CIVIL PLEADING.

1. LEGAL NOTICE
ADVOCATE NAME OFFICE ADDRESS
DESIGNATION _____________
CONTACT NO.
__________________________________________________________________

Ref. No.________ Dated: ________

REGISTERED A.D.
To,
1- _______________
2- _______________
SUBJECT: LEGAL NOTICE UNDER SECTION ____OF _____ ACT, _____.

Dear Sirs,

Under instruction and on behalf of our client _______ son of _______, resident of _______, I do
hereby serve upon you with the following notice under section ___ of the _______ Act
1- That my client ______________.
2- That since ______________.
3- That on ______________.
4- That my client filed a Demand Notice ______________.

I therefore through this Notice call upon you ______________.

A copy of this legal notice is retained in my office for further necessary action.

ADVOCATE NAME

1
 2. PLAINT
In the court of the Senior Civil Judge at Chittoor.
O.S.No. 12 of 2008.
Between:
A --------Plaintiff
And:
B
C --------Defendant1 and 2
Plaint filed u/s.26, orderu11, Rules 1&2 cpc Read with sections 26 of specific Rules
Act, 1963.
The above named plaintiff humbly submits as follows:

1. Description of plaintiff: The description, of the plaintiff is the same that

specified in the above cause title and the address for service of summors,
notices and processes in respect of the plaintiff is the same as that of the
counsel Mr.-----------------Advocate, Chittoor Court, Ctr.
2. Description of Defendants: The description, addresses for service of summors,
notices and processes in respect of Defendants No.1 and 2 are the same as
specified in the above cause-title.
3. No.2 by entering into a fresh agreement for sale instead of registering the same
in favour of plaintiff.
4. On coming to know about the proposed sale of the suit scheduled property by
d1 to d2, the plaintiff has issued a legal notice dt------------------(Annexure-II) to
d1 to obtain a clear title of the said property and come forward for registration.
But the defendant No.1 failed to comply with the same and instead he issued a
reply legal notice dt-------(Annexure-III)to the effect that the agreement for sale
dt----------- entered by him with plaintiff stands cancelled because of not
paying the balance amount within stipulation period and therefore he is going
to sell the said property to defendant No.2 (d2).

Prayer – The plaintiff humbly prays that this hon’ble court may be pleased to pass a
judgement and decree infavour of plaintiff and against the d1.

Place:
Date:
Sd/-
Plaintiff
Sd/-
Councel for the plaintiff
Verification – I, the above named plaintiff hereby declare that the contents mentioned
inpara 1 to 11 are true to the best of my knowledge and belief.

Place:

Date:
Sd/-

2
 Plaintiff

Schedule property List of Documents

North|: 1.
South: 2.
East: 3.
West:

3. AFFIDAVIT

IN THE COURT OF SENIOR CIVIL JUDGE,CHITTOOR

O.S.NO…..of……..

Between:
plaintiff
………………………….. …………………….
……………………….
And:
……………
………………. …………………….. Defendant No:1&
2
Affidavit filed by the plaintiff
I……….s/o………., aged…………,Hindu,occupation………..H.No………chittoor do
hereby solemnly affirm and sincerely state on oath as follows:
1,Iam the petitioner/plaintiff herein and as such I am well acquainted and with
the facts and circumstances of the case.Hence I am depositing through this
affidavit

2, I had entered into an agreement on………….with the defendant No.1 herein for
purchase of the suit scheduled property bearing H.No…………chittoor,adlanded
measuring a total area 300sq.yards with a constructed plaint area of 1200 sft.for
a total sale consideration of Rs 5 lakhs.

3,I further submit to this honable court that despite payment of substantial sale
amount against the sale consideration agreed upon, the did not come forward to
execute a sale deed although I was ready and willing to get the same always

Deponent

Sworned and signed on this day

………………….at chittoor

Before me
Advocate, Chittoor

3
 4. INTERLOCUTORY APPLICATION

INTERLOCUTORY APPLICATION
BEFORE THE APPELLATE TRIBUNAL FOR ELECTRICITY
IA NO._OF 200
In
Appeal/Original Petition No._of 200 .
CAUSE TITLE
Set out the Appeal No._of 200
Appeal / Petition short cause title
Set out the 1. Appeal No._200
Cause Title - Interlocutory Application
Petition for stay/direction/dispense with/condone delay/calling records
The applicant above named state/s as follows :
1. Set out the relief (s)
2. Brief facts
3. Basis on which interim orders prayed for
4. Balance of convenience, if any :
(All interlocutory applications shall be supported by an affidavit sworn by the Applicant/on
its behalf and attested by a Notary Public).
DECLARATION
The applicant above named hereby solemnly declare that nothing material has been concealed
or suppressed and further declare that the enclosures and typed set of material papers relied
upon and filed herewith are true copies of the originals or fair reproduction of the originals or
true translation thereof.
Verified at_dated at_this day_of_200 .
Counsel for Applicant Applicant
VERIFICATION
I_(Name of the applicant) S/o.W/o.D/o. (indicate any one, as the case
may be ) _age _working as _ in the office of
_resident of_do hereby verify that the contents of the
paras_to_are true to my personal knowledge / derived from
official record ) and para_ to_are believed to be true on legal advice
and that I have not suppressed any material facts.
Date :
Place :
Signature of the Appellant/Petitioner or authorized
officer

4
 5. Counter for an I.A.

In the court of the district judge at karnal

Civil Appellate Jurisdiction
Misc. Appn. No......if 1988
In Civil Appeal No.19 of 1988
Applicant

XY............................ ......(Orig.
Defendant)

Opponent

AB........................ .....(Orig.
Plaintiff)

Application for security of costs under O.25 r.1., C.P.C.

The applicant humbly states as under t hat.

1. The opponent has filed an appeal before the Hon’ble court to while away time and to
harass the present applicant.
2. The said appeal is frivolous and the opponent is not likely to succeed therein.
3. The opponent is instigated by some persons who are on inimical terms with the
applicant and the opponent had filed appeal at their instance only.
4. The applicant could not recover his costs of the lower Court from the opponent though
execution proceeding were taken against him to recover the same.
5. The opponent avoided payment of casts of the lower court though he is a man of
means.
The applicant therefore most humbly prays that the opponent may be ordered to
furnish h security for the payment of all cost incurred and likely to be incurred by the
applicant in both in the appeal and original suit.

Sd/- Sd/-
Applicant’s Advocate Applicant

5
 6. Written statement

In the court of Senior CIVIL Judge, Chittoor

O.S.No……………of…………..
Between:
…….Plaintiff
And:

…….Defendants 1 to 3
Written statement filed on behalf of the Defendants No. 1 to 3

1. The above named defendant No.1 herein humbly states that the present written
statement is submitted on his behalf and also on behalf of the defendants No.2
and 3 who have authorized him so to do as much as the interests of all the
three defendants in the suit are one and the same.
2. That the defendant No.1 submits that the contentions and averments made by
the plaintiff in the plaint are false and fabricated so as to gain weight to the
undue demand of the plaintiff for position and separate properly. As such the
same are hereby devided as illegal, false and frivolous, except to the extent of
which the defendant no.1 expressly admits herein below if any.
3. In reply to paragraph 1 and 2 of the plaint, it is submitted that there are no
comments to be made thereon.
4. In reply to paragraph 3 of the plaint, it is submitted that the contents
mentioned, therein the defendant no.1 refused to get the properties partitioned
by allotting a share to the plaintiff. The respondent no.1 devied partition for the
reason that the suit scheduled property is the self acquired property of the
defendant no.1 and the same is never treated either as ancestral property or
coparcenary property. As such the plaintiff has no right to claim any partition
for a share in the suit scheduled property. As along as the defendant no.1 is
alive.

Place:
Date: Sd/-
Defendant/Respondent No.1

VERIFICATION

I, def.no.1, on my own behalf and on behalf of defendant 2 and 3 do hereby

declare that the facts stated above in para 1 to 4 are true and correct to the best
of my knowledge, information & belief. Hence verified.

Place:
Date:
Sd/-

Defendant

6
 7. MEMORANDUM OF APPEAL

MEMORANDUM OF APPEAL
APPEAL BEFORE THE NATIONAL COUNCIL FOR TEACHER EDUCATION
UNDER SECTION 18 OF NCTE ACT, 1993
Appeal No.............of 20............
ABC..............................................................................,............................Appellant
here furnish complete postal address)....................................................................
Versus
DEF......................................................................................................Respondent
To
The Member Secretary,
National Council for Teacher Education,
New Delhi.
Sir,
The appellant named above begs to prefer this Memorandum of Appeal under Section
18 of the National Council for Teacher Education Act, 1993 on the following facts and grounds
:_
FACTS
1. Your above-mentioned appellant had applied to the Regional Committee
under Section........................................................................................
of the National Council for Teacher Education Act, 1993 (73 of 1993) for
2. The Regional Committee ................................... refused to grant such
...............................vide its order dated...................................a copy of which is
attached ......................................... For the reasons set out below, your
appellant(s) submit(s) that the.............................ought to have been granted by
the Regional Committee. The Regional Committee erred in deciding the matter on the
following grounds.
GROUNDS OF APPEAL
1.
2.
3.
PRAYER
The appellant therefore prays that the order appealed against may be set aside and
appropriate relief granted to the appellant.

