Download as pdf or txt
Download as pdf or txt
You are on page 1of 79

R.

Raghava Krishna Bharadwaj


Roll number – 172820831198
PMR Law collage

S.l No TOPIC
1. LEGAL NOTICE

2. AFFIDAVIT AND PETITION

3. TEMPORY INJUNCTION PETITION

4. MEDICAL NEGLIGENCE PETITION

5. SUIT BEFORE RAILWAY TRIBUNAL

6. WRIT OF HEABUS CORPUS

7. CAVEAT PETITION

8. PUBLIC INTEREST LITIGAGTION

9. WRIT OF MANDAMUS

10. DIVORCE PETITION

11. WRITTEN STATEMENT BEHALF OF


CHANDRA
12. SUIT FOR CLAIM FOR NEGLIGENT
ACT
13. WRITTEN STATEMENT BEHALF OF
JOHNY
14. SPECIFIC PERFOMENCE OF
CONTRACT
15. BAIL APPLICATION

16. GIFT DEED

17. TRUST DEED

18. WILL

19. SIMPLE MORTAGE

20. GENERAL POWER OF ATTORNY


R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

21. LEASE DEED

22. SALE AGREEMENT

23. SURETY BOND

24. DEED OF EXCHANGE

25. PROMISORY NOTE

26. ADOPTION DEED

27. PLEDGE DEED

28. CHEQUE DISHONER

29. PATNERSHIP DEED

30. USEFRUCTUARY MORTAGAGE DEED

\
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

PROBLEM – 1

LEGAL NOTICE
BY REGD. POST WITH ACK. DUE

To,

Vikram

Under the instructions from my client Ravi R/o. Hyderabad, I am herewith issuing
following statutory notice.

1. My client states that he is the absolute and lawful owner and possessor of Shop
premises at Hyderabad.

2. My client states that you have approached my client for rent of the above said
premises for running a business and my client agreed to give rent above said premises
for 8,000/-per month, subsequently rental agreement was executed between you and
my client.

3. My client states that, you have defaulted in payment of 48,000/- rents from last 6
months to till this day, in this regard my client contacted you and gave several reminders
to pay due rent but you failed to respond to choose either of the options but you have
been negligently postponing and avoiding to talk to my client.

4. It is stated that by the above said acts you are depriving my client to enjoy the
premises, causing financial and monetary loss to have prospective monthly rents
generated on the demised premises, thereby caused mental agony to my client, So You
are deliberately and with an ulterior motive are depriving my clients to undergo financial
loss, only with an intention to defraud my client by committing breach of covenants of
the rental agreement. Hence my client does not want to keep you any more as tenant,
therefore your tenancy is terminated advising to deliver the vacant possession.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Therefore , I call upon you to pay my client a sum of Rs.48,000/- (6 month’s rent )
within 7days from the receipt of this notice, and to handover the vacant demised
premises to my client, failing which you would be treated using the demised premises
in wrongful and unauthorizedly and you shall be liable to pay an additional amount
towards illegal continuation until you are ejected through due process of law for which
you shall be liable to pay damages as well and my client will be constrained to take
appropriate action as per law for recovery of rent as stated above , for which you
will be held liable for all the costs and consequences arising thereto.

(RAGHAV KRISHNA BHARADWAJ)


ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No 2

IN THE COURT OF HON’BLE JUNIOUR CIVIL JUDGE: AT RANGAREDDY


O.S. No: 450 OF 2014

Between:

Krishna S/o Narayana,


Aged abut 40years,
R/o Hayathnagar …Petitioner/ Applicant

And

Jagadeesh S/o Shankar,


Aged abut 50years,
R/o L.B Nagar, Rangareddy
…Respondent/Defendants

PETITION FILED UNDER ORDER XIII RULE IX OF CPC

For the reasons stated in the accompanying affidavit that this Hon’ble Court may
be pleased to issue all my original documents which submitted in OS 450/2014 in the
interest of justice and pass such further or other order or orders as this Hon’ble Court may
just and proper in the circumstances of the case.

Place: Hyderabad
Date : 27 -06-2023 COUNSEL FOR PETITIONER

(RAGHAV KRISHNA BHARADWAJ)


ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

IN THE COURT OF HON’BLE JUNIOUR CIVIL JUDGE: AT RANGAREDDY

O.S. NO 450 OF 2014

Between:

Krishna S/o Narayana,


Aged abut 40years,
R/o Hayathnagar …Petitioner/ Applicant

And

Jagadeesh S/o Shankar,


Aged abut 50years,
R/o L.B Nagar, Rangareddy
…Respondents/Defendants

AFFIDAVIT

I, Krishna S/o Narayana, Aged abut 40years, R/o Hayathnagar do hereby


solemnly affirm and state on oath as follows:

1. I am the deponent herein and party to the proceedings as such I am well acquainted
with the facts of the case.

2. I submit that I have filed suit for permanent injection against Jagadeesh S/o
Shankar aged 50years residing at L.b.nagar, Rangareddy District before Hon’ble
junior civil judge at Rangareddy District vide original suit bearing no 450 / 2014.

3. I submit that I have filed all my original documents along with the suit before
Hon’ble civil judge at Rangareddy, the same suit was disposed on 10/01/2023.

Therefore, it is prayed that this Hon’ble Court may be pleased to return all my original
documents back in the interest of justice.

Sworn and signed before me


On this the day of July, 2023
DEPONENT
At Hyderabad
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No: 3

IN THE COURT OF THE HON’BLE CIVIL JUDGE: CITY CIVIL COURT:


AT SECUNDERABAD

O.S No. OF 2023

Between:

Mr.Ranga … Plaintiff

AND

Mr.Manish … Defendant

PLAINT FILED UNDER ORDER 39 C.P.C


SUIT FOR TEMPORARY INJUNCTION

DESCRIPTION OF THE PLAINTIFF:

The address of the plaintiff for the purpose of service of summons, notices and
process etc. is the same as shown in the above cause title.

DESCRIPTION OF THE DEFENDANT:

The address of the defendant for the purpose of service of summons, notices and
process etc., is the same as shown in the above cause title.

FACTS OF THE CASE :

1. The plaintiff submitted that city civil court Hyderabad passed decree in favour of
respondent that granting permission to sell away bungalow situated in Ameerpet .
2. The plaintiff submitted that His brother is plaintiff in above said suit and decree passed
in favour of defendant.
3. Further It is submitted that plaintiff is the real and true tittle holder of the bungalow,
plaintiff brother has no legal authority to file above said suit , decree has no legal
grounds to execute,
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

4. It is submitted that plaintiff did not received any notice from the respondent and decree
passed by city civil court violates legal rights or legal interest of plaintiff.

• CAUSE OF ACTION:

The cause of action for the suit arose when decree passed in fevour of defendant
by city civil court Hyderabad and when the plaintiff got knowledge about decree.

• JURISDICTION

The plaintiff is residing at Hyderabad which comes under Hyderabad mandal. The
cause of action also arose at Hyderabad city civil court where the promissory note was
executed by the defendant at plaintiff’s residence. Hence this Hon’ble court has got
jurisdiction to entertain the suit.

VI. LIMITATION

Plaintiff declare that cause of action arose within limitation period

VII. DECLARATION

The plaintiff hereby declares that he had not filed any suit before any court against
the defendant for the relief claimed in the suit.

PRAYER

The Hon’ble court be pleased decree the suit of the plaintiff and against the defendant as
under:
a) That plaintiff is the owners and possessors of the suit property.
b) That the Temporary injuction order be passed against the defendants and in favour
of plaintiff
c) Any reliefs to which the plaintiff is entitled to in the circumstances of the case.

Place: Secunderabad PLAINTIFF


Date : -03-2023

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

VERIFICATION

We the above, named plaintiff do hereby state that the contents of above parts of
plaint have been read over and the same are true and correct to best of my knowledge,
and belief and information.

Place : Hyderabad
Date : 27-03-2023

PLAINTIFF

LIST OF DOCUMENTS

1. Certified copy of Decree passed in city civil court.


2. Certified copy sale deed of property
3. Identity proof of plaintiff

Place: Hyderabad
Date : 27 -03-2023

PLAINTIFF

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

IN THE COURT OF THE HON’BLE CIVIL JUDGE: CITY CIVIL COURT:


AT SECUNDERABAD

O.S.No. OF 2023

Between:

Mr.Ranga … Plaintiff

AND
Mr.Manish … Defendant

VERIFY AFFIDAVIT

I Ranga age 36 years, Occ: Business, R/o. Hyderabad. do hereby solemnly affirm
and oath as under.

1. That I am the petitioner herein and plaintiff in the main suit and as such I
well acquainted with the facts of the case.
2. It is submitted that city civil court Hyderabad passed decree in favour of
respondent that granting permission to sell away bungalow situated in
Ameerpet.
3. It is submitted that my brother has no legal authority to plaintiff in above said
suit and decree passed in favour of defendant.
4. Further It is submitted that plaintiff is the real and true tittle holder of the
bungalow, plaintiff brother has no legal authority to file above said suit,
decree has no legal grounds to execute.
5. It is humbly submitted that plaintiff did not received any notice from the
respondent and decree passed by city civil court violates legal rights or legal
interest of plaintiff.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

I hereby declare that the contents of the affidavit herein above are true and
correct to the best of my knowledge and belief, and legal advice and documents filed by
me are genuine,
hence verified the same to be true and correct, and hence verified on this day of March,
2023 at Hyderbad.

Sworn and signed before me


On this the day of March, 2023
DEPONENT

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No.4

BEFORE THE HON’BLE DISTRICT CONSUMER DISPUTES REDREESAL FORUM: ,

AT: HYDERABAD

C.C.No. OF 2023

BETWEEN:

Mr.Venkatesh
….Petitioner

AND

State of Telangana
Rep by chief secretary
And other concern doctors …RESPONDANT

COMPLAINANT FILED UNDER SECTION 12 OF THE CONSUMER PROTECTION


ACT 1986

I. DESCRIPTION OF THE COMPLAINANT:

The description of the complainant is the same as stated above in the cause title
and the address for service of all notices, summons etc.,.

II. DESCRIPTION OF THE OPPOSITE PARTY:

The description of the opposite parties and their address for service of all notices,
summons etc., is the same as stated above in the cause title.

III. BRIEF FACTS OF THE CASE:


R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

1. The complainant herein humbly submits that he had swelling in his knee suffered
abnormal knee pain, visited in opposite parties hospital.

2. The complainant submits that the opposite party after examine him, they has
written some medical tests after checking report was referred to general surgeon.
According to the reference he went to the General surgeon, and explained about
the knee pain. After checkup and talking with the complainant and the opposite
party doctor said it is general pain and gave some medicines and if the pain is not
reduced to come again.

3. The complainant submits that he visited to the opposite party hospital again, as his
pain was not reduced to the medicines prescribed by the opposite party hospital
doctors, Doctors advised complainant to admit in the hospital for knee
implementation surgery. The complainant asked about details of knee surgery and
the doctor prescribed the same medicines and asked to continue the same
medicines for 3 days. the complainant along with his family member went to
hospital as the pain was subsisting. The doctor advised to admit. The complainant
admitted in the hospital, he was given some medicines and did medical test
following, ECG, X-Ray, Blood, urinal and other tests. The complainant requested the
hospital to show the report to show them to his relatives who are in medical
profession, but the hospital has not accepted to show the reports and promise knee
implementation surgery will cure your knee pain permenantly. Took all necessary
signatures and operated knee implementation surgery.

4. The complainant submits that doctors suggested to him take 15 days bed rest.
After implementation surgery, complainant disable and he couldn’t move his legs
even after rest for 1 month, and complainant along with his family members
contacted opposite party hospital, the response from opposite hospital was not
adequate.

5. The complainant humbly submits that he consulted other medical professional


along with medical reports of opposite hospital, after detailed examination medical
professional declare that the knee implementation surgery is failed as result which
complainant is disabled.

6. The complainant humbly submits that complainant disabled and his family spent
sleepless nights due to the wrong diagnosis and treatment of the Opposite hospital
doctors Negligence but they did not accept their negligence though they have
executed a bond to compensate if their negligence is established, complainant
approached the Opposite hospital but it was denied any compensation by the
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

respondant in the given circumstances the complainant has no other way but to
approach this Hon’ble Forum to seek redressal of his case hence this complaint.

7. It is humbly submitt that complainant work as private employee and he is only


earning capacity for his family, responsible over his old aged parents, wife and
children, disability of complainant leads financial imbalance and family members
future is uncertain.

I. CAUSE OF ACTION:

Cause of action arose when the complainant visited hospital for treatment, and all
subsequent dates when the complainant has admitted and treated in the opposite
hospital.

