By Hand

08.02.2018

AE (B)
EDMC
Behind arkardooma Courts,
Delhi

Sibject:- Submission of details regarding construction with

measurements of the existing construction alongwith site plan and
photographs of the property

Ref:- Ms. Ritu Soorma Vs EDMC, Appeal No. 47/18 pending

before ATMCD, Tis Hazari, Delhi, NDOH-4.4.2018

Sir,

In reference to aforesaid matter and in compliance of order dated

2.2.18 passed by the learned Presiding officer, ATMCD, Tis
Hazari, the undersigned is submitting the affidavit with details
regarding construction with measurements of the existing
construction alongwith site plan and photographs as Annexures A-
1 to A-3 of the property bearing no. 13, 2 n d Floor, Hargobind
Enclave, Delhi for your perusal and needful action at your end.

Thanking you

Yours Truly,

Ritu Soorma
13, 2 n d Floor
Hargobind Enclave
Delhi

Encl: As Above
 BEFORE SH. SANJEEV KUMAR, PRESIDING OFFICER,
APPELLATE TRIBUNAL MUNICIPAL CORPORATION OF
DELHI AT TIS HAZARI COURTS, DELHI

APPEAL NO. 47 OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA …

APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

N.D.O.H-04.04.2018

AFFIDAVIT

I, Ritu Soorma wife of Shri Virender Soorma, aged 48 years,

resident of 2 n d Floor, 13 Hargobind Enclave, Delhi-110092 do
hereby solemnly affirm and state as under:

1. That I say that I am appellant in the accompanying appeal

and am well conversant with the facts, records and
circumstances of the case and I am competent to swear this
Affidavit.
2. That I say that in terms of the directions of the Hon’ble
Tribunal passed on 2 n d February, 2018, the details regarding
construction with measurements of the existing construction
alongwith site plan and photographs of the property are
annexed herewith. The site plan along with details of the
measurements of existing construction is annexed herewith
as Annexure A-1. The photographs of property are annexed
herewith as Annexure A-2 & Annexure-3. The Annexure A-
1 has been being prepared at my instructions and the
Annexures A-2 and A-3 are being taken by me. All the
Annexures are true and correct to my knowledge and are as
per the existing situation at site. The Annexures from A-1 to
A-3 enclosed herewith be read as part and parcel of this
affidavit and the contents of the same are not being repeated
herein for sake of brevity.

3. I say that copy of all the aforesaid Annexures along with this
Affidavit has already been served upon the office of AE (B)
at EDMC, Shahdara South Zone, Behind Karkardooma
Courts, Delhi.

DEPONENT
VERIFICATION :
Verified at Delhi on this 8 t h of February, 2018 that contents of
above affidavit are true and correct to the best of my knowledge.
No part of it is false and nothing material has been concealed
therefrom.

DEPONENT
BEFORE THE PRESIDING OFFICER, APPELLATE TRIBUNAL
MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA

W/OSH. VIRENDERSOORMA
R/O 2 N D FLOOR, 13, HARGOBIND ENCLAVE,
DELHI-110092. …
APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

THROUGH ITS COMMISSIONER,
UDYOGSADAN, PATPARGANJ INDUSTRIAL AREA,
DELHI
...RESPONDENT

INDEX

S. Particulars Page Court

N. No. Fees
A. Urgent Application
1. Memo of parties
2. Appeal under Section 343 (2) of the
D.M.C. Act 1957 (Demolition), along
with affidavit
2. Annexure P
Copy of Site Plan of property
3. Annexure P-1
Photocopy of the Notice dated 6.10.2017
u/s 343 of DM Act
4. Annexure P-2
Photocopy of the Notice dated
23.10.2017
4. Annexure P-3
Photocopy of the letter dated 6.11.2017
5. Annexure P-4
Copy of Conveyance deed dated 29.7.94
6. Annexure P-5 (Colly)
Copy of Property Tax Receipts

7. Annexure P-6 (Colly)

Copy of Bill and Receipts of Delhi Jal
Board
`8. Annexure P-7
Copy of Electricity Bills showing the
Energisation dated as of year 1994
9. Annexure P-8
Photographs showing the old
construction of the property in issue
10. Annexure P-9
Copy of the Aadhaar Card of the
appellant.
11 Application under Section 151 CPC
seeking stay of the demolition order
dated 6.11.2017 certified copies
12 Affidavit of the Appellant
13 Vakalatnama
 …APPELLANT
Through

R.K Sahni, Advocate

E-606, Lawyers Chambers
Karkardooma Courts, Delhi
Mob: 9811114348
PLACE: DELHI
DATE: 16.01.2018
BEFORE THE PRESIDING OFFICER, APPELLATE TRIBUNAL
MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA

… APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

URGENT APPLICATION

MOST RESPECTFULLY SHOWETH:

That the accompanying appeal may be treated as urgent and may

be listed for hearing immediately for today since the respondent

have scheduled to take the sealing and demolition action and the

stay of further enforcement of the impugned orders have been

prayed for.