Date:
I/We............................the appellant(s) above named do hereby declare that what is
stated herein is true to the best of my/our information and belief and nothing material has
been suppressed or concealed.
Place:
Date:
Signature of the Appellant or his authorized signatory
(Address of the appellants)

7
 8. MEMORANDUM OF CIVIL REVISION PETITION.

Revision petition
IN THE HIGH COURT OF JUDICATURE AT MADRAS
(Appellate side)
(Sec. 60(1))
MEMORANDUM OF CIVIL REVISION PETITION
[See rule 14(13) ]
Civil Revision Petition No......of 200
Petitioner (s)
Versus
Respondent
Revision petition to the High Court to revise the order of the
Chennai
APPELLATE TRIBUNAL Madurai dated..........and passed in
Coimbatore
1. District in which the assessment was made
2. TIN / Assessment year
3. The designation of the officer whose orders were appealed against before the Appellate
Tribunal
4. Date of communication of the order of the Appellate Tribunal
5. Findings of the Appellate Tribunal (state in serial and appropriate order the relevant
findings arrived at by the Tribunal)
6. Questions of law raised for decision by the High Court (here formulate the questions of
law raised concisely, etc.)
(Signed)
Petitioner(s)

(Signed)

Authorised Representative, if any

Verification
I/We..............the petitioner(s) do hereby declare that what is stated above is true to the
best of my/our knowledge and belief.

Verified today the................day of..........200

(Signed)
Petitioner(s)

(Signed)
Authorised Representative, if any

8
 9. MEMORANDUM OF CIVIL REVIEW PETITION

MEMORANDUM OF REVIEW PETITION

(UNDER SEC.114 ORDER-47 AND RULES-1,4 & 5 OF C.P.C.
AND ART.226 OF THE CONSTITUTION OF INDIA)

IN THE HIGH COURT OF JUDICATURE OF ANDHRA PRADESH

AT HYDERABAD

REVIEW W.P.M.P.No. OF 2010

IN

W.P.No. OF 2010

BETWEEN: __________
..Petitioner
And
____________
…Respondents

The address for service of all notices and process on the above named Appellant is that
of his counsel M/s ____________________________

This Memorandum of Review Petition is filed seeking to Review the Order in

WP.No.___________, Dt.__________passed by The Hon'ble Sri Justice ___________ for the
following :
GROUNDS

1. This Hon'ble Court disposed of the writ petition on ______ directing the respondents to
_________.
2. The mistake is neither willful nor wanton.
3. The orders of the Hon'ble High Court Dtd._______ may be reviewed in the light of the
orders passed by the Hon'ble Supreme Court of India in Civil Appeal No._______
The other grounds will be urged at the time of hearing.
It is therefore prayed that this Hon'ble Court may be pleased to
______________________________________________________ and pass such other order or
orders may deem fit and proper in the circumstances of the case.
DATE:
HYDERABAD COUNSEL FOR THE PETITIONER
________ District
HIGH COURT :: HYDERABAD

REVIEW WPMP.NO. OF 2010

IN

W.P. NO. OF 2010

9
10. BATTA FORM

In the court of the ADM Junior Civel

Judge AT Chittoor.

O.S.No of 20

Between

XXXXX Plaintiff

And

XXXX Defendant

BATTA MEMO OF THE PLAINTIFF

Summon to defendant 1. YYY (Address) Chittoor Rs30/-

XXXXX 2. YYY (Address) Chennai TC. Rs.1

One is residing at Chittoor and Postal Rs.25-

another is residence at Chennai Rs.30/-

T.C. Rs.100/-

Postal Rs.25/-

Total Rs.177/-

Advocate for Plaintiff

10
11. STEPS PETITION

12. SUIT FOR PARTITION

SUIT FOR PARTITION OF JOINT HINDU FAMILY PROPERTY:

In the court of civil judge (senior division) Dehradun

Original Suit No. …………………of 2014

1. Sri Ram Lal s/o Late Sri Chunee Lal r/o ……………………………………………Dehradun
Plaintiff
Versus
1. Sri ……………………………………………… .s/o Chunee Lal
r/o………………………………………
2. Sri …………………………………………………s/o Chunee Lal
r/o……………………………………...
3. Sri …………………………………………………s/o Chunee Lal
r/o……………………………………..
4.Sri ………………………………………………….s/o Late Sham Lal r/o
……………………………….....
Defendant
5. Sri Rati Ram s/o Sri Sati Ram r/o 171 Shakti Vihar Dehradun.
Performa defendant.
Sir,
The above named plaintiff states as follows:

1. That the plaintiff and the defendant No.1 to 4 are a member of a joint Hindu family.
Defendant No.1 to 3 and plaintiff are real brothers whereas defendant No.4 is the son of late
Sham Lal who is also a real brother of plaintiff and defendant No. 1 to 3. Unfortunately he has
died on…………………leaving behind his only son (defendant No.4).

2. That the father of the plaintiff and defendant No.1 to 4 late Sri Chunee Lal is the Karta of
joint Hindu family purchased the property in suit, from Sri Nand Lal vide sale deed dated
………….which is duly registered in the office of sub registrar Dehradun in bahi No.

11
…..volume ………page No. ………registered on ………….full details of which are given in the
end of this plaint in schedule of property. Late Chunee Lal died on …………………….intestate.

The plaintiff claims:

(1)…………………………………………………………………………………………………………
…
(2)…………………………………………………………………………………………………………
…
(3)…………………………………………………………………………………………………………
…

Schedule of property:
………………………………………………………………………………………………………………
…
………………………………………………………………………………………………………………
…
………………………………………………………………………………………………………………
…
………………………………………………………………………………………………………………
…

Signature
Verification:

I, the above named plaintiff, declare that the contents of paragraphs 1 to 7 of the plaint are true
within my personal knowledge, and that the contents of paragraphs 8 to 10 of the plaint are
based on legal advice received by me and believed to be correct. Verified on………… at
Dehradun.

Date…..........

Place, Dehradun.
Signature

12
13.SUIT FOR DEFAMATION.
In the Court of Civil Judge Class - I at Indore
Suit No. ………… / 20…….
A. B. s/o B. C.
123, M G Road, Indore, MP ......................................... Plaintiff
Vs.
M. N. s/o O. P.
456, M G Road, Indore, MP ......................................... Respondent

Plaint under Order 7 Rule 1 for Compensation for Defamation

The plaintiff respectfully states as follows : -

Brief Description of the case:

(1) The respondent publicly accused the plaintiff of selling watered down milk, which has
caused immense harm to the reputation of the plaintiff. The present suit is meant for
compensation for the harm done to the plaintiff's reputation.

Matters of Inducement:
(2) Plaintiff is a milk man and sells milk in many colonies of Indore including MG Road, AB
Nagar.
(3) Respondent is the president of an informal residents association of MG Road.
Facts constituting cause of action:
(4) In a residents association meeting held on 10/10/2009, the respondent publicly accused the
plaintiff of selling milk mixed with water. A tape record of the respondent making the
accusation is attached with this petition.
(5) The said speech made by the respondent was heard by hundrends of residents of MG
Road, where the plaintiff sells milk.
(6) The said speech has caused the plaintiff a lot of embarrament and loss of business.
(7) The plaintiff denies that he sells watered milk and claims that the statement made by the
respondent was completely baseless.
...
Place: …………………. (Signature of the plaintiff)
Date: …………………..

Advocate for Plaintiff

Verification
I, ______, do hereby verify that the contents from paras 1 to 12 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 2009.

(Signature)
Plaintiff

13
14. PETITION FOR RESTITUTION OF CONJUGAL RIGHTS.

PETITION FOR RESTITUTION OF CONJUGAL RIGHTS

IN THE COURT OF THE _______

Matrimonial Case No. _______ of 20 _______

Shri AA. etc. _______ Petitioner;

Versus

Smt BB. _______ Respondent.

Petition under Section 9 of the Hindu Marriage Act, 1955.

The Petitioner, named above, states:

1. That the petitioner was married to the respondent on _______ at _______ within the jurisdiction
of this Court.

2. That the petitioner and his wife lived last together at _______

3. That on _______ last the respondent went to her father’s house at _______ . She gave word to
return within 15 days, but she did not abide by her word and has not returned so far.

4. That the petitioner went to his father-in-law’s house at_______ to bring the respondent, a
number of times, but on one pretext or the other, she declined to come along with the petitioner to
his house.
Dated. _______ Petitioner.

