r 20(16) Appl. for Substitution

IN THE SUPREME COURT OF INDIA
CIVIL APPELLATE JURISDICTION

I.A. No. ________ of 2024
IN
SPECIAL LEAVE PETITION (C) NO(S).
DIARY NO. 21050 OF 2022
IN THE MATTER OF:-
THE STATE OF HARYANA & ANR. ETC.ETC. …PETITIONERS

VERSUS
SMT. CHANDER (SINCE DECEASED)
THROUGH HER LRS & ORS. …. RESPONDENTS
INDEX
S.NO. PARTICULARS Pg No
1. I.A. NO. ____ OF 2024: APPLICATION FOR

SUBSTITUTION OF LEGAL HEIRS OF
DECEASED RESPONDENT NO. 20(16), IN
RFA NO. 9306/2014, ALONG WITH
AFFIDAVITS.
2. ANNEXURE A-1: TRUE COPY OF DEATH

CERTIFICATE OF RESPONDENT NO. 20
(16)
3. VAKALATNAMA OF RAJENDER SINGH

S/O LATE PARMESHWARI DEVI
4. VAKALATNAMA OF RAJ KUMAR S/O

LATE PARMESHWARI DEVI
5. VAKALATNAMA OF PAWAN KMAR S/O

LATE PARMESHWARI DEVI
6. VAKALATNAMA OF SATYA PRAKASH
S/O LATE PARMESHWARI DEVI
FILED BY
SNEHASISH MUKHERJEE
ADVOCATE FOR THE PETITIONER
ADDRESS: D-506 SUPREME COURT, ADDL. BUILDING
BLOCK, MATHURA ROAD, NEW DELHI 110001
MOBILE: 9818493560
AOR CODE: 1817
PLACE: NEW DELHI

FILED ON: .07.2024
DIARY NO. 21050 OF 2022
IN THE MATTER OF:-

VERSUS
THROUGH HER LRS & ORS. ….RESPONDENTS
APPLICATION FOR SUBSTITUTION OF LEGAL HEIRS OF

DECEASED RESPONDENT NO. 20(16), LATE
SMT.PARMESHWARI DEVI WIDOW OF LATE SH.GOPI
RAM.
MOST RESPECTFULLY SHOWETH:

1. That the Petitioners have preferred the present Special Leave
Petition before this Hon’ble Court against the Final Order and
Judgement dated 16.03.2022 passed by the Hon’ble High Court
of Punjab and Haryana at Chandigarh in RFA No. 9306/2014.
2. That Respondent No. 20 (16), namely Smt. Parmeshwari Devi,
Widow of Late Sh. Gopi Ram died on 06.04.2023. A true copy of
the death certificate dated 20.04.2023 is enclosed herein as
ANNEXURE-1.
3. That Respondent No. 20 (16) is survived by the following legal
heirs:
a. SH. RAJENDER SINGH (SON);

b. SH. RAJ KUMAR (SON);
c. SH. PAWAN KUMAR (SON);
d. SATYA PRAKASH (SON);
4. It is stated that there are no other legal heirs who are
beneficiaries to the subject land and the above are the only legal
heirs.
5. That the application is being in bona fide manner and in the
interest of justice.
PRAYER:
It is therefore most respectfully prayed that this Hon’ble Court may be
pleased to:
1. Take on record legal heirs of Respondent No. 20(16) as detailed
in paragraph 3 hereinabove;
2. Direct the Petitioners to file an amended memo of parties; and
3. Pass any such other or further orders as this Hon’ble Court may
deem fit in the facts and circumstances of the present matter.
AND FOR THIS ACT OF KINDNESS THE APPLICANT AS IN
DUTY BOUND SHALL EVER PRAY.
DRAWN BY: FILED BY:

ANSHU DAVAR SNEHASISH MUKHERJEE
AOR FOR THE RESPONDENT

DIARY NO. 21050 OF 2022
IN THE MATTER OF: -

VERSUS
AFFIDAVIT
I, Rajender Singh, aged about, 65, s/o late Parmeshwari Devi, resident
of Pehrawar, Rohtak, Haryana- 124021, do hereby solemnly affirm and
state on oath as hereunder:
1. That I am s/o late Parmeshwari Devi/ Respondent No. 20(16) in
the captioned matter and as such am well acquainted with the
facts and circumstances of the present case and am fully
competent to swear this present affidavit.
2. I say that the facts stated in the accompanying application are
true to my knowledge and belief and no part of it is false and no
material has been concealed there from.
DEPONENT
VERIFICATION:
Verified at __________ on this ________ day of _________,
2024 that the contents of the foregoing affidavit are true and correct to
my knowledge. No part of it is false and nothing material has been
concealed therefrom.
DEPONENT

