Anshita Drafting and Pleading

CIVIL PLEADINGS
EXERCISE-1 PLAINT
PLAINT
IN THE COURT OF THE III ADDITIONAL JUNIOR CIVIL

JUDGE :
CITY CIVIL COURT : AT VARANASI.
O.S. No……………of 2016
Mr.Kushal Kumar,
S/o Sunder Lal, Aged 45 years,
Occ: BUSSINESS
R/o. D.No. 161, Ramiya Road,
Varanasi ………………………..Plaintiff
Vs.
Mr.Deepak,
S/o Raju, Aged 47 Years,
Occ: Employee
R/o.D.No211,RamiyaRoad,
Varanasi. ……………………..…Defendant
PLAINT FILED UNDER SECTION 26 READ WITH ORDER VII

OF CPC
I) DESCRIPTION OF THE PLAINTIFFS:
The address for service of all notices and summons of process to the above
named plaintiff is that of his Counsel Mr. Kishori Lal, Varanasi.
DRAFTING PLEADING AND CONVEYANCE Page 1

II) DESCRIPTION OF THE DEFENDANTS:
The address for service of all summons, notices and process on the
defendants is as stated above in ‘Cause Title’.
III. BRIEF FACTS OF THE CASE:

1. It is submitted that the Defendant having an acquaintance with the
plaintiff approached him and requested to advance a hand loan
of Rs.45,000/- (Rupees Forty five thousand only) to meet his son’s
education needs. The Defendant also proposed to execute a Promissory
Note for the said amount and with a simple interest @ 10% p.a. Due to
that acquaintance, the Plaintiff agreed for the same and thus, the defendant
has borrowed a sum of Rs.45,000/- as hand loan on 1st January, 2017 from
the Plaintiff at the Plaintiff’s home situated at Varanasi and executed a
Promissory Note for the said amount in favor of the Plaintiff and promised
to repay the said hand loan within a period of 2 years from the date of
execution of the promissory note. It is respectfully submitted that in spite
of repeated oral demands made by the Plaintiff, the Defendant did not
bother to repay the said hand Loan amount.
2. The Plaintiff having vexed with the conduct of the Defendant avoiding
the repayment, got issued a legal notice to the Defendant on 1st January,
2017 through his Counsel by way of Regd Post with Ack. Due as well as
UCP, to his Residence. The Defendant received the same on 25th January
2019, neither paid the amount nor did he respond to the notice. On 10th
February, 2019. Kushal Kumar filed a suit for the recovery of the debt but
did not reply.
3.The Plaintiff submits that the Defendant having borrowed the amount of
Rs.45,000/- (Rupees Forty Five Thousand only) as hand loan and having
executed the promissory not is bound to repay the same to the Plaintiff
who is entitled for interest on the suit amount from the date of demand i.e.

1st January, 2016 till realization @ 10% p.a. As the Defendant is avoiding
payment, the Plaintiff has left with no option except to approach this
Hon’ble Court by way of this suit. In view of the above said facts, the
Plaintiff is entitled to sue the defendant.
4.The Plaintiff submits that The Defendant is liable to pay the following
outstanding amount:
(i) Promissory Note Amount : 45,000.00

(ii) Interest on 45,000 @ 10% p.a. From
01.01.2008 as on date filing of the suit : 9,000.00
---------------
54,000.00
----------------
Therefore, the Defendant has to pay a total sum of Rs.54,000/- (Rupees
Fifty Four Thousands Only) to the Plaintiff as on the date of filing of the
present suit. Hence, this suit.
IV. CAUSE OF ACTION : The cause of action for the suit arose on
01.01.2017 when the Defendant borrowed the amount and executed pro-
note and on 01.01.2019 when the Plaintiff got issued a legal notice to
Defendant calling upon defendant to repay the amount and still subsists.
V. VALUATION: The relief of recovery of money is paid thereon and the

same is sufficient.
VI. JURISDICTION: The Plaintiff is residing at VARANASI and the

Defendant borrowed the said loan amount from the Plaintiff at the
residence of the Plaintiff and hence this Hon’ble Court is having territorial
& pecuniary Jurisdictions to entertain the present suit.

VII. DECLARATION : The Plaintiff has not filed any suit against the
Defendant and no suit is pending between the parties in respect of the
relief being claimed in this suit.
VIII. LIMITATION : The Defendant borrowed the said hand loan amount
on 01.01.2017 and the legal notice issued to the Defendant on 01.01.2019
and therefore the present suit is within the limitation.
IX. PRAYER :
It is therefore, prayed that the hon’ble court may be pleaded to pass a

judgement or decree against the defendant and in favor of the plaintiff
(a) To direct the Defendant to pay a sum of Rs. 54,000/- together with
future interest thereon, from the date of this suit, till the date of realization
of the entire suit claim
(b)To award the costs of this suit;
and to pass such other order or orders as this Hon’ble Court may deem fit
and proper in the circumstances of the case in the interest of Justice.
PLACE: PLAINTIFF
.……………….
DATE: COUNSEL FOR THE PLAINTIFF
………………………………

VERIFICATION
I, Mr. Kushal Kumar, S/o. Sunder Lal, Age 45 years, Occ: Business, R/o.
D.No. 161, Ramiya Road, Varanasi do hereby declare that the contents of
Para III are true and correct to the best of our knowledge and believed to
be true and correct, and the rest of the paras are on the basis of information
and legal advice and verified and signed by me on 10th February 2019 at
the Court of the Additional Junior Civil Judge: City Civil Court
Compounded at Varanasi.
PLACE: PLAINTIF
……………..
DATE: PLEADER
……………..
LIST OF DOCUMENTS FILED BY PLAINTIFFS
S.NO. DATES PARTIES DESCRIPTION P.NO.

1. 01.01.2017 Defendant & Promissory Note in
Plaintiff Original
2. 01.01.2019 Defendant & Office Copy of the
Plaintiff Legal Notice
3. 01.01.2019 Defendant & Proof of sending Legal
Plaintiff Notice and
Acknowledgements in
receipt of the Notice
served on the
Defendant.