…APPELLANT
 Through

R.K Sahni, Advocate

PLACE: DELHI
DATE: 16.01.2018
 BEFORE THE PRESIDING OFFICER, APPELLATE
TRIBUNAL MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

MEMO OF PARTIES

SMT. RITU SOORMA

W/O SH. VIRENDERSOORMA
R/O 2 N D FLOOR, 13, HARGOBIND ENCLAVE,
DELHI-110092. … APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

THROUGH ITS COMMISSIONER,
UDYOGSADAN, PATPARGANJ INDUSTRIAL AREA,
DELHI ...RESPONDE
NT

…APPELLANT
Through

R.K Sahni, Advocate

E-606, Lawyers Chambers
Karkardooma Courts, Delhi
Mob: 9811114348
PLACE: DELHI
DATE: 16.01.2018
BEFORE THE PRESIDING OFFICER, APPELLATE TRIBUNAL
MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA

… APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

APPEAL UNDER SECTION 342 (2) READ WITH

347B OF THE D.M.C. ACT, 1957 (DEMOLITION)

MOST RESPECTFULLY SHOWETH

1. Name of the Appellate Presiding Officer,

Tribunal in which the Appellate Tribunal,
appeal is filed Municipal Corporation of Delhi
2. Name and permanent SMT. RITU SOORMA
address of the W/O SH. VIRENDERSOORMA
Appellant R/O 2 N D FLOOR, 13, HARGOBIND
ENCLAVE, DELHI-110092
3. Name and Address of EASTDELHI MUNICIPAL
the Respondent CORPORATION
 THROUGH ITS COMMISSIONER,
UDYOGSADAN, PATPARGANJ
INDUSTRIAL AREA,
DELHI
4. Details of Subject Appeal Under Section 343 (2) read
Matter of Appeal with 347-B of the D.M.C. Act
against the notices dated
06.11.2017in file
No.237/B/UC/SS/17 passed by the
Area Junior Engineer (Building),
Ward No. 226(17-E) in respect of 2 n d
Floor, 13 Hargobinf Enclave, Delhi.
The said notices are Annexure P-1
& P-2 respectively.
5. Name and designation Area Junior Engineer (Building),
of the Officer who has Shahdara South Zone
passed the order

6. Date of The show cause and notices dated

communication of the 06.11..2017 in file No.
order/ notice appeal No.237/B/UC/SS/17 were never
against addressed and served on the
appellant. However on 15.01.2018
handed over a bunch of photocopied
papers to the appellant.
The appellant was shocked and
 surprised to find the show cause
notices and demolition order dated
06.11.2017.
It is pertinent to mention over here
that perusal of the said show cause
notices and demolition order clearly
reveal that the same were never
addressed to the appellant nor they
were ever served upon the appellant.
The fact that such alleged notices
were neither addressed to the
appellant and nor served on the
appellant and the same came within
the knowledge only on 15.01.2018.

7. STATEMENT OF FACTS:

I. That the appellant is a bonafide law abidingcitizen of this

Country and is the owner of the property bearing No.2 n d Floor,

13 Hargobind Enclave, Delhi (hereinafter referred to as the

property in question). The site plan of the property along with

measurements is annexed as Annexure P-__.

II. That the plot no. 13, Hargobind Enclave, Delhi measuring

253 Sq.mt. was initially allotted by way of a perpetual lease

 dated 29.7.94 to one Sh.Jitender Kumar Jain, who

constructed thereupon basement, ground and first floor,

Second Floor. The copy of the perpetual lease deed is

annexed asAnnexure P-4.

III. That on 31.08.2000 Smt. Chand Jain W/o Sh. Jitender Kumar Jain sold

the terrace floor over the double storied House No.13, Hargobind

Enclave, Delhi-92, Vide registered sale deed and after purchase of the

suit property Sh. Rajan Kumar constructed the suit property and

constructed the second and third floor of the suit property and therefore

the Second Floor and third floor in the suit property.