II. JURISDICTION: This Honorable Forum has jurisdiction to try this complaint, as such
this Hon’ble Forum has pecuniary jurisdiction and the opposite party hospital is
situated at Hyderabad - 44, and the complainant resides at Hyderabad , as such,
this Honorable Forum has territorial jurisdiction also to try the present complaint.

III. LIMITATION: This complaint is within the limitation of two years prescribed under
the Consumer Protection Act, as the complainant was taken for treatment to the
opposite party hospital on before two years. Hence, this complaint is within time.
.
PRAYER:
a) To direct the opposite parties to compensate Rs. 10,00,000 as per the undertaking
given by the hospital.
b) To direct opposite party to 60% of my wages for the loss of earning capacity due to
the disability.
c) To direct the opposite party to return Rs. 2,00,000 other expenses incurred by the
complainant towards transportation and other incidental expenses.
d) To pay an amount of Rs. 25,000/- towards legal expenses and filing this complaint.
e) to grant any other reliefs the Hon’ble Forum deems fit and proper in the
circumstances of the case in the interest of justice.

Place: Hyderabad
Date : 27 -06-2023 COUNSEL FOR PETITIONER

(RAGHAV KRISHNA BHARADWAJ)


ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

VERIFICATION

I, Mr.Venkatesh , Occ: Private Employee, R/o, Hyderabad-500092; do hereby verify and


declare that the contents stated above are true and correct to the best of my knowledge,
belief and as per legal advice.

Deponent
Hence, verified on this the day
Of 2023 at Hyderabad.
ADVOCATE/ HYDERABAD

LIST OF DOCUMENTS

a) All medical reports of govt hospital including test reports.


b) Reports that declare disability.
c) I ‘d proof and employment certificate

BEFORE THE HON’BLE DISTRICT CONSUMER DISPUTES REDREESAL FORUM: ,

AT: HYDERABAD

C.C.No. OF 2023

BETWEEN:

Mr.Venkatesh
….Complainant

AND

State of Telangana
Rep by chief secretary
And other concern doctors …RESPONDANT
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

VERIFY AFFIDAVIT

I, Mr.Venkatesh , Occ: Private Employee, R/o, Hyderabad-500092,do hereby solemnly


affirm and oath as under.

1. That I am the petitioner herein and plaintiff in the main suit and as such I
well acquainted with the facts of the case.
2. It is submitted that I had swelling in his knee suffered abnormal knee pain ,
visited in opposite parties hospital.

3. It is submits that the opposite party after examined me, they has written
some medical tests after checking report was referred to general surgeon.
According to the reference I went to the General surgeon, and explained
about the knee pain. After checkup and talking with the complainant and the
opposite party doctor said it is general pain and gave some medicines and if
the pain is not reduced to come again.

4. It is submits that I have visited to the opposite party hospital again, as my


pain was not reduced to the medicines prescribed by the opposite party
hospital doctors, Doctors advised me to admit in the hospital for knee
implementation surgery, I have asked about details of knee surgery and the
doctor prescribed the same medicines and asked to continue the same
medicines for 3 days. I am along with my family member went to hospital as
the pain was subsisting. The doctor advised to admit. I am admitted in the
hospital, I was given some medicines and did medical test following, ECG, X-
Ray, Blood, urinal and other tests. I have requested the hospital to show the
report to show them to my relatives who are in medical profession, but the
hospital has not accepted to show the reports and promise knee
implementation surgery will cure your knee pain permenantly. Took all
necessary signatures and operated knee implementation surgery.

5. It is submits that doctors suggested to me take 15 days bed rest. After


implementation surgery, I am disabled and I couldn’t move my legs even after
rest for 1 month, and I am along with his family members contacted opposite
party hospital, the response from opposite hospital was not adequate.

6. I humbly submits that I have consulted other medical professional along with
medical reports of opposite hospital, after detailed examination medical
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

professional declare that the knee implementation surgery is failed as result


which I was disabled.

7. I further submits that I am and my family spent sleepless nights due to the
wrong diagnosis and treatment of the Opposite hospital doctors Negligence
but they did not accept their negligence though they have executed a bond
to compensate if their negligence is established, I have approached the
Opposite hospital but it was denied any compensation by the respondent in
the given circumstances I have no other way but to approach this Hon’ble
Forum to seek redressal of his case hence this complaint.

8. It is humbly stated that I work as private employee and I am the person who
earning capacity for my family, I am responsible over my old aged parents,
wife and children, my disability leads financial imbalance and family
members future is uncertain.

I hereby declare that the contents of the affidavit herein above are true and correct to the
best of my knowledge and belief, and legal advice and documents filed by me are genuine,
hence verified the same to be true and correct, and hence verified on this day of
March, 2023 at Hyderbad.

Sworn and signed before me


On this the day of March, 2023
DEPONENT

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No .5

BEFORE THE HON’BLE RAILWAY TRIBUNAL:AT: HYDERABAD

C.C.No. OF 2023

BETWEEN:

Raghav Krishna Bharadwaj


… Plaintiff
AND

The Union of India, Rep. by General Manager,


South Central Railways. … Defendant

COMPLAINANT FILED UNDER RAILWAY CLAIMS TRIBUNAL ACT.1987

I. DESCRIPTION OF THE COMPLAINANT:

The description of the complainant is the same as stated above in the cause title
and the address for service of all notices, summons etc.,.

II. DESCRIPTION OF THE OPPOSITE PARTY:

The description of the opposite parties and their address for service of all notices,
summons etc., is the same as stated above in the cause title.

III. BRIEF FACTS OF THE CASE:

1. It is submitted that plaintiff decided to shift his goods to one place to another
place through railway cargo. and defendant company is involved in business of
transportation of goods to one place to another place through train.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

2. it is submitted that value of goods in transit is above Rs 2.00.000/- and plaintiff


packed goods separately and all put together safely in one large size carton box
and sealed tightly with tape.
3. It is submitted that plaintiff filled all required forms and handover goods to
defendant company to transport and paid specified amount therein and defendant
company accept the shipment and issued CIM (Consignment note), CIM is
document providing the conclusion of transport contract include undertaking.
4. It is submitted that plaintiff after received box from defendant company , opened
box and found that some of goods in transit were lost, the value of goods lost transit
is 70,000/-.
5. It is submitted that plaintiff given multiple reminders to railway authority also sent
legal notice to concern officer for compensate as per contract and insurance terms
but response from the defendant company was inadequate in the given
circumstances I have no other way but to approach this Hon’ble Forum to seek
redressal of his case hence this complaint.

IV. CAUSE OF ACTION: Cause of action arose when the plaintiff given his goods for
transport with defendant company.

V. JURISDICTION: This Hon’ble Tribunal has jurisdiction to try this complaint, as such
this Hon’ble Tribunal has pecuniary jurisdiction as cause of action arose and and
the complainant resides at Hyderabad.

VI. LIMITATION: This complaint is within the limitation of one year prescribed under the
Act, as plaintiff lost his goods before 0ne year. Hence this complaint is within time.

PRAYER

The Hon’ble Tribunal be pleased order the suit of the plaintiff and against the defendant
as under:

a) To direct the opposite parties to compensate value of lost goods Rs.70,000/-


including specified amount which paid by plaintiff and other expenses incurred
by the plaintiff towards transportation and other incidental expenses.
b) To pay an amount of Rs. 25,000/- towards legal expenses and filing this
complaint.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

c) to grant any other reliefs the Hon’ble Tribunal deems fit and proper in the
circumstances of the case in the interest of justice.

Hyderabad
Complainant
Date

VERIFICATION

I, am plaintiff of the above said suit, Occ: Private Employee, R/o, Hyderabad-500092; do
hereby verify and declare that the contents stated above are true and correct to the best
of my knowledge, belief and as per legal advice.

Deponent
Hence, verified on this the day
Of 2023 at Hyderabad.
ADVOCATE/ HYDERABAD

LIST OF DOCUMENTS

a) Bill of Lading.
b) Cargo insurance certificate.
c) Report of detail valuation of goods in transit
d) Notices and letter of remainders
e) Id proofs

Place: Hyderabad
Date : 27 -06-2023
Deponent

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No : 6

IN THE HIGH COURT OF THE JUDICATURE OF TELANGANA


: AT HYDERABAD

(SPECIAL ORIGINAL JURISDICTION)


UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

W.P.No. OF 2023

Between:

Gopal ... Petitioner

And

1. State of Telangana
Rep by home department.

2. Station officer
Vanastalipuram PS … Respondent

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA


PRAYING INTER ALIA FOR ISSUING WRIT OF HABEAS CORPUS.

I. BRIEF FACTS OF THE CASE:

1) That the petitioner resides at hyderbad ,Telangana and has been a law
abiding citizen of India.

2) That the respondent called petitioner to station for a urgent piece of work
and detained in lockup without being assigned any reason and legal cause.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

3) That, on the date of getting detained and arrested in PS Vanastalipuram.


The Petitioner was not informed about the grounds of his detention by
Respondent No. 1 and 2.

4) That the petitioners family members along with their counsel approached
respondents and also given multiple remainders regarding arrest but the
response from respondent inadequate.

5) That the Petitioners have no other efficacious remedy except to approach


this Hon'ble Court by way of this Petition under Article 226 of the
Constitution of India. 9. That the Petitioners have not filed any other petition
or preceding in any court or tribunal throughout the territory of India
regarding the matter.

6) It is submitted that the process of detention that followed by respondent


violative of Fundamental Rights which guaranteed under Article 21 of the
Indian Constitution.

PRAYERS:

In view of the facts & circumstances stated above, it is most respectfully


prayed that this Hon'ble Court may be pleased to pass following orders :-

1. Issue a Writ of Habeas Corpus to the Respondent 1 to 2 thereby Writ


Directing release of the Petitioner.
2. Issue appropriate Writ granting reasonable compensation to the
Petitioner.
3. Any other relief, order or direction this court may deem fit and proper under
the facts and circumstances of this case.

VERIFICATION STATEMENT

I, Sri Gopal, being the petitioner and deponent herein do hereby declare that the
contents of petition are true to the best of my knowledge, belief, and information and rest on
legal advice of my counsel, hence verified on this the Day of 2023 at Hyderabad.

DEPONENT

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :7

(Memorandum of Caveat Petition U/s 148-A of C.P.C.)

IN THE HIGH COURT OF JUDICATURE OF TELANGANA


AT HYDERABAD

Caveat Petition No. / 2023

Between:

Mr.A … Caveator

And

Mr.B . … Respondents

The address for service of all notices and processes on the above named Petitioner
is that of their Counsel Raghav Krishna Bharadwaj ,Shravan patel, Mahaveer Srujan
Reddy and Santhoshi, Advocates Hyderabad - 007.

MAY IT PLEASE THE HON’BLE COURT:

1) Pray that no Ex-parte order be passed in any suit or case for orders to be
instituted by opponents above-named in the honorable civil court against
caveator in connection with the loan granted to Mr. A by opponent bank without
due notice of proposed suit to the caveator above named.
2) The address of the Caveator for service of notice/summons of the proposed
suit/application of the Opponent above named is as per the title clause of this
application.
3) The Caveator undertakes to serve a copy of this application by Registered Post
A.D. to the Opponents above-named.
4) Fixed Court fees stamp is affixed to the Caveat application.

Hyderabad

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :8

IN THE HIGH COURT OF THE JUDICATURE OF TELANGANA


: AT HYDERABAD
(SPECIAL ORIGINAL JURISDICTION)
UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

W.P.No. OF 2023

Between:

RAGHAV KRISHNA BHARADWAJ ... Petitioner

And

1) TELANGANA STATE COMMISSION FOR


PROTECTION OF CHILD RIGHTS (TSCPCR).

2) POLICE COMMISSIONERATE OF WOMEN DEVELOPMENT


AND CHILDWELFARE.

3) STATE OF TELANGANA
REP BY MINISTRY OF EDUCATION

4) UNION OF INDIA
REP BY MINISTRY OF HOME AFFAIRS

5) ANY OTHER CONCERN AUTHORITY


… Respondent

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA


PRAYING INTER ALIA FOR ISSUING WRIT

• BRIEF FACTS OF THE CASE:

1. That the I am the petitioner and resides at hyderabad, Telangana and has been a
law abiding citizen of India.
2. It is stated that child beggars almost everywhere in hyderabad city, most commonly
at traffic signals, railway stations, bus stands, religious places and popular markets.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

3. It is stated that begging mafia is actively behind this menace of begging by the
children and they in fact they kidnap through train, force and torture innocent
children for begging.
4. It is stated that females carrying small children and toddlers can be easily seen
begging at traffic signals, in markets, outside temples or any other crowded places,
can easily spot women with toddlers or small girls and boys begging near redlight
crossings near High court.

5. It is stated that begging mafia is actively behind this menace of begging by the
children and they in fact they kidnap, train, force and torture innocent children for
begging.