PLAINTIFF
……………..
AFFIDAVIT
IN THE COURT OF ADDITIONAL JUNIOR CIVIL JUDGE: CITY

CIVIL COURT AT VARANASI
SUIT NO…………………..…....of Year 2019
IN THE MATTER OF
KUSHAL KUMAR
Vs.
DEEPAK
SUIT FOR RECOVERY OF MONEY
AFFIDAVIT ON BEHALF OF PLAINTIFF
I, Kushal Kumar, S/o Sunder Lal, Aged 45 years, Occ: Business R/o.
D.No. 161, Ramiya Road, VARANASI at present residing at this given
address, do hereby solemnly declare and affirm on oath as under:

the Plaintiff at the Plaintiff’s home situated at VARANASI and executed a

2.The Plaintiff having vexed with the conduct of the Defendant avoiding
did not reply.
executed the promissory note is bound to repay the same to the Plaintiff
I, do hereby affirm that the contents of para 1,2,3 are correct to my

knowledge and belief. Nothing has been concealed therein.
PLACE: DEPONENT
DATE: ……………………
WRITTEN STATEMENT
Written statement is the defense of the defendants. A defense called the

written statement ,in general this is a reply of plaint ,in which defendant
deny or admit the each and every allegation or facts given in the plaint.

Denial or admission must be Para wise and clear. In the written statement
defendant can put his case also under the heading additional plea, and can
states new facts or ground which is necessary to defeat the opponent. If
defendant wants to put his own claim against the plaintiff he can put it by
way of set- off and counterclaim u/o 8 Rule 6 and 6A of C.P.C.
Order VIII provides for the filing of a written- statement, the particulars to
be contained therein and the manner of doing so. It requires what a written
statement should contain. Before drafting the written statement it is the
duty of the defendant to study the plaint thoroughly and all the documents
submitted by the plaintiff with the plaint in support of his claim. After the
thorough study of the plaint and supported documents a Para wise answer
of the plaint can be prepared. Order VIII of the Code of Civil Procedure
deals with the written statement set off and counter claim. The defendant
shall, within thirty days from the date of service of summons on him,
present a written statement of his defense:
Provided that where the defendant fails to file the written statement within
the said period of thirty days, he shall be allowed to file the same on such
other day, as may be specified by the Court, for reasons to be recorded in
writing, but which shall not be later than ninety days from the date of
service of summons.
Three things are clear. Firstly, a careful reading of the language in which
Order VIII, Rule 1 has been drafted, shows that it casts an obligation on
the defendant to file the written statement within 30 days from the date of
service of summons on him and within the extended time falling within 90
days. The provision does not deal with the power of the Court and also
does not specifically take away the power of the Court to take the written
statement on record though filed beyond the time as provided for.
Secondly, the nature of the provision contained in Order VIII, Rule 1 is

procedural. It is not a part of the substantive law.

Thirdly, the object behind substituting Order VIII, Rule 1 in the present
shape is to curb the mischief of unscrupulous defendants adopting dilatory
tactics, delaying the disposal of cases much to the chagrin of the plaintiffs
and petitioners approaching the Court for quick relief and also to the
serious inconvenience of the Court faced with frequent prayers for
adjournments. The object is to expedite the hearing and not to scuttle the
same. The process of justice may be speeded up and hurried but the
fairness which is a basic element of justice cannot be permitted to be
buried.

IN THE COURT OF THE III ADDITIONAL JUNIOR CIVIL
JUDGE :
CITY CIVIL COURT : AT VARANASI.
O.S. No. of 2019
Mr.Kushal Kumar,
Occ: Local Shopkeeper
R/o. D.No. 277,Ramiya Road,
VARANASI ………………………..Plaintiff
Vs.
Mr.Deepak,
Occ: Worker
R/o. D.No.161 , Ramiya Road, Varanasi. ……………..…Defendant
WRITTEN STATEMENT FILED BY THE DEFENDANT

UNDER ORDER VIII, RL.1, C.P.C.
1) It is submitted that the defendant has gone through the averments made
in the plaint and affidavit filed in support of the plaint. The averments,
which are not specifically admitted, are denied. The Plaintiff is put to strict
proof of the same. Most of the averments are not correct and false and the
suit is not maintainable.
2) In reply to Para III (1) of the plaint, it is submitted that I have no

acquaintance with the plaintiff and did not approach at any point of time
for hand loan to meet my son’s education and executed promissory note in
favor of the plaintiff. I have sufficient means to support my family. Hence,

there is no question of taking hand loan from the plaintiff and execution of
promissory note in favor of the plaintiff.
3) In reply to para III (2) of the plaint, it is submitted that the notice issued
by the plaintiff was received by me on 15.01.2019. The contents of the
notice are vague and false. Since I did not approach the plaintiff for any
hand loan and executed promissory note, I did not choose to reply the
notice. Hence, the allegations in the notice are denied.
4) In reply to para III (3) of the plaint, it is submitted that I did not borrow
any amount from the plaintiff and executed promissory note in favor of
him. The allegation of the plaintiff is false and I need not bound to pay any
amount to the plaintiff. It is not correct to say that I have borrowed a sum
of Rs.45,000/- from the plaintiff and executed a promissory note in favor
of him.
5) In reply to Para III (4) of the plaint, it is submitted that since there is no
amount is borrowed from the plaintiff and executed pro-note, the figures
of outstanding stated in para therein is false and fabricated one.
6) It is submitted that I have never approached the plaintiff for any amount
said to have been borrowed by me and executed pro-note. Since we reside
in the same street and due to rivalry between our two families regarding
some disputes relating to colony problems, the plaintiff has fabricated the
pro-note and filed the present suit alleging that I have borrowed a sum of
Rs.45,000/- from plaintiff and executed a pro-note.
The plaintiff is trying to mislead this Hon’ble Court and made false
allegations in the plaint.
7) The other allegations of the plaint which are not specifically admitted
herein are denied. The plaintiff is put to strict proof of the same.