IV. That on 06.07.2001 Sh. Rajan Kumar S/o Lt. Sh. P.L. Kumar sold the

second floor of the suit property to Sh. P.S. Chabbra vide registered sale

Deed and at that time also second floor of the suit property was in

existence.

V. Thereafter on 31.07.2002 Sh. P.S. Chhabra sold the second floor of the

property bearing No.13, Hargobind Enclave, Delhi-92 vide Registered

G.P.A., and registered Will that on 13.02.2004 Sh. J.K. Jain sold the

second floor of the property to Smt. Uma Dang W/o Sh. Madan Mohan

Dang vide registered sale deed.

VI. That on 05.05.2006 Smt. Uma Dang Sold the Second Floor of the

property to Sushil Arora vide registered sale deed.

VII. That on 06.06.2007 Sh. Sushil Arora Sold the Second Floor of the suit

property to Smt. Manjula Gupta vide Registered sale deed.

VIII. That Smt Manjula Gupta Sold the suit property 24.01.2007 to Harprasad

Gupta vide registered sale deed.

IX. That on 28.06.2011 Harprasad Gupta sold the second floor of the suit

property to Vipin Gupta and BabitaSinghlaJointly (Manju Gupta D/o

Harprasad Gupta W/o Sh. Satish Gupta).

X. That the appellant Ritu SoormaPurcahsed the second floor of the

property bearing NO.13, Hargobind Enclave, Delhi-92 from Vipin

Gupta and BabitaSinghal vide registered sale deed 29.07.2016.

XI. It is pertinent to mention over here that since the year 2000 no new

construction in the property was carried out by any of the subsequent

owners including the appellant.

XII. That the property in question (Second Floor) is also assessed

to house tax by Municipal Corporation of Delhi. The House

 tax receipts showing payment of property tax are annexed

herewith as Annexure _____

XIII. That it is humbly submitted that the area which exists since

the year 2000 has also been clearly depicted in the

documents and property tax filed in 2004-2005 when the unit

area method was introduced. The measurement of

construction on each floor is as under:

Second Floor: __________________

Third Floor: ____________________

It is humbly submitted that till date the measurements as is clear

from the site plan filed is the same and hence there cannot be

any occasion to even remotely suggest the existence of

carrying on any sort of construction in the property in

question.

XIV. That despite the Respondent already being in knowledge of

the status of the property in question, the Appellant as an

abundant precaution again took the documents again to the

AE of the Respondent, however the AE of the Respondent

 intimated to the Appellant that there is no need for the said

documents and they are already in their knowledge and the

matter will be closed.

XV. That the Appellant believed and trusted the said AE and did

not insist on receiving and acknowledging the said

documents.

XVI. That the respondent thereupon without even serving or

sending any show cause notice to the appellant have passed

the recommendation for demolition order.

XVII. That a bare perusal of the said show cause notice dated

06.10.2017 and 23.10.2017 will show that the same were

never addressed to the appellant nor ever served on the

appellant and the demolition order has been passed without

affording any opportunity to respond to the same. It is

humbly submitted that no such allegation or breach was ever

raised earlier and no opportunity was given to the Appellant

in that regard and as such the said notices being in violation

of Principles of Natural Justice are bad in law and any action

 taken on the strength of the said notices will be equally bad.

The notices are also bad for the reason that the nature of

unauthorized construction has not been elaborated in the

notice.

XVIII. It is pertinent to mention here that the appellant had

filed a Civil suit bearing no. titled as “Ritu Soorma Vs

Naresh Narula&Anr.” for Permanent and Mandatory

injunction against the un-authorized construction being

carried out on ground and First Floor of the property in

question. The Hon’ble court vide order dated 4.9.217 and

further on 20.11.2017 called for the status report and ATR

from EDMC. The status report dated 9.10.2017 filed by

EDMC revealed that the property in question had

unauthorized construction from Basement till Third floor and

the same had been booked vide file no.

237/B/UC/SH/S/17.However it is pertinent to mention here

no notice has either been addressed nor has been served upon

the Appellant till date.

XIX. That even otherwise the occupation of the Appellant and

previous owners are in the property in question is since the

year 2000 and the property tax receipts are eloquent of the

said fact and the construction as it existed in the year 2000 is

same till date which can be easily inferred from the site plan

and measurement given for property tax in 2004-2005. It is

thus clear that the construction is old in nature and as such

the same is protected as per the THE NATIONAL CAPITAL

TERRITORY OF DELHI LAWS (SPECIAL PROVISIONS) ACT, 2011.