6. Further it is stated that Gangs/ Mafia members deliberately harm and injure and
many time make these children handicapped in order to get maximum sympathy of
people, it has been commonly in winters that young girls hold toddlers without
clothes to gain maximum sympathy.
7. It is stated that department that is responsible for curbing this menace has failed
to take remedial steps.

• PRAYERS :

In view of the facts & circumstances stated above, it is most respectfully prayed that this
Hon'ble Court may be pleased to pass following orders :-

a. Directions to respondents that Constitution of India mandates the State to make


efforts to provide best opportunities for the development of children and ensure
that they are not abused.
b. Directions to respondents concerned to file a status resport in court after every
three months and identify number destitute of children who are involved or pushed
into begging.

c. Directions to respondents to council and rehabilitate children who are pushed into
begging and make proper facilities for proper education of children.

d. Directions to respondent that to find and arrest the mafia/gangs who are pushing
children and innocent women into begging.

e. Any other relief, order or direction this court may deem fit and proper under the
facts and circumstances of this case.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

VERIFICATION STATEMENT

I, Raghava krishna Bharadwaj , being the petitioner and deponent herein do hereby
declare that the contents of petition are true to the best of my knowledge, belief, and
information and rest on legal advice of my counsel, hence verified on this the day of
2023 at Hyderabad.

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE DEPONENT
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No : 9

IN THE HIGH COURT OF THE JUDICATURE OF TELANGANA


: AT HYDERABAD
(SPECIAL ORIGINAL JURISDICTION)
UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

W.P.No. OF 2023

Between:

Mr. Prakash ... Petitioner

And

Regional passport officer


73, red cross road, Shivaji Nagar,
Secunderabad
… Respondent

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA


PRAYING INTER ALIA FOR ISSUING WRIT OF MANDAMUS.

• BRIEF FACTS OF THE CASE:

1. It is stated That the petitioner resides at hyderabad. Telangana and has been a
law abiding citizen of India.
2. It is stated that petitioner applied for passport along necessary fees and fullfield
all requirements therein.
3. It is stated that respondent in the course of interviews Indeed the petitioner had
personally explained the nature of his visit to respondent and had also offered
to produce any guarantee which may be required but respondent had verbally
informed the petitioner that the same was unnecessary.
4. It is stated that respondent rejected the application of petitioner and
respondent verbally informed the petitioner that the passport could not be
granted to him without assigning any reasons.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

5. It stated that petitioner visited passport office multiple times but the response
from the passport was inadequate.
6. It is stated passport to an Indian citizen can only be refused if he is anti-
Government, not Communist, established smuggler, trying to jump the bail
granted in a criminal case or being involved in a murder case or is trying to run
away, The petitioner submit that he does not fall in any one of the above
categories
7. It is stated that Refusal to issue a passport by the respondents is thus described
to be arbitrary, illegal, without jurisdiction and ultra vires the Constitution. Article
21 and 14 of the Constitution have been specifically relied upon in support of
the fundamental right possessed by the petitioner to go abroad.
8. It is submitted that the Petitioners have no other efficacious remedy except to
approach this Hon'ble Court by way of this Petition under Article 226 of the
Constitution of India.
9. It is confirm that the Petitioners have not filed any other petition or preceding in
any court or tribunal throughout the territory of India regarding the matter.

• PRAYERS :

In view of the facts & circumstances stated above, it is most respectfully prayed that this
Hon'ble Court may be pleased to pass following orders: -

1. Issue a Writ of mandamus to the Respondents thereby Writ Directing issue


passport to the Petitioner.
2. Issue appropriate Writ granting reasonable compensation to the Petitioner.
3. Any other relief, order or direction this court may deem fit and proper under the
facts and circumstances of this case.

VERIFICATION STATEMENT

I, Prakash, being the petitioner and deponent herein do hereby declare that the contents
of petition are true to the best of my knowledge, belief, and information and rest on legal
advice of my counsel, hence verified on this the day of 2023 at Hyderabad.

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE DEPONENT
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :10

IN THE COURT OF THE HON’BLE JUDGE FAMILY COURT:


RANGA REDDY DISTRICT: AT L.B.NAGAR

F.C.O.P No. OF 2023

Between:

Latha W/o Chandra,


R/o Hyderbad … Petitioner

And

Chandra S/o Surya,


R/o Hyderbad. … Respondent

PETITION FILED U/S.13 (1) (ia) (ib) OF HINDU MARRIAGE ACT, 1955

I. DESCRIPTION OF THE PETITIONER:

That the address of the petitioner for the purpose of service of summons, notices
and process etc., is the same as shown in the above cause title.

II. DESCRIPTION OF THE RESPONDENT:

That the address of the respondent for the purpose of service of summons, notices
and process etc., is the same as shown in the above cause title.

III. BREIF FACTS OF THE CASE:

1. The petitioner humbly submits that the marriage between the petitioner and
respondent was an arranged marriage was held on 30-01-2023 at Sri Venkateswara
Swamy temple in Dilsukhnagar as per Hindu Rites and Customs. Immediately after the
marriage the petitioner joined the company of respondent at his residence to lead
matrimonial life with the respondent. At the time of the marriage, mother of the petitioner
gave of Rs.5 lakhs to the respondent towards dowry, besides household articles worth
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Rs.1,50,000/- and gold. Since 11 years back, father of the petitioner demised, her mother
used to manage the family and performed the marriage of the petitioner with the
respondent. After the marriage, the petitioner joined with the respondent. Since 15th day
of the marriage, respondent, parents-in-law and daughter–in-law of the petitioner began
to harass the petitioner to bring some more dowry towards additional dowry. When the
petitioner reported the same to her mother, she met the respondent and parents-in-law of
thepetitioner herein. Then they demanded Rs.2,00,000/- towards expenses to send
respondent to Malaysia. Then the mother of the petitioner revealed her inability to meet
the demand of the respondent and his family. They began to harass the petitioner
physically and mentally. The respondent regularly used to abuse the petitioner and he also
used to beat the petitioner by demanding more dowry from her mother.

2. The petitioner submits that the respondent always abuses the petitioner and her
relatives in filthy language and used to insult her before his relatives. The petitioner was
always attending her normal household duties such as cooking and doing other household
works, in spite of the same the respondent, parents-in-law, sister-in-law of the petitioner
herein always used to find fault with the petitioner in the household work attended by the
petitioner. In order to secure Visa to the petitioner for Malaysia, the respondent took the
petitioner to Chennai, where the respondent extorted Passport and Educational
Certificates of the petitioner. The respondent harassed physically and mentally in Chennai
also, beat the petitioner and left her on footpath. With utmost efforts she reached her
maiden house. Then mother of the petitioner and relatives entertained mediations with
the respondent to lead the matrimonial life between the petitioner and respondent. After
the mediations the respondent agreed to lead conjugal life with the petitioner peacefully
and also assured that he will not harass the petitioner further. Again after some days
passed the respondent and his family members started harassing the petitioner for more
dowry from her mother.

3. The petitioner submits that on 08-03-2023 the respondent early in the morning
started the harassment by abusing in a filthy language. Moreover he started beating the
petitioner with stick in a very cruel manner, for that the petitioner raised hue and cry. By
listening the same neighbors came to rescue the petitioner and informed the incident to
mother of the petitioner.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

4. The petitioner submits that herself and her mother and other relatives tried their
level best to convince the respondent and his family to lead matrimonial life, but all the
attempts of the petitioner and her mother were failed and there is no scope for
reconciliation between the petitioner and respondent to lead matrimonial life peacefully.
There is no cohabitation between the petitioner and respondent since dispute arise.

5. The petitioner further submits that the marriage between the petitioner and
respondent is irretrievably broken down and there is no scope of changing the attitude of
the respondent to lead the matrimonial life and the respondent has no love and affection
towards the petitioner. The respondent regularly used to beat the petitioner on petty issues
by abusing in filthy language and he also threaten the petitioner that he will see the end
of the petitioner by pouring kerosene and burning the petitioner or forcing her to consume
poison for death as such the petitioner has left with no other alternative way/option except
to approach this Hon’ble Court for dissolution of the marriage between the petitioner and
respondent. The respondent has treated the petitioner with mental and physical cruelty
during her stay in the matrimonial house of the petitioner.

IV. CAUSE OF ACTION:

That the cause of action for this petition arose on 30-01-2023 when the petitioner
was driven out of her matrimonial house and also arose on 08-03-2023 .

V. JURISDICTION:

The petitioner and respondent lived together as husband and wife in the
matrimonial house in Dilsukhnagar hyderbad as such this Hon’ble Court has got
jurisdiction to entertain this case.

VI. That the petitioner submits that she has not filed any petition before any court of
law for the relief claimed in this petition. There is no collusion between the parties in filing
this petition.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

PRAYER

Therefore the petitioner herein prays that this Hon’ble Court may be pleased to pass
judgment and decree in favour of the petitioner and against the respondent by dissolving
the marriage between the petitioner and respondent which was held on 30-01-2023 and
direct the respondent to pay costs of this petition and grant a decree of divorce and pass
such other relief or relives for which the petitioner is legally entitled in the interest of
justice.

Place: hyderbad
Date: 17-06-2023 PETITIONER

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE

VERIFICATION

I, the above named petitioner do hereby declare and state that the contents of
paras 1 to 5 of this petition are true to the best of my knowledge belief, information and
legal advise. Hence verified the same to be true and correct on this 17th day of June ,
2023 at Hyderbad.

PETITIONER
LIST OF DOCUMENTS

1 30-01-2023 Marriage invitation card


2 30-01-2023 Photographs of the marriage

Place: Hyderabad
Date: 17-06-2023 PETITIONER

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :11

IN THE COURT OF THE HON’BLE JUDGE FAMILY COURT:


RANGA REDDY DISTRICT: AT L.B.NAGAR

F.C.O.P No. OF 2023

Between:

Latha W/o Chandra,


R/o Hyderbad … Petitioner

And

Chandra S/o Surya,


R/o Hyderbad. … Respondent

COUNTER FILED ON BEHALF OF RESPONDENT

1. The address of the above Respondent for the purpose of service of all notices,
process etc., is that their Counsels M/s Raghav krishna Bharadwaj, Shravan kumar, Srujan
Reddy Advocates, Hyderabad.

2. All the material allegations made in the above petition are false and the petition is
not maintainable either on facts or in law against this Respondent. Hence the petition is
liable to be dismissed with costs against this Respondent.

3. This respondent does not admit and denies all the allegations made in the petition
and the petitioner is put to strict proof of all the allegations except those, which are
specifically admitted hereunder.

4. It is that replay to para number 1, it was true that t marriage between me and
petitioner held on 30-01-2023, Dilsuknagar as per Hindu rites and customs and it is an
arranged marriage except these, remaining content of the para was totally false and
baseless allegations and created one that we did not demanded any dowry and received
any payments from Petitioners family.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

5. It is that replay to para number 2 &3 that content of the para was totally false and
baseless allegations and created one by the petitioner family and it is submitted that I did
not even scold petitioner and his family, my family members treat petitioner and her family
with love and very respectful manner.

6. It is that petitioner herein filed the above FCOP for grant divorce under section 13
(1) (ia) of Hindu marriage Act.1955, and hereby demand made therein, marriage cannot
dissolved within one year from date marriage and my marriage with respondent held
30/01/2023 means not exceeded 1 year.

7. It is stated that the above said FCOP neither maintainable in law nor facts and liable
to dismiss at any cost

Therefore, I pray this Hon’ble court to dismiss above said FCOP at any cost in the interest
of justice.

Place: Hyderbad
Date: 17-06-2023 RESPONDENT

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :12

IN THE COURT OF THE HON’BLE CIVIL JUDGE: CITY CIVIL COURT:


AT HYDERABAD

O.S.No. OF 2023

Between:

Mrs. Lalitha … Plaintiff

AND

Mr.Johny …Respondent

SUIT FOR COMPENSATION ON ACCOUNT OF DEATH BY ELECTRIC SHOCK

1. Plaintiff No. 1 is house wife residing at hyderabad, That the husband of the Plaintiff,
aged about 34 years working as electrician with respondent and left this world and
That Respondent is the Owner of the Building.
2. That on 03/05/2023 at petitioner husband as part of daily activity reach work place
and started attaching main electric wires with main units.
3. That the suddenly electricity passed through wires and Husband of the Plaintiff was
buried under electric shock and was died.
4. That the Respondent had failed necessary preventive measures while electric work in
process.
5. That it was the duty of Respondent to maintain standards and duty bound to provide
adequate protection to the electric workers.
6. That the matter was immediately reported to the police and as such criminal case
has also been registered against the Respondent.
7. That the husband of the Plaintiff has lost his life due to negligence or carelessness
on the part of the defendants in the aforesaid manner.
8. That the Husband of the Plaintiff was electrician and was earning Rs. 35,000/- per
month.
9. That the husband of the Plaintiff was left behind the Plaintiff, two sons and one
daughter. Plaintiff, the three school going children were wholly dependent upon the
deceased.
10. That the Plaintiff put forth demand for payment of Rs. 5,00,000/- but the
Respondent had refused to do so or to settle the matter.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

CAUSE OF ACTION:

That cause of action has arisen to the Plaintiff on 03/05/2023 when here husband
died on account of negligence or carelessness on the part of the Respondent in the
aforesaid manner

JURISDICTION:

That having regard to the claim of the Plaintiff and the cause of action having
arisen in the area of hyderabad this Hon'ble Court has jurisdiction to entertain and
try this Suit

P R A Y E R:

Therefore the petitioner herein prays that this Hon’ble Court may be pleased to pass
judgment and decree in favour of the petitioner and against the respondent in
following manner.

a) A decree for recovery of Rs. 5,00,000/- with interest @ 5 % per annum from the
date of accident upto the filing of this suit, and 5% per annum, from the date of
decision till realization till decree amount.
b) The Plaintiff be paid their cost from the defendants.
c) Any other relief, which the Hon'ble court deems fit, may please be granted to the
plaintiff in the interest of justice.