Hence, it is prayed that this Hon’ble Court may be pleased to dismiss the
suit with costs.
PLACE: DEFENDANT
DATE: ………………………..
COUNSEL FOR THE DEFENDANT
………………………………………...
Verification
I, Deepak, S/o Raju, Aged 47 Years, Occ: Worker, R/o. D. No. 161,
Ramiya Road, VARANASI, Occ: Employee, do hereby declare that the
facts stated in paras 1 to 7 are true and correct to the best of my
knowledge, information and belief and I believe the same to be true and
correct. Hence, verified on this the day of June, 2019 at VARANASI.
PLACE: DEFENDANT
………………………..
COUNSEL FOR THDEFENDENT

DATE: ……………………………

AFFIDAVIT
IN THE COURT OF ADDITIONAL JUNIOR CIVIL JUDGE: CITY
CIVIL COURT AT VARANASI
SUIT NO…………………..…....of Year 2019
IN THE MATTER OF KUSHAL KUMAR

Vs.
DEEPAK
SUIT FOR RECOVERY OF MONEY
I, Mr.Deepak S/o Raju, Aged 47 Years,Occ: Employee, R/o. D.No. 161 ,

Ramiya Road, VARANASI at present residing at this given address, do
hereby solemnly declare and affirm on oath as under:
1) It is submitted that the defendant has gone through the averments made
in the plaint and affidavit filed in support of the plaint. The averments,
which are not specifically admitted, are denied. The Plaintiff is put to strict
proof of the same. Most of the averments are not correct and false and the
suit is not maintainable.
2) In reply to Para III (1) of the plaint, it is submitted that I have no

acquaintance with the plaintiff and did not approach at any point of time
for hand loan to meet my son’s education and executed promissory note in
favor of the plaintiff. I have sufficient means to support my family. Hence,
there is no question of taking hand loan from the plaintiff and execution of
promissory note in favor of the plaintiff.
3) In reply to para III (2) of the plaint, it is submitted that the notice issued
by the plaintiff was received by me on 15.01.2019. The contents of the
notice are vague and false. Since I did not approach the plaintiff for any

hand loan and executed promissory note, I did not choose to reply the
notice. Hence, the allegations in the notice are denied.
4) In reply to para III (3) of the plaint, it is submitted that I did not borrow
any amount from the plaintiff and executed promissory note in favor of
him. The allegation of the plaintiff is false and I need not bound to pay any
amount to the plaintiff. It is not correct to say that I have borrowed a sum
of Rs.45,000/- from the plaintiff and executed a promissory note in favor
of him.
5) In reply to Para III (4) of the plaint, it is submitted that since there is no
amount is borrowed from the plaintiff and executed pro-note, the figures
of outstanding stated in para therein is false and fabricated one.
6) It is submitted that I have never approached the plaintiff for any

amount said to have been borrowed by me and executed pro-note. Since
we reside in the same street and due to rivalry between our two families
regarding some disputes relating to colony problems, the plaintiff has
fabricated the pro-note and filed the present suit alleging that I have
borrowed a sum of Rs.45,000/- from plaintiff and executed a pro-note. The
plaintiff is trying to mislead this Hon’ble Court and made false allegations
in the plaint.
7) The other allegations of the plaint which are not specifically admitted
herein are denied. The plaintiff is put to strict proof of the same.
Hence, it is prayed that this Hon’ble Court may be pleased to dismiss the
suit with costs.
I, do hereby affirm that the contents of para 1,2,3,4,5,6,7 are correct to my
PLACE: DEPONENT
DATE: ………………

EXERCISE-2
INTERLOCUTORY APPLICATION
IN THE COURT OF JUNIOR CIVIL JUDGE, KANPUR
I.A. No. of 2017 O.S. No. of 2017
Mr.Kushal Kumar,
Occ: Local Shopkeeper
R/o. D.No. 247, Netaji Road, Kanpur ……………….Plaintiff
Vs.
Mr.Deepak,
Occ: Worker
R/o. D.No. 249, Netaji Road,Kanpur ……………………..…Defendant
Application filed on behalf of the plaintiff under 0rder XXX VII Rule
5 of C.PC.
Respected Sir/Madam,
The Applicant humbly states as under:


the Plaintiff at the Plaintiff’s home situated at KANPUR and executed a
2. The Plaintiff having vexed with the conduct of the Defendant avoiding
did not reply.
4. Not only this, it is prayed that, the Hon’ble court may be pleased to
direct that the property described in the schedule below be attached before
judgement passing such further or other orders as circumstances of the
case.
SCHEDULE

5. In Vaishali District, Sri Taiji Registration District, Vaishali sub district
Vaishali town within Vaishali Municipality in ward No. 8, Town Survey
[T.S.] No: 1447, where in D.No. 161, Bazaar Street a house with R.C.C.
Roof with all doors, door frames, all fittings are with electric service
connection measuring 35 feet east, west and 20 feet north, south and
bounded on the east by the house of T. Rama Lakshmi on the south by
Nalinibhai lane on the west by the house of Bazaar Street.
PLACE:
APPLICANT
DATE: ……………………
COUNSEL FOR APPLICANT
………………………………..
AFFIDAVIT
IN THE COURT OF JUNIOR CIVIL JUDGE, Vaishali
I.A. No. of 2017 O.S. No. of 2017
Mr.Kushal Kumar,
Occ: Bussiness
R/o. D.No. 161, Ranjhana Road,
Vaishali ………………………..Plaintiff
Vs.
Mr.Dhanush,
S/o Rajnikant, Aged 47 Years,
Occ: Worker

R/o. D.No. 242, Ranjhana Road, Vaishali …………..…Defendant
APPLICATION FOR ATTACHMENT OF PROPERTY

I, Kundan Kumar, S/o Sunder Kumar, Aged 45 years,Occ: Local

Shopkeeper, R/o. D.No. 161, Ranjhana Road, Vaishali at present residing
at this given address, do hereby solemnly declare and affirm on oath as
under:

of Rs.45,000/- (Rupees Forty five thousand Rupees only) to meet his son’s
the Plaintiff at the Plaintiff’s home situated at VARANASI and executed a
2.The Plaintiff having vexed with the conduct of the Defendant avoiding

did not reply.
4. Not only this, it is prayed that, the Hon’ble court may be pleased to
direct that the property described in the schedule below be attached before
judgement passing such further or other orders as circumstances of the
case.
SCHEDULE
5. In Vaishali District, Sri Paji Registration District, Vaishali sub district
Muzaffarpur town within Vaishali Municipality in ward No. 7, Town
Survey [T.S.] No: 1337, where in D.No. 161, Ramjhana a house with
R.C.C. Roof with all doors, door frames, all fittings are with electric
service connection measuring 45 feet east, west and 20 feet north, south
and bounded on the east by the house of T. Ram Lak on the south by Nalin
bhai lane on the west by the house of Ranjhana Street.
I, do hereby affirm that the contents of para 1,2,3,4,5 are correct to my

PLACE: DEPONENT
…………………..
DATE:

EXERCISE-3
ORIGINAL PETITION
In the Family Court Judge, Jaipur

MARRIAGE O.P. No. 17/2017
Smt.Sia, Aged 35 years,

R/o. D.No. 222, MG Road,
Jaipur ………………………..Plaintiff
Vs.
Mr.SK Gupta
Occ: Doctor
R/o. D.No. 223, MG Road,
Jaipur ……………………..…Defendant
Petition filed on behalf of the petitioner under section 10 Hindu

Marriage Act.
Name of the Petitioner:
Smt. Sia, W/o S. SK Singh, Hindu aged about 30 years house wife
residing at 20-3-93, Brahmin Street, Jaipur.
The address of the petitioner for the service of notice etc. is as stated
above and also care of her counsel. Smt. MN Singh, Advocate, Jaipur.
Name of the Respondent: S. SK Gupta, S/o. Raja Reddy, Hindu aged

about 32 years, Doctor by Profession, residing at, G.S. Mada Street,
Jaipur.
The address of the respondent for the service of notices etc. is as stated.