DIARY NO. 21050 OF 2022
IN THE MATTER OF: -

VERSUS
AFFIDAVIT
I, Raj Kumar, aged about, 55, s/o late Parmeshwari Devi, resident of
House No-B-12-C/302, Vishwakarma Colony, South Delhi- 110044, do
hereby solemnly affirm and state on oath as hereunder:
DEPONENT
VERIFICATION:
DEPONENT

DIARY NO. 21050 OF 2022
IN THE MATTER OF: -

VERSUS
AFFIDAVIT
I, Pawan Kumar, aged about, 55, s/o late Parmeshwari Devi, resident of
Pehrawar, Rohtak, Haryana- 1972, do hereby solemnly affirm and state
on oath as hereunder:
1. That I am s/o late Parmeshwari Devi/ Respondent No. 20 (16) in
DEPONENT
VERIFICATION:
DEPONENT

DIARY NO. 21050 OF 2022
IN THE MATTER OF: -
VERSUS
AFFIDAVIT
I, Satya Prakash, aged about, 50, s/o late Parmeshwari Devi, resident of
Pehrawar, Rohtak, Haryana- 124001, do hereby solemnly affirm and
state on oath as hereunder:
DEPONENT
VERIFICATION:
DEPONENT

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IN THE SUPREME COURT OF INDIA

CIVIL APPELLATE JURISDICTION

IN THE MATTER OF:-

THE STATE OF HARYANA & ANR. ETC.ETC. …PETITIONERS

1. I.A. NO. ____ OF 2024: APPLICATION FOR

2. ANNEXURE A-1: TRUE COPY OF DEATH

3. VAKALATNAMA OF RAJENDER SINGH

4. VAKALATNAMA OF RAJ KUMAR S/O

5. VAKALATNAMA OF PAWAN KMAR S/O

PLACE: NEW DELHI

IN THE MATTER OF:-

APPLICATION FOR SUBSTITUTION OF LEGAL HEIRS OF

MOST RESPECTFULLY SHOWETH:

Judgement dated 16.03.2022 passed by the Hon’ble High Court

of Punjab and Haryana at Chandigarh in RFA No. 9306/2014.

2. That Respondent No. 20 (16), namely Smt. Parmeshwari Devi,

Widow of Late Sh. Gopi Ram died on 06.04.2023. A true copy of

the death certificate dated 20.04.2023 is enclosed herein as

3. That Respondent No. 20 (16) is survived by the following legal

a. SH. RAJENDER SINGH (SON);

c. SH. PAWAN KUMAR (SON);

d. SATYA PRAKASH (SON);

4. It is stated that there are no other legal heirs who are

5. That the application is being in bona fide manner and in the

It is therefore most respectfully prayed that this Hon’ble Court may be

1. Take on record legal heirs of Respondent No. 20(16) as detailed

2. Direct the Petitioners to file an amended memo of parties; and

deem fit in the facts and circumstances of the present matter.

AND FOR THIS ACT OF KINDNESS THE APPLICANT AS IN

DUTY BOUND SHALL EVER PRAY.

DRAWN BY: FILED BY:

IN THE SUPREME COURT OF INDIA

IN THE MATTER OF: -

of Pehrawar, Rohtak, Haryana- 124021, do hereby solemnly affirm and

state on oath as hereunder:

1. That I am s/o late Parmeshwari Devi/ Respondent No. 20(16) in

the captioned matter and as such am well acquainted with the

facts and circumstances of the present case and am fully

competent to swear this present affidavit.

2. I say that the facts stated in the accompanying application are

true to my knowledge and belief and no part of it is false and no

material has been concealed there from.

Verified at __________ on this ________ day of _________,

my knowledge. No part of it is false and nothing material has been

IN THE SUPREME COURT OF INDIA

IN THE MATTER OF: -

House No-B-12-C/302, Vishwakarma Colony, South Delhi- 110044, do

hereby solemnly affirm and state on oath as hereunder:

1. That I am s/o late Parmeshwari Devi/ Respondent No. 20(16) in

the captioned matter and as such am well acquainted with the

facts and circumstances of the present case and am fully

competent to swear this present affidavit.

2. I say that the facts stated in the accompanying application are

true to my knowledge and belief and no part of it is false and no

material has been concealed there from.

Verified at __________ on this ________ day of _________,

my knowledge. No part of it is false and nothing material has been

IN THE SUPREME COURT OF INDIA

IN THE MATTER OF: -

Verified at __ on this day of _,

Verified at __ on this day of _,

Verified at __ on this day of _,