IN THE COURT OF Ms.

COLLATE RASHMI KUJUR

ADJ DIST. CENTRAL DELHI

C.S NO. 239OF 2021

IN THE MATTER OF:-

SHRI. MUKESH GUPTA & OTHER ….PLAINTIFFS

VERSUS

SMT. URVASHI AGGARWAL & OTHER ….DEFENDANTS

REPLICATION FILED ON BEHALF OF PLAINTIFF No. 3

MOST RESPECTFULLY SHOWETH:-

PRELIMINARY OBJECTIONS:-

1. At the outset, it is submitted that unless specifically referred to the admitted

hereinafter, the contents of the reply/ preliminary submissions filed by the
Defendants are denied iSn entirety, being wrong, incorrect and contrary to
the facts. The Plaintiff craves leave of this Hon’ble Court to refer and rely
upon the Plaint, the content of which are not repeated herein for the sake of
brevity and in order to avoid repetition. The contents of the Plaint are
reiterated as true and correct.
2. That the defendant has
3. That the Plaintiff No.1 and the Plaintiff No.2 are brothers in relation to
defendant no. 1 and also the Directors in Plaintiff no.3 which is a Private
Limited Company duty incorporated under the provisions of the Companies
Act, 1956, having its registered office at the address given above in the case
title. Copy of Certificate of Incorporation Dated 15.05.1941 issued by the
then Registrar of Companies is already Annexed to the Plaint.
4. That the present suit for recovery of damages is being signed and filed by
the plaintiff no.1 and 2 in their personal capacity and also on behalf of the
Plaintiff no.3 who have been duly authorized by the Board of Directors of
the Plaintiff no.3 who have been duly authori
5. That on 23,.04.1983 Defendant No.1 executed an irrevocable General Power
of Attorney which was duly registered before the court of Sub Registrar II
Kashmiri Gate, Delhi vide registration bearing no. 3285 at page no. 93 of
book no. 2 in favour of Plaintiff No.1 inconsideration of settlement and
satisfaction of all her inherited properties, empowering Plaintiff No.1 to act
in any manner for the same and represent her as if she was/were present
wherever required. The said GPA was duly executed by defendant no.1 in
presence of her mother and other family& staff members legal counsels.
Thus, the aforesaid GPA dated 23.04.1983 is a valid and legal document
without any doubt executed before the court of Sub Registrar II and duly
witnessed and registered in the records of Sub Registrar above said.