1.The petitioner submits that she is legally married wife of the respondent.
This marriage was celebrated in the year 2010 at Jaipur. At the time of
marriage the petitioner‟s parent‟s gave 15 thulas of gold and Rs.
3,00,000/- in cash as dowry to the respondent. The marriage was
consummated immediately.
2.The petitioner submits that, she is the legally married wife of the
respondent. Their submits that respondent has started his nursing home at
Reddy & Reddy colony and gained good reputation and were happy for 4
years i.e., since 2014 his life started to have ups and downs.
3.The petitioner submits that the respondent slowly cultivated the bad
habits and became share to alcohol and used to have ephedrine etc. So
have slowly began to lose his sexual potency and attach become a total
impotent. When he has been taken to Max Hospital, Jaipur, the doctors
have concluded that he lost his potency because of excessive narcotic
drugs and alcohol. The respondent became frustrated in his life. He gave
up his practice slowly the petitioner sold her jewels to maintain the family.
Her parents also helped to some extent.
4. The petitioner submits that because of inferiority complex the

respondent started to suspect the character of the petitioner. He used to
abuse her with vulgar and filthy words that, she had illegal connections
with others. He used to abuse her even, if beggar stands in front of the
house, as the beggar is awaiting for her. She tolerate all these mental
torture added to this the respondent used to put cigarettes on her breast
thighs and other private parts and burn them. He enjoys her screaming’s.
Sometimes he gaged her mouth with cloth and subjects her to physical
cruelty.
5. The petitioner further submits that on 10.02.2014 he made her naked

put the blade on her left breast and applied chillies powder on the wound
she cried loudly apprehending danger and her neighbor and her mother-in-
law came there and saved her from the clutches of the respondent than on

11.02.2014 she came away to her parents house. She apprehends danger to
her parents house also. She apprehends danger to her life in the hands of
the respondent and it is impossible for her to live with such sadistic
husband. Hence the petition for Judicial separation Filed.
6.The cause of action for this petition for Judicial Separation arose on
01.02.2016 the date of marriage and also 10.02.2014 when she frightened
of her life ran away to her parents house continues de divindum with the
jurisdiction of this hounourable court.
7. The value of the petition for the purpose of court fee is of Rs……. Net
and fixed court fee of Rs. 10/- paid V/Sec of A.P.C.F. & S.V. Act.
8.The petitioner submits that no similar petitioner has been filled so far
before any court.
Prayer
The petitioner therefore prays that the Hon’ble court may be pleased to
pass an order and decree.
(a) Declare that the marriage has been dissolved by judicial separation.
(b) Direct the respondent to pay cost of the petition. And pass such others
and further orders as it deem fit and proper in the circumstances of the
case.
PLACE: PETITIONER
…………………
DATE: ADVOCATE FOR PETITIONER
……………………………..

VERIFICATION
I, the petitioner do here by declare that the facts state above are true and
correct to the best of my knowledge and belief and signed this verification
on this the 25.02.2014 at Jaipur.
LIST OF DOCUMENTS
1) 01.02.2010 marriage invitation card.
2) Doctor prescription with wound certificate.
PLACE: PETITIONER
…………………
DATE Advocate for petitioner Petitioner
…………………………………..

EXERCISE-4
WRIT PETITION UNDER ARTICLE 226
WRIT OF HABEAS CORPUS UNDER ARTICLE 226
IN THE HIGH COURT OF JUDICATURE AT DELHI
WRIT PETITION NO. OF 2010
In the Matter of X
R/o 16/850, MG Colony,
District Delhi
A detenue at present in Tis Hazari Police Station.
And
In the Matter of Article 226 of the Indian Constitution and Article

22(2) of the Constitution
Y, S/o B aged about 38,
Occupation- Business
R/o B16/380; MG Colony, Delhi ………...Petitioner
Versus
a) State of Delhi
b) Deputy Superintendent of Police, Delhi
c) Station House Officer,Tis Hazari, Delhi ........Respondent

To,
The Honourable Chief Justice
And the other Judges of the
Honourable Court.
The petitioner named above humbly submits:
1. That the petitioner is the businessman carrying his business at

Sigra and he is a cousin of the above named detenue.
2. That the above named detenue on 03-03-2010 exchanged some hot

words with his neighbour Mr Z.
3. That on 4-03-2012 the police came and arrested the detenue at

abount12:30 PM on the assurance that after investigation the
detenue would be released.
4. That on 05-03-2009 at about 7:00pm when the petitioner went to

police for making inquiry about his brother, the police arrested
abused him and told to go back
5. That the detenue has neither been released nor produced before the
magistrate within 24 hrs after making the arrest.
6. That the violation of the provision of Article 22(2) of the

Constitution of India is made by above named respondent.
7. That the arrest made by the police in collusion with the detenue
neighbour Mr Z.
8. That the detenue is a loyal peaceful peace loving and law abiding
citizen and not connected in any way in criminal activity in his
whole life.

Prayer
In the light of aforesaid circumstances the petitioner humbly and

respectfully prays that your Lordships may graciously pleased:
1. That to order the detenue to be brought before the Hon'ble Court

for being dealt with according to law.
2. That to declare the detention illegal unjust, unfair, unconstitutional.
3. That to order the detenue be set at liberty.
Date: .............. Counsel for Petitioner.
Place:.............. XXXXX
Verification
I, ______, do hereby verify that the contents from Para 1 to 8 are correct
and true to the best of my knowledge and personal belief and no part of it
are false and nothing material has been concealed therein.
Date:
Place:
Petitioner

EXERCISE-5
MEMORANDUM OF APPEAL
IN THE HIGH COURT OF RAJASTHAN, JAIPUR

Civil Appeal No. ... / 2009
Under Section 96 of CPC, 1908.
Ram Kishore. s/o Bir Chandra.