VERIFICATION

I, the abovenamed petitioner, do hereby verify that the contents of this petition in Paras
______________ are true to my personal knowledge and those in Paras Nos______________ are
believed by me to be true.

Signed and verified this _______ day of _______ 20 _______ at _______ in Civil Court compound.

Petitioner.

14
15. DIVORCE PETITION FILED ON BEHALF OF HUSBAND.

PETITION BY HUSBAND FOR ANNULMENT OF VOIDABLE MARRIAGE

IN THE COURT OF THE DISTRICT JUDGE AT _______

Matrimonial Petition No_______ of 20_______

__________________________________________ Petitioner ;

VERSUS

__________________________________________Respondent.

Petition under Section 12(1)(d) of the Hindu Marriage Act, 1954.

The Petitioner states as follows :

1. The parties were married after the commencement of the Hindu Marriage Act on _______ at
_______ An extract from the Hindu Marriage Register/Affidavit is filed herewith.

2. The parties before the marriage and even now are Hindus and reside at the addresses
mentioned above.

3. After the aforesaid marriage the respondent came to live with the petitioner at his house. The
respondent showed symptoms of retching and was often unable to retain any food or liquid. The
petitioner grew apprehensive and desired to consult some physician but the respondent said that
there was nothing serious and she may be sent to her parental home where she would recover
soon.

4. The petitioner sent the respondent to her father’s house on _______ and kept on visiting her to
ascertain her welfare. The petitioner insisted that a doctor be consulted and on the respondent’s
father’s assent, Dr _______. was requested to examine the respondent. Dr _______suspected that
the respondent was pregnant and for confirmation advised that some gynaecologist be consulted.
Sd. _______.

Petitioner.

VERIFICATION

The abovenamed petitioner states on solemn affirmation that Paras 1 to _______ of the petition
are true to the best of petitioner’s information and belief. Verified at _______ (place).

Sd. _______
Dated. _______.

Petitioner.

15
 CRIMINAL PLEADING

1. MAINTENANCE FOR PERMANENT ALIMONY.

Plaint filed under section 26 order VII, R.1 of C.P.C R.w Section 7(1) Explanation (F) of Pamily
court Act, 1984

Suit for recover of past maintenance and for future maintenance

Description of plaintiff:

The Plaintiff above named submit as under .

i) That the plaintiffs marriage was solemnized with the defendant on ....., as per
customs and rites of Hindu Religion.
ii) The Plaintiff restrict their claim for post maintenance for one year from today
and this Plaintiff claims the following amounts as past maintenance.
Maintenance from .......... to ..... at the rate of Rs.......p.m. being 2/3 of the
salary drawn by the Defendant amounting to Rs..............
The plaintiff also claims future maintenance at the rate of Rs..... per month
from the date of filing of this suit every month. Hence the suit.
iii) The suit for past maintenance as valued at Rs........ and court fee Rs....... is paid.
The suit for a direction to pay future maintenance is also valued at Rs.......... at.
Rs...... and a court fee of Rs..... is paid which is just and sufficient.
a. A decree for payment of past maintenance at Rs.......... against the person and
property of the defendant, in favour of the plaintiff.
b. Interest of Past Maintenance at rate of .....% per annum from the date of
filing of this suit till realisation.
c. Cost of the Suit and
d. Such other relief or reliefs as this Hon’ble Court feel just and necessary in the
nature and circumstances of the Case.

Place: Plaintiff

Date: Counsel for the Appellant

16
2. MAINTENANCE UNDER SECTION 125 CR.P.C

IN THE HONOURABLE COURT OF V ADDITIONAL DISTRICT JUDGE-CUM-JUDGE:

FAMILY COURT AT VISAKHAPATNAM
O.P.No. /2008
Between:
ABCD Petitioner
And
XYZ Respondent

PETITION FILED UNDER SECTION 24 OF HINDU MARRIAGE ACT

I. The Petitioner is:

The address of the Petitioner for the purpose of service of court summons and notices is
as stated above

II. The Respondent is:

The address of the Respondent for the purpose of service of court summons and notices
is as stated above.

III.

(a) The Petitioner submits that her marriage with the Respondent was solemnized on XX-
XX-XXXX at Petitioner’s mother place as per Hindu caste customs and religious rites. The
Petitioner submits that at the time of marriage as per the demand of the Respondent and
his family members, the Petitioner’s mother gave a sum of Rs. XXXXX/- in cash towards
dowry, customary gift articles worth of Rs. XXXXXXX/- , a gold chain and one gold ring.
The Petitioner submits that although the Respondent is her near relative the Respondent
and his parents demanded for dowry and other laanchanams and having no other option
the mother of the petitioner paid the amounts as stated above.

IV. A Court fee of Rs. /- under article 11(8) of schedule 11 of A.P.C.F. and
S.V. Act.

V. The Petitioner, therefore, prays the Honourable Court in the interests of justice that the
Honourable Court may be pleased to direct the Respondent:

a) To pay a sum of Rs.2, 000/- (Rupees Two Thousand only) per month to the Petitioner
towards her maintenance,

b) To grant such other relief or reliefs as the Honourable Court deems fit and proper in
the circumstances of the case.

17
 PETITIONER

VERIFICATION

I, the above named Petitioner, do hereby verify and declare that the facts stated above
are true and correct to the best of my knowledge, belief and information.

Visakhapatnam

Date: PETITIONER

3. PRIVATE COMPLAINT.
In the Court of Judicial Magistrate Ist Class at Indore
Criminal Complaint No. ... / 2009
A. B. s/o B. C.
123, A B Road, Indore, MP ......................................... Complainant
Vs.
M. N. s/o O. P.
456, A B Road, Indore, MP ......................................... Accused
Complaint of Offence under S. 506 (Criminal Intimidation) I P C
Complaint of Offence under S. 290 (Public Nuisance) I P C

The aforementioned complainant begs to state as under:-

1. That the complainant is a resident of 123, MG Road, Indore.

2. That the accused is a resident of 222, MG Road, Indore, which is in the same area.
3. Since 10/10/2009, the accused and his friends have started playing cards on the street in front of
the plaintiff's house every evening and late night.
4. The accused and his friends create a lot of noise while playing and also shout obscenities at each
other.
5. The plaintiff also gave the respondent a written notice in this respect.
6. The complainant, therefore, prays that –
(a) appropriate proceeding be initiated against the accused under Cr P C.
(b) the accused be stopped from continuing the nuisance in the residential locality.
(c) the accused be convicted of the offence under S. 290.
(d) the accused be ordered to pay compensation for medical treatment, mental agony to the
amount of 100,00/-

Place: …………………. (Signature of the Complainant)

Date: …………………..
No Verification No Verification

No Notary

18
 4. BAIL PETITION.
IN THE COURT OF SESSIONS JUDGE, CHITTOOR.

Case No. 576 of 2008.

IN THE MATTER OF:

Petition for bail of the accused – petitioner pending hearing of appeal.

State ……….. Petitioner.

Versus

Sudharsan ………. Respondent.

The humble petition of the accused in the abovementioned case.

Most Respectfully Showeth:

1. That the petitioner was convicted under section 379 IPC Theft and sentenced to undergo seven
rigorous imprisonment.
2. That the petitioner is filing this appeal against the said order of conviction before this Hon’ble
court.
3. That the petitioner is a business man of repute and there is no apprehension of the petitioner
absconding pending the hearing of the appeal.
4. That the petitioner has good chances of succeeding in the appeal.

PRAYER

It is therefore humble prayed that this Hon’ble court may be pleased to grant ad interim bail
pending the hearing of the appeal.

AND for this act of kindness the petitioner shall ever pray.

Petitioner
Through
Advocate
Place:
Dated:
VERIFICATION

I, Sudharsan son of R. Sundaram if Chittoor residing at Chruch Street solemnly affirm and state
as follows:-

1. That I am the petitioner above named and am aware of the facts and circumstances of this case.
That the statements made in paras…….to……..hereinabove of the petition are true to my
knowledge and belief.

19
5. ANTICIPATORY BAIL PETITION.

IN THE COURT OF HON’BLE SESSIONS JUDGE, _____

____ S/o _____ R/o _____
____ S/o _____ R/o _____

…..Applicants/Petitioners

Versus
State of ____

…..Respondent

First Application Under Section ____For Grant of Anticipatory Bail in Case FIR No.
____Under Section ____IPC
Sir,

The applicant/petitioner most respectfully submits as under:-

1- That the ____ has ____ registered the above mentioned case against the
applicant/petitioner.
2- That the applicant/petitioner has no nexus or connection with the above-mentioned
offence.
3- That the applicant/accused is a ____ of India as ____ is aged about____ years.
4- That the applicant/petitioners have not caused any hurt/injury to any one.
5- That the allegations in the FIR as alleged by the ____ are wrong, incorrect and concocted
story made by the complainant.
6- That no recovery is pending in the above mentioned case and nothing is to be recovered
from the applicant/petitioner.
7- That the applicant/petitioner undertakes to join the investigation as and when required
by the police of police Station ____.
8- That there is no apprehension for absconding or evading of taking trial.
9- That the applicant/petitioner undertakes not to temper with the evidence or witnesses.
10- That the applicant/petitioner undertakes to abide by all the terms and conditions as
imposed by the Hon’ble court in the event of bail.