XX. That the appellant is aggrieved by the illegal, arbitrary and

motivated action on the part of respondent who have illegally

despite being in the knowledge that the property in question

is an old construction and that the policy in respect of the

alleged construction work is still pendingand are in a process

of carrying out demolition on the basis of the demolition

notice and order which were never served upon the appellant.

XXI. That fact that the construction is an old construction and that

the second floor and above has been since long in possession

of the Appellant can be easily inferred from the title

 documents and property tax receipts. Hence the notice and

the alleged order is defective and not in conformity with the

DMC Act.

XXII. That the Respondent in order to extort money and probably

in connivance with the neighborsfor the reasons best known

to them are trying to get the property in question sealed and

demolished despite well being in knowledge of the fact that

the construction i.e. the property in question is an old

construction.

XXIII. That the Appellant is also annexing the photographs of

the property in question to prima facie show that the

construction is an old construction and that there has not

been any alteration to the structure. The said photographs are

Annexure P-11 (Colly). The Respondent cannot be after a

period of 18 years be permitted to get the property in

question evicted and demolished. The chain of title

documents and property tax receipts placed shows that the

acquiescence on the part of the Respondent.

XXIV. That the respondent on the basis of wrong and

incorrect information in regard to the status of the property

and without applying their mind had issued the alleged show

causenotices under challenge that too without serving with

any notice for the purpose taking coercive action against the

property in question and have informed and threatened the

appellant that the officials will come anytime for demolition,

which is a deliberate attempt on the part of the respondent

which has the effect of taking away the right from the

appellant to approach this Hon’ble Tribunal for the redressal

of his grievance. The Respondent had not served even a

single notice and the fact that such notices came in the

knowledge of the appellant only on 15.1.2018.

XXV. That notices dated 06.10.2017, 23.10.2017 and order dated

06.11.2017 are arbitrary and illegal and are liable to be set

aside on the following amongst other grounds:-

8. GROUNDS OF APPEAL
A. Because the impugned notices and the order of

demolition passed by the respondent is based on

conjectures and surmises and even otherwise the entire

proceedings being vague and contrary to law is liable to

be quashed.

B. Because the impugned notices were never served on the

appellant and the Respondent has issued the demolition

order in a mechanical manner without application of

mind and without the due procedure that is to be

followed as per the DMC Act and as such it is liable to

be quashed.

C. Because the impugned notices have been passed in

complete violation of principles of natural justice. It is

submitted that the no demolition notice or order has

been served on the Appellant and thus there was no

occasion for the appellant to respond to the same and

hence the vacation notices to carry out demolition and

sealing of the property in question is bad in law and

liable to be quashed.
D. Because the Appellant has already placed on record

relevant material to show that the property in question

was constructed in the year 2000 and that there has been

no alteration which the structure and as such being an

old construction and as such there is no alleged illegal/

unauthorized constructions existing on the property in

question.

E. Because the impugned order/ notice is in complete

violation of the protection/ right of the appellant as has

been given under “The National Capital Territory Of

Delhi Laws (Special Provision) Second (Amendment)

Act, 2014” which is in operation and remain in operation

till 31.12.2020.

F. Because the alleged action of the Respondent is an

afterthought and has been done so with the intention to

extort money from the Appellant.

G. Because the no show cause notice for the alleged

violation of Section 346 of the Act was ever served upon

the Appellant and hence in the absence of the same the

 Appellant cannot be held to be guilty of the alleged

violation.

H. Because the alleged notices have been issued by the

Respondent without actual verification or inspection of

the premises and the fact that neither any details of the

alleged unauthorized construction has been given nor the

fact that what construction is being carried on by the

Appellant which needs to be stopped. It is pertinent to

mention that there is no construction material on the site

to even suggest contrary.

I. Because a bare perusal of the notices will reveal that the

Respondent have failed to disclose as to how they have

established the factum of unauthorized construction

which amounts to being judge of its own cause which is

not permissible in law.

J. Because the appellant has not carried out any alleged

unauthorized construction as has been alleged by the

respondent in the impugned order/ notice and thus the

impugned order/ notice is unwarranted and uncalled for.