123, A B Road, Jaipur, Rajasthan............................ Plaintiff/Appellant
Vs.
Manvendra. s/o Omprakash.
456, A B Road, Jaipur, Rajasthan .................Defendant/Respondent
Memorandum of Appeal
The aforementioned plaintiff-appellant appeals against the judgement and

decree of the Court of Civil Judge Class II, at Jaipur, passed in Original
Suit No 1234 of 2010 between Ram Kishore s/o Bir vs Manvendra s/o
Omprakash ., dated 10/10/2011.
TO,
The Hon’ble Chief Justice and Companion and other respected Judges of
the High Court,
The Appellant most respectfully submits that:
(1) That the orders passed by the Learned Lower Court are contrary to the
provisions of law and the principles of natural justice.
(2) That the findings arrived by the Learned Lower Court are not
supported by the evidence on record.

(3) That the Learned Lower Court committed an error in holding that the
house premises are not required by the plaintiff/appellant for his personal
bonafide occupation.
(4) That the copy of the Judgment and the Decree against which this
appeal has been preferred is attached alongwith.
(5) That the Learned Lower Court has having answered the first issue in
the negative decided the rest of the issues against the appellant, which
itself is improper and illegal.
(6) That the necessary court fee is paid herewith.
Prayer:
(7) That the appellant, therefore, prays that for the reasons stated above
and as may be argued at the time of hearing, the record and proceedings be
called for, this appeal be allowed, the orders under appeal be set aside and
quashed, and orders deemed just and proper be kindly passed. Further that
the cost of this petition be awarded in favor of plaintiff-appellant.
Any other order which may be deemed fit in the interest of the justice may
be passed in favor of the appellant.
PLACE: APPELLANT
………………..
DATE: ADVOCATE FOR THE APPELLANT
………………………………….

Verification
I, ______, do hereby verify that the contents from paras 1 to 5 are correct
and true to the best of my knowledge and personal belief and no part of it
is false and nothing material has been
concealed therein. Affirmed at Indore this 4th Day of September 2011.
PLACE: APPELLANT
………………..
DATE: ADVOCATE FOR THE APPELLANT
……………………………………….

EXERCISE-6-REVISION PETITION
APPLICATION FOR REVISION
SECTION 115, C.P.C
In the High Court of Judicature, Indore,

Civil Appeal No. ... / 2018
Under Section 96 of CPC, 1908.
Ram Kishore. s/o Bir.

123, A B Road, Jaipur, Rajasthan
......................................... Petitioner
Vs.
Manvendra s/o Omprakash.
456, A B Road, Jaipur, Rajasthan
.........................................
Defendant/Respondent
The petitioner above mentioned submits this
Petition for revision U/Sec 115, C.P.C. against the decree of the District
Judge at Chittoor dated 15.02.2011 reversing the decree of the Civil Judge
of Chittoor, dated the 25.07.2018, passed in Suit No: 315 of 1996 valued
At Rs.24,000/-.
To,
The Chief Justice or his/her companion of the High Court above stated,
The Petitioner above mentioned submits as follows that:
The revision application of the petitioner against order dated 25.07.2018 in

the court of Indore,District, between the parties stated above in which the

petitioner is the defendant preferred on the following amongst other
grounds of revision under the statement of the case in brief as follows:
(1) That the applicant was the plaintiff in the aforesaid suit which had
been brought U/Sec 9 of the specific Relief Act.
(2) That the suit was decreed by the Munsif, but the District Judge on
appeal has reversed the Munisifs decree.
(3) That U/ the law no appeal lay to the District Judge from the Munsifs
Decree, and the District Judge from therefore exercised a Jurisdiction
which was not vested in him by law.
PRAYER
Therefore, the applicant prays that this Hon’ble Court will call for the
record of the case and set aside the said decree of the District Judge and
restore that of the Munsif and award him cost in all courts.
Any other order which may be deemed fit in the interest of justice may be
passed in favor of the petitioner.
PLACE: PETITIONER
……………….
DATE COUNSEL/ADVOCATE
…………………………….

EXERCISE-8
Writ Petition under Article 32
IN THE HON’BLE SUPREME COURT OF INDIA, NEW DELHI
(Original Criminal Jurisdiction)
Writ Petition No__of 2016
Arjun aged about 56 s/o Ram Chandra,

R/o B16/380; MG Colony, Delhi……………………………..Petitioner;
Versus
1. Additional Secretary, Ministry of Finance,

Government of India.
2. The Superintendent, Jail Delhi
3. The State of Delhi………………………………….....Respondents.
PETITION FOR THE ISSUE OF WRIT OF HABEAS CORPUS

UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA
To
The Hon’ble the Chief Justice and his companion Judges of the Court
aforesaid, the humble petition of the above named Petitioner most
respectfully he weth:
1. That the petitioner is a resident of Delhi and he was living peacefully at

his residence at the place aforesaid.

2. That on 25.05.15 Respondent No. 1 made an order under Section 3 of
the Conservation of Foreign Exchange and Prevention of Smuggling
Activities Act, 1974 by which he directed that the Petitioner shall be
arrested and detained for a period of three months. A copy of the order is
annexed herewith as Annexure ‘‘A’’.
3. That the Petitioner was arrested the same day and was detained in Delhi
Jail. The grounds of detention were not supplied to the petitioner on that
day. The grounds were actually supplied on. A copy of the grounds
supplied is annexed herewith as Annexure ‘‘B’’.
4. That on 05.07.2015 the Petitioner submitted a representation against his

detention through Respondent No. 2 but the same was considered by the
Advisory Board after one month and was rejected on 07.10.2015.
5. That the grounds of detention supplied to the Petitioner were in English

which language the Petitioner does not know.
6. That the orders of detention of the Petitioner are illegal, improper and
without jurisdiction on the following:
GROUNDS
1. Because the Conservation of Foreign Exchange and Prevention of

Smuggling Activities Act, 1974, is unconstitutional and void as it is
beyond the legislative competence of Parliament.
2. Because the order has been passed by an officer not duly authorised.
3. Because the grounds were supplied after undue delay.

4. Because the grounds are in English which language the Petitioner does
not know and this has prevented him from making an effective
representation.
5. Because the grounds are irrelevant to the object of the Act.
6. Because the grounds are vague.
7. Because there was undue delay in the disposal of the representation

submitted by the petitioner. Wherefore it is respectfully prayed that this
Hon’ble Court may be pleased to issue a writ in the nature of Habeas
Corpus to the opposite parties quashing the order of detention and
directing that the Petitioner be set at liberty forthwith.
PLACE: PLAINTIFF
………………..
DATE:

CRIMINAL PLEADING
EXERCISE-9 CRIMINAL COMPLAINT
IN THE COURT OF THE JUDICIAL FIRST CLASS

MAGISTRATE, VARANASI, C.C.
NO. 13 OF 2012
Miss. Ranjana, D/o. Kamlesh, Hindu,

Student, aged about 21 year studying in III Year
Batch, B.Tech., V. Engg, College, Varanasi,
Residing at S. Women Hostel, Varanasi,
Permanent residing of 43/790, K.S. Road,
Rajampet, Kanpur District
Within jurisdiction of East Police Station, Varanasi…….Complainant
Vs.
Mr. J. S. Rai, S/o. N.P. Rai, Hindu,

aged about 26 years 4th Year, B.Tech
student, residing at Men‟s Hostel, S.. Engg. College,
permanent address 7/90, T. Nagar,
Rajampet, Kadapa District,
within Jurisdiction of East Police Station, Varanasi….…….. Accused.
COMPLAINT FILED ON BEHALF OF THE COMPLAINANT

U/Sec 200 Cr. P.C.
(1) The complaint submits that she is studying III Year B.Tech., in S.V.
Engineering College, Varanasi, she knew the accused well.

(2) The complaint submits that the accused had been behind her for last 6
months, but she never cared him. He wrote a love letter to her and she
admonished him, then one day he
pulled her upper Dupata in the class room and on her report he suspended
college for a month. This happened on 01.05.2012.
(3) The complainant submits that on 12.05.2012, she came to Varanasi

Bus Station along her friends Yogi, Anitha, Valli to bid farewell to the
hockey team of her college going to Visakhapatnam in Tirumala Express.
She came out of the station and went to the Bus Station at about 8.00 pm
along with her friends, she found the accused near auto stand.
(4) The complaint submits that, while she was bargaining auto the accused
came there and abused her that, she was responsible for his suspension
from the college, tried to grab her right hand. When she protested he
immediately stabbed on her left and right cheeks and also on her back with
his fists, she cried loudly and the auto rickshaw drivers and passengers
handed over him to police constable near the Bus Station. But he did not
take the accused to police station that it was a noncognizable offence.
Hence thus complaint was made directly.The complaint therefore prays

that the Hon’ble court may be pleased to take cognizance of the offence
U/sec 323 IPC and punish him according to law.
xxxxxxxx xxxxxx
Advocate for complainant Complainant

EXERCISE-10
CRIMINAL MISCELLENEOUS PETITION
In The Court of Second Addl. Judicial Magistrate,Kolkata

Criminal Misc. Petition No........2018
X, S/o Y aged 30 years,
Occupation- Business,
R/oTaramandal, Kolkata……..........Petitioner
Versus
Z, S/o A ages 35 years,
Occupation- Business,
R/o Nala Road, Kolkata……........Respondent
Petition filed on behalf of the Petitioner U/Sec 128 Cr. P.C
(1) The petitioner submits that he filed the above M.C. for grant of
separate maintenance on 31.12.2017 against the respondent seeking a sum
of Rs. 500 per month to be awarded.
(2) The Hon’ble Court, after due contest, by order dated 06.01.2018
granted maintenance to the petitioner directing the respondent to pay a
sum of Rs. 400 per month to the petitioner from 01.01.2018 and keep
praying in future.
(3) The petitioner submits that, the respondent has not paid any
maintenance so far, and these disobeyed the order of this Hon’ble court.
(4) The petitioner further submits that the arrears of maintenance from
01.01.2017 to 31.03.2018 to Rs. 6000/-

(5) It is therefore prayed that the Hon’ble court may be pleased to commit
the respondent to prison for such kind has the law required or till he paid
the arrears of maintenance.
Prayer
It is therefore must humbly prayed that in the light of aforesaid

circumstances the honble court may be pleased to adjudge hold and
declare
(1) That the petition is maintainable u/s128 of crpc.
(2) That to pass the order to pay the maintenance with arrears.
(3) That to pass any other order which the hon’ble court may think fit for
the end of justice.
PLACE: PLAINTIFF
………………..
DATE: ADVOCATE FOR THE PLAINTIFF
…………………………………….
VERIFICATON
I, the petitioner, to hereby declared that the facts stated above or true and
correct to the facts stated above or true and correct to the best of my
knowledge information and belief.
PLACE: PLAINTIFF
………………..
DATE: ADVOCATE FOR THE PLAINTIFF
…………………………………….

EXERCISE-11
BAIL PETITION
APPLICATION FOR BAIL
IN THE COURT OF THE FIRST CLASS MAGISTRATE,

CHANDRAGIRI
X …………………………………………….…… Petitioner
Versus
State ………………………………………………. Respondent
FIR no………
Date:
Police station:
PETITION FILED ON BEHALF OF THE PETITIONER ACCUSED

UNDER SEC. 409 OF IPC
Sir, Ma’am,
Applicant most humbly apply for his release on bail on

following reasons:
1. That the accused was arrested on 05.11.2011 by the Chandragiri

Police on a charge U/Sec 409 I.P.C. the main complaint against
him being that he being the V.A.O. of Peruru village and as such
being a public servant failed to maintain and show accounts for a
sum of Rs. 3,000/- to the Government Treasury.
2. That though offence is non-bailable taking into consideration the
fact that, the amount involved is only Rs. 3000/- it is highly
probable that there must be some honest mistake on the part of the
accused for no one would think of Misappropriating such a small
amount as Three Thousands.
3. That the accused is a respectable old man of 60 and is certainly not
going to abscond. Moreover his family is resident in the village for
over 40 years. His pensions and provident fund all came to more
than Rs. 7000/- and the missed amount will be compensate by the
accused soon. Due notice of this applications is given to the Police.
PRAYER
Therefore, it is most respectfully prayed that the said accused may be

granted bail and released from the policy custody where he is for the
last 45 days.
Date:
Place: Accused/
Council of Accused

