from this side.

WEST by a house Door no 24, bearing R.S no 200003/80 and belonging to Gnanasekar.

EAST by a 40 feet road leading to a Lord Vishnu temple and situated within the registration
and sub- registration Taluk of Srirangam.

Dated at Trichy, the 24th day of April, 2017.

(sd/-)

xxxxxxxx

Lokesh (Plaintiff)

Page | 43