IN THE COURT OF HONBLE SENIOR, CIVIL JUDGE,

ROHINI NORTH DISTRICT COURT, DELHI

CS /2023
IN THE MATTER OF:-
M/S. STAR ENGINEERING WORKS
(THROUGH IT’S PROP. MR. ARIF KHAN) …PLAINTIFF

VERSUS

M/S. HI- LAND TRADING COMPANY

(THROUGH IT’S PROP. MR. TAHIR AKHTAR)
...DEFENDANT
INDEX
S.NO. PARTICULARS PAGE
NO.

1 MEMO OF PARTIES

2 SUIT FOR RECOVERY OF OUTSTANDING

PAYMENT OF RS. 94,572/- (RUPEES NINETY
FOUR THOUSAND FIVE HUNDRED
SEVENTY TWO ONLY) INCLUDING
2%INTEREST P.M. SINCE LAST PAYMENT
RECEVIED FROM PARTY.

3 AFFIDAVIT

4 LIST OF DOCUMENTS

5 VAKALATNAMA
 PLAINTIFF
THROUGH

UNSOLVED LEGAL GROUP

Adv. Jagriti Jain &Parthesh
OFFICE AT:-C-8, Ground Floor,
Mahendru Enclave, Delhi-110009
MOB: - 8527506427, 7042312792
PLACE: NEW DELHI
DATED: 24.05.2023
 IN THE COURT OF HONBLE SENIOR, CIVIL JUDGE,
ROHINI NORTH DISTRICT COURT, DELHI
CS /2023
IN THE MATTER OF:-
M/S. STAR ENGIEERING WORKS
(THROUGH IT’S PROP. MR. ARIF KHAN)…PLAINTIFF

VERSUS

M/S. HI- LAND TRADING COMPANY

(THROUGH IT’S PROP. MR. TAHIR AKHTAR)
...DEFENDANT
MEMO OF PARTIES

M/S. STAR ENGINEERING WORKS

(THROUGH IT’S PROP. MR. ARIF KHAN)
OFFICE AT: - C-9, SHIVA MARKET,
KHUREJI KHAS, NEW DELHI- 110051
GSTIN- 07AAPP12812K1ZL …PLAINTIFF

VERSUS
M/S. HI- LAND TRADING COMPANY
(THROUGH IT’S PROP. MR. TAHIR AKHTAR)
AT- 00, HI- LAND TRADING COMPANY,
LAL BAZAR MALERKOTLA, SANGRUR,
PUNJAB- 148023
PHONE NO- 9915289917, 9877485286
GSTIN- 03APDPA6619K1Z5 …DEFENDANT
 THROUGH

UNSOLVED LEGAL GROUP

Adv. Jagriti Jain &Parthesh
OFFICE AT:-C-8, Ground Floor,
Mahendru Enclave, Delhi-110009
MOB: - 8527506427, 7042312792
PLACE: NEW DELHI
DATED: 24.05.2023
 IN THE COURT OF HONBLE SENIOR, CIVIL JUDGE,
ROHINI NORTH DISTRICT COURT, DELHI
CS /2023
IN THE MATTER OF:-
M/S. STAR ENGINEERING WORKS
(THROUGH IT’S PROP. MR. ARIF KHAN) …PLAINTIFF

VERSUS

M/S. HI- LAND TRADING COMPANY

(THROUGH IT’S PROP. MR. TAHIR AKHTAR)
...DEFENDANT

CIVIL SUIT FOR RECOVERY OF RS. 94,572/- (RUPEES NINETY FOUR

THOUSAND FIVE HUNDRED SEVENTY TWO ONLY) INCLUDING 2%
INTEREST P.A. SINCE LAST PAYMENT UNDER CODE OF CIVIL
PROCEDURE CODE, 1908.

MOST RESPECTFULLY SHOWETH:

1. That plaintiff is a proprietorship firm running its business under the name and
style “M/S. STAR ENGINEERING WORKS” having its Office At- C-9,
Shiva Market, Khureji Khas, Delhi- 110051.
2. That plaintiff is working as a leading manufacturer and trader of Toy products
in India. That the company has a considerable amount of market goodwill and
reputation in his respective field. The present civil suit is being filed for and on
behalf of the company by its authorized representative of Mr. ARIF KHAN.
The Copy of GST Certificate of plaintiff firm annexed herewith as
Annexure P-1
3. BRIEF FACTS OF THE PRESENT CIVIL SUIT:
A. That plaintiff is a proprietorship firm running its business under the name
and style “M/S. Star Engineering Works” having its Office At- C-9, Shiva
Market, Khureji Khas, Delhi- 110051.That plaintiff is working as a leading
manufacturer and trader of toy products in India. That the company has a
considerable amount of market goodwill and reputation in its respective
field.
B. That the defendant Mr. Tahir Akhtar Proprietor of M/s. HI- Land Trading
Company having the business relationship with plaintiff since long time and
defendants always purchase the products with the good relationship from
Plaintiff Company. The Copy of the GST Certificate of defendant firm
annexed herewith as Annexure P-2
C. That plaintiff had supplied the defendant with the products and services at
the premises as stated above. That the defendant had placed their requisition
for the plaintiff’s aforementioned goods and services and issued order in
favor of the plaintiff. Thereafter the plaintiff company had provided the said
goods and services by raising Invoices/ Bills that were duly accepted.
Further the goods were duly received and acknowledged by the defendant
with full satisfaction. That the details of goods supplied and the amount
received from defendant are given below:

Particulars Amount (Rs)

Pending Amount 38,793/-

Total Pending Amount With 2% P.M 55,779/-

interest
Total Payable Amount 94,572/-

The Copy of Invoices is annexed herewith as Annexure P-3.

D. That as per the ledger statement maintained by the plaintiff pending principal
amount of Rs 38,793/- (Rupees Thirty Eight Thousand Seven Hundred
Ninety Three Only) for goods and services provided by plaintiff and Rs.
55,779/- (Rupees Fifty Five Thousand Seven Hundred Seventy Nine Only)
as 2% interest P.M. on pending principal amount. Hence, total payable
amount is Rs. 94,572/- (Rupees Ninety Four Thousand Five Hundred
Seventy Two Only) The Copy of ledger statement is annexed herewith as
Annexure P-4.
E. That thus defendant is liable to pay the total amount of Rs. 94,572/- (Rupees
Ninety Four Thousand Five Hundred Seventy Two Only) to plaintiff and
plaintiff is entitled to recover the same from defendant.
F. That plaintiff had requested the defendant several times through telephonic
calls messages and through other modes for release of the said outstanding
payment, but defendant has always been dilly delaying the same on one
pretext or other and so far have not paid the said outstanding undisputed
amount. It is quite clear that defendant do not intend to make the payment of
the due amount and that the defendant are illegally and mala-fiddly
withholding the payment of plaintiff.
G. That the plaintiff sent a legal notice dated 04.05.2023 via speed post and
Whatsapp to defendant about the same and asking them to immediately pay
his outstanding liability of Rs. 94,572/- (Rupees Ninety Four Thousand Five
Hundred Seventy Two Only) including 2% interest P.M since last payment
but since the defendant has failed to pay the outstanding and legitimate dues
to the plaintiff despite aforesaid legal notice which has been duly served to
the defendant via speed post and whatsapp. That the details of services
mention in the below table:
 SERIAL SENT SENT AT DELIVERY
NO. BY STATUS

1. Petitione AT- 00, HI Land Item delivered

r through Trading Company, On 09/05/2023
Speed Lal Bazar
Post Malerkotla, Sangrur,
Punjab- 148023

3. Petitione 9915289917, Message delivered

r through 9877485286 shows “online” on
whatsap the screenshot.
p on
08/05/20
23 to the
defendan
t
number.
The Copy of Legal Notice along with tracking receipt and report and
screenshot of WhatsApp message attached hereunder as Annexure P-5
(colly).
F. That because of defendant’s dilly-dallying tactics and apathetic attitude,
plaintiff has been suffered huge mental pain and agony. It is clear from
defendants’ conduct and attitude that defendant has deceitfully and malafide
intention against plaintiff and further, it is self-evident from the facts that
defendant has misused the business relationship with ulterior motives.
4. CAUSE OF ACTION AGAINST DEFENDANT AND IN FAVOUR OF
THE PLAINTIFF: That the cause of action arose in favour of the Plaintiff and
against the Defendant’s. The cause of action arose when the plaintiff raised first
invoice no. SFW/058/19-20 on 10.06.2019 in year 2019-2022. Further, the
cause of action arouses on every single occasion the defendant’s made part
payment against the invoices raised by the plaintiff. That the cause of action on
against the defendant started the supplying of products. Further, Cause of action
arouses when the defendant’s failed to make payment to the plaintiff. Last
invoice no. SFW/100/19-20 on 27.07.2019. Further the cause of action arose
when a legal notice dated 04.05.2023 was sent on 06.05.2023 through his
lawyer by the plaintiff via speed post to the defendant. The cause of action is
continuing as the Defendant has not made payment as demanded by the plaintiff
till date.
5. The Defendant’s’ even after repeated reminders has failed to honor his
outstanding debt and the plaintiff therefore has sufficient cause of action to file
the present civil suit for recovery.
6. That the plaintiff has no other way to recover the legitimate dues against the
plaintiff, therefore, the plaintiff has been moved the present suit before this
Hon’ble Court for expedited relief.
7. That part of the cause of action arose within the territorial jurisdiction of this
Hon’ble court as the goods were supplied by the plaintiff to the defendant from
the principal place of business of the plaintiff which is situated within the
territorial jurisdiction of this Hon’ble Court. That further the payment for the
goods supplied is to be received at the principal place of business of plaintiff
situated within the territorial jurisdiction of this Hon’ble Court. That therefore,
this Hon’ble Court has got the territorial jurisdiction to entertain and try the
present suit in view of the section 20(c) of the Code of Civil Procedure, 1908.
8. That the value of the suit for jurisdiction and payment of court fees is
approximately Rs. 94,572/- (Rupees Ninety Four Thousand Five Hundred
 Seventy Two Only) on which court fee of Rs. 3,500/- (Rupees Three Thousand
Five Hundred Sixty Only) has been paid.
9. That the plaintiff has valued this suit at Rs. 94,572/- (Rupees Ninety Four
Thousand Five Hundred Seventy Two Only) and the same be allowed before
this Hon’ble Court for an expedited relief.
10.That the present suit is being filed well within the limitation period as
prescribed under the law of limitation.

PRAYER:-

It is therefore respectfully prayed that in the light of the facts and the circumstances of
the present case, the Hon’ble Court may be pleased to:-
1. Pass a decree for a sum of Rs. 94,572/- (Rupees Ninety Four Thousand Five
Hundred Seventy Two Only) in favor of the plaintiff and against the
defendants. 
2. Pass an order for payment of future interest of @2% P.M w.e.f. the date from
when the defendant stopped making payment till its actual realization in the
favor of the plaintiff and against the defendant.
3. Pass an order for awarding the cost of the suit in favor of the plaintiff and
against the defendant. 
4. Pass any other order that this Hon’ble Court may deem fit in the interest of
equity, justice and good conscience.

PLAINTIFF

THROUGH
 UNSOLVED LEGAL GROUP
Adv. Jagriti Jain &Parthesh
OFFICE AT:-C-8, Ground Floor,
Mahendru Enclave, Delhi-110009
MOB: - 8527506427, 7042312792

PLACE: NEW DELHI

DATED: 24.05.2023
Verification: -

I Arif Khan authorized represtative of plaintiff firm do hereby verify that the contents
1 to 4 are true and correct to the best of my knowledge and information obtained from
the records of the firm while the contents of Paragraphs 5 to 11 are based on legal
advice received and believed to be true by me, whereas the last paragraph is the prayer
to this Hon’ble Court. Verified at New Delhi.

PLAINTIFF
THROUGH

UNSOLVED LEGAL GROUP

Adv. Jagriti Jain &Parthesh
OFFICE AT:-C-8, Ground Floor,
Mahendru Enclave, Delhi-110009
MOB: - 8527506427, 7042312792
PLACE: NEW DELHI
DATED: 24.05.2023
 IN THE COURT OF HONBLE SENIOR, CIVIL JUDGE,
ROHINI NORTH DISTRICT COURT, DELHI
CS /2023
IN THE MATTER OF:-

M/S. STAR ENGINEERING WORKS

(THROUGH IT’S AR. MR. ARIF KHAN)

…PLAINTIFF

VERSUS

M/S. HI- LAND TRADING COMPANY

(THROUGH IT'S PROP. MR. TAHIR AKHTAR)
. ...DEFENDANT

AFFIDAVIT

I Arif Khan authorized representative of “Star Engineering Works” having its

At-C-9, Shiva Market, Khureji Khas, Delhi- 110051,the deponent above named
do hereby solemnly affirm and declare as under:-
1. That the accompanying plaint has been drafted under my instructions.
2. I am sufficiently conversant with the facts of the case and have also examined
all relevant documents and records in relation thereto.
3. I say that the statement made in the paragraphs 1 to 4 are true to my knowledge
and statements made in paragraphs 5 to 11 are based on legal advice and
believed to be correct.
4. I say that there is no false statement or concealment of any material fact,
document or record and I have included information that is according to me,
relevant for the present petition.
5. I say that all documents in my power, possession, control or custody, pertaining
to the facts and circumstances of the proceedings initiated by me have been
disclosed and copies thereof annexed with the petition and that I do not have
any other document in my power, possession, control or custody.
6. I say that I am aware for any false statement or concealment; I shall be liable
for action taken against me under the law.  
7. That the content of the petition has been read over to me in vernacular.

DEPONENT
VERIFICATION: -
I ARIF KHAN authorized representative of “Star Engineering Works”, hereby
declare that the statements above are true and correct to my knowledge.

DEPONENT
 IN THE COURT OF HONBLE SENIOR, CIVIL JUDGE,
ROHINI NORTH DISTRICT COURT, DELHI
CS /2023
IN THE MATTER OF:-
M/S. STAR ENGINEERING WORKS
(THROUGH IT’S PROP. MR. ARIF KHAN) …PLAINTIFF

VERSUS

M/S. HI- LAND TRADING COMPANY

(THROUGH IT’S PROP. MR. TAHIR AKHTAR)
...DEFENDANT

LIST OF DOCUMENTS

S. Details of Documents in Original or Mode of Line Page No.

N parties to power/possessi photo copy of execution/is of
O documents on control office copy suance of custo
. custody of receipt dy
1. Copy of Plaintiff Photocopy
GST Copy of GST
Certificate Certificate of
of Plaintiff Plaintiff
firm company
2 The Copy Photocopy of
of the GST GST
Certificate Certificate of
of defendant firm
defendant
firm
3 Copy of Plaintiff Photocopy of
the Invoices/Bills
 Invoice/Bil
ls
4 Copy of Plaintiff Photocopy of
the ledger Ledger
statement Statement

5 Legal Plaintiff Original Copy

notice to
dated Defen
04.05.2023 dant
with proof
of dispatch
along with
the
whatsapp
screen
shot.

PLAINTIFF
THROUGH

UNSOLVED LEGAL GROUP

Adv. Jagriti Jain &Parthesh
OFFICE AT:-C-8, Ground Floor,
Mahendru Enclave, Delhi-110009
MOB: - 8527506427, 7042312792
PLACE: NEW DELHI
DATED: 24.05.2023
 IN THE COURT OF HONBLE SENIOR, CIVIL JUDGE,
ROHINI NORTH DISTRICT COURT, DELHI
CS /2023
IN THE MATTER OF:-
M/S. STAR ENGINEERING WORKS
(THROUGH IT’S AR. MR. ARIF KHAN)

…PLAINTIFF

VERSUS

M/S. HI- LAND TRADING COMPANY

(THROUGH IT'S PROP. MR. TAHIR AKHTAR)
. ...DEFENDANT
I ARIF KHAN authorized represtative OF “STAR ENGINEERING WORKS” HAVING ITS AT-C-9,
SHIVA MARKET, KHUREJI KHAS, DELHI- 110051, DO HEREBY SOLEMNLY AFFIRM AND
DECLARE:
The above-named plaintiff does hereby appoint.
UNSOLVED LEGAL GROUP
LAW FIRM
Adv.JAGRITI JAIN (D/6347/2018)
Adv.PARTHESH(D/3800/2020)
COUNSELS FOR PLAINTIFF
OFFICE AT:-C-8, GROUND FLOOR,
MAHENDRU ENCLAVE, DELHI-110009
MOB: - 8527506427, 7042312792
Advocate(s), to be my/ our true and lawful attorney (s), in the matter noted above, to do all the following
acts, deeds and things, or any of them, (jointly and severally) and also ratify anything already done on our
behalf that is to say: -
1. To sign, verify and present and send notices, replies rejoinders, pleadings, appeals, cross-objections or
petitions for execution, review, revision, other petitions or affidavit or other documents as shall be deemed
necessary or advisable for the prosecution of the case or in relation thereto in all its stages.
2. To appear, act, and plead in the above-mentioned case in any court or tribunal etc, in which the same be
heard or tried in the 1st instance or in appeal or review or revision or execution or in any other stage of its
progress until its final decision.
3. To withdraw or compromise the said case or submit to arbitration any differences or disputes that may arise
to or in any manner relating to the said case.
4. To receive documents, papers, records, orders etc. and to do all other acts all things, which may be necessary
or proper to be done for the progress and in all course of the prosecution of the said case.
5. To employ any other legal practitioner, advocate or consultant authorizing him to exercise the power and
authority hereby conferred on the Advocate (s) whenever he/they may think fit to do so.
And I/We hereby agree that whatever the Advocate (s) or his/ there substitute shall do in the premises shall be
binding on me in all intents and purposes just as if it would have been done by me.
And I/We hereby agree not to hold the Advocate (s) or his/their substitute responsible for the said case in
consequence of his absence from the court when the said case is called up for hearing.
And I/We hereby agree that in the event of the whole or any part of the free agreed by me/ us to be paid to
the Advocate (s) remaining unpaid he/they shall be entitled to withdraw from the prosecution of the said
case, or not to appear until the same is paid.
In witness whereof I/We hereunto set my/our hand to these presents the contents of which have been
explained to and understood by me/us.

Date: ___________
Advocate Client