PRAYER:
It is, therefore prayed that the applicant/petitioner may kindly be released/granted
anticipatory bail and the ____ concerned of concerned police station ____ may kindly be
directed to release the applicant/petitioner on bail in the event of their arrest
Dated:

Applicant/Petitioner

Through counsel:
____ Advocate, ____

20
6. CRIMINAL REVISION PETITION.
IN THE COURT OF THE ADDL. DISTRICT MUNSIF -CUM-I ADDL. JUDICIAL
MAGISTRATE OF FIRST CLASS AT CHENNAI.

IN THE COURT OF THE SESSIONS OF……………..DIVISION

Cr. R.P. No of …….

IN THE HIGH COURT OF JUDICATURE of ...........................at CHENNAI

Crl. R. C. No of….. …..

Between :---

Sreenu ………… Petitioner / Respondent/ Respondent

And

Yyyy …………… Respondent/Petitioner/Petitioner.

The address for service of all notices, summons, and processes on the above named
petitioner is that of his counsel MIs , Advocates, High Court
Buildings,…………… .

The petitioner herein begs to present this Memorandum of Criminal R.C. under Section
397 & 401 of Crl. P.C. aggrieved against the Order made in Crl. R.P.No of dated ……..
of the……. Additional Sessions Judge… reversing the order made in M. C. No …….. of …...
dt……….of the I Additional District Munsif -cum-I Additional Judicial Magistrate of First
Class,…………. is totally unsustainable in Law, for the following among other.

GROUNDS:

1. The order of the Revisional Court in reversing the well considered order of the Original Court is
totally unsustainable either in Law or on facts.

2. The Revisional Court ought to have appreciated that on facts it is clear that the respondent alone
had deserted the petitioner raising some dispute regarding the execution of the decree in favour of
his brother's son and in the said circumstances the finding of the Court of the first instance that the
wife alone is guilty of leaving the husband cannot be disturbed by the Revision Court without
appreciating the contents raised by the husband at all.

3. The Revisional Court ought to have appreciated that the petitioner never neglected or refused to
maintain the wife and hence the respondent cannot maintain this application under Section 125 of
Cr.P.C. in the absence of any of the ingredients specified under Section 125 of Cr.P.C.

Place:

Date:

Counsel for Petitioner

21
7. Criminal Appeal

IN THE HIGH COURT OF KARNATAKA AT BANGALORE

DATED THIS THE 14th DAY OF AUGUST 2012 ,•
BEFORE
■

THE HON'BLE MR. JUSTICE K.N.KESHAVANARAYANA

CRIMINAL APPEAL NO.2347/2005 fCl
BETWEEN:
IMRAN @ KARADI IMRAN
S/O KHARADI RASHID
AGED ABOUT 25 YEARS
RESIDING AT CHELUGUDDA
THIPPAREDDY EXTENSION,
CHITRADURGA.
…… APPELLANT

(BY SRI B.M.SIDDAPPA, ADV.

AND
THE STATE OF KARNATAKA,
BY STATE PUBLIC PROSECUTOR,
HIGH COURTS BUILDING,
BANGALORE.
…….RESPONDENT
(BY SRI K.RAJESH RAI, HCGP)
This criminal appeal is filed under section 374 cr.p.c. By the advocate for te
appellant against the judgment dated 11.8*2005 passed by the addl. S.j.,
ftc,chitradurga in s.c.no. 10/2005, convicting the appellant-accused no.l for the
offence p/'u/s 326 ipc and sentencing him to undergo r.i. For 2 y2 years (2 years
six months) and to "pay fine of rs. 1,000/- and in default undergo 3 months r.i.
This criminal appeal coming for hearing on this day. The court delivered the
following.

In view of the above, the appeal is allowed.

i. The judgment of conviction and order of sentence dated 11.08.2005

passed by the Addition Sessions judge and Fast Trach Court,
Chaitradurga, in S.C.No.10/2005 conviction the appellant for the offence
punishable under section 326 of IPC is hereby set aside.
ii. The appellant is acquitted of the said charge. The bail bond and surety
ban executed by the appellant are ordered to be discharged.
iii. The fine amount, if any , paid by the accused is ordered to be refunded to
him.

Sd/-

Judge

22
 8. COMPLAINT UNDER N.I.ACT

IN THE COURT OF _____________________________

COMPLAINT NO ___________ OF____
IN THE MATTER OF:
Mr.____________________
COMPLAINANT
VERSUS
Mr. _______________
ACCUSED
POLICE STATION:____________
COMPLAINT UNDER SECTION 138 OF THE NEGOTIABLE INSTRUMENTS ACT, 1881
(AS AMENDED UPTO DATE) FOR THE SUM OF RS. ______________ (RUPEES
________________ ONLY)
MOST RESPECTFULLY SHOWETH:
1. That the Complainant is working as _________________________ and is residing at
______________________________________
2. ______________ Dated ____________for Rs. ___________to the complainant. That in
order to discharge their above said liability and in accordance with the agreed terms
and conditions, the accused had issued Cheque No. _____________ Dated
___________for Rs. ___________/- drawn on ___________________. The said cheque
was issued from Account No. ____________________which is held in the name of the
accused. That the present complaint is based on the dishonor of the above said cheque
which was issued in discharge of a lawful debt.

3. That the dishonor of the cheque clearly shows and establishes that the accused did not
intend to honor the amount under the said cheque.

4. That on account of the dishonor of the said cheque, the complainant had served a legal
notice dated ____________upon the Accused by way of Registered Post vide Receipt
No. _________________ dated ___________However, despite service of notice, the
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble Court may be pleased to:
a. Summon, prosecute and punish the Accused and also direct the accused to pay the
amount as double to the amount covered under the said dishonored cheques, under the
provisions of Section 138 read with Section 142 of the Negotiable Instruments Act,1881
as amended by the Negotiable Instrument laws (Amended and Miscellaneous
Provisions) Act, 2002. In accordance with Section 357 of Code of Criminal Procedure
1974, out of the penalty imposed, the Accused be ordered to compensate the
Complainant to the extent of Rs._______ /- (Rupees ______________ Only) and

23
PLACE:
DATED:
COMPLAINANT
THROUGH :
ADVOCATES

9. COUNTER OF N.I. ACT

In the court of senior civil judge at delhi
Civil suit No.90 of 1991
A.B.C., r/o........ Delhi ....Plaintiff
Versus
XYZ, r/o ......., Delhi ....Defendant
Suit for recovery of Rs.3000/-
Sir,

The Plaintiff above named respectfully submits as under.

1. That the plaintiff and the Defendant are friends. The defendant requested the Plaintiff
to give him a loan of Rs.3000/- for the medical treatment of his son.
2. That the Palintiff accordingly gave Rs.3000/- to the defendant through a per-note dated
01.01.1987. which the Defendant executed.
3. That the suit has been filed with in limitation.
4. That trhe valuation of the suit being Rs.3000/- on which the requisite court fee has been
paid.
5. That the suit has been filed under the provisions of Sec.7, C.P.C.

PRAYER
The Plaintiff claims the following reliefs.
i. That a decree for the realization of Rs.3000/- along with costs of the suit and
interest at the rate of 12% per annum be passed against the Defendant and in
favour of the Plaintiff.
ii. Any other relief to which the Plaintiff be held entitled.
Plaintiff
Place:
Date:
Throu
gh
Sd/-
(Advocate)

24
 10. WRIT PETITION FOR MANDAMUS.

WRIT OF MANDAMUS
IN THE HON’BLE HIGH COURT OF JUDICATURE AT_____
(Original Civil Jurisdiction)
Writ Petition No_________of _________20_________

AA., son of _________resident of _________Petitioner;

Versus
1. Collector, _________.District

2. State of _________. Respondents.

Petition under Article 226 of the Constitution for the issue of a writ of mandamus.

To

The Hon’ble the Chief Justice and his companion Judges of the Hon’ble High Court of
Judicature at _________.

The above named Petitioner begs to submit as under:

1. That the Petitioner is the owner of a plot of land numbered _________in _________at
_________detailed in Annexure ‘‘A’’ to this petition.

2. That on _________a notification under Section 4 of the Land Acquisition Act, 1894, was
published that certain land including the Petitioner’s aforesaid plot was needed for a public
purpose.

3. That the Petitioner filed objections to the proposed acquisition of his plot under Section 5-A
of the Act.

4. That the objections filed by the petitioner were heard by the Collector on _________and
thereafter he submitted his report with recommendations to the State Government.

5. That the State Government accepted the report and recommendations of the Collector and
rejected the objections filed by the petitioner.
It is, therefore, most respectfully prayed that a writ, direction or order in the nature of
mandamus be issued to Respondent No. 1 directing him to refer the matter of compensation
for the Petitioner’s plot for determination to the District Judge . . . . . . .

AA.
Dated _________.
(Petitioner)
___________________
(Counsel for the Petitioner)

25
 11. MEMORANDUM OF WRIT PETITION FOR MANDAMUS.

IN THE SUPREME COURT OF INDIA AT NEW DELHI

W.Petition No..... of 19 .....
In the matter of Art. 32 of the Constitution of India and Sec.3 Maintenance of internal Security
Act,1980.

And
In the matter of A. Of etc of Naini, A Detenue at Naini Jail
And
B, Son of D, aged about 52 Years,
Occupation business, Resident of ....... Petitioner
V

1. The State of U.P

2. The District Magistrate, Allahabad.
3. The Superintendent of Police (City)
Allahabad.
4. The Superintendent of Naini Central, Jail Allahabad. Respondents

Mandamus.
It is a high Prerogative writ of a most extensive remedial nature. The Supreme court
and the high Court High Courts have Powers Respectively under Article 32 and Article 226 of
the Indian Constitutional to issue this writ in the form of command direction any person
holding public office under the Government or, statutory bodies or corporation to an inferior
court exercising judicial or quasi judicial function to do a particular act pertaining to his office
or duty and which the court issuing the writ consider to be the right of the petitioner and is in
the interest of justice.
It is issued only when there is a specific legal right, but no specific legal remedy to
enforce that right. It may also, lie for the delivery, inspection and production of public book,
papers and documents provided that the petitioner has a direct tangible interest in such books,
papers and documents.
Mandamus will not be issued when any alternative remedy by way of appeal or an
other remedy under any other statute is available, Article 32 is limited to the enforcement of
Fundament Rights of Part-III of the Constitution only.

26
12. WRIT PETITION FOR HABEAS CORPUS
.
THE HIGH COURT OF JUDICATURE AT CHENNAI.

(SPECIAL ORIGINAL JURISDICTION)

W. P. No………………… of ………………

Between: -----

Bharath ……………… Petitioner.

Vs.

M/S Bharath ……………. Respondent(s).

The address for service of all notices, summons, and processes on the above
named petitioner is that of his counsel m/s Subramanian Advocates, High Court, R/o
Anna Nagar, Chennai.

For the reasons and in the circumstances stated in the accompanying

affidavit, the petitioner herein prays in the interests of Justice, that this Hon’ble Court
may be pleased to issuer a Writ of Habeas Corpus, or any other appropriate Writ, order
or direction, holding that the impugned action of detention made in C.C. No 234/08,
dated 20-04-08 under Section 3(1) and (2) of the Act 10f 1986 as highly illegal, arbitrary,
and unconstitutional, being violative of Articles 14, 21 and 22 of the Constitution of
India, and the provisions of Act 1 of 1986 and directing the respondents to release the
petitioner's brother Sri Vasu, S/o S. Banu Forthwith, and pass such other and further
order or orders as this Hon'ble Court may deem fit and proper in the circumstances of
the case.

Counsel for Petitioner

27
13. MEMORANDUM OF WRIT PETITION FOR HEBEAS CORPUS.
WRIT OF HABEAS CORPUS

IN THE HON’BLE SUPREME COURT OF INDIA, NEW DELHI

(Original Criminal Jurisdiction)
Writ Petition No_________of _________20 _________

A _________ aged about _________ son of __________________., resident _________

Petitioner;
Versus

1. Additional Secretary, Ministry of Finance,

Government of_________.

2. The Superintendent, _________ Jail _________

3. The State of_________ 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 sheweth:

1. That the petitioner is a resident of _________. and he was living peacefully at his residence
at the place aforesaid.

2. That on _________. 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’’.

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 grounds are in English which language the Petitioner does not know and this
has prevented him from making an effective representation.
3. Because the grounds are irrelevant to the object of the Act.

Date _________ Advocate for the Petitioner.

28
14. CAVEAT PETITION.

IN THE COURT OF THE CIVIL JUDGE ___________________ AT

MUMBAI
CAVEAT APPLICATION NO. /2000
SHRI _______________________
Aged_________Years, Occupation:
(Complete Address)......................... ………………………………………………...
Caveator
V/s
The ________________________Limited )
Having their registered office______________
...................................................................................Other Party/Opponents

Caveat Application u/s. 148-A of the Code of Civil Procedure is as under;

MAY IT PLEASE THE HON'BLE COURT:
1. Pray that no Ex-parte order be passed in any Suit/Case/Application for
injunction/any Recovery/prohibitory order/s to be instituted by the Opponents
above-named in the Honorable Civil Court, ______________against Caveator in
connection with the Loan granted to Shri ______________ by the Opponent Bank
without due notice of the proposed Suit/Application to the Caveator above-named.
2. The address of the Caveator for service of notice/summons of the proposed
suit/application of the Opponent above named is as per the title clause of this
application.
3. The Caveator undertakes to serve a copy of this application by Registered
Post A.D. to the Opponents above-named.
4. Fixed Court fees stamp is affixed to the Caveat application.
Filed in the Court

On _____________________
PLACE:

CAVEATOR Advocate for Caveator

29
15. CONTEMPT PETITION
BEFORE THE HON'BLE CENTRAL ADMINISTRATIVE TRIBUNAL TN AT CHENNAI
Contempt Petition No.:______ of 2004 in O. A. No: ______
Petitioner/Applicant
Versus

Respondents/Condemner
Civil Contempt Petition under Section 17 of the Administrative Tribunals
Act, 1985 read with Rules 18 of the Central Administrative Tribunals (Contempt of Court
Rules) 1986 and Section 12 of the Contempt of Courts Act, 1971 for punishing the
condemners/respondents for having willfully and deliberately disobeyed and not complied with
the orders/directions passed by this Hon'ble Tribunal Chennai
Applicant
______

Through, Advocate

Respectfully Sheweth:

1. That the petitioner filed an OA No. ___ titled as ______Vs ______ before this Hon'ble
Tribunal and this Hon'ble Tribunal was pleased to pass the orders on __ (Annexure C-1)
directing the respondents ______.

2. That it is apparent from the above directions passed by this Hon'ble Tribunal that the order
was comprehensive, unambiguous and clear in directing the respondents/condemners to
______

3. That the above orders of this Hon'ble Tribunal were personally served by the applicant on
the condemner on ______. Service of the above orders were complete on the condemners.
Despite this the condemner has not ______.

4. That it is evident from the foregoing that in this way the condemner has committed
contempt of this Hon'ble Tribunal for which the condemner deserves to be punished severely
in accordance with the law in the interest of justice.

5. That the condemner has purposely, willfully and knowingly disobeyed the sacrosanct orders
of this Hon'ble Tribunal, thereby have conducted himself in the most reprehensible and
unbecoming manner showing scant regard to the orders of this Hon'ble Tribunal which
conduct on the part pf the condemner is palpably, manifestly and gravely contumacious and
makes the condemner liable to be dealt with in accordance with the law and punished severely
for willfully, deliberately and intentionally flouting, defying and disobeying the supreme
authority of this Hon'ble Tribunal.

AND FOR THIS ACT OF KINDNESS, THE HUMBLE PETITIONER AS IN DUTY BOUND,
SHALL EVER PRAY.
Chennai Applicant

______ Through, Advocate

30
 CONVEYANCING
1. Model Deed of Simple Mortgage
This Deed of simple Mortgage is made and executed on this the 12 th day of January 2013 at
Chittoor.
BETWEEN
Sri venkateswar Rao, S/o Sri Tirumaleswar Rao, Aged about 45 years, Occupation: Business,
Address: 1-2A, Sri Nagar Colony, Chittooor-517001,
AND
Sri Rangachari, S/o. Sri Venkatachari, aged about 40 years, Occupation:
Government employee, Address: H.No, 1-5-7, Durga Nagar Colony, Tirupati.

WHEREAS the mortgagor her in is the absolute owner and possessor of the house building
property hearing House No. 1-2A, situated at Sri Nagar Colony, Chittoor-517001. A.P.
consisting of a plinth area of 1200 Sq.ft. Constructed on a total landed area of 300 Sq.yds.
WHEREAS the nature of the mortgage is by way of simple mortgage and therefore the
mortgagor agreed to bind himself personally to repay the mortgage money.
NOW THIS DEED OF MORTGAGE WITNESSETH AS FOLLOWS:
1) In pursuance of the said offer and acceptance by and between the parties and in
consideration of the sum of Rs, 10 lakhs (Rupees Ten lakhs only) now paid to the
mortgagor by the mortgagee, the receipt of which sum is hereby acknowledged by the
mortgagor, undertakes to repay the sum of Rs. 10 lakhs (Rupees ten lakhs only) with
interest at the rate of 8% per annum within a period of three years from the date of this
mortgage and if he fails to do so within the said period, the mortgagee shall be entitled
to enforce against the said mortgage property all or any of the remedies available in
law relating to simple mortgage.
SCHEDULE OF THE PROPERTY
All that part and parcel of house building property bearing Municipal N0. 1-2A
situated at Sri Nagar Colony, Chittoor District Chittoor-517001. A.P. consisting of a plinth
area of 1200 sft. Constructed on a total landed area of 300 Sq yds. And bounded by-
North: Neighbour’s house bearing No. 1-11
South: 30 feet public Road
East : Neithbour’s house bearing No. 1-14
West : 15 feet public Road.
In witness whereof the parties herein have put their and signed this deed of simple
mortgage on the day, month year and place a aforementioned with their free will and
consent and without any coercion or fraud in the presence of the following witnesses.
Witnesses:
Sd/- Sd/-
1. S. Prasad (Mortgagor)
H.No. 3-3-55 Sd/-
Sri Nagar Colony (Mortgagee)
Chittoor-517001.
Sd/-\

31
 2. LEASE DEED
THIS DEED OF LEASE, is made and executed on this the 11th day of September
2013 at Chittoor by and between Sri Venkateswar Rao, S/o. Sri Tirumaleswar Rao, Aged
about 45 years, occupation: Business, Address: 1-2A, Ashok Nagar, Chittoor-
517001.A.P.(hereinafter referred to as the “LESSOR” which expression shall mean and
include all his successors/survivors/legal heirs/ representatives/assignees etc.) as the first
party.

AND
Sri Rangachari, S/o. Sri Venkatachari, aged about 40 years, Occupation: Government
employee, Address: H.No. 1-5-7, Gandhi Nagar, Chittoor-517001, A.P.(hereafter referred to
as the “LESSEE” which expression shall his given in the schedule provided herein below).
WHEREAS the lessee herein has agreed to take the said scheduled property in
lease for the said rent and refundable deposit accordingly.
In pursuance of the above offer and acceptance the parties herein have entered
into present deed of lease based on the following terms and conditions.
NOW THIS DEED OF LEASE WITNESSTH AS FOLLOWS:
1) That the lessor herby delivered on lease to the lessee the vacant and peaceful possession
of the said scheduled property for his occupation and enjoyment to enjoy the same as
the lessee subject to the terms and conditions specified herein.
2) That the lessee has to pay the monthly rent regularly at the rate of Rs. 3,000/- on or
before 5th of every month without fail.
SCHEDULE OF THE PROPERTY
All that part and parcel of house building property bearing Municipal No. 1-2A,
situated in Ashok Nagar, Chittoor-517001, A.P. consisting of a plinth area of 1200 sft.
Constructed on a total landed area of 300 sq. yds. And bounded by-
North: Neighbor’s house bearing No. 1-11
South: 30’ Public Road
East: Neighbor’s house bearing No. 1-14
West: 15’ Public Road.
In witness whereof parties herein have put their hands and signed this deed of lease
on the day, month, year and place aforementioned with their free will and consent and
without any coercion or fraud in the presence of the following witnesses.
Witnesses:
Sd/- Sd/-
(Lessor)
1. S. Rama Rao Sd/-
H.No. 36/3/A
Ashok Nagar (Lessee)
Chittoor-517001.

Sd/-
2. K. Vekat Rmana
H.NO. 5-4-23
Ashok Nagar
Chittoor-517001.

32
 3. GIFT DEED
THIS DEED OF GIFT is made and executed on this the 13th day of 2014 at chittoor.
BETWEEN
Sri Venkateswar Rao S/o. Sri Tirumaleswar Rao, Aged about 72 years, Occupation;
Business, Address: 1-2A, Ram Nagar, Chittoor-517001, A.P. (hereinafter referred to as the
“DONOR” which expression shall mean and include all his successors/survivors/legal
heirs/representatives/assignees etc. as the first party)
AND
Sri Rangachari, S/o Sri Venkateswar Rao, Aged about 40 years, occupation: Government
employee, Address: H.No. 1-5-7, Gandhi Nagar, Chittoor-51700, A.P.(hereinafter
referred to as the “DONEE" which expression shall mean and include all his successors,
survivors, legal heirs/representatives/assignees etc. as the second party.)
WHERE the mortgagee herein is the absolute owner and possessor of the house
building property bearing House No. 1-2A, situated at Ram Nagar, Chittoor-51700, A.P.
Consisting of a plinth area of 1200 Sft. Constructed on a total landed area of 300 Sq. Yds.
(hereafter referred to as the said scheduled given below and also earmarked in RED ink
in the plan annexed hereto)
WHEREAS the done herein is the natural born only son of the donor.
WHEREAS the done having been married and residing separately from the donor is
in need of a residential house.
SCHEDULE OF THE PROPERTY
All that part and parcel of house building property bearing Municipal No. 1-
2A situated in Gandhi Nagar Chittoor-51700, AA.P. Consisting of a plinth area of
1200 sft. Constructed on a total landed area of 300 Sq. YDS. And bounded by-
North: Neighbor’s house bearing No. 1-11
South: 30 feet public Road.
East: Neighbor’s house bearing No. 1-14
West: 15 feet public Road.
In witness whereof, the parties herein have put their hands and signed this
deed of gift on the day, month, year and place a fore mentioned with their free will
and consent and without any coercion or fraud in the presence of the following
witnesses:
Witnesses: Sd/-
(Donor)
1. S. Rajaiah
H.No.10-2-A Sd/-
RamNagar, Chittoor-517001 (Donee)
2 K.S. pratap
H.No. 13-2-A
Ram Nagar.
Chittoor-517001.

33
 4. PROMISSORY NOTE
On demand, I, Deshmukh Kirpal, S/o. Sri Shyam Kirpal, aged about 50
years, Hindu, Occupation: Business, residing at H.No. 90/A/3, Sai Nagar Chittoor
District, A.P., promise to pay to sri Nagaraj, S/o. Raghavendra, aged about 48 years,
Occupation: Government servant, residing of H.No. 95/A/4, Sai Nagar Chittoor District,
A.P.., or to his order the sum of Rs. 50,000/- (Rupees fifty Thousand only) for value
received.
Place: Chittoor
Date: 13-8-2014 Sd/-
(Executor)

5. DEED OF GENERAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS THAT I, Venkateswar Rao, S/o sri
Rangachari, S/o. Tirumaleswar Rao, aged about 45 years, Occupation: Business,
Address: H. No. 1-2A, Sree Nagar, Chittoor-517001, A.P., do hereby appoint Sri
Rangachari, S/o. Sri Venkachari, Aged about 40 years, Occupation: Government
Employee, Adress: H.No. 1-5-7, Padmavathi Nagar, Chittoor-517001, A.P., as may
ATTORNEY in my name and on my behalf to do and execute all or any of the acts, deeds
and things mentioned herein below, as I am not able to undertake the same personally
due to my unavoidable per-occupations.
WHERAS I am the owner and possessor of House building property bearing
Municipal No. 1-2A, Sri Nagar, Chittoor-517001. A.P, The detailed description of which
is shown in the Schedule given below (hereinafter referred to as the said scheduled
property).
WHERAS I am in need of funds and therefore would like to sell away the said
property to any intending purchaser for a total sale consideration of Rs. 10 lakhs (Rupees
Ten lakhs only).

HEREAS the said Sri Rangachari, S/o. Sri Vekatachari, has agreed to act as my
attorney holder the general power to sell away the said property for the said sale
consideration to any intending purchaser.
NOW THIS DEED OF GENERAL POWER OF ATTORNEY WITNESSETH AS
FOLLOWS:

34
 I hereby authorized my said power of attorney holder to do execute all or any of the
following acts, deeds and things:
i) to offer and enter into any agreement for sale of said scheduled property with
any intending purchaser for a total sale consideration of Rs. 10 lakhs (Ten
lakhs only):
ii) to deal or correspond and settle the issues, if any, with any of the Government
or other authorities or bodies for and on my behalf in relation to said scheduled
property for the transfer of a better title to the intending purchaser;
iii) to receive the total sale consideration either in full or in instalments fixed
mutually to issue necessary receipt there for to the intending purchaser and to
hand over the said amount to me accordingly;
iv) To obtain encumbrance certificate and other relevant documents from the
concerned authorities in respect of the said scheduled property and to hand
over the same to the intending purchaser for his personal satisfaction as to the
rights and titles of the said scheduled property.
In witnesseth whereof I have signed this deed of General Power of Attorney the 11th
day of September 2013 at Chittoor with my free will and consent.
In witnesseth whereof I have signed this deed of General Power of Attorney the 11th
day September 2013 at Chittoor with my free will and consent.
Witnesses:
Sd/- Sd/-
1. V. Narasingh Rao (Executant)
H.NO. 4-5-210 (Holder of the power of
Chittoor-517001. Attorney)
Sd/-
2. K. Laxman Reddy
H.No. 565/A/2
Sri Nagar
Chittoor-517001.

K. Ramakrishna Phone: 25980765

Advocate Cell: 25809879483
H.No. 3/1/A/5
Durga Nagar Date 30 th june 2014
CHITTOOR-517001.

35
 6. LEGAL NOTICE
On the instruction of my client Sri Rangachari, S/0. Sri Venkatachari
Aged about 40 years, Occupation employee, Address: H.No.1-5-7, Bazaar Street, Chittoor-
517001, A.P., I issue the following legal notice for compliance:
1) That my client and yourself have entered into an agreement for sale dated 20 th
January 2013 in respect of your House building property hearing Municipal No, 1-
2A, Nehru Street, Chittoor=517002, A.P., consisting of a plinth area of 1200 sft
constructed on a total landed area of 300 sq. Yds with constructed plinth area of
1200 sft.
2) That as per the terms of the said agreement you are required to accept the balance
sale consideration of Rs. Lakhs 9Rupees Five lakhs only) and to execute a regular
sale deed in favour of client within the period of six months from the date of
execution of the said agreement.
3) That inspire of lapse of nearly one year, you have not come forward to perform
your part of the contract for sale in respect of the said property.
Please also arrange to send a sum of Rs. 500/- (Rupees Five Hundred only)
towards cost of issuing the present legal notice immediately.

Yours faithfully,
Sd/-
(Advocate)

36
 7. RELINQUISHMENT DEED
THIS DEED OF RELINQUISHMENT is executed at Delhi this 3th day of July 2013 BY
1. Smt. Anuradha wife of Sri. Srinivasulu daughter of late Sri. Govandaiah, residence
of 2-13, Bazar Street Chittoor-517003.
2. Smt. Rekha wife of Sri.munirathanam, daughter of late Sh. Ramesh, residence of 3-
14, vinayaka temple street, Chittoor-517004.
3. Smt. Manjula, wife of Sri. Ravikumar, daughter of late Krishna kumar, residence of
4-13-5, Lakshminagar colony, Chittoor-517005.
4. Sh. Madhu son of late Sri.Balaiah. residence of Gandhi Nagar, Chittoor, herein after
called ‘the RELEASORS’ which expression shall, unless repugnant to the context of
meaning hereof, mean and include their heirs, successors, legal representatives and
executors, of the FIRST PARTY;

NOW THIS DEED OF RELINQUISHNMNET WITNESSES AS UNDER.

1. That the Releasors voluntarily, without any outside influence from any side and
their full senses give-up and release all their right title and interest in property No.
234, at Chittoor, along with the land beneath the same measuring 330 sq. yds in
favour of their 4/5th share without taking or receiving any consideration from them
to the extent of their 4/5 th share and now the Releasee is the absolute and the sole
owner of the above mentioned property in to (4/5th share of the Releasors and 1/5
share of the Releasee herself).
2. That the Releasors, their heirs, successors and assigns have been left with no claim,
title or interest in the property herby relinquished and the Release is the sole and
absolute owner thereof.
3. That the possession of the above-mentioned property is exclusively with the
Releasee and the Releasee is entitled to continue the same.
4. That the Release is fully entitled to get the above-mentioned property mutated and
transferred in her name on the basis of this deed of relinquishment.
5. That the original sale-deed and other relevant papers regarding the above-
mentioned property are with the Releasee.

IN WITNESS WHEREOF the Releasors and the Releasee

Set their respective hands to this deed of Relinquishment
at Chittoor on the date mentioned above.

RELEASORS
1. Anuradha
2. Rekha
3. Manjula
4. Madhu
RELEASEE
Witnesses
1. Hari Babu
2. Venkatesh

37
 8. PARNERSHIP DEED
THIS DEED OF PARTNERSHIP made at Delhi this 23 rd day of 2013.
Between: Sh.Mohan son of Sh. Govindaiah, residence at Gandhi Nagar, Chittoor-
517002, of the one part which expression shall mean and include his heirs, successors
executors and legal representatives.
AND:
Sh. Dooraswami, son of Ragupathi, residence of Ashok Nagar Chittoor-517002, Of
the other part which expression shall mean and include his heirs, successors, executors
and legal representatives;
Recitals:
WHEREAS as party of the one part and the party of the other part have decided to
enter into a partnership business upon the terms and conditions herein contained;
NOW THEREFORE THESE PRESENTS WITNESSETH and it is hereby agreed
between the parties as follows:
Commencement of partnership;
1. This Deed of Partnership shall be deemed to have come into force with
effect from the first day of April 2013
Nature of business:
2. The partnership business shall be of dealing in sale, purchase and
manufacture of dyes and chemicals and /or such other business as may be
decide by the partners from time.
Nature of Partnership:
3. The partnership shall be carried on in the name and style of “Mohan &
sons”.
4. The partnership shall be a partnership at will.
Place of Business:
5. The partnership business shall be conducted at Delhi, and/or at such other place
of places as shall be agreed to by the partners from time to time.
Capital:
6. The partner shall equally invest initially Rs. 2.00, 000/-, and the amounts so invested
by the partners shall form the capital of the partnership and the same shall be used as
per these presents in the partnership business.
7. Further capital, if any, required by the partnership shall be obtained from time to
time by the partnership by way of loans, bundies or otherwise from outside on payment
of interest at the market rate and such interest shall be paid out of the partnership
funds, irrespective of profits and losses of the said business.
IN WITNESS WHEREOF the partners hereto have signed this document on the date
first hereinabove written in the presence of the following witnesses.
Party of One Part
Party of Other Part
Witnesses
1. Ramu
2. Srinivas

38
 9. MODEL DEED OF PARTITION/FAMILY SETTLEMENT

One Mr. Srikanth aged about 65 years had two sons and two daughters namely, varun,
vivek, sindhu, sandhya aged about 40 years, 38 years, 35 years and 32 years respectively.
They own a coparcenary property consisting of two houses with three floors and two floors
respectively bearing Municipal Nos. 23 and 24 situated at Malakpet, Hyderabad-500 036.
Differences arose and therefore they wanted to live separately by mutual agreement. Draft
a partition Deed.

DEED OF PARTITION
THIS DEED OF PARTITION is made and executed on the 14th day September,
2006 at Hyderabad by and between:
1. Sri V. Srikanth, son of Shri Veeraiah, aged about 65 years, occupation: Business,
Address: H.No. 23, Old Malapet, Hyderabad-500 036,
2. Sri S. Varun, S/o. V. Srikanth, aged about 40 years, Occupation:
Employee, Address: H.No 23, old Malakpet, Hyderabad-500 036.
3. Sri S. Vivek, S/o. V. Srikanth, aged about 40 years, occupation, Employee, Address:
H.No. 23, Old Malakpet, Hyderabad-500 036.
4. Smt, Sindhu, W/o Sri Prakash, aged about 35 years, House wife, Address: H.No,
205/3.
5. Smt. Sandhya, W/o, Sri Krishna aged about 32 years, House wife, Addreess: H. No.
34-1-A, Old Malapet, Hyderabad-500 036.
Wheras Sri Srikanth, father of the parties 2to 5 owns and possess the following joint
family properties:

Sd/-
1. Srikanth
2. Varun
3. Vivek
4. Sindhu
5. Sandhya

Witnesses:
Sd/-
1. S.S. Rajaiah
H.No. 15
Old Malakpet
Hyderabad-500 036.
Sd/-
2. K.S. Pratap Reddy
H. No. 13
Old Malakpet
Hyderabad-500 036.

39
 10. INDEMNITY BOND (IN THE FORM OF AGREEMENT)
This agreement, etc.,
Whereas by a deed of lease dated the…the said CD demised certain land to the said
AB and on XY, since deceased, for term of nine years from…;
And whereas one of the conditions entered in the said lease was that during first
years the said CD will not require the said lessees to pay rent for uncultivated land;
And whereas though the whole of the demised land was not cultivated during the
first year, full rent for that year was realized by the said CD on the alleged ground that the
aforesaid condition was not intended to apply to this lease, and that it was by an accidental
omission that the same not scored out of the printed form of lease before execution;
And whereas the said AB and XY served a notice on the said CD threatening to file
a suit against the said CD for refund of the amount of rent so realized from them in
violation of the aforesaid condition;
And whereas the said XY died leaving behind him as his heirs two minor sons KL
and MN who are under the natural guardianship of their mother PQ;
And whereas the said AB and the PQ on behalf of the said minor sons KL and
MN have withdrawn the aforesaid notice and have agreed to forgo their claim for the said
refund on the said CD agreeing to revise the term of the said lease and to extend the same
from nine to twelve years.
And whereas in consideration of the aforesaid agreement of the said CD from
any claim which the said minor sons of the said XY may instituted for refund of the said
amount of rent in spite of the said PQ relinquishing the same on their behalf.
Now these presents, witness that in pursuance of thee said agreement and for the
consideration aforesaid the said AB hereby agrees always to indemnify and keep harmless
the said CD from any claim which the aforesaid KL and MN or either of them or their
respective successors or assigns or any of them may at any time institute for refund of any
part of the rent paid by the said AB and XY for the year… under the aforesaid deed of lease
dated the…
In witness thereof, etc.,

40
 11. DEED OF ASSIGNMENT OF DEBT UNDER A DECREE
THIS DEED OF ASSIGNMENT OF DEBT UNDER A DECREE made and executed
this the…day of…2004,
BY
(A) Son of… aged…years…resident of…occupation…(hereafter called the Assignor)
which term shall, unless the context otherwise requires include his heirs, executors,
administrators, legal representatives and assigns of the one part;

(B) Son of… aged … years, resident of …occupation…(hereinafter called the Assignee)
which term shall, unless the context otherwise requires, include his heirs, executors,
administrators, legal representatives and assigns of the other part.

WHEREAS in O.S.No…on the file of subordinate Judge Court…the Assigner

secured a simple money decree for Rs.50,000/-(Rupees fifty thousand only) against
(c ), son of aged…years, resident of…(hereinafter called the judgment-Debtor);
AND WHEREAS the Assignor has not so far filed an execution petition against the
judgment-Debtor for realizing the money due to him under the aforesaid decree;
AND WHEREAS the Assignor is in immediate need of money and apprehends
delay in realization of the decretal amount even if an execution petition is filed;
AND WHEREAS the Assignor is in immediate need of money and apprehends
delay in realization of the decretal amount even if an execution petition is filed;
AND WHEREAS the Assignee has agreed to pay a sum of Rs 45,000/- in
consideration of the beneficial interest of the said decree, if the same is transferred to
him;
NOW THIS DEED OF ASSIGNMENT WITNESSETH:
(1) the Assignor has received a sum of Rs 45,000/- (Rupees forty five
thousand only) from the Assignee the receipt of which he hereby
acknowledges in consideration of transferring the beneficial interest under
the said decree to the Assignee; and
(2) that the assignor hereby transfers to the Assignee all the beneficial
interest with interest and all the rights and benefits accruing under the
said decree to the Assignee.
In witnesses whereof (A) AND (B) above named have set their hands and
seal in the presence of witnesses:

1. Signature of (A)
Assignor
2. Signature of (B)
Assignee

41
12. ASSIGNMENT OF COPYRIGHT IN A BOOK FOR LUMPSUM
This Assignment is made on the… day of ….. BETWEEN…….(assignor) of (address
etc.,), hereinafter called the assignor of the one part and (assignee) of (address etc.,).,
herein after called the assignee of the other part.
Whereas the assignee wishes to acquired and the assignor is willing to grant unto
the assignee the copyright in a book entitled…(hereinafter called the work) throughout
the world upon terms and conditions hereinafter appearing.
NOW THIS ASSIGNMENT WITNESSETH as follows:
1. In consideration of the sum of Rs….now paid by the assignee to the assignor (the
receipt whereof the assignor hereby acknowledges) the assignor as beneficial owner
hereby assignees to the assignee the copyright and rights in the nature of Copyright
in the work throughout the world TO HOLD the same unto the assignee absolutely
for the full period of copyright and rights in the nature of Copyright and all renewals
and extensions thereof.
2. The assignor hereby warrants that:
(a) the assignor is and all times during the writing of the work was an Indian,
subject ordinarily resident of India;
(b) The assignor is the owner of the Copyright and the rights in the nature of
Copyright in the work which is original in the assignor and does not infringe
upon the right of any third party;
(c) to the best of the assignor’s knowledge and belief the work is not defamatory;
(d) he assignor is entitled to enter into this assignment and has not previously
encumbered the said Copyright so as to derogate.

(e) The assignment will at the request and expense of the assignee do all such future
acts deeds and things and execute all such future Documents and instruments
from time to time necessary to vest the said copyright and rights in the nature of
Copyright in the assignee and for protection and enforcement of the same.

3 the assignor hereby covenants with the assignee that the assignor will keep
the assignee indemnified from and against all actions proceedings damages
incurred or awarded and paid in respect of or arising out of any breach or
non performance of any of the warranties on the part of the assignor herein
contained or out of any claim by a thir party based on any facts which if
substantiated would constitute a branch or non performance of such
warranties.
4 The assignee shall have the right to assign the benefit of this assignment to
any third party.

WITNESSES (with addresses) (Signature of both

Parties)
1. ……….. Assignor
2. ……….. Assignee

42
 13. DEED OF EXCHANGE
(adjusting boundaries of adjoining lands)
This Deed of Exchange is made on…. In the city of…… between AB of….hereinafter
called “party No.1 CD of……hereinafter called “party No.2” on the terms mentioned
below :
Whereas the lands of party No. 1 and party 2 adjoining together
village…..tehsil…..district …..,the boundary line between the said land being uneven; and
Whereas the value of the parcel being included in the land of AB is greater owing
to its area being larger than the parcel of land which is being conveyed by the party No.2
in exchange, and the parties have agreed that party No.1 accordingly by shall pay Rs…. to
party No 2 to equalize the value of the land being so exchanged;
Now, therefore, in consideration of the premises and terms of exchange hereby
arranged the parties have agreed that the boundary line between the land aforementioned
of two parties as delineated on the plants P and P1 annexed hereto shall be JKMN as
shown therein instead of the blue irregular line originally existing heretofore therein and
to effectuate the said purpose the first party hereby transfers and conveys by way of
absolute assignment all that parcel of land coloured red in the plans P and P1 measuring
about…..kanal….morals……ft. comprised in khasra No…..of jamabandi for ear….to the
second party to have and to hold the same unto the said second party absolutely and
forever for himself and his heirs, assigns and legal representatives.
The original deed of exchange so registered shall remain in possession of
the first party. Who shall be bound to keep it is safe custody and shall be bound to
produce the same when requisition for inspection or production before any authority or
court. The plan P which is an exact copy of plan P1 and is signed by both parties, shall be
delivered in original to the second party.
In witness whereof the parties aforementioned have executed this deed
and have signed the plans P and P1 in token of being bound by terms thereof.

Witness…….. ------------
First party
Witness……… ---------

Second party

43
 14. TRUST DEED FOR THE BENEFIT OF SETTLOR
This deed of trust executed by AB, son of X, aged about…. Years, resident of…. Occupation
agriculturist (hereinafter called the author of the Trust) of the one part and CD, son of Y,
aged about… years, resident of…. (hereinafter called the Trustee)of the other part.
Whereas the author of the Trust is the owner of the agricultural lands admeasuring 14
acres at Korukonda Village, Korukonda Mandal, East Godavari District more clearly
described in the Schedule (hereinafter called the Scheduled properties);
And whereas the author of the Trust is a paralytic patient residing at Rajahmundry and is
not able to look after the lands in a prudent manner and his son aged about 13 years is a
student at Rajahmundry and is therefore not able to assist his father in the management of
the Scheduled properties;
And whereas the author of the Trust has decided to create a Trust for the scheduled
properties for their management during his lifetime and appoint CD as the Trustee for
which the latter has agreed.
Now, therefore, this deed of Trust witnesseth:
(1) The author of the Trust hereby conveys the Scheduled properties to the Trustee for
his prudent management thereof without any hindrance or conditions;
(2) The trustee shall pay a sum of Rs.1,000/- a month to the author of the Trust for his
maintenance;
(3) The trustee shall be entitled to annually take 25bags of paddy from the produce of
the trust property as his remuneration in addition to the transport charges he incurs
for going to korukonda for the management of the trust properties;
In witness where of etc.
Witnesses:

1. (Sd/-)AB
Author of the truest
2. (Sd/-) CD
Trustee.

44
 15. DEED OF ADOPTION
This Deed of Adoption executed by……….son of Hindu aged about………..years
and residing at……….
Witnesses I have no children and whereas I am fairly old and of opinion that I will
not have any issue hereafter and whereas I desire to adopt a son for performing the
ceremonial rites after my death and succeed to my properties which are all self
acquired.
I hereby, adopt………son of……….residing at aged about ……..as my son, I have
adopted the said…….as my son with the full consent of his parents who are also
related to me. Here after the said …………shall be deemed to be my law full right
on my properties, movable and immovable, and shall perform the obsequies after
my death. This Deed of adoption is executed by me in a sound disposing state of
mind and out my own accord without the pressure of any body. This adoption has
also got full body. This adoption has also got full consent of my wife.
It witness where of I have set my hand this the…….day of ……2014.
Executant

Witnesses.

45