EXERCISE-13
ANTICIPATORY BAIL
IN THE COURT OF DISTRICT AND SESSIONS JUDGE, AT

LUCKNOW
IN THE MATTER OF
STATE……………………………………………………….Petitioner
VS
X, S/O A, aged 55 years,
R/O B-30/441 Nagwa,
Lanka, Lucknow…………………………………………….Respondent
Police Station -- -- -- --
FIR NO. Yet to be filed
U/S Section 66A of ITA 2008 and other sections of IPC such as
295A,505,499
APPLICATION U/S 438 CRPC FOR GRANT OF ANTICIPATORY
BAIL ON BEHALF OF THE ACCUSED-- -- -- -- -- -- -- -- -- -- -- -- -- -- -

- -- -- .
The applicant most respectfully submits as follows:
1. That I, Sri X s/o A residing at B-30/441 Nagwa, Lanka, Lucknow have

posted the content as indicated in annexure to this application
2. That based on the precedents of the actions initiated by Police in

different parts of the country in recent days and more particularly in the
cases of Government of Delhi Vs DJ Ravi on the complaint made by one

S. Kartik and State of Bihar Vs Dadabhai on the complaint of on Jaikant
Sikre, there is a reasonable probability of a false and bogus case being
hoisted on me with mala fied intentions,
3. That I have no malicious intentions in making this post which I have

made as a free Citizen of India under the Freedom of Expression
guaranteed to me by the Constitution of India under article 19(1)
4. That the police may falsely implicate the applicant in any case, the
applicant is a respectable citizen of the society and is not involved any
criminal
5. That the postings does not constitute any criminal offence under any
law in India.
6. That the applicant is not required in any kind of investigation nor any
kind of custodial interrogation is required.
7. That the applicant is having very good antecedents, he belongs to good

family and there is no criminal case pending against them.
8. That the applicant is a permanent resident and there are no chances of

their absconding from the course of justice.
9. That the applicant undertakes to present himself before the court as and
when directed.
10. That the applicant undertakes to cooperate with the police during the
course of investigation.
11. That the applicant undertakes not to tamper with the evidence or the
witnesses in any manner. It is therefore prayed that the court may direct
that the applicant shall be released on bail in the event of their arrest by
the police.

Any other order which the court may deem fit and proper in the facts and
circumstances of the case may be also passed in favor of the applicant.
PLACE: APPLICANT
………………..
DATE: ADVOCATE FOR THE APPLICANT
……………………………………….

EXERCISE-14
CRIMINAL APPEAL
IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE AT

NAINITAL
MK SAH, residing at MALLROAD, NAINITAL………….. Appellant
Vs.
The State of UTTRAKHAND.…………………………. Respondent
CRIMINAL APPEAL NO: 101 OF 2010
For the following among grounds the Appellant here in begs to prefer this
appeal against the judgement dated ………………….. of judicial
Magistrate, F.C., Varanasi in criminal case No: 101 of 2010, convicting
the appellant U/Sec 411 I.P.C and sentencing him to U/go, 6 months R.I.
and to pay a fine of Rs. 300/-
The appellant most respectfully submits the
appeal on the following groungs:
1. That the conviction is bad in law.
2. That the Judgement of the lower court offends Sec. 367 of the Cr.P.C.
3. That the learned magistrate should have inferred from the conduct of
your petitioner deposed to by the investigating officer, that he was
absolutely straight forward in his dealings. The conduct of your petitioner
as has been deposited to by P.Ws. No. 52 and 4 would hardly be consistent
with his guilty knowledge.

4. That the learned Magistrate should have taken into accent the
representation made to him by the alleged thief.
5. That the learned Magistrate should have bellered that the articles were
purchased bonafide for proper market price and inferred from that the
absence of any guilty knowledge of your
petitioner.
6. That the articles sold were common articles of everyday use to be found
in possession of people of even modest means.
7. That the learned Magistrate should have disbelieved the evidence of

P.W.s No: 56 and 7 who identified the parker pen and the Wallet alleged
to belong to Sri Anand and should have
hold that they were ordinary, common articles incapable of identification
in the absence of any special mark or name.
8. That the learned Magistrate should have believed the defence witnesses
who disposed to having seen the articles sold to the appellant some five
months prior to the incident.
9. That the Lower Court ought to have given the benefit of responsible
doubt to the appellant and acquitted him.
PRAYER
In the circumstances stated above, the petitioner prays that your honour
may be pleased to admit the appeal, call for the record.Release your
petitioner pending disposal of the appeal on bail and after hearing the case,
set aside the order of conviction and sentence or pass such other order as

the ends of Justice may call for and your petitioner, as in duty bound, shall
ever pray.
DATE:
COUNSEL FOR THE APPLICANT
……………………………………

EXERCISE-15
REVISION APPLICATION
IN THE HIGH COURT OF JUDICATURE AT LUCKNOW

CRIMINAL REVISIONAL JURISDICTION
In the matter of an application U/Sec. 439, Cr. P.C.
MK SHA, residing at Mall road, Lucknow…….. Petitioner/ Accused

Vs.
The State of Uttar Pradesh. …………………….. Respondent
In the matter of a Revision from the order of conviction passed U/Sec

324, I.P.C. on 30.01.2010 by the learned presidency magistrate sixth
court,Lucknow
To His lordship the Chief Justice and the Judge of the said Hon’ble court,
THE HUMBLE PETITION OF THE ABOVE NAMED PETITIONER

MOST RESPECTFULLY SHEWETH
In the matter of an application U/sec. 439, Cr. P.C.
MK SAH, residing at Mall Road, Lucknow………. Petitioner / Accused
Vs.
The state of Uttar Pradesh. …………………………. Respondent
In the matter of a Revision from the order of conviction passed U/sec 324,
I.P.C. on
30.01.2010 by the learned presidency magistrate sixth Court,

VARANASI.
To

His lordship the Chief Justice and the … judge of the said Hon’ble Court.
THE HUMBLE PETITION OF THE ABOVE NAMED PETITIONER
MOST
RESPECTFULLY SHEWETH
That the learned president Magistrate convicted the applicant and one MK
SHA under the mentioned section and sentenced him to undergo Vigorous
imprisonment for a period of four month and to pay a five of Rs.100 or in
default to undergo further R.I. for 15 days. Being aggrieved by the
aforesaid order, your petitioner begs to more the Hon’ble court in its
Revisional Jurisdiction on the following.
Grounds
1. That the order of the lower court is against law.
2. That the learned presidency magistrate erect in believing the complaints

who were interested witness.
3. That the learned presidency magistrate was wrong in dis-believing the

two respectable and independent witnesses examined on behalf of the
defence.
4. The learned magistrate has erred in not complying with the mandatory
provisions of the Cr. P.C. whereby an opportunity to explain away the
circumstances appearing against them
was refused.
5. The learned magistrate has not maintained a full record of the evidence
and hence certain admissions by the prosecution given in their cross
examination are not available.