Place: Hyderabad
Date: 17-06-2023 PETITIONER

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :13

IN THE COURT OF THE HON’BLE JUDGE FAMILY COURT:


RANGA REDDY DISTRICT: AT L.B.NAGAR

OS No. OF 2023

Between:

Mrs. Lalitha … Plaintiff

AND

Mr.Johny …Respondent

COUNTER FILED ON BEHALF OF RESPONDENT

1. The address of the above Respondent for the purpose of service of all notices,
process etc., is that their Counsels M/s Raghav krishna Bharadwaj, Shravan kumar,
Srujan Reddy Advocates, Hyderabad.
2. All the material allegations made in the above petition are false and the petition is
not maintainable either on facts or in law against this Respondent. Hence the
petition is liable to be dismissed with costs against this Respondent.
3. This respondent does not admit and denies all the allegations made in the petition
and the petitioner is put to strict proof of all the allegations except those, which are
specifically admitted hereunder.
4. It is that replay to para number 1 & 2, it was true that husband of petitioner worked
as electrician in our building except these, remaining content of the para was totally
false and baseless allegations and created one.
5. It is that replay to para number 2&4 that content of the para was totally false and
baseless allegations and created one by the petitioner and it is submitted that I
have complied all rules regulations regarding electrical works and took all
preventive steps regarding safety of electricians.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

6. It is that petitioner herein filed above said OS for compensation, and hereby
demand made therein, It is stated that the above said petition neither maintainable
in law nor facts and liable to dismiss at any cost.

Therefore I pray this Hon’ble court to dismiss above said OS at any cost in the interest of
justice.

Place: Hyderbad
Date: 17-06-2023 RESPONDENT

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :14

IN THE COURT OF THE HON’BLE CIVIL JUDGE: CITY CIVIL COURT: AT


HYDERABAD

Ramu … Plaintiff

AND

Balu …Respondent

SUIT FOR SPECIFIC PERFORMANCE OF AGREEMENT TO SELL

1. Plaintiff residing at hyderbad. The present Suit is being filed through Mr. Raghav
Krishna Bharadwaj, the authorised Signatory of the Plaintiffs who has been duly
authorised vide Special Power of Attorney dated 05/04/2023 issued by Plaintiffs,
to file the present Suit on behalf of the Plaintiffs.

2. That Defendant had agreed to sell open plot to plaintiff, That the Defendants have
demanded an advance amount of Rs, from the Plaintiffs towards 85% of the cost
of the property and taxes. The plaintiffs have paid to the Defendants the said
amount as per the payment details given below, Copies of the aforementioned
receipts issued by the Defendants are annexed hereto as Annexure P2 (Colly).

3. That the Plaintiffs and Defendants have entered into Agreement to sell, Copy of
Agreement to sell is annexed as Annexure P3.

4. That clause 4.1 of Article 4 of the agreement to sell dated 05/03/2020 read as
follows "That the possession of the Unit shall be delivered to the Purchaser within
36 months from the date of signing this agreement..."As per the agreement to sell
the Defendants have assured to the Plaintiffs to give possession of the property by
05/03/2021.

5. That Clause 5 of the MoU read as follows "That from , however subject to receipt of
85% of the sale consideration, the Developer assures a monthly return ("Assured
Return") of Rs. 51/- (Rupees Fifty One only) per square feet per month of the super
area being purchased by the purchaser,.

6. That the Plaintiffs have waited for 36 months to get possession of the property. Till
date no communication regarding possession of the property has been received
from the defendants.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

7. That the Plaintiffs enquired about progress of the construction and shocked to
know that the Defendants have not started any construction in the site. The
Defendants have just collected money from customers and not done any work to
develop the project.

8. That till date the Defendants has not handover plot to plaintiff or refunded the
amount to the Plaintiffs. It shows the malafide intension to of Defendants to cheat
the Plaintiffs by giving false promises.

9. That the Plaintiffs have issued a legal notice dated 03/05/2023, vide postal
receipt No. through their advocates M/s Raghav Krishna Bharadwaj, Shravan Patel
demanding refund of amount paid in advance along with interest @ 18% for the
period from date of agreement to till date and assured return of Rs. 51 per square
feet as per clause 5 of Memorandum of Understanding till payment date, which was
not replied by the Defendants. Copy of the Legal Notice dated 03/05/2023 along
with postal receipt is annexed here as Annexure P-5.

10. Since the Defendants have not responded to the legal notice dated 03/05/2023,
the Plaintiffs have again send another legal notice dated 03/06/2023, to the
Defendants addressed to Registered office of the Defendants posted on the same
date through above said advocates demanding refund along with interest @ 18%
and assured return of Rs. 51 per square feet as per clause 5 of Memorandum of
Understanding till payment date, which was not replied by the Defendants. Copy of
the Legal Notices along with postal receipt and acknowledgement.

11. That the Defendants have created unnecessary financial loss and mental pressure
to the Plaintiffs and committed cheating, fraud and breach of trust by giving false
promises.

12. That the Suit is within the period of limitation.

13. That the cause of action arose in favour of the Plaintiff and against the Defendants.
The cause of action arose on 05/03/2020 and when the Defendants accepted
advance and acknowledged the receipts of the amount

14. That this Hon'ble Court is competent to try the present Suit as the Plaintiffs are
Residents/ Permanent address are of its territorial jurisdiction, The Agreement to
Sell and Memorandum of Understanding are signed in its territorial jurisdiction, the
registered office of the Defendant Company is in its territorial jurisdiction and the
transactions are done its territorial jurisdiction.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

• PRAYER

That the Plaintiff, therefore, pray that-

a. A decree for specific performance of the agreements to sell be passed in favour of


the Plaintiff and against the defendant thereby directing the defendants to execute
the sale deed and get the same registered in favour of the plaintiff in respect
convey the suit property, and do all other acts, deeds and things as may be
necessary in this regard.
b. A decree for specific performance of the Memorandum of Understanding vide
which Defendants agreed that from, however subject to receipt of 85% of the sale
consideration, the Developer assures a monthly return ("Assured Return") of Rs.
51/- (Rupees Fifty One only) per square feet per month of the super area being
purchased by the purchaser.
c. If the Hon'ble court finds that the plaintiff is not entitled to the relief of specific
performance of agreement then the suit be decreed for the alternative relief by
way of decree for recovery of advance amount and damages against the
defendants with interest @ 18% from the date of the agreement till realization of
the decree amount, with future interest @ 18% till realization
d. The Plaintiff be paid their cost from the defendants.
Any other relief, which the Hon'ble court deems fit, may please be granted
to the plaintiff in the interest of justice.

Place: Hyderabad
Date: 17-06-2023 PETITIONER

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :15

IN THE COURT OF II METROPOLITAN SESSESSIONS COURT L.B NAGAR,


: AT : RANGAREDDY.

Crl.M.P. NO. of 2023

Cr.No. of 2023

( On the file of P.S. SAROORNAGAR)

Between:

SALMAN …Petitioner/Accused No.

And

State of A.P., Rep.by S.H.O.


Saroornagar, Hyderabad. … Respondent/Complainant

PETITION FILED UNDER SECTION 439(1)Cr. P.C

1. It is submitted that the petitioner herein is accused No. in the above crime
number.
2. It is submitted that the respondent/complainant has falsely implicated the petitioner
herein under section 302 of I.P.C and registered the above crime number. The petitioner
was arrested on 2.3.2023 and the petitioner is produced before this Hon’ ble Court on
3.3.2023. The Hon’ ble Court was pleased to remand the petitioner/accused No. to
Judicial Custody up to 7 days.
3. It is humbly submitted that the petitioner is innocent of any offence, much less the alleged
offence. In fact, the respondent have foisted a case against him in a routine manner for
the sake more statistics. The petitioner is a well known personality and law obtaining
citizen in the locality and he carries on his business in automobile. The petitioner hails from
a respectable family with an unsullied social image and reputation. The petitioner is a law
abiding citizen and will not infer nor evade with due process of law, even if he is granted
bail. The petitioner being a permanent address at the above given address and has both
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

movable and immovable properties. Such, the petitioner also undertakes to attend before
this Hon’ ble Court as and when directed and ordered. The petitioner also undertakes to
abide by any conditions as ordered by this Hon’ ble Court.

4. It is submitted that the applicant filed by the petitioner is the first, and no similar application
for similar relief has been filed before this Court or any other Court.

It is therefore prayed that for the circumstances above stated this Hon’ ble Court may
be pleased to enlarge the petitioner on bail and pass such other orders or orders as the
Hon’ ble Court may be deem fit and proper in the circumstances of the case.

Place: Hyderabad
Date: 17-06-2023 PETITIONER

COUNSEL FOR PETITIONER


(RAGHAV KRISHNA BHARADWAJ)
ADVOCATE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :16

GIFT DEED
IN FAVOUR OF SISTER_SON

on this 14th JUNE 2023 by:-

Rajender, aged about 72 years Occupation: House hold, Presently residing


HYDERABAD – 053 (HEREINAFTER Called the DONOR)

IN FAVOUR OF

Raghav krishna bharadawaj, aged about 25 years, Occupation: Advocate, R/o,


HYDERABAD - 053.(HEREINAFTER Called the DONEE)

(The expressions of the DONOR and DONEE herein used shall wherever the context
so admits mean and includes their respective heirs, executors, administrators, legal
representatives, successors and assignees etc.,)

WHEREAS the DONOR herein is the sole and absolute owner and peaceful
possessor of the House, Admeasuring 99.00 Square Yards equal to 82.7 Square Meters,
situated at, HYDERABAD (Hereinafter called the said property), having purchased the same
from its original owner through notarized document of sale dated 28th Day of October,
2005 and there are no other legal heirs except the vendor.

WHEREAS the DONEE is OWN SON of the DONOR and out of Natural Love and
Affection, the DONOR desires to gift the above said property, more fully described in the
schedule property, on the DONEE in order to provide some property for his benefit.

NOW THEREFORE THIS DEED OF GIFT WITNESSES AS UNDER:

THAT in consideration of the natural love and affection of the DONOR towards the DONEE
and without any coercion or undue influence of anybody the DONOR does hereby grants,
transfers, assigns, conveys and gift all the said property described in the schedule hereto,
now in occupation and enjoyment of the DONOR along with ways, water courses, liberties,
privileges, easements and appurtenances hereto and all the estate, right, title and interest
or claim and demand whatsoever of the DONOR in or to the said property. The DONEE
hereafter shall hold and enjoy the same as the owner absolutely and forever and the
DONEE has expressed his acceptance for the said gift.

The DONOR has today delivered vacant, physical and peaceful possession of the
schedule property to the DONEE who shall hold and enjoy the same with all proprietary,
possessory, easementary and hereditary rights, without any let or interruption from the
DONOR or any one claiming through or under or in trust for the DONOR.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

The DONOR does hereby declares that he is the sole and absolute owner of the
schedule property and that no other person or persons have any manner of right, claim,
title or interest whatsoever in the said property.

The DONOR does hereby further covenants that the said property is free from all
encumbrances, charges, prior assignments of sale, legal impediments and court
attachments etc.,

The DONEE may get the title of the schedule property mutated in his name in the
concerned office records and the DONOR hereby agrees to co-operate with him in this
regard.

The Schedule Property does not belong to or under mortgages to Government or


Government Undertakings/Agencies.

SCHEDULE OF PROPERTY

The House No. 18-1-337/231, Admeasuring 99.00 Square Yards equal to 82.7
Square Meters, situated at HYDERABAD by:-

NORTH : Road 15’ Wide


SOUTH : : Neighbour’s House
EAST : Neighbour’s House
WEST : Neighbour’s House

IN WITNESS WHEREOF the DONOR has signed on this Deed of Gift out of free will
and consent on the day, month and year first above written in the presence of the following
witnesses:-

WITNESSES:- SIG.OF DONOR

1.

2.
SIG.OF DONEE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :17

DEED OF TRUST

This Deed of Trust is made and executed on this day of January, 2023 by:

1. Shri. Raghav krishna bharadwaj aged about 25 years, R/o, Hyderabad,

And

4. Shri. G.Ramarao, aged about 42 years, R/o, Hyderabad,

(Hereinafter referred to and called as the FOUNDER/SETTLERS of the Trust)

WHEREAS the Founders/Settlers are dearious to establish a Charitable Trust with the
objects of run educational institution and orphanage homes, and other objects mentioned
more specifically in Clause-3 of the Trust Deed.

AND WHEREAS pursuant to the above, the said Founders/Settlers of the Trust herein have
created and constituted an irrevocable Charitable Trust

AND WHEREAS the Trustees have agreed individually and collectively to act as Trustee and
have taken possession of the aforesaid corpus.

AND WHEREAS it is desired by the Founder/Settlers that the Corpus of the Trust should
further be augmented from time of time by way of donations gift, etc.

AND WHEREAS the Trustees have desired that a formal deed may be executed in respect
of the corpus of the Trust being held by them unto the Trust.

NOW THIS DEED OF TRUST THEREFORE WITNESSES OF FOLLOWS:

1. That with a view of effectuate the said desire, the Founders/Settlers do hereby
declare that Trust to be used exclusively for the charitable purpose and more
specifically mentioned hereunder and subject to the powers, conditions and
provisions of the Trust Deed hereafter.

2. That the name of the Trust shall be “karanya charitable trust” with its office,
Hyderabad.

3. The objects of the said Trust for the following purpose.

a. To support children in need of care and protection and held destitute poor,
neglected needy and orphan children.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

b. To run educational institute in order to mould students as worthy citizens


with moral & ethical values with strong societal commitment to full-fill their obligation
towards society and nation at large.

4. That the Trust shall be managed by the Board of Trustees, constituted with the
above Founder/Settlers and one of the Founder/Settler shall be the Chairman of
the Board of Trustees for a period of one year by rotation system among the
members of Founders/Settlers, one of his heirs will become the Founder/Settler
member of the Board of Trustees.

5. Further, another member of the Founder/Settlers shall be elected as Secretary fo


the Board of Trustees who shall look after and administer the affairs of the Trust.
The appointment of Secretary shall be as per the decision of majority of
Founders/Settlers and the tenure of the Secretary shall be for a period of 2 (Two
years), and cane be extended for a further period by the consent of majority of
founders/Settlers of Board of Trustees.

6. The Board of Trustees shall be constituted always from among the above said
Founders/Settlers and their heirs and the Chairman of the Board of Trustees shall
always from among founders/Settlers only. They shall be the life time trustees of
the Board of Trustees of the Trust.

7. The board of Trustees with their majority decision can opt ordinary members to the
said Trust and their number shall not exceed eleven and their terms is only for 2
years. In case of death of retirement of any of such ordinary member, the Board of
Trustees shall opt persons who in their opinion are of repute and integrity to be a
one of the member of the Trust.

8. That out of the said eleven ordinary members of the Board of Trustees with their
majority decision can constitution an Advisory Body consisting of 7 members to the
Board of Trustees and however, the Board of Trustees decision on such advise of
advisory body shall prevent and binding.

9. The Board of Trustees shall meet from time to time at least once in a month to
review the functioning of the Trust and administration of the Trust property. The
time, place and date of meeting may be agreed upon by the trustees, place and
date of meeting may be agreed upon by the Trustees. The Chairman shall be the
Presiding Officer of the meeting. The majority decision of the Trustees who are
present in the meeting shall follow. Where there is no majority decision, the
Chairman shall exercise another vote power in addition to exercise of his vote one
of the manage, The chairman of the Board of the Trustees shall manage, supervise,
administer and control the day to day affairs of the Trustees with their majority
decision can impeach the chairman on proof of grave irregularities and illegalities
committed by him against the interest and object of the Trust.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

10. Usual and regular books of accounts shall be caused to be maintained by the Board
of Trustees and the same shall be closed the accounts of income and expenditure
every year ending with 31st March, the books of accounts shall be audited by an
Accountant every year.

11. The Board of Trustees may accept donations, gifts, etc., of money and property
either moveable or immovable from any person or from any institutions or
organizations for and on behalf of the Trust for building up of the corpus or
otherwise.

12. The Bank Account of the Trust shall be operated jointly by the Chairman and
Secretary of the Board of Trustees of Founder/Settlers members or by any other
person or persons of may be appointed by the Board of Trustees in this regard, with
absolute majority decision, however it can be withdrawn with similar decision.

13. The funds of the Trust may be invested in such Bank or Banks in such account or
accounts, ie., current or fixed or in such assets and securities and shall not invest
the funds fo the Trust in any other assets which are prohibited under the income
Tax Act.

14. As far as possible, and property whether movable or immovable is to be acquired,


the same shall be acquired in the name of the Trust.

15. The Trust may enter into any contract of purchase or sale of movable property or
may enter into contract of lease of any such property for the objects of the Trust.

16. It is further declared that the income of the Trust or the profits or any part thereof
shall not be applied for the benefit of the Founders/Settlers of their relatives, or
persons more particularly mentioned under the Income Tax Act.

17. In case of dissolution of the Trust, the property of the Trust shall pass on to such
Trust or institution having the similar objects of this Trust in India, and which is
registered with the Income Tax Department as a public Charitable Trust.

18. It shall be lawful to accumulate the surplus and invest the same wherever required
in accordance with the provisions of the Income Tax Act, 1961 as may be in force
from time to time.

19. No alterations amendments, deletions or additions to the rules of the Trust Deed
shall be made without prior approval by the unanimous decision of the Board of
Trustees of the Trust.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

IN WITNESS WHEREOF, the Founders/Settlers have signed have signed this deed of Trust
on this the day, month and year first written above.

SIGNATURE OF THE FOUNDERS/SETTLERS


R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :18

WILL DEED

This DEED OF WILL is made and executed on this the day of July,2023 at Hyderabad.

I, GOPAL, aged 79 years, Occ: Business, R/o. H Hyderabad -500001, do hereby make
this Will, which is my first and last Will and bequeath all my movable properties located in
India to my Granddaughter Swarupa

I have become old, so presently I am in conscious state of good sound mind and now
I have decided to make the Will and this is my last Will.

I hereby revoke all wills and testamentary dispositions made by me.


Without affecting the generality of the foregoing, I hereby declare the following as part
of my will.

I. In case there are properties in India in which I have any rights including tenancy and /
ownership rights at the time of my demise, all such rights shall pass total share to my
Granddaughter.
II. In case I acquire any other property or properties or rights in any property or properties
in India before my demise all such properties and rights in properties will also pass total share
to my granddaughter.
III. All movable assets including Jewellery, house hold goods, Furniture, Fixtures, Vehicles,
Shares (In listed and unlisted companies), Investments in Mutual Funds, Deposits in Banks
(Including balances in current accounts, saving accounts, fixed deposit accounts and any
other accounts), Contents of Bank Lockers, Deposits with financial companies, Money
receivable from other parties, Dues or claims from insurance companies and cash will pass
total share to My Granddaughter after my demise.

IV. All Rights vest with me due to membership of Societies, Clubs, Associations and such
other bodies will also pass total share to my Granddaughter after my demise.

V. That I executant, till I am alive, shall remain owner of my entire movable and
immovable properties, Investments etc. mentioned above which I posses at present or which
may be added to it during my lifetime and which I, the executants, leave behind at the time of
my death. After my death my entire properties mentioned above bequeath total share to my
Granddaughter and any other my family members have no rights or claim over the above said
properties.

VI. Any other Assets, which are not mentioned above or subsequently acquired by me after
execution of this Will, are also given total share to my Granddaughter.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

VII. I have made this Will with my own free Will and without any Force, Compulsion or Undue
Influence. I am in good health condition at the time of making this Will. I have clearly
understood the contents of this Will in full. There was no force or coercion by any one on me
to execute this Will or to add any part to this Will.

VIII. I, the executant hereby declare that this is my first Will and the last will executed by me
and there is no other will executed by me.

IX. This Will deed will coming to force only after my demise.

IN WITNESS WHEREOF, I, GOPAL, aged 79 years, Occ: Business, R/o. H Hyderabad -


500001, has executed this Will by signing on each page of this Will in front of the two below-
named witness who have both signed in front of me.

Date: -07-2023
Place: Hyderabad (G. GOPAL)
(Executant)

The above name testator has signed in our presence and we, the attesting witness, have
signed the Will as Witness in front of him at the same time.
Witnesses (Signatures, names and addresses)

WITNESSES:- SIG.OF DONOR

1.

2.
SIG.OF DONEE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :19

SIMPLE MORTGAGE DEED


(WITHOUT POSSESSION)

This Deed of First Simple Mortgage is executed on this the day of April, 2023 at
Hyderabad, by and between:

Pawan, aged 32 years, Occ: Doctor, R/o, R.R. District.

Hereinafter referred to as the “MORTGAGOR(S)” which term shall mean and include wherever
the context so requires or permits his respective heirs, legal representatives, executors,
administrators, nominees and assignees of the ONE PART.

And

Mahesh, aged 39 years, Occ: Financer, R/o, Secunderabad.

Hereinafter referred to as the “MORTGAGEE” which term shall mean and include wherever
the context so requires or permits its successors-in-interest and assignees of the OTHER PART.

WHEREAS, the Mortgagor herein is the sole and absolute owner of the House No. admeasuring
244.44 Sq.yds or 204.38 Sq.mtrs, Sy.No.1, situated at, Ranga Reddy District, having
purchased and the same registered before SRO, R.O. Ranga Reddy District.
WHEREAS the Mortgagor had already submitted the original documents of the schedule
mentioned property as security for the loan availed from the Mortagee.

NOW THIS DEED OF FIRST SIMPLE MORTAGE WITNEESETH THAT:

In pursuance of the aforesaid agreement and in consideration of the sum of Rs.20,00,000/-


paid by the Mortgagee to the Mortgagor(S) at the time of execution of these presents and the
receipt of which the Mortgagor(S) do hereby admits and acknowledges and undertakes that
he/shall repay to the Mortgagee herein the said sum of Rs.20,00,000/- within a period of 10
years from this date together with interest at 16% P.A. and repayable by way of equated
monthly installments as advised by the Mortgagee from time to time and creates this first
simple mortgage over the Schedule mentioned property in favour of the Mortgagee herein.
1. In the event of the Mortgagor(S) committing default in payment of the equated monthly
installments, the Mortgagee shall be entitled to demand the entire principal and interest
accrued thereon as on that date. Similarly, in the event of default in payment of interest
continuously at any time prior to commencement of equated monthly installments payment,
the Mortgagee shall be entitled to demand the entire principal and interest accrued thereon
as on the date.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

2. So long as the said principal sum of Rs.20,00,000/- or any part thereof shall remain
due and payable by the Mortgagor(S) to the Mortgagee, the Mortgagor(S) covenant to pay to
the Mortgagee interest calculated on the principal and outstanding at the rate of 16% P.A.,
regularly once in every quarter.

3. The Mortgagor(S) do hereby covenant with the Mortgagee that the property hereby
mortgaged is their absolute property and that the same is free from all encumbrance
whatsoever.

4. So long as the principal amount due under the mortgage is outstanding, the
mortgagor(S) will keep the premises hereby mortgaged in good and substantial repair.

5. The Mortgagor(S) further covenant with the Mortgagee to pay all the Taxes, rates and
other outgoings in respect of the schedule mentioned property hereby mortgaged, to the
Government, Revenue, CMWSSB, electricity Board and other authorities punctually without
committing any default.

6. In the event of the Mortgagor(s) committing default in the faithful performance and
observance of anyone of the conditions or covenants hereinabove contained. The
Mortgagors(s) personally and /or against the property hereby mortgaged as the Mortgagee
shall be at perfect liberty to proceed against the Mortgagor(s) personally and /or against the
property hereby mortgaged as the Mortgagee may think fit including to cause the said property
to be sold in due process of law and for the due recovery of all the amounts hereby secured.

SCHEDULE OF PROPERTY

All that the House No. admeasuring 244.44 Sq.yds or 204.38 Sq.mtrs, Sy.No.1, situated at,
Ranga Reddy District, having purchased and the same registered before SRO, R.O. Ranga
Reddy District, WHEREAS the Mortgagor had already submitted the original documents of the
schedule mentioned property as security for the loan availed from the Mortagee.
and bounded as follows:

NORTH : Road 15’ Wide


SOUTH : : Neighbour’s House
EAST : Neighbour’s House
WEST : Neighbour’s House

IN WITNESS WHEREOF the Mortgagor(s) have signed this Deed of First Simple Mortgage on
the day, month and year first above mentioned in the presence of:

WITNESSES:

MORTGAGOR(S)
1.
2.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :20

GENERAL POWER OF ATTORNEY


This General Power of Attorney executed by me, VIJAY, aged 50 years, Occupation:
Software Engineer,Residing at # USA,

IN FAVOUR OF

Sri. Ravi Kumar, aged 47 years, Occupation: Employee, R/o. Hyderabad-500 013On this the
30th day of June, 2023 whereas I am shortly to leave India for United States of America and
reside there for considerable period and whereas, therefore I desire to have an agent to look
after my affairs and manage my properties, I hereby appoint and nominate my brother Sri.
Ravi Kumar, aged 47 years, Occupation: Employee, R/o. Hyderabad-500 013O as my General
Power of Attorney, generally to look after and manage the schedule properties which stand in
my name and do all or any of the acts, deeds and things hereunder mentioned. This deed is
being executed without received any consideration.

Whereas I hereby appoint, nominate and constitute the said attorney to do the
following acts, deeds and things in my name & on my behalf.

1. To sign all the papers, forms, applications, etc., in any name and on my behalf.

2. To act in all the offices, firms, corporation bodies, whether of State or Central
Government in my name and on my behalf.

3. To sign all the papers, affidavits, vakalatnama, etc., and to appear in the court of
law whether of Civil or High Court in my name and on my behalf.

4. To appoint any advocate/s, and to pay their remuneration/s etc., in my name and
on my behalf.

5. To file case or cases in Court of law for recovery of money in my name and on my
behalf.

6. To make representations with Income Tax or any State/Central Govt. Departments


or Corporations or any authorities.

7. To represent me and to file, prosecute or as the case may be to defend suits,


petitions, appeals, reviews or revision petitions before Court of law or any
authorities.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

8. To approach any Court of law or authorities for securing the property and my funds,
withdraw the documents from any Court of law or authorities in my name and on
my behalf.

9. To appear before all Government offices, judicial and quasi-judicial authorities,


statutory bodies and authorities in any matter pertaining to the schedule
properties.

10. To appoint, constitute or remove advocates, pleaders, vakils, solicitors, chartered


accountants and other legal practitioners as may be necessary for the purpose of
conduction or prosecuting any proceedings.

11. AND TO DO all the acts, deeds and things, which is not mentioned in the documents
and also which my attorney may think fit and proper regarding the suit schedule
properties.

I do hereby agree to ratify and confirm all the acts and deeds done by my above said
attorney in my name and on my behalf, and to be construed as acts and deeds done by
me as if personally present.

IN WITNESS WHEREOF the Executant herein has signed on this General Power of Attorney
with my own free will and consent on this the 30th day of June, 2023 in the presence of
the following witnesses:

WITNESSESS:

1) Signature of Attorney Holder

2. Signature of Executant
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :21

LEASE AGREEMENT

THIS AGREEMENT TO LEASE is made and entered into at Hyderabad on this the of -
-2023:

BETWEEN

RAKESH aged about 38 years, Occupation: Air Force, Resident of Hyderabad,Hereinafter


called the LESSOR (which expression shall include his heirs, successors, legal
representatives, administrators, executors and assignees) OF THE ONE PART.
AND
Mr.Jahangir aged about 38 Years, Resident of Anantapuram 515001,Herein after called
the LESSEE (which expression shall include his heirs, successors, legal representatives,
administrators, executors and assignees) OF THE OTHER PART:

RECITALS:

The LESSOR is the sole and absolute owner, in possession of the premises which is more
particularly described hereunder (hereinafter referred to as the ‘SCHEDULED PREMISES’)
having full and unfettered rights to lease the same or any portion thereof.

The LESSEE intends to take on lease the SCHEDULED PREMISES to be used as


“Residential Premises” for their own purpose.

The LESSOR has agreed to give on lease and the LESSEE has agreed to take on lease, the
SCHEDULED PREMISES on certain terms and conditions as are stated hereunder.

NOW THIS AGREEMENT WITNESSETH AS FOLLOWS:

1. The LESSOR agrees to lease the SCHEDULED PREMISES to the LESSEE for a period
of 12 months (hereinafter referred to as the “Agreement Period”), commencing
from 1stDecember 2021 and ending on 31st November 2022.

2. The LESSEE shall use the SCHEDULED PREMISES as “Commercial


Premises”.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

3. The LESSEE shall pay to the LESSOR as lease rent for the SCHEDULED
PREMISES, an amount of Rs.12500/- (Rupees Twelve thousand Five Hundred
only) per month, exclusive of electricity / water charges as per meter reading, by way of
a cheque/ on or before the 10th day of every month.

4. The LESSEE has paid an amount of Rs.25,000/- (Rupees Twenty five thousand
only) to the LESSOR, by way of online transfer, as interest free refundable security
deposit, which shall be refunded by the LESSOR to the LESSEE promptly at the
expiry or earlier termination of this Agreement, whichever is earlier, after adjusting
any outstanding dues payable by the LESSEE, if any, and on the LESSEE delivering
vacant possession of the SCHEDULE PREMISES.

5. The LESSEE shall pay the applicable electricity and water charges directly to the
concerned authorities according to the meter, installed at the SCHEDULED PREMISES or
as billed by the concerned authorities on presentment of the bills.

6. The LESSEE shall not carry out any structural additions or alterations to the
SCHEDULED PREMISES without the prior consent of the LESSOR. However, the
LESSEE shall at its own cost, be entitled to install such domestic electrical appliances
as may be found necessary by it. On the expiry or earlier termination of this Agreement,
the LESSEE shall remove and take away all the appliances installed by it and restore
the SCHEDULED.

7. All rates, taxes and other levies and / or out goings on account of property tax and
all other levies, municipal or otherwise shall be paid by the LESSOR in time, failing
which the LESSEE can pay any such outstanding dues to the concerned authorities and
deduct such amount from the monthly lease rent payable.

8. The LESSOR undertakes to fully perform his obligations stated herein and also
comply with the requirements of the concerned municipal and other applicable
authorities to ensure peaceful occupation of the SCHEDULED PREMISES by the
LESSEE, during the Agreement Period.

9. The LESSOR shall not violate any rules, regulations, laws and byelaws of the
municipal corporation or any local authority having jurisdiction over the
SCHEDULED PREMISES.

10. The minor day-to-day repairs such as replacement of fuses, fixing of leaking
water taps, minor maintenance of electrical/sanitary and other fittings and
fixtures shall have to be carried out by the LESSEE at its own cost, but all
major repairs including replacement or breakage, bursting of sanitary pipes,
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

changes in the electrical system, cracks in construction etc., shall be


repaired/replaced by the LESSOR at his cost.

11. This Lease Deed is a time bound Deed and the LESSOR at the expiry of the
Agreement Period may at its option renew the lease for a further period of 12
months from time to time on such terms and conditions as are mutually agreed
by the LESSOR and the LESSEE.

12. On the expiry of the lease or on earlier termination of the lease, the LESSEE
shall deliver the vacant possession of the SCHEDULED PREMISES to the LESSOR in
good condition, subject to natural wear and tear.

13. The LESSEE shall not sub-let, assign or transfer or otherwise part with the
possession of the whole or any part of the SCHEDULED PREMISES.

14. The LESSEE or the LESSOR may terminate this Agreement any time during the
Agreement Period, subject to the issuance of an advance notice of Two month,
made in writing. Failure to do so will write off the advances.

15. This Agreement may be varied or modified only by the mutual consent of
Parties hereto, expressed in writing.

16 Any dispute that may arise between the Parties shall be subject to the jurisdiction
of the courts of Ananathapuram.

SCHEDULE PREMISES

All the part and parcel of open plot, situated in autonagar, admeasuring 50000 sq. yards a
bed rooms and bounded by:

North: ------Apartment
South: ----- Road
East: -------House
West: -------House
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

In witness whereof the LESSEE and the LESSOR have hereunto set and subscribed their
respective hands and seal on the - -2023 first above written.

…………………… ………………………
LESSOR LESSEE

WITNESS:
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :22

SALE DEED
This Deed of Sale is made and Executed on this day of ___ day of October, 2023 by:

Smt.Savithri, aged about 28 years ,Occ: Advovcate, R/o, Hyderabad (Hereinafter called the
“VENDOR” which expression shall mean and include his heirs, executors, administrators, legal
representatives, nominees and assignees etc.,)

IN FAVOUR OF

Smt.Madhuri, aged about 29 years, occupation : AGM State Bank of India, Resident of
Hyderabad, Telangana State (Hereinafter called “VENDEE” Which expression shall mean and
include his heirs, executors, administrators, legal representatives, nominees and assignees etc.,)

WHEREAS the Vendor/First Party is the absolute owner and possessor of House at kothapet,
Ranga Reddy District, admeasuring 79 Square yards under a registered Sale Deed before
Sub-Registrar Uppal, Hyderabad.

AND WHEREAS the said land is the self acquired property of the VENDOR and the same also
stands mutated in the name of the VENDOR in Revenue Records as owner /bhumidar and the
VENDOR has full rights absolute authority to sell dispose off and transfer the aforesaid land.

WHEREAS, the Vendor has offered to sell the House at kothapet, Ranga Reddy
District, admeasuring 79 Square yards to the Vendee for the total sale consideration of
Rs.50,00,000/- (Rupees Fifty Lakhs Only). The Vendee agreed to purchase the same for the
said price.

NOW THIS DEED WITNESSETH AS FOLLOWS:

1. That for a total sale consideration of Rs.50,00,000/- (Rupees Fifty Lakhs Only). for the
schedule property mentioned above, which has already been received by the VENDOR
from the VENDEE, the receipt of which the VENDOR hereby admits and acknowledges,
in full and final settlement, the VENDOR doth hereby sell, convey and transfer the said
land to the VENDEE, who shall hereafter be the absolute owner/bhumidar of the same
and shall enjoy all rights of ownership, possession, privileges, easements and
appurtenances whatsoever of the said land, unto the VENDEE, absolutely and forever.

2. That the actual physical vacant possession of the said land has been delivered by the
VENDOR to the VENDEE, on the spot, at the time of registration of this Sale Deed.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

3. Now the VENDOR has been left with no right, title, interest, claim or concern of any nature
with the said land and the VENDEE has become the absolute owner of the said and, with
full right to use and enjoy the same as absolute owner without any hindrance or objection
by the VENDOR or any other person claiming under him.

4. That the VENDOR hereby assures the VENDEE that the VENDOR has neither done nor
been party to any act whereby the VENDOR's rights and title to the said land in any way
be impaired or whereby the VENDOR may be prevented from transferring the said land.

5. That the VENDOR hereby declares and represents that the said land is not subject matter
of any HUF and that no part of the said land is owned by any minor.

6. That the VENDOR hereby assures, represents and covenants with the VENDEE as
follows:

a) That the said land is free from all encumbrances whatsoever or howsoever.

b) That there is no order of attachment by the Income Tax Authorities or any other
authorities under law for the time being in force or by any other authority nor any notice
of acquisition or requisition has been received in respect of the said land.

c) That excepting the VENDOR nobody else has any right, title, interest, claim or demand
whatsoever or howsoever in respect of the said land.

d) That there is no legal impediment or bar whereby the VENDOR can be prevented from
selling, transferring and conveying the absolute title in the said land in favour of the
VENDEE.

e) That there is no subsisting agreement for sale in respect of the said land hereby sold to
the VENDEE and the same has not been transferred in any manner whatsoever, in favour
of any other person or persons.

f) That the VENDOR has a marketable title in respect of the said land.

g) That there is no notice of default or breach on the part of the VENDOR or its pre-
deceasors in interest of any provisions of law in respect of the said land.

7. That the VENDOR further assures the VENDEE that the said land is free from all kinds of
encumbrances such as prior sale, gift, mortgage, disputes, litigation, acquisition,
attachment in the decree of any court, lien, court injunction, Will, Trust, Exchange, Lease,
legal flaws, claims, prior Agreement to Sell etc., and if it is ever proved otherwise, or if
the whole or any portion of the said land is ever taken away or goes out from the
possession of the VENDEE on account of any legal defect in the ownership and title of
the VENDOR then the VENDOR will be liable and responsible to make good the loss
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

suffered by the VENDEE and keep the VENDEE indemnified, saved and harmless against
all such losses, costs, damages and expenses accruing thereby to the VENDEE.

8. That the VENDOR undertakes to have the said land mutated in favour of the VENDEE in
Revenue Records and other concerned authorities, otherwise, the VENDEE can also get
the said land mutated in its own name in Revenue Records and other concerned
authorities on the basis of this Sale Deed for its certified true copy.

9. That the land Revenue and other dues and demands if any payable in respect of the said
land shall be paid by the VENDOR upto the date of handing over the possession to the
VENDEE and thereafter the VENDEE will be responsible for the payment of the same.

10. That the Vendors agrees to execute any deed or do any act which might be necessary to
perfect of the title of the vendee to the property covered under this deed of sale, at his
cost as and when it is necessary.

11. The Schedule land is not an assigned land within the meaning of A.P. Assigned Land
(Prohibition of Transfers) Act 9 of 1977 and it does not belong to or under mortgage to
Government or other agencies or undertakings.

12. That all relevant documents in original in respect of the said land has been handed over
by the VENDOR to the VENDEE.

13. That all the expenses of this sale deed viz. stamp duty, registration charges etc., has
been borne and paid by the VENDEE.

Whereas the VENDOR has this day delivered the vacant possession of the schedule
property to the VENDEE along with all the available original title deeds and documents, which
are in his possession pertaining to or relating to the schedule property.

SCHEDULE PROPERTY

All that House at kothapet, Ranga Reddy District, admeasuring 79 Square yards and
bounded by

NORTH : Road 15’ Wide


SOUTH : : Neighbour’s House
EAST : Neighbour’s House
WEST : Neighbour’s House

This document has been executed/presented on _________ on Non-Judicial Stamp paper


worth of Rs.100/- with the deficit stamp duty is Rs._____________ & Registration fee Rs.250/-
, user charges is Rs.50/- totaling to Rs.__________/- is paid through Bank receipt/challan
no._________ dtd __________ on State Bank of Hyderabad, ___________Branch, _________,
Medak District.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

The Stamp duty is paid on the market value as computed above.

IN WITNESS WHEREOF the parties herein have affixed their respective signatures to
this deed at Ramayanpet on this day of 2023 in presence of the witness:

WITNESSES:-

1. VENDOR

2. VENDEE
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :23

(To be typed on a Rs.100/- non judicial stamp paper)

ODEL FORM OF LOAN BOND WITH SURETY AND HYPOTHECATEION OF PROPERTY This Loan
Bond is executed on this……….day of…………at …………………..

Between:
1. Mr. Vinodh, aged about 32 years r/o hyderabad hereinafter called the guarantor.
2. Mr.Rajkiran, aged about 30years r/o hyderabad,hereinafter called borrower.
3. Mr.Rajkiran, aged about 36 years r/o hyderabad hereinafter called the creditor

Whereas the debtor has received for a loan of Rs.5,00,000/- which shall be repayable in
instalments as specified hereunder with interest at the rate of 18% per annum. And whereas
the surety has agreed to give security for the above loan and the creditor has agreed to
advance the loan on such security. NOW THIS BOND WITNESSES AS UNDER :

1. That in pursuance of the said agreement the creditor has advanced a sum of
5,00,000/- to the debtor. The debtor and surety have jointly and severally agree with
the creditor as under.
2. That the debtor and the surety are jointly and severally responsible for repayment of
the above amount in four equal instalments with interest on half yearly basis.
3. That in case of failure to pay any instalment or part thereof with interest, the debtor
amount along with interest shall become payable at once and the debtor and the surety
shall be jointly and severally liable to pay the same.
4. That for the consideration aforesaid and in further pursuance of the aforesaid
agreement the debtor and the surety grant and transfer by way of simple mortgage to
the creditor. All that property described in the shall remain and be charged by way of
simple mortgage as security for the payment to the creditor of the said principal
amount alongwith interest in accordance with the covenants herein contained.
5. The debtor and the surety hereby declare that the said property is free form all
encumbrances.
6. That it is hereby agreed and declared that in cases of failure of the part of debtor to
pay the instalment in time, the creditor shall be entitled to dispose the mortgage
property in part or full to recover the principal amount and interest. We the above noted
parties have signed this deed on the date and place mentioned above, after fully
understanding the contents of this deed in the presence of the following witnesses:
Witnesses:
a) Name…………. Signature ………….. Address………… Debtor
b) Name…………… Signature…………… Address…………. Gurentor.
c) Name……………Signature……………. Creditor

Date
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :24
EXCHANGE DEED

Exchange Deed or Deed of Exchange of Property THIS DEED OF EXCHANGE is made on this
day of 2023.

BETWEEN

Smt. Veena, aged about 28 years,R/o Hyderbad,hereinafter described as First Party, which
expression shall mean and include the heirs, successors, legal representatives, executors,
administrators and assigns) of the first part

AND

Smt. Vani, aged about 25 years, R/o Hyderbad, hereinafter described as Second Party (which
expression shall mean and include the heirs, successors, legal representatives, executors,
administrators and assigns) of the second part

WHEREAS the First Party is sole and absolute owner of PROPER - TY comprised in FIRST
SCHEDULE hereto and whereas the property although in possession of said property is far
away from the residence of the said property and it is too expensive to often visit the said
property to ascer - tain and ensure that it has not gone in illegal possession of any trespasser
and the said property was looking for a purchaser, who could purchase the said property;
AND
WHEREAS, the Second Party is sole and absolute owner in possession of the PROPERTY
comprised in SECOND SCHEDULE hereto and was eager to sell or exchange the same on
account of same problems;
AND
WHEREAS the parties hereto after knowing intention of each other deliberated frankly and
arrived at one agreement to EXCHANGE the PROPERTIES and transfer the ownership as
between them viz., that the said Parties shall convey the PROPERTY described in FIRST
SCHEDULE to Second Party., who will convey in lieu thereof the PROPERTY described in
SECOND SCHEDULE hereto.

NOW THIS DEED OF EXCHANGE WITNESSETH AS UNDER :—


1. That the both do hereby grant, convey, transfer, assign and as - sure unto and in favour
of the said properties free from all and any encumbrances the plot of land absolutely
and forever in exchange for what is hereunder transferred by said First Party in favour
of Second Party
2. That the Second Party do hereby grant, convey, transfer, assign and assure unto and
in favour of the said property free from all and any encumbrances the plot of land
comprised in SECOND SCHEDULE hereto unto and in favour of the said First Party to
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

have and hold the same absolutely and forever in EXCHANGE for the transfer as
aforesaid effected by . Second Party in favour of the First Party
3. That the parties hereto do hereby declare and state that each one has good right,
absolute, lawful authority and indefeasible title to give, grant, transfer and convey the
PROPERTY EXCHANGED by THIS DEED and that the each party shall hereinafter
peaceably and quietly hold, possess and fully enjoy the respective property without.
• FIRST SCHEDULE
Description of property transferred by First Party

• SECOND SCHEDULE Description of property transferred by Second Party

IN WITNESS WHEREOF the parties hereto have executed these presents in presence of
the under-named at Hyderabad on the aforementioned. Signed, sealed and delivered.

WITNESSES:-

1. First Party

2. Second Party
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :25

(To be typed on a Rs.100/- non judicial stamp paper)

PROMISSORY NOTE UNDER SEC.4, NEGOTIABLE INSTRUMENTS ACT, 1881

I, A promise to pay Mr.B or order, on demand, the sum of Rs.10,00,000/- (Rupees 10 lakhs
only) with interest at the rate of 2 per cent. Per annum from the date of these presents, for
value received.

Place:

Date:

Signature.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :26

ADOPTION DEED
This Deed of Adoption is made and executed on this 25th day of November, 2023, hereinafter
referred to as the “Adoption Deed”.

BY AND BETWEEN
Mr. Narender, aged 46 years, working as Pvt. Employee, resident of, Hyderabad-500 013,
hereinafter referred to as the “First Party”.
AND
M/s Orphanagehome , hereinafter referred to as the “Second Party”.
(First Party and Second Party are hereinafter collectively referred to as the “Parties” and
individually as “Party” with their respective prefixes).

WHEREAS the First Party visited second party and desirous of adopting the Adopted Child from
the Second Party

AND WHEREAS the Second Party is willing to give in adoption Second Party male child, the
Adopted Child to the First Party.
AND WHEREAS the First Party has the capacity and also the right to take in adoption and the
Second Party has the capacity to give in adoption the Adopted Child and the Adopted Child is
capable of being taken in adoption in terms of the provision of Hindu Adoption and
Maintenance Act, 1956.

NOW THEREFORE, in consideration of the foregoing, accepted and agreed to, the Parties
hereto, intending to be legally bound, agree to the terms set forth below:

1. The Second Party with free will, consent and in consensus with her father, the 2nd
Conforming Party hereby on the date of execution of this Adoption Deed, in presence of the
respective relatives/friends of the Parties, gives in adoption her younger child, the Adopted
Child to the First Party and the First Party with free will, consent and in consensus with his
wife, the 1st Conforming Party by way of the present Adoption Deed adopts the Adopted Child.
2. The Adopted Child shall have all the rights as of a biological/natural child of the First
Party from the date of execution of this Adoption Deed. The Adopted Child henceforth ceased
to be a member of family of the Second Party and would have no right remaining with the
Second Party.
3. The First Party along with 1st Conforming Party shall henceforth be responsible for the
maintenance, education, health, wellbeing and safety of the Adopted Child. The First Party
and the 1st Conforming Party are hereby restrained from further giving in adoption the Adopted
Child as per the provisions of Hindu Adoption and Maintenance Act, 1956.
4. The Second Party shall have no claim in regard to custody and for that matter any other
right over the Adopted Child.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

5. The First Party hereby represents and warrants that neither he nor his wife has, any
son, son’s son or son’s son’s son and not even any daughter or son’s daughter whether by
legitimate blood relationship or by adoption living at the time of execution of this Adoption
Deed.
6. The Second Party hereby represents and warrants that the Adopted Child is not
adopted by anyone else, anytime before the execution of this Adoption Deed, but the First
Party along with his wife, 1st Confirming Party by way of the present Adoption Deed.
7. The Parties further covenant and acknowledge that the present Adoption Deed has
been executed without any undue influence, threat, force or coercive measure and with free
and unhindered will and in consensus with their respective wife and father i.e. the Confirming
Parties.
8. The Parties represent and warrant that they are fully capable and competent to
execute this Adoption Deed in accordance with the provisions of Hindu Adoption and
Maintenance Act, 1956 and that the information and particulars furnished herein by them are
true and correct and nothing has been concealed therefrom.
9. The Parties hereby represent and warrant that they are Hindu by religion and have
never converted to any other religion or have never ceased to be Hindu.
10. The Parties herein covenant and acknowledge that this Adoption Deed and the terms
herein are irrevocable and are binding upon them.

We the above noted parties have signed this deed of adoption on this 25th day of November,
2023 with our own free will without any threat or coercion and after fully understanding the
contents of this Adoption Deed in presence of the following witnesses:

(FIRST PARTY) (SECOND PARTY)

WITNESSESS:
1) Signature
Name:
Address:

2) Signature
Name:
Address:

Date: 25-11-2023
Place: Hyderabad
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :27

PLEDGE DEED

This Deed of PLEDGE is executed on this the day of April, 2023 at Hyderabad, by and
between:

Mr.Shekar, aged 35 years, Occ: Doctor, R/o R.R. District, Hereinafter referred to as the
“PAWNER” which term shall mean and include wherever the context so requires or permits
his respective heirs, legal representatives, executors, administrators, nominees and
assignees of the ONE PART.

And
------------, having its Branch Office, Secunderabad. Hereinafter referred to as the “PAWNEE”
which term shall mean and include wherever the context so requires or permits its successors-
in-interest and assignees of the OTHER PARTIES.
WHEREAS, the PAWNER herein is the sole and absolute owner of the jewellary
WHEREAS the PAWNER had already submitted the original jewellary as security for the loan
availed from the PAWNEE.

NOW THIS DEED OF FIRST SIMPLE MORTAGE WITNEESETH THAT:


1. In pursuance of the aforesaid agreement and in consideration of the sum of Rs.3,00,000/-
paid the PAWNEE) at the time of execution of these presents and the receipt of which the
PAWNEE) do hereby admits and acknowledges and undertakes that he/shall repay to the
PAWNEE herein the said sum of Rs.3,00,000/- within a period of 10 years from this date
together with interest at 16% P.A. and repayable by way of equated monthly installments
as advised by the PAWNEE.
2. In the event of the PAWNOR) committing default in payment of the equated monthly
installments, the PAWNEE shall be entitled to demand the entire principal and interest
accrued thereon as on that date. Similarly, in the event of default in payment of interest
continuously at any time prior to commencement of equated monthly installments
payment, the PAWNEE shall be entitled to demand the entire principal and interest
accrued thereon as on the date.
3. So long as the said principal sum of Rs.3,00,000/- or any part thereof shall remain due
and payable by the PAWNOR) to the PAWNEE) covenant to pay to the PAWNEE interest
calculated on the principal and outstanding at the rate of 16% P.A., regularly once in every
quarter.
4. So long as the principal amount due under the PAWNEE is outstanding, the PAWNEE) will
keep the premises hereby PAWNEE in good and substantial repair.
5. The PAWNEE further covenant with the PAWNOR to pay all the Taxes, rates and other
outgoings in respect of mentioned property hereby PLEDGE, to the Government, Revenue,
CMWSSB, electricity Board and other authorities punctually without committing any
default.
6. In the event of the PLEDGE) committing default in the faithful performance and
observance of anyone of the conditions or covenants hereinabove contained, personally
and /or against the property hereby PAWNNOR as the PAWNEE shall be at perfect liberty
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

to proceed against the PAWNEE) personally and /or against the property hereby PLEDGED
as the PAWNEE may think fit including to cause the said property to be sold in due process
of law and for the due recovery of all the amounts hereby secured

WITNESSES:

PAWNEE
1.

2.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :28

IN THE COURT OF THE HON’BLE JUDGE: COURT:


AT SECUNDERABAD

O.S.No. OF 2023
Between:

x … Plaintiff

AND

Y … Defendant

Complaint Under section 138 and 142 of the Negotiable Instrument Act, 1881.
Respectfully Showeth :-

1. That the accused issued one cheque bearing No. _______ dated________ for a sum of Rs.
6,00,000/- ,drawn on for a lawful valuable consideration in discharge of his liability in favour
of the complainant.

2. That the complainant presented the said cheque lastly on __________ which was
returned unpaid by drawee Bank vide returning Memo dated ________ for the reasons
`Insufficient Funds`. The said cheque was presented within its validity period and stood
dishonoured on presentation.

3. That the complainant got a notice issued through his counsel dated ______ under
registered AD cover and UPC to the accused demanding the amount of the dishonoured
cheques within 15 days of the receipt thereof which was duly served upon him on(Date)
________. It is submitted that the Registered cover containing the notice was received back
as unclaimed as the accused has deliberately avoided the service of the notice, however the
notice sent through UPC stood served upon the accused on (Date)_______, the copy of
notice with postal receipt/ UPC and envelop containing notice is filed with the complaint.

4. That the accused person has not cared to make the payment of the amount of
dishonoured cheques to the complainant within 15 days as required under the law as
demanded in the notice.

5. That the cause of action for filing the complaint arose to the complainant with in the
jurisdiction of this learned court when the accused failed to make the payment of the
cheques in dispute to the complainant with in 15 days of the receipt of notice.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

6. That the accused is guilty of an offence under section 138 of the Negotiable Instrument
Act, 1881 and is liable to be punished under section 142 of the said Act.

It is, therefore, prayed that the accused person be proceeded against and punished in
accordance with law as envisaged under section 142 of the Negotiable Instrument Act in
accordance with law. Complainant

Through Advocates

Place: _________

Dated: _________

List of Documents attached:-

1. Original dishonoured cheque No. ____ dated ____ for Rs.____ drawn on _______

2. Original returning Memos of the drawee Bank dated ________

3. copy of Notice dated ________.

4. Postal and UPC receipt dated _________ and envelop containing notice.

AFFIDAVIT

I Mr. x do hereby solemnly affirm and declare on oath that the contents of the accompanied
application from para 1 to 6 are true and correct to my personal knowledge and belief and
that nothing false is stated therein and also nothing material is concealed there from.

I further declare and verify on oath that the contents of this affidavit are true and correct
and nothing material is concealed there from. Verified at _______ on this _______ day
of_________. DEPONENT.

COUSEL FOR PETITIONER DEPONENT


R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :29

DEED OF PARTNERSHIP
THIS DEED OF PARTNERSHIP made on this 1st day of August, 2023 at Hyderabad.

Between:

1. X (Hereinafter referred to as the party of the FIRST PARTY)

AND
2. Y (Hereinafter referred to as the party of the SECOND PARTY)

AND
3. Z (Hereinafter referred to as the party of the SECOND PARTY)

WHEREAS the parties hereto have agreed to start in partnership to carry on the business

AND WHEREAS both the parties desired to reduce the terms and conditions into writing in
order to avoid any doubts, dispute or ambiguities in future.

NOW THEREFORE THIS DEED WITNESSETH AS FOLLOWS:

1. The deed of partnership shall be carried on under the name decide therein.

2. That the partnership shall be effective from 01st day of August, 2014 and shall be at
WILL.

3. That the principal place of business be at hyderbad and the partners may open any
branches at any other place or places as the partners may mutually decide.

4. That the Party of the Second Party will participate in day to day work and shall be
treated as working partner and work for the business. Remaining parties are investment
partner/sleeping Partner.

5. The partners of the business may borrow from time to time after taking consent from
the other partner from persons, firms, companies or Banks, such money as may be required
for the purpose of the business.

6. The First Part has invested Rs.12,00,000/- towards the capital of the partnership
business. The Second Part is only a working partner and has not invested any amount towards
capital.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

7. That the profits and losses of the partnership business after charging all the expenses
necessary and incidental to carry on the business shall be shared or borne by the partners in
the following ratios:

Party of the First party 40%


Party of the Second Party 30%
Party of the Third Party 30%

8. That the business may open bank account/s with any bank/s and which shall be
operated by Second Party.

10. All records and books of accounts of the partnership business shall be maintained in
English and on mercantile basis regularly in the business and each partner or his authorized
agent shall at all times have access to and right to inspect and take copies thereof at the
principal place of business. Such accounts shall be closed on the day of Diwali Festival every
year and statement of accounts shall be prepared.

11. That the partners during the continuance of the partnership business may withdraw
reasonable amount per month towards their household expenses as mutually agreed by the
partners and such drawings shall be adjusted against their share of profit.

12. Every Partner shall:


a) carry on the business to the greatest advantage be just and faithful to each other,
and furnish full information of all matters relating to the business to other partner
or his legal representatives.
b) attend diligently to his duties in the conduct of his business.
c) Forthwith deposit all moneys, cheques and negotiable instruments etc., received
by him on account of the business to the business account in the Bank.
d) Indemnify the business for any loss caused to it by his fraud or willful negligence in
the conduct of the business.

13. No partner shall, without the written consent of other partner:

a) lend to any persons any sums of money on behalf of the business.


b) Open a bank account on behalf of the business in his own name.
c) Draw, accept or endorse any bill of exchange or promissory note on account of the
business.
d) Sell or mortgage or assign in any manner or transfer his share of property in the
business.
e) Enter into partnership with others on behalf of the business.
f) Compromise or relinquish the whole or any portion of a claim by the business,
except in the ordinary course of business.
g) File or withdraw a suit or other legal proceedings on behalf of the business.
h) Become a bail or surety for any person on behalf of the business and thereby
endanger the assets of the business.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

14. If during the continuance of this partnership, any partner desires to retire from
partnership business, he can do so by giving Six calendar month notice in writing to other
partner, upon which the other partner may takeover the business after settlement of balance
in capital account and profit accumulated to the retiring partner account till the date of
retirement.

15. That it is mandatory that the Second party shall give Six Calendar month notice in
writing to the First Party and further the Second Party has to furnish the complete accounts
including liabilities and debtors of the business and help to close the pending accounts before
he retires.

16. That as the Second party is working partner and sole person to maintain accounts and
bank related transactions. Hence the Second Party is liable for all the transactions of bank.

17. The death, removal or retirement of any of the partner shall not dissolve the
partnership business but business may be continued by the
surviving partner by admitting the heirs or legal representatives of the deceased or retired
partner as expressed in writing.

18. The business shall upon dissolution be wound up and the assets and liabilities dealt
with in accordance with the provisions of the Indian Partnership Act.

19. Any dispute or differences which may arise between/among the partners or their
representatives with regard to the business, meaning and effect of this deed or any part
thereof, profit or losses or in respect of the accounts of the business, or the dissolution or
winding up of the business or any other matter relating to the business shall be referred to
District Courts Ranga Reddy at L.B.Nagar.

20. That the terms and conditions of this partnership deed may be altered, modified, varied
added or cancelled by any deed arrived at in writing among and signed by all the partners
hereof. Such deed when executed shall have effect, unless otherwise provided, from the day
and the date on which such deed is executed and the same shall form part of this deed of
partnership.

21. The provisions of the Indian Partnership Act, 1932 with the amendments thereof, for
the time being in force shall apply to this indenture except in respect of those herein above
specifically provided.

IN WITNESS THEREOF the said parties have herewith signed before the following
witnesses on the day, month and year mentioned above.

WITNESSES:
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

Problem No :30

MORTGAGE DEED
(WITH POSSESSION)

This Deed of First Simple Mortgage is executed on this the day of April, 2023 at
Hyderabad, by and between:

Pawan, aged 32 years, Occ: Doctor, R/o, R.R. District.

Hereinafter referred to as the “MORTGAGOR(S)” which term shall mean and include wherever
the context so requires or permits his respective heirs, legal representatives, executors,
administrators, nominees and assignees of the ONE PART.

And

Mahesh, aged 39 years, Occ: Financer, R/o, Secunderabad.

Hereinafter referred to as the “MORTGAGEE” which term shall mean and include wherever
the context so requires or permits its successors-in-interest and assignees of the OTHER PART.

WHEREAS, the Mortgagor herein is the sole and absolute owner of the House No. admeasuring
244.44 Sq.yds or 204.38 Sq.mtrs, Sy.No.1, situated at, Ranga Reddy District, having
purchased and the same registered before SRO, R.O. Ranga Reddy District.
WHEREAS the Mortgagor had already submitted the original documents of the schedule
mentioned property as security for the loan availed from the Mortagee.

NOW THIS DEED OF FIRST SIMPLE MORTAGE WITNEESETH THAT:

In pursuance of the aforesaid agreement and in consideration of the sum of Rs.20,00,000/-


paid by the Mortgagee to the Mortgagor(S) at the time of execution of these presents and the
receipt of which the Mortgagor(S) do hereby admits and acknowledges and undertakes that
he/shall repay to the Mortgagee herein the said sum of Rs.20,00,000/- within a period of 10
years from this date together with interest at 16% P.A. and repayable by way of equated
monthly installments as advised by the Mortgagee from time to time and creates this first
simple mortgage over the Schedule mentioned property in favour of the Mortgagee herein.
1. In the event of the Mortgagor(S) committing default in payment of the equated monthly
installments, the Mortgagee shall be entitled to demand the entire principal and interest
accrued thereon as on that date. Similarly, in the event of default in payment of interest
continuously at any time prior to commencement of equated monthly installments payment,
the Mortgagee shall be entitled to demand the entire principal and interest accrued thereon
as on the date.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

2. So long as the said principal sum of Rs.20,00,000/- or any part thereof shall remain
due and payable by the Mortgagor(S) to the Mortgagee, the Mortgagor(S) covenant to pay to
the Mortgagee interest calculated on the principal and outstanding at the rate of 16% P.A.,
regularly once in every quarter.

3. The Mortgagor(S) do hereby covenant with the Mortgagee that the property hereby
mortgaged is their absolute property and that the same is free from all encumbrance
whatsoever.

4. So long as the principal amount due under the mortgage is outstanding, the
mortgagor(S) will keep the premises hereby mortgaged in good and substantial repair.

5. The Mortgagor(S) further covenant with the Mortgagee to pay all the Taxes, rates and
other outgoings in respect of the schedule mentioned property hereby mortgaged, to the
Government, Revenue, CMWSSB, electricity Board and other authorities punctually without
committing any default.

6. In the event of the Mortgagor(s) committing default in the faithful performance and
observance of anyone of the conditions or covenants hereinabove contained. The
Mortgagors(s) personally and /or against the property hereby mortgaged as the Mortgagee
shall be at perfect liberty to proceed against the Mortgagor(s) personally and /or against the
property hereby mortgaged as the Mortgagee may think fit including to cause the said property
to be sold in due process of law and for the due recovery of all the amounts hereby secured.

SCHEDULE OF PROPERTY

All that the House No. admeasuring 244.44 Sq.yds or 204.38 Sq.mtrs, Sy.No.1, situated at,
Ranga Reddy District, having purchased and the same registered before SRO, R.O. Ranga
Reddy District, WHEREAS the Mortgagor had already submitted the original documents of the
schedule mentioned property as security for the loan availed from the Mortagee.
and bounded as follows:

NORTH : Road 15’ Wide


SOUTH : : Neighbour’s House
EAST : Neighbour’s House
WEST : Neighbour’s House

IN WITNESS WHEREOF the Mortgagor(s) have signed this Deed of First Simple Mortgage on
the day, month and year first above mentioned in the presence of:

WITNESSES:

MORTGAGOR(S)
1.
R. Raghava Krishna Bharadwaj
Roll number – 172820831198
PMR Law collage

You might also like