r 20(11) 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(11), IN
RFA NO. 9306/2014, ALONG WITH
AFFIDAVITS.
2. ANNEXURE A-1: TRUE COPY OF DEATH

CERTIFICATE OF RESPONDENT NO. 20
(11)
3. VAKALATNAMA OF ISHWANTI W/O

LATE SH. KRISHAN LAL
4. VAKALATNAMA OF RAKESH S/O LATE

SH. KRISHAN LAL
5. VAKALATNAMA OF ANIL KUMAR S/O

LATE SH. KRISHAN LAL
6. VAKALATNAMA OF PARDEEP S/O LATE
SH. KRISHAN LAL
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(11), SH. KRISHAN LAL,
S/O, RAM BHAGAT
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 (11), namely Sh. Krishan Lal died on
18.05.2021. A true copy of the death certificate dated 29.04.2024
is enclosed herein as ANNEXURE-1.
3. That Respondent No. 20 (11) is survived by the following legal
heirs:
a. SMT. ISHWANTI (WIFE);
b. SH. RAKESH (SON);
c. SH. PARDEEP (SON);

d. SH. RAJPAL (SON);
e. ANIL KUMAR (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(11) 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 fir 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, Ishwanti, aged about, 58 years, w/o late Sh. Krishan Lal, resident of
Pehrawar, Rohtak, Haryana- 124021, do hereby solemnly affirm and
state on oath as hereunder:
1. That I am w/o late Sh. Krishan Lal/ Respondent No. 20(11) 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, Rakesh, aged about, 37 years, s/o late Sh. Krishan Lal, resident of
735, Pehrawar, Rohtak, Haryana- 124021, do hereby solemnly affirm
and state on oath as hereunder:
1. That I am s/o late Sh. Krishan Lal/ Respondent No. 20(11) in the
DEPONENT
VERIFICATION:
DEPONENT
DIARY NO. 21050 OF 2022
IN THE MATTER OF:-

VERSUS
AFFIDAVIT
I, Anil Kumar, aged about, 35 years, s/o late Sh. Krishan Lal, resident
of, Sultanwali Gali, Amrit Colony, Rohtak, Haryana- 124001, 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, Pardeep, aged about, 35 years, s/o late Sh. Krishan Lal, resident of
492, Pehrawar, Rohtak, Haryana- 124021, do hereby solemnly affirm
and state on oath as hereunder:
DEPONENT
VERIFICATION:
DEPONENT

r 20(11) Appl. for Substitution

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r 20(11) Appl. for Substitution

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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 ISHWANTI W/O

4. VAKALATNAMA OF RAKESH S/O LATE

5. VAKALATNAMA OF ANIL KUMAR 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 (11), namely Sh. Krishan Lal died on

18.05.2021. A true copy of the death certificate dated 29.04.2024

is enclosed herein as ANNEXURE-1.

3. That Respondent No. 20 (11) is survived by the following legal

a. SMT. ISHWANTI (WIFE);

b. SH. RAKESH (SON);

c. SH. PARDEEP (SON);

e. ANIL KUMAR (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(11) as detailed

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

deem fir 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 MATTER OF: -

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

state on oath as hereunder:

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 MATTER OF: -

735, Pehrawar, Rohtak, Haryana- 124021, do hereby solemnly affirm

and state on oath as hereunder:

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 MATTER OF:-

of, Sultanwali Gali, Amrit Colony, Rohtak, Haryana- 124001, do

hereby solemnly affirm and state on oath as hereunder:

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 _________,

Verified at __ on this day of _,

Verified at __ on this day of _,

Verified at __ on this day of _,

Verified at __ on this day of _,