That the planters was owner of land measuring 8 canal for the detailed a vendor 0 canal – 15 m being

half share of land measuring 1 canal – 10 m comprised in cable khata number 47 oblique 3 – 472
rectangle rectangle number 5 kila number 13 public to one-10-1 next para 3 canal 12 and half Marley
being half share of land measuring 7th situated in village dhanela tahsil Sohna district gurugram white
jamabandi for the year 2014-15 and mutation number 1932 1 sanctioned on 21 2016 next para that
defendantly executive number 1661 dated 22 may 2022 in favour of defendant by alluring the planter
that next para that at the time of execution of the other was not having remaining consideration
amount and when shrimati Shital Arora raised objection 1 4100 which is which is mentioned in the
agreement dated 8 February 2020 and also raised objection that in the agreement there is a mention
regarding a passage where as no such mention has been made in the agreement but in the sale deed
passage land has been mentioned then the defendant threat and shrimati Shital Arora that this is not
her area and this area is under the defendant under the position of the defender at this what spot so on
compiling circumstances shrimati Shital Arora executive under pressure which is illegal null and void
voidable and is not bound upon the rights of the planter. It is also pertinent to mention here that
defendant with malafide intention mentioned 11 checks and also mentioned rupees 1 60000 cash and
same has not been paid by the dependent till today in the sale deed next para that after execution of
the cell did when printed presented the check bearing number 596425 of rupees 10 lakh and check
number 596 426 of rupees 10 lakh both dated 25.8.2 State Bank of India ward number 5 Delhi Alwar
road opposite stand Sona district Gurgaon Haryana from account number 62318945272 which were
issued by one Shahid only asking of and on behalf of the defended which is mentioned for payment to
the banker the same was was received back by the banker of the plantiff wide two memodated 26.8.20
each as well as second time memos get it 6.10.2 with the remarks funds in sufficient meaning their by
that there was no and cashment of the side checks and sale has not been completed it is also putting
mention here that these checks have been issued only for the full film of the requirement of the sel
deed before the registrar. Next para that it is pertinent to mention here that the check bearing number
000 dated 25.8.2 of rupees 10 lakh drawn from HDFC Bank limited Village dhanala district gurugram
from account number 501 000 329 711 77 you should buy the defendant himself which is mentioned in
the cell did has also behind wide Memon dated 26.8.2 as well as second time memorated 6.10.2020
with the remarks funds insufficient meaning their by that there was no engagement of the set check and
sale has not been completed. Next para that there after plentiff many times represted the dependent to
pay the check amount and request to transfer the land of the passag

That there after the plantive many times requested the defendant as well as the as well and we also to
cancel the sale deed which is quite illegal nal and ward invalid and infective in operative but defendant
did not pay any heat to the genuine request of the planter next para that there after the planted came
to know that the defendant have been making negotiations for the further sale deed of the above set
land

the plantive does not left with any alternative except to file a civil suit before the unable court at
Gurgaon seeking the seeking the declaration to the effect that the cell did bearing 166 and also not
winding up on the rights of the blanket with the consequential relief of permane injection from
furthering the suit property by way of sale mortgage charge line gift etc. Gurgaon next para that the
plantiff also file complaints under section 138 negotiable instruments act before the London judicial
magistrate first class at Karnal seeking proper legal remedy against against the defendant. Next para
that during the pregnancy of detail litigation the defendant transferred a sum of rupees 30 lacs in the
account of the planter on dated black black. That the receipt this amount under protest and with drew d
complaint under section 138 making statement before the honorable code to reserve the right to
recover the interest on the delayed payment the charges for the harassment and humiliation waste by
the plantiff due to the this delay in the payment and to see the recovery of the remaining payment as
mentioned in the agreement to sell but troubletely not mentioned in the cell did by the defendant

That the plantiff has suffered invisible loss due to the delay in payment by the defendant in fact it was
not only the delay in the payment but the mall intention and fraudulent behaviour of the defendant
which caused grave in convenience harassment emulation to the lentif as she was under the fear of
losing precious land as well as the due compensation which she was entitled after the sale of this land. It
is pertinent to mention here that the plentified also entered into an agreement to purchase further
piece of land so as to reinvest the amount received by her in this cell dead but as she did not receive the
full payment of this cell did she was unable to execute the purchase agreement of the next de which she
made for the purchase of property she had to further suffer a huge loss to the tune of rupees 10 lacs as
she was unable to complete this d deal. The plantiff also had to beer a huge cost of the unwanted
litigation to in pursuing the complaint under section 138 to recover her rightful due from the defendant
full stop that the defendant also lost precious time in running from pillar to post and pursuing this
litigation to recover her rightful views also suffer from grave mental torture and Agoni act and omission
of the defendant for which cannot be concern compensated in any form or manner however the ends of
justice would be serve if the defendant is directed to pay damages of rupees 10 lakhs along with interest
and cost due to his cost