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O.S.-RADHA - Site 172
O.S.-RADHA - Site 172
CJM AT RAMANAGARA
O.S.NO. /2019
BETWEEN:
SMT.RADHA
W/o. Sri. Veeranna,
Aged about 44 years,
Residing at 1st Block,
Kaiwara,
Chikkaballapura-563 128 …… PLAINTIFF
AND:
1.M/s. DREAMLAND VENTURES (P) LTD.
Office at #4, New No.100, Plot No. 48,
2ndFloor, K.H. Road, Sudhama Nagar,
Bengaluru-560 027.
Represented by its Authorized Signatory,
SRI.G. DHARMA PRAKASH
S/o H. Govindappa.
10. The Plaintiff submits that, the Plaintiff had tried her best, but
in vain, to get the Defendant to come forward and execute the Sale
Deed in her favour. However, the Defendants have never attempted
to execute the Sale Deed in favour of the Plaintiff. It appears that
the approach of the Defendants towards performing their part of
contract has been only to avoid the discharge of their part of the
obligation by making false promises.
11. The Plaintiff submits that, thus the Plaintiff had got issued a
Legal Notice on 22.08.2019 thereby calling upon the Defendants to
approach her immediately and make arrangements for the
execution of the Sale Deed as per the terms and conditions of
thePlot Allotment Letter dated 15.11.2014 with respect to the
schedule property mentioned in the said Plot Allotment Letter,
within 15 days from the date of receipt of this notice, failing which
she will be constrained to initiate the appropriate legal action, both
civil and criminal to get the appropriate remedy at their risks and
costs. A copy of the Legal Notice dated 22.08.2019is produced
herewith and marked as DOCUMENT NO.6. The Postal receipts for
serving notice through RPAD are produced herewith and marked
as DOCUMENT NO.7. The unserved returned postal cover
containing the Legal Notice dated 22.08.2019 with the postal
shara marked as “Addressee left – Returned to Sender” are
produced herewith and marked as DOCUMENT NO.8and
DOCUMENT NO.9 respectively. This approach of the Defendants
indicates their malafide intention of selling the suit schedule
property to the third parties thereby depriving the legal right of the
Plaintiff.
12. The Plaintiff submits that, the cause of action for the suit
aroused when the Defendants, having issued the Plot Allotment
Letter dated 15.11.2014 and having received the full consideration,
willfully defaulting regarding execution of the sale deed,
constraining the Plaintiff to issue Legal Notice on 22.08.2019.
13. The Plaintiff submits that, there is no case filed between the
same parties seeking the same reliefs & pertaining to the same suit
schedule property either before any Civil Court or before any
Authority or Tribunal.
14. The Suit is in time and valuated for the purpose of Karnataka
Court Fee Act and the Court Fee is paid as per the valuation slip
annexed herewith.
VERIFICATION
RAMANAGARA PLAINTIFF
DATE: .09.2019 (RADHA)
IN THE COURT OF THE PRINCIPAL SENIOR CIVIL JUDGE AND
CJM AT RAMANAGARA
O.S.NO. /2019
BETWEEN:
AND:
M/s. DREAMLAND VENTURES (P) LTD.
AND ANOTHER ……DEFENDANTS
VERIFYING AFFIDAVIT
I swear accordingly.
IDENTIFIED BY ME DEPONENT
(RADHA)
ADVOCATE
RAMANAGARA
DATE: .09.2019
IN THE COURT OF THE PRINCIPAL SENIOR CIVIL JUDGE AND
CJM AT RAMANAGARA
I.A.NO.I
IN
O.S.NO. /2019
BETWEEN:
SMT. RADHA
W/o. Sri. Veeranna,
Aged about 44 years,
Residing at 1st Block,
Kaiwara,
Chikkaballapura-563 128 …… PLAINTIFF
AND:
1.M/s. DREAMLAND VENTURES (P) LTD.
Office at #4, New No.100, Plot No. 48,
2ndFloor, K.H. Road, Sudhama Nagar,
Bengaluru-560 027.
Represented by its Authorised Signatory,
SRI.G. DHARMA PRAKASH
S/o H. Govindappa.
RAMANAGARA
DATE: .09.2019 ADVOCATE FOR PLAINTIFF
(B.P.SATHEESHA)
IN THE COURT OF THE PRINCIPAL SENIOR CIVIL JUDGE AND
CJM AT RAMANAGARA
I.A.NO.I
IN
O.S.NO. /2019
BETWEEN:
AND:
AFFIDAVIT
1. That I am the Plaintiff in the above case and conversant with the
facts of the case. Hence, I am swearing to this affidavit. The
contents of the plaint may be read as part and parcel of this
affidavit.
2. I state that, the above Suit has been filed seeking to pass the
Judgment and Decree for the relief of Specific Performance for the
execution of the Sale Deed as per the terms and conditions of the
Plot Allotment Letter dated 15.11.2014 issued by the Defendants
in my favour with respect to the schedule property mentioned in
the said Plot Allotment Letter dated 15.11.2014 in my favour
issued by the Defendants and consequently put me in possession
of the Suit Schedule Property with respect to the schedule property
mentioned in the said Plot Allotment Letter and to grant
compensation to be payable by the Defendants to me for the
breach of the contract as per the Plot Allotment Letter dated
15.11.2014 issued by the Defendants in my favour with respect to
the schedule property mentioned in the said Plot Allotment Letter
dated 15.11.2014 issued by the Defendants in my favor and in the
alternative to pass the Judgment and Decree for any other relief in
my favour to which I am entitled including the refund of the entire
sale consideration amount paid by me, in case my claim for
specific performance is refused along with the penalty and to grant
such other relief as this Hon’ble court deems fit to grant in the
facts and circumstances of the case, in the interest of justice.
7. I further state that, I had waited all these years thinking that
the Defendants will come forward and executes the Sale Deed in
my favour, but the same was in vain. It appears that the approach
of the Defendants towards performing their part of contract has
never been attempted.
I swear accordingly.
IDENTIFIEDBY ME DEPONENT
(RADHA)
ADVOCATE
RAMANAGARA
DATE: .09.2019
IN THE COURT OF THE PRINCIPAL SENIOR CIVIL JUDGE AND
CJM AT RAMANAGARA
O.S.NO. /2019
BETWEEN:
AND:
LIST OF DOCUMENTS
RAMANAGARA
DATE: .09.2019 ADVOCATE FOR PLAINTIFF
(B.P.SATHEESHA)
IN THE COURT OF THE PRINCIPAL SENIOR CIVIL JUDGE AND
CJM AT RAMANAGARA
O.S.NO. /2019
BETWEEN:
AND:
The Names of the parties mentioned in the plaint are the registered
one. Any correspondence by this Hon’ble court may be made to the
address mentioned in the plaint.
(B.P.SATHEESHA) (RADHA)
VERIFICATION
RAMANAGARA
(RADHA)
IN THE COURT OF THE PRINCIPAL SENIOR CIVIL JUDGE AND
CJM AT RAMANAGARA
O.S.NO. /2019
BETWEEN:
AND:
INDEX
2. Verifying Affidavit
3. Valuation Slip
6. Vakalath
8. Affidavit
RAMANAGARA
DATE: .09.2019 ADVOCATE FOR PLAINTIFF
(B.P.SATHEESHA)