IN THE COURT OF HON,BLE SENIOR CIVIL JUDGE,
NORTH DISTRICT, ROHINI COURT, DELHI
CIVIL SUIT NO. ............... 2024
SH. RAM KISHORE MANN
THROUGH ATTORNEY
SH. BHUPINDER SINGH MANN PLAINTIFF
VERSUS
SH. AJAY MANN & ANRS. DEFANDANTS
WRITTEN REPLY ON BEHALF THE DEFENDANTS TO THE SUIT FOR
PERMANENT INJUNCTION FILED BY THE PLAINTIFF
MOST RESPECTFULLY SHOWTH:
1. That the contents of para no.1 of the plaint are wrong and
denied. The defendants state that suit property is ancestral land,
lawfully owned and possessed by the defendants's family for
generations. The plaintiff's claim of ownership is false and without
basis. The defendants have legal records, including mutation
entries, in their favour that confirm their ownership.
2. The defendants deny the allegations in para no. 2 of the plaint. It
is submitted that the land was inherited from the defendants'
forefathers, and the Godavari records clearly the defendants as
the rightful owners. The plaintiff's claim of possession is baseless
and intended to interefere with the defendants' peaceful
ownership.
3. That the contents of para no. 3 of the plaint are incorrect and
denied by defendants. The land has always been in the lawful
possession of the defendants, who have continuously cultivated it.
The plaintiff has no legal right to claim possession of the land or
any cultivation activities on it.
4. The statements in para no. 4 are strongly refuted by defendants.
The defendants state that the land was developed and cultivated
by their family. The plaintiff's allegations about cultivation and
establishment of guava orchads are false. The defendants and
their ancestors have been responsible for all agricultural activities
on this land, as recorded in the mutation and Godavari records.
5. The defendants categorically deny the claims in para no. 5. The
plaintiff has ownership or legal rights to the suit property and has
attempted to interfere with defendants's peaceful possession. The
defendants also refute the plaintitff's claim of approaching the
police, as there is no official complaint on recpord
6. The allegations of para no.6 of the plaint are wrong and denied by
the defendant. The plaintiff's claims of incidents on 09/06/2024
and threats by the defendants is baseless. The defendants state
that they have always peacefully cultivated and possessed the
land. Any suggestion of forceful possession by the defendants is
false.
7. The defendands deny the statements in para no. 7. The plaintiff
has attempted to disrupt the defendants' peaceful enjoyment of
the land on several occasions. The defendands, being lawful
owners,have merely defended their right against the plaintiff's
unlawful attempts to encroach.
8. That contents of para no.8 of the plaint are wrong and denied by
the defendants. The defendands maintain that the plaintiff has no
legal ownership or title to the land. the The plaintiff's claim that
the land belongs to him is unsubstantiated and contrary to the
legal documents, inclunding the Godavari record, that confirm the
defendants' ownership.
9. The defendants deny the contents of para no 9 of the plaint. The
plaintiff's claim of issuing legal notices is irrelevant, as the land is
ancestral property lawfully held by the defendants. Any notices or
demands by no legal validity.
10. T
he statements in para 10. are strongly refuted by the defendants.
The defendants contend that the plaintiff has no right to challenge
their ownership. the plaintiff's assertions regarding ownership
laws are misplaced, as the land's legal records favor the defedants.
11. t
he defendants refute the statements made in para no 11. The
Godavari and mutation records clearly demonstrate that the
defendants' family has maintained continuous ownership and
possession of the land. The plaintiff's claims are an attempt to
disrupt this lawful ownership.
12. T
he contents of para 12 are denied .The defendants argue that the
plaintiff's suit is filed with malicious intent the lacks legal basis.
The defendants request the court to dismiss the plaintiff's suit as it
seeks to interfere with the defendants' lawful and ancestral rights.
13.
The allegation in para no 13. are deny by the defendants. The
plaintiff has no cause of action to file the present suit. The
defendants' ownership is well-documented, and plaintiff's
repeated attempts to interfere are unlawfull and harassing.
prayer:
In light of the above, the defendants respectfully request that this
hon'ble court :
14. D
ismiss the plaintiff's suit for permanent injunction.
15. C
onfirm the defendants' lawful ownership and continuous
possession of the suit property as per the ancestral, mutation, and
Godavari records.
16. R
estrain the plaintiff from further interfering with the defendants's
peaceful possession and cultivation of the property.