Prayer
The petitioner therefore prays that your lordship may be graciously

pleased to call for the record of the case and issue a rule upon the
presidency. Magistrate, sixth court and upon the opposite party to show
cause why the aforesaid, order complained of should not be vacated and to
release the petitioner on bail pending the disposal of this revision
applications and your lordships may be pleased to pass such other order or
orders as the circumstances of the case demand.
And your petitioner, as in duty bound, shall ever pray.
DATE: COUNSEL FOR THE APPELLANT
…………………………

CONCLUSION
The art of drafting the pleadings has not yet fully developed in spite of the
increase in the civil litigation. As a matter of fact, the art of pleading
should be the foundation course and great emphasis should be laid on this
paper. Because of this absence of rigorous training, the young lawyers
often indulge in prolixity rather than clarity and conciseness.
Irrelevant matters, unnecessary details are often included and the facts
placed before the lawyer by his client are not marshaled. The result is that
the martial facts are often mixed up with inessential matter.
Pleading is an art, of course, and art which requires not only technical and
linguistic skill but also an expert knowledge of the law on the given point
brought before a lawyer. However, in the matter of pleadings longer
experience and a great linguistic acumen are both essential ingredients.
What ultimately matters is how clearly and systematically have the facts
been presented before the court of law. It is a matter of common
knowledge that when a person comes to seek the assistance of the court of
law in any matter, he has to prepare a statement of his claims, and the facts
on which such claims are founded. Such statements fully drawn up, setting
out all contentions, are called "pleadings". Thus pleadings are the
foundation of all sorts of litigation; no judicial system in the world can do
justice in any matter unless and until the court of justice is fully aware as
to the claims and contentions of the plaintiff and of the counter claims and
defenses of the defendant.
The administration at justice was separated from the executive and

assigned to the court of law. Complexity of resulted in enormous
litigation, and oral hearing of the ancient times became almost impossible.
Scribes used to keep records of all the proceedings gradually this
procedure was also abandoned and the litigants were allowed to bring their
claims and contentions duly drawn up to file them before the Hon’ble
courts.

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CIVIL PLEADINGS

IN THE COURT OF THE III ADDITIONAL JUNIOR CIVIL

PLAINT FILED UNDER SECTION 26 READ WITH ORDER VII

I) DESCRIPTION OF THE PLAINTIFFS:

DRAFTING PLEADING AND CONVEYANCE Page 1

III. BRIEF FACTS OF THE CASE:

DRAFTING PLEADING AND CONVEYANCE Page 2

(i) Promissory Note Amount : 45,000.00

V. VALUATION: The relief of recovery of money is paid thereon and the

VI. JURISDICTION: The Plaintiff is residing at VARANASI and the

DRAFTING PLEADING AND CONVEYANCE Page 3

It is therefore, prayed that the hon’ble court may be pleaded to pass a

(b)To award the costs of this suit;

DRAFTING PLEADING AND CONVEYANCE Page 4

LIST OF DOCUMENTS FILED BY PLAINTIFFS

S.NO. DATES PARTIES DESCRIPTION P.NO.

DRAFTING PLEADING AND CONVEYANCE Page 5

IN THE COURT OF ADDITIONAL JUNIOR CIVIL JUDGE: CITY

1. It is submitted that the Defendant having an acquaintance with the

DRAFTING PLEADING AND CONVEYANCE Page 6

I, do hereby affirm that the contents of para 1,2,3 are correct to my

Written statement is the defense of the defendants. A defense called the

DRAFTING PLEADING AND CONVEYANCE Page 7

Secondly, the nature of the provision contained in Order VIII, Rule 1 is

DRAFTING PLEADING AND CONVEYANCE Page 8

DRAFTING PLEADING AND CONVEYANCE Page 9

WRITTEN STATEMENT FILED BY THE DEFENDANT

2) In reply to Para III (1) of the plaint, it is submitted that I have no

DRAFTING PLEADING AND CONVEYANCE Page 10

DRAFTING PLEADING AND CONVEYANCE Page 11

COUNSEL FOR THDEFENDENT

DRAFTING PLEADING AND CONVEYANCE Page 12

IN THE MATTER OF KUSHAL KUMAR

I, Mr.Deepak S/o Raju, Aged 47 Years,Occ: Employee, R/o. D.No. 161 ,

2) In reply to Para III (1) of the plaint, it is submitted that I have no

DRAFTING PLEADING AND CONVEYANCE Page 13

6) It is submitted that I have never approached the plaintiff for any

DRAFTING PLEADING AND CONVEYANCE Page 14

IN THE COURT OF JUNIOR CIVIL JUDGE, KANPUR

I.A. No. of 2017 O.S. No. of 2017

The Applicant humbly states as under:

1. It is submitted that the Defendant having an acquaintance with the

DRAFTING PLEADING AND CONVEYANCE Page 15

DRAFTING PLEADING AND CONVEYANCE Page 16

COUNSEL FOR APPLICANT

IN THE COURT OF JUNIOR CIVIL JUDGE, Vaishali

I.A. No. of 2017 O.S. No. of 2017

DRAFTING PLEADING AND CONVEYANCE Page 17

APPLICATION FOR ATTACHMENT OF PROPERTY

I, Kundan Kumar, S/o Sunder Kumar, Aged 45 years,Occ: Local

1. It is submitted that the Defendant having an acquaintance with the

DRAFTING PLEADING AND CONVEYANCE Page 18

I, do hereby affirm that the contents of para 1,2,3,4,5 are correct to my

DRAFTING PLEADING AND CONVEYANCE Page 19

In the Family Court Judge, Jaipur

Smt.Sia, Aged 35 years,

Petition filed on behalf of the petitioner under section 10 Hindu

Name of the Petitioner:

Name of the Respondent: S. SK Gupta, S/o. Raja Reddy, Hindu aged