In The Court of Hon'Ble High Court of Madhya Pradesh, Principal Bench, Jabalpur (M.P.)

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IN THE COURT OF HON'BLE HIGH COURT OF MADHYA

PRADESH, PRINCIPAL BENCH, JABALPUR (M.P.)

Caveat No.             /2022

Nasir Ahmad Wani


S/O Shafeeq Ahmad Wani
Aged about 34 years,
R/O H. No. 262, Mohammadiya Colony,
Bemina, Srinagar (J&K) ……….……Petitioner / Caveator

-Versus-

1. Shiv Sharma alias Aashiya Wani


W/o Nasir Ahmad Wani
Currently R/O 33/B, Vikas Nagar,
Near Royal Higher Secondary School,
Govindpura, Bhopal (M.P).

2. Dr. Shakti Sharma


W/O Late K.C. Sharma
R/O 170, Jawahar-Nagar.
Neemuch, (M.P.) ………Respondents / Caveatees

INDEX

S. No Particulars Page No.

1. Index 1-2

2. CAVEAT Petition filed u/s 148 (a) 3-4

3. Prayer 4-5

1
4. Affidavit 6

5. List of Documents 7

6. Vakalatnama 8-9

Petitioners / Caveators
PLACE:
DATED: Through COUNSEL:
1. SRISHTI SURYAVANSHI
2. RAHUL MACHEVAR
(Advocate)

IN THE COURT OF HON'BLE HIGH COURT OF MADHYA


PRADESH, PRINCIPAL BENCH, JABALPUR (M.P.)

Caveat No.             /2022

Nasir Ahmad Wani


S/O Shafeeq Ahmad Wani
Aged about 34 years,
R/O H. No. 262, Mohammadiya Colony,
Bemina, Srinagar (J&K) ……….……Petitioners / Caveators

-Versus-

1. Shiv Sharma alias Aashiya Wani


W/o Nasir Ahmad Wani
Currently R/O 33/B, Vikas Nagar,
Near Royal Higher Secondary School,
Govindpura, Bhopal (M.P).

2. Dr. Shakti Sharma

2
W/O Late K.C. Sharma
R/O 170, Jawahar-Nagar.
Neemuch, (M.P.) ………Respondent / Caveatee

CAVEAT PETITION FILED UNDER SECTION 148 (A) R/W ORDER 52 OF C.P.C

Most respectfully showeth:


1. That the Caveator is the Citizen of India as such is entitled to invoke the extraordinary
jurisdiction of this Hon'ble Court for the redressal of his legitimate grievances & has
every right to approach this Hon'ble Court with this instant Caveat Petition seeking,
safeguard, protection & enforcement of his legal, fundamental & Constitutional rights
available under the Constitution & law of the land governing the subject matter.
2. That the Non-Caveators have filed Various Petitions in the state of Jammu & Kashmir
and in the State of Madhya Pradesh at various grievance redressal forums with false,
frivolous, bogus and Vague allegations, Caveatees are chronic litigants and are habitual
of filing contrived complaints against the Caveator. (Copies of Complaints filed by
Caveatee in the State of Jammu & Kashmir are attