COMPROMISE DEED BETWEEN MULTIPLE PARTIES & MULTIPLE

DEFENDANTS RECORDING CONSENT TERMS TO BE FILED BEFORE THE

HON’BLE HIGH COURT IN A SUIT FOR SPECIFIC PERFORMANCE

BEFORE THE HON’BLE---------HIGH COURT

IN SUIT NO.------------ OF ---------
ALONGWITH 39 OTHER CONNECTED SUITS BEARING NOS.----------

IN THE MATTER OF :

Mr./Mrs./Ms.------------
S/W/D/o----------------
R/o……………. & 39 Others …. Plaintiffs

Versus

M/s.----------- & 6 Others ….Defendants

COMPROMISE DEED BETWEEN MULTIPLE PARTIES & MULTIPLE

DEFENDANTS RECORDING CONSENT TERMS

(1) The Parties have agreed that the amounts advanced by the respective
Plaintiffs to Defendant No. 1 and the dates on which these advances were
made, are as particularized in the Schedule annexed hereto as Annexure 1.
The aggregate Principal Amount advanced is Rs. ____________________
(Rupees ____________________________________________Only).

(2) The Parties have agreed to leave the questions of (i) whether any
interest is to be awarded; and (ii) if so, at what rate, solely to the Court. The
Parties have also agreed that no reasons need to be given in regard to such
determination.

(3) Defendant No. 1 agrees to deposit, in one single payment on or before

______, in this Court the following:-

(i) the Principal sum of Rs.____________ (Rupees ____________Only);

and

(ii) interest at such rate as this Court determines (if/as) payable from the
date of the respective advance(s) [as particularized in Annexure 1] till
the date of deposit.

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 This deposit shall be accompanied by a statement particularizing the
details of the Principal sum and the interest calculations qua each
Plaintiff and a copy of such Statement will be supplied by Defendant No.
1 to the Plaintiff.

(4) Simultaneous with the deposit as per clause 3 above being made, all civil
(including the lis-pendens) and criminal proceedings filed by the Plaintiffs
against Defendant Nos. 1 to 7 and other persons named in criminal
complaints/FIRs [including particularly those particularized in Annexure 2
hereto]in various Courts in the country shall stand withdrawn and/or
compounded. List of the notices of lis-pendens is at Annexure 2A. The
Plaintiffs undertake to forthwith make the necessary applications to the
appropriate court (s) and do all acts, deeds and things necessary for giving
formal effect thereto, including obtaining the consents of the
Plaintiffs/Complainants/Petitioners/Applicants in those proceedings who are
not parties to these Compromise Deed Recording Consent Terms. In so far as
Suit No._____ of _____, filed by Defendant No. 4 against Ms. ______ and
____ others is concerned, the same shall stand disposed off in accordance
with the draft Compromise Deed Recording Consent Terms (annexed as
Annexure 3 hereto) ______ as the Constituted Attorney of the Defendants
namely ______ and ______ in the aforesaid Suit No. _______ of ______,
hereby agrees and undertakes to do everything that needs to be done in the
matter, including obtaining signatures of Mrs. ______ and Mr. ______ and
filing the same in court.

(5) Simultaneous with the deposit as per clause 3 above being made, all civil
and criminal proceedings, including all the criminal complaints and FIRs filed
by Defendant Nos. 1, 4 and 5 against the Plaintiffs [including particularly those
particularized in Annexure 4, 5 and 6] in various courts in the country shall
stand withdrawn and/or compounded. Defendant Nos. 1, 4 and 5 undertake to
forthwith make the necessary applications to the appropriate court (s) and do
all acts, deeds and things necessary for giving formal effect thereto.

(6) Simultaneous with the deposit as per clause 3 above being made, the
web links/urls/web search results/ blogs/ ______ videos / video films /web
postings/internet content particularized in Annexure __ hereto, shall
forthwith stand liable to be taken down/removed/discontinued. The Plaintiffs
undertake to forthwith address the necessary communications to the
appropriate internet/web authority/agency viz. M/s ______, ______ and M/s
______, M/s ______, ______ and ______ owned by ______ and ______ in
this behalf stating that the said web links/urls/web search
results/blogs/______ videos/video films/web postings/internet content
particularized in Annexure __ are removed from the concerned web

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sites/search engines. Independent thereof, the concerned internet/web
authority/agency/i.e. M/s ______, ______ and M/s ______, M/s ______,
______ and ______ is directed to forthwith remove/take down/discontinue the
same.

(7) Agreed, declared and confirmed that subject to clause 6 hereinabove,

this Hon’ble Court shall pass an appropriate order directing:

a. M/s ______, ______ M/s ______:

i. not to display, operate and keep alive the weblinks/urls/web

search results contained in Annexure _ and not to publish,
transmit or cause to be published or transmitted
defamatory, derogatory, humiliating, obnoxious, false,
mischievous and malafide content, data and information
concerning the Defendant No.1, Defendant No.4, Mr.
______, his Companies, his family members and
employees;

ii. to forthwith completely and absolutely remove all website

postings (including the urls at Annexure __ hereto) posted
on its web portal, search engine, platforms and computer
resources, which pertain to, or mention or have a relation or
association, of any kind whatsoever concerning the
Defendant No.1, Defendant No.4, Mr. ______, his
Companies, his family members and employees

b. M/s ______, ______:

i. to remove the video films titled “__________________” posted

by one ______ and/or any other such video/videos lying on
its site/www.______.com containing films/pictures and
other contents concerning the Defendant No. 1, Defendant
No.4 Mr. ______, his companies, family members and
employees as mentioned in Annexure __ hereto;

ii. notto permit any one to post any such video/videos on its
“site/www.________” etc. containing
defamatory/derogatory remarks/contents/film/video against
Defendant No. 1, Defendant No. 4, Mr. ______, his
companies, family members and employees.

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 iii. In this behalf, it is agreed, understood and undertaken that
if there is any blog or blogs or ______ videos or any such
communication on electronic or social media containing
material/contents concerning Defendant No. 1, Defendant
No. 4 Mr. ______, his companies, family members and
employees defamatory/derogatory false, mischievous and
malafide to the Defendants in the said suits apart from the
items mentioned in the lists at Annexure __ and the same
might have left behind inadvertently would also be got
removed from the websites/_____/other electronic or social
media.

c. M/s ______ :

i. to remove the electronic data and information available at

(a) _________________________

(b) http://www.______/_________

and/or any other such data/information/video/videos lying

on its site/www.______ containing derogatory and
defamatory data/information/films/pictures and other
contents concerning the Defendant No.4 Mr. ______, his
companies, family members and employees as mentioned in
Annexure –__;

ii. notto permit any one to post any such

data/information/video/videos lying on its site/www.______
etc. containing derogatory and defamatory data/
information/films/pictures and other contents concerning the
Defendant No.4 Mr. ______, his companies, family
members and employees

d. That within __ days after removal of all blogs/_____ videos as per

Annexure __, M/s ______, ______, M/s ______, M/s ______ and
______ shall sent written confirmation to the Prothonotary & Senior
Master, High Court, _______, that all the blogs/_____ videos as per
Annexure __ have been removed and deleted.

e. It is further Agreed and declared by the Plaintiffs that they shall not post
any data, information, or content on any blog, web page, computers,

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 computer systems, computer networks, computer resources and
communication devices which is defamatory, derogatory, abusive,
humiliative or offensive to the Defendants, their businesses, their family
members and their other companies and legal entities. It is further
Agreed and declared by the Plaintiffs that they shall not post any data,
information, or content whether in the actual world or in cyberspace, in
any format whatsoever, whether electronic or non-electronic, either in
present as also in future, which are patently false, forged and fabricated,
or which is likely to impact prejudicially and irretrievably the reputation,
standing, repute and goodwill of the Plaintiff.

It is further agreed and declared that the Plaintiffs will not use any un-
parliamentary and unwarranted language of any kind whatsoever as also
will not post any fake and forged photographs of the Defendants,in any
manner whatsoever in order to demean them in the society and business
circle. However, in any case Defendants found any kind of such fake,
forged, un-parliamentary and unwarranted posts/photos, the Plaintiffs
will be solely liable for all the legal consequences emanating therefrom.

(8) Upon compliance with clauses 4 and 6 and upon production of certified
copies of court orders establishing the factum of dismissal/ withdrawal/
compounding/ removal of all civil and criminal proceedings filed by the
Plaintiffs against Defendant No. 1 to Defendant No. 7 and other persons
named in Criminal Complaints/FIRs [including particularly those particularized
in Annexure __ hereto] and blogs/URL’s/______ videos, postings and URLs at
______ and Notice of Lis Pendences, the Prothonotary and Senior Master, High
Court, ____ shall issue and dispatch the cheques/DD for the amount deposited
in this Court (as per clause 3 above) to the respective Plaintiffs[and not in the
name of Constituted Attorney] by Registered Post at the present address of
the Plaintiffs as per Annexure 8 in full and final satisfaction of their respective
claims in their respective Suits as mentioned in the statement to be
accompanied with the deposit in terms of clause 3 above.

(9) Save and except as stipulated herein, Defendant No. 2 undertakes that
until deposit as contemplated by clause 3 above is made, Defendant No.2 shall
not create any third party rights in the property situated at _____________,
admeasuring _______ sq. ft., equivalent to ______ sq. meters together with
the open land adjacent to the built up structure, admeasuring _____ sq. ft.,
equivalent ______ sq. meters (“said Property”) or hand over possession
thereof. Defendant No. 2 is however expressly permitted to raise finance
against the security of the “said property”, provided that before disbursement
of sanctioned loan, the lendor Bank shall issue/draw first the Demand
Draft/Banker’s cheque for the payment contemplated by clause 3 in the name

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of the Prothonotary and Senior Master to the extent of the amount as more
particularly mentioned in clause 3 above.

(10) In the event of a default in payment of the amount set out in clause 3
above, there will be a decree for the amount payable as per clause 3 against
Defendant No. 1 with continuing interest and the Plaintiffs shall be entitled to
execute the same against the “said property” and the money so realized on
execution of decree shall remain deposited in this Hon’ble Court to the extent
of the amount payable as per clause 3 (i) and (ii) above alongwith the
continuing interest and shall be released by the Prothonotary and Senior
Master upon compliance with clauses 4 and 6 as contemplated in clause 8.

(11) All allegations made by the parties against each other stand withdrawn.

(12) It is agreed between the parties that the above settlement does not
include the claims of the parties, in relation to an immoveable property being
land admeasuring ______ sq. yards situate in Khasra No. _____ (part),
_______, _______(part), ________, ________(part), ______(part),
_______(part), ______(part) and ______ bearing Khatoni No.
_____________ of the Revenue Estate of Village _______, in controlled Area -
__, ______ + _____ sq. yds. falling in Khasra No. ______ Min,
_________________ Min, bearing Khatoni No. _________ and ________ and
land admeasuring ______ sq. yds. falling in Khasra No. ______ bearing
Khatoni No. ____ of the revenue Village _____, in controlled area-__,
_______ as more particularly described in Annexure – 9 hereto, which is
subject matter of an arbitration proceedings before Justice _______ (Retd.)

(13) The Prothonotary & Senior Master will address appropriate

communications to the concerned Police Authorities/Stations, web/internet
authorities and the Sub-Registrar _____, for the efficacious implementation of
this Agreement.

(14) Agreed, declared and confirmed that save and except the above, neither
party, including the other accused in __ FIRs shall have any claims/disputes
against the other in respect of either the above Suits and/or the said Property
and/or under the Suit Agreements.

(15) Agreed, declared and confirmed that each of the Plaintiffs and
Defendants, including other accused in ___ FIRs, unconditionally relinquishes,
waives and gives up, all their respective other claims, rights and/or
entitlements in the above Suits as also all the other civil and criminal
proceedings, including criminal complaints/ FIRs.

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(16) Agreed, declared and confirmed that each of the Plaintiffs unconditionally
withdraw the above Suits against all the other Defendants who have not
signed these Compromise Deed Recording Consent Terms.

(17) The Parties hereto, agree and undertake to this Hon’ble Court that they
shall sign (and/or get signed from other accused in ___ FIRs, if and as
required) all the documents/petitions/applications as may be required for the
withdrawal/ dismissal/ quashing of all the civil cases, criminal cases, criminal
complaints, FIRs, Blogs, urls, ______ videos, etc. as mentioned in Annexures
_____

(18) That, in view of the present settlement the Parties to the Suit and other
persons including accused in various civil and criminal cases undertake before
this Hon’ble Court that they shall not engage in any further direct or indirect
and proxy litigations, civil, criminal and defamation of any nature whatsoever
with regard to the present controversy and/or various court proceedings
pending in various courts.

(19) Agreed, declared and confirmed that in view of settlement of the Suits as
above, the respective Notices of Motion pending therein shall stand
withdrawn/dismissed for non-prosecution.

(20) Agreed, declared and confirmed that the signatories who have signed this
Compromise Deed Recording Consent Terms are fully empowered/authorized
by the Plaintiffs and they have attached with this Compromise Deed Recording
Consent Terms attested copies of their authorizations/power of attorneys
(valid upto date) as Annexure 10 (colly). This Consent Minutes of the Order
is being presently signed by ______ on behalf of the Plaintiffs as their
Constituted Attorney/Authorised Signatory. It is expressly and specifically
agreed by and between the Parties hereto that prior to the deposit by
Defendant No. 1, the amounts mentioned in clauses 3(i) and (ii) above, he,
the said ______shall submit with The Prothonotary & Senior Master, High
Court, ____, and the copies thereof, to M/s _______, Advocates and Solicitors
for Defendant No. 1, 4, 5 and 6 an attested Affidavit/Declaration, inter alia,
declaring that the powers and authorities granted to said ______ is valid,
subsisting and binding; that all the actions taken by _________ in the
aforesaid Suits are valid, subsisting and binding upon them; that they have
gone through this Consent Minutes of the Order and accept the same in its
entirety.

(21) Agreed, declared and confirmed that this Compromise Deed Recording
Consent Terms shall be binding on the parties, including other accused in 18

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FIRs, their heirs, legal representatives, administrators, executors, successors,
receivers, liquidators and assigns.

(22) Liberty to the Parties to move this Hon’ble Court for any
clarification/removal of difficulty relating to and/or arising out of this
Compromise Deed Recording Consent Terms.

(23) Refund of Court Fees as per Rules.

(__________)
(____________) Plaintiff/Constituted
Advocates for the Attorney/Director of
Plaintiffs Plaintiffs in all the above
Suits
For M/s _______, For ______________

Proprietor Director
Advocates for Defendant No. 1
Defendant Nos. 1& 4
For M/s ______ For M/s ______

Proprietor Director
Advocates for Defendant No. 2
Defendant No. 2

(______)
Defendant No. 4

( )
Defendant No. 5