9. VALUE FOR THE SUBJECT MATTER:

The value of the subject matter of appeal is fixed as

provided under the Provisions of Municipal Law. The

appellant has paid the same

RELIEF

It is, therefore, prayed that this Hon’ble Tribunal/Court may

graciously be pleased to:

A. Accept the present appeal and the impugned notices

dated 06.10.2017, 23.10.2017 in file

No.237/(B)/UC/SS/17 passed by the Junior Engineer

(Building), Shahdara South Zone and demolition order

dated 06.11.2017 passed by Area Junior Engineer

(Bldg), Shahdara South Zone in respect of 2 n d Floor of

13, Hargobimd Enclave, Delhi-110092be quashed/ set

aside in the interest of justice, fair play and equity;

B. Restrain the Respondent from demolishing or sealing

any portion of the 2 n d Floor of 13, Hargobimd Enclave,

Delhi-110092.

C. pass any other or further order(s) as may be deemed fit

and proper in the facts and circumstances of the case.

…APPELLANT

Through

R.K Sahni, Advocate

PLACE: DELHI
DATE:-16.01.2018
 BEFORE THE PRESIDING OFFICER, APPELLATE
TRIBUNAL MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA

… APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION ...

RESPONDENT

AFFIDAVIT

I, Ritu Soorma wife of Shri VirenderSoorma, aged 48 years,

resident of 2 n d Floor, 13 Hargobind Enclave, Delhi-110092 do
hereby solemnly affirm and state as under:

1. That I say that I am appellant in the accompanying appeal

and am well conversant with the facts, records and
circumstances of the case and I am competent to swear this
Affidavit.

2. That the contents of accompanying appeal have been drafted

by my counsel at my instructions and the same have been
read over to me which are true and correct to my own
knowledge. Same be read as part and parcel of this affidavit
which are not being repeated for sake of brevity.
 DEPONENT.
VERIFICATION :
Verified at Delhi on this 16 t h day of January, 2018 that
contents of above affidavit are true and correct to the best of my
knowledge. No part of it is false and nothing material has been
concealed therefrom.
DEPONENT
BEFORE THE PRESIDING OFFICER, APPELLATE
TRIBUNAL MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA

… APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

APPLICATION UNDER SECTION 343 (2) OF THE

D.M.C. ACT FOR STAY OF OPERATION AND
ENFORCEMENT OF NOTICES DATED06.11.2017

MOST RESPECTFULLY SHOWETH:

1. That the appellant has filed the accompanying appeal against

the impugned notices dated 06.11.2017the contents and

 grounds of which may kindly be read as part and parcel to

this application and the same are not repeated here for the

sake of brevity.

2. That the perusal of the appeal would show that the appellant

has a prima facie case in his favour and there is every

likelihood of accepting the appeal as prayed for.

3. That the appellant submits that the balance of convenience

also lies in favour of the appellants and against the

respondent.

4. That the neither demolition notice nor order has been served

upon the Appellant and the vacation notices were never

served upon the Appellants and the same came to the

knowledge of the appellant only on 15.1.2018 when the

owner of the ground floor handed over bunch of photocopied

notices and the the appellant was shocked and surprised to

see them as they were neither communicated nor served on

the appellant. The respondent have threatened to carry out

further demolition anytime.

5. That the appellant being the occupant of the property in

question has a substantial right to protect his property

against the illegal action of the respondent and if the

respondent causes damage to the property in question, the

appellant shall suffer irreparable loss. On the contrary, no

prejudice will be caused to the respondent if the operation of

the impugned order is stayed.

6. That the Hon’ble Tribunal has been vested with the statutory

powers to stay the enforcement of the demolition order.

PRAYER

It is therefore most respectfully prayed that this Hon’ble

Court may under the facts and circumstances be pleased to:

a. stay the operation of the impugned notices dated

06.10.2017, 23.10.2017 and 06.11.2017.

b. pass any other order as this Hon’ble Court may deem fit

and proper.

…APPELLANT
 Through

R.K Sahni, Advocate

PLACE: DELHI
DATE:-16.01.2018
BEFORE THE PRESIDING OFFICER, APPELLATE
TRIBUNAL MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA

… APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

AFFIDAVIT

I, Ritu Soorma wife of Shri VirenderSoorma, aged 48 years,

resident of 2 n d Floor, 13 Hargobind Enclave, Delhi-110092 do
hereby solemnly affirm and state as under:

1. That I say that I am appellant in the accompanying appeal

and am well conversant with the facts, records and
circumstances of the case and I am competent to swear this
Affidavit.

2. That the contents of accompanying appeal have been drafted

by my counsel at my instructions and the same have been
read over to me which are true and correct to my own
knowledge. Same be read as part and parcel of this affidavit
which are not being repeated for sake of brevity.
 DEPONENT.
VERIFICATION :

Verified at Delhi on this 16 t h day of January, 2018 that

contents of above affidavit are true and correct to the best of my
knowledge. No part of it is false and nothing material has been
concealed therefrom.

DEPONENT
 BEFORE THE PRESIDING OFFICER, APPELLATE
TRIBUNAL MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA … APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

AFFIDAVIT

I, Ritu Soorma wife of Shri VirenderSoorma, aged 48 years,

resident of 2 n d Floor, 13 Hargobind Enclave, Delhi-110092 do
hereby solemnly affirm and state as under:

1. That the property in question measurement of construction

on each floor is as under:

Second Floor: 59.09 Sqm. (636.03 Sq. Ft.)

Third Floor: 46.72 Sqm. (502.88 Sq Ft.)

Terrace Floor: 24.16 Sqm. (260 Sq Ft.)

2. That the construction that exists at the property in question

is old construction and was done way back in 1993, since

 then there has not been any structural alteration in the

property and the property tax returns also conform with the

same.

3. That there does not exist any unauthorized construction as is

alleged.

DEPONENT.
VERIFICATION :

Verified at Delhi on this ___ day of January, 2018 that

contents of above affidavit are true and correct to the best of my
knowledge. No part of it is false and nothing material has been
concealed therefrom.

DEPONENT
 BEFORE THE PRESIDING OFFICER, APPELLATE
TRIBUNAL MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA … APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

APPLICATION UNDER SECTION 151 CPC

SEEKING EXEPTION FROM FILING OF THE
ORIGINAL/ CETIFIED COPY OF THE
ANNEXURES

MOST RESPECTFULLY SHOWETH:

1. That the appellant has filed the accompanying appeal against

the impugned notices dated 01.10.2017, 23.10.2017 and
06.11.2017 the contents and grounds of which may kindly be
read as part and parcel to this application and the same are
not repeated here for the sake of brevity.

2. That the appellant has filed true copy of documents/ order.

Certified copy of the same are not available with the

 appellant and the appellant undertakes to file the same on

record as and when made available.

PRAYER

It is therefore most respectfully prayed that this Hon’ble

Court may under the facts and circumstances be pleased to:

a. exempt the appellant from filing the certified/ original of the

annexures and permit him to files the copies;

b. pass any other order as this Hon’ble Court may deem fit and
proper.

…APPELLANT

THROUGH

R.K Sahni, Advocate

PLACE: DELHI
DATE:-16.01.018
 BEFORE THE PRESIDING OFFICER, APPELLATE
TRIBUNAL MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA … APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

AFFIDAVIT

I, Ritu Soorma wife of Shri VirenderSoorma, aged 48 years,

resident of 2 n d Floor, 13 Hargobind Enclave, Delhi-110092 do
hereby solemnly affirm and state as under:

1. That I say that I am appellant in the accompanying appeal

and am well conversant with the facts, records and
circumstances of the case and I am competent to swear this
Affidavit.

2. That the contents of accompanying application have been

drafted by my counsel at my instructions and the same have
been read over to me which are true and correct to my own
knowledge. Same be read as part and parcel of this affidavit
which are not being repeated for sake of brevity.
 DEPONENT.
VERIFICATION :

Verified at Delhi on this 16 t h day of January, 2018 that

contents of above affidavit are true and correct to the best of my
knowledge. No part of it is false and nothing material has been
concealed therefrom.
DEPONENT
 BEFORE THE PRESIDING OFFICER, APPELLATE
TRIBUNAL MUNICIPAL CORPORATION OF DELHI

APPEAL NO.______ ATMCD OF 2018

IN THE MATTER OF:

SMT. RITU SOORMA … APPELLANT

VERSUS

EAST DELHI MUNICIPAL CORPORATION

... RESPONDENT

AFFIDAVIT

I, Ritu Soorma wife of Shri VirenderSoorma, aged 48 years,

resident of 2 n d Floor, 13 Hargobind Enclave, Delhi-110092 do
hereby solemnly affirm and state as under:

1. That I say that I am appellant in the accompanying appeal

and am well conversant with the facts, records and
circumstances of the case and I am competent to swear this
Affidavit.

2. That the contents of accompanying application have been

drafted by my counsel at my instructions and the same have
been read over to me which are true and correct to my own
knowledge. Same be read as part and parcel of this affidavit
which are not being repeated for sake of brevity.
 DEPONENT.
VERIFICATION :

Verified at Delhi on this 16 t h day of January, 2018 that

contents of above affidavit are true and correct to the best of my
knowledge. No part of it is false and nothing material has been
concealed therefrom.
DEPONENT