WRITTEN STATEMENT

IN THE COURT OF CIVIL JUDE (S.D.) FARIDABAD

Original suit no .79 of 2020

Siddhant Sikhawat, S/o Late Sunder Shikhawat. r/o House o. B. 20/40, Mohalla
Bhelupur, Faridabad

---------Plaintiff

Vs.

1- Kumar a/a 48 years S/o Late Sunder Shikhawat r/o House no. B. 20/40, Mohalla
Bhelupur, Faridabad.

2- Nanavati Devi a/a 75 years W/o Late Sunder Das both R/o House no. B. 20/40,
Bhelupur, Faridabad.

3- Bhavna a/a 40 years W/o Sri. Mahesh Kumar D/o Late Sunder Das r/o House no.
200 Shyama Building Gorakhnath Lane Faridabad.

------Defendants

The defendants no. 1 -3 submit as under;

1. That contents of para 1 of the plaint is admitted.

2. That contents of para 2 of the plaint is admitted.
3. That contents of para 3 of the plaint is admitted.
4. That contents of para 4 of the plaint is admitted.
5. That contents of para 5 of the plaint is admitted that in the life time of sunder das
(now deceased) that marriage of defendant no. 3 Bhavna was solemnized . Rest
content of this para is denied subject to additional pleas.
6. That contents of para 6 of the plaint is admitted.
7. That contents of para 7 of the plaint is admitted.
8. That contents of para 8 of the plaint is denied. There was no any oral partition
between the parties at any time. The true fact is that the plaintiff himself got
prepared a memorandum of family settlement as he liked and got signatures of the
defendant on the stamp papers and some other papers. As the defendants had full
trust and confidence on the plaintiff so they signed on the memorandum of family
settlement which is prepared by plaintiff without reading and understanding the
contents of the said family settlement.
9. That contents of para 9 of the plaint is not admitted. True facts are given in
additional pleas.
10. That contents of para 10 of the plaint is denied.
11. That contents of para 11 of the plaint is not admitted. The plaintiff has mention the
wrong cause of action in the plaint only to file a wrong suit.
12. That contents of para 12 of the plaint is denied subject to additional pleas.
13. That contents of para 13 of the plaint is denied. The true facts have been
mentioned in additional pleas.
14. That contents of para 14 of the plaint is denied. The true facts have been
mentioned in additional pleas.
15. That contents of para 15 of the plaint is admitted.
16. That contents of para 16 of the plaint is denied. The plaintiff valued the wrong
plaint and pays very less court fees.
17. That the proposed relief in para 17 of the plaint is denied and the plaintiff is not
entitled to get any relief.

Additional Pleas
1. That the plaintiff thus filed the above noted suit with all together false facts only
with a view to harras and blackmail the defendant as such the said suit is liable to
be rejected.
2. That the true fact is that previously there was joint family of plaintiff, defendants
no. 1-3 and sunder das (now deceased) they were residing jointly.
3. That the plaintiff, defendants no. 1-3 and the deceased jointly purchased the
property in question of the suit with the fund of joint family and
4. That there is no partition between of plaintiff and defendants no. 1-3 in respect of
the disputed property of the suit nor any memorandum of family settlement ever
executed between the parties.
5. That the above mention suit is likely to be rejected.

Prayer

The defendant humbly and most respectfully prays to the court to reject the suit
filed by the plaintiff whose main motive is only to harras the defendant and
provides the defendant any other relief as the court may deem fit and proper.

Place – Faridabad, Haryana …………………….

Date – 22 August, 2020 Signature of defendant

……………………….

Signature of advocate

Verification

I, Siddhant Sikhawat, S/o Late Sunder Shikhawat, r/o House no. B. 20/40, Mohalla
Bhelupur, Faridabad do hereby verify that the contents of this written statement
are true and correct to best of my knowledge and personal belief. Nothing has
been concealed therein.
Place – Faridabad, Haryana …………………….

Date – 22 August, 2020 Signature of defendant

……………………….

Signature of advocate
 Affidavit

IN THE COURT OF CIVIL JUDE (S.D.) FARIDABAD

Original suit no .79 of 2020

Siddhant Sikhawat, S/o Late Sunder Shikhawat. r/o House o. B. 20/40, Mohalla
Bhelupur, Faridabad

---------Plaintiff

Vs.

1- Kumar a/a 48 years S/o Late Sunder Shikhawat r/o House no. B. 20/40, Mohalla
Bhelupur, Faridabad.

2- Nanavati Devi a/a 75 years W/o Late Sunder Das both R/o House no. B. 20/40,
Bhelupur, Faridabad.

3- Bhavna a/a 40 years W/o Sri. Mahesh Kumar D/o Late Sunder Das r/o House no.
200 Shyama Building Gorakhnath Lane Faridabad.

------Defendants

I, Siddhant Sikhawat, S/o Late Sunder Shikhawat, r/o House no. B. 20/40, Mohalla
Bhelupur, Faridabad do hereby affirms as follows that the defendant is fully
acquainted with the fact and circumstances of the case and the proforma attached
with the application contains the true fact. The statement made above are true and
nothing has been concealed

Verification

I, Siddhant Sikhawat, S/o Late Sunder Shikhawat, r/o House no. B. 20/40, Mohalla
Bhelupur, Faridabad do hereby verify that the contents of this affidavit are true and
correct to best of my knowledge and personal belief. Nothing has been concealed
therein.

Place – Faridabad, Haryana …………………….

Date – 22 August, 2020 Signature of defendant

……………………….

Signature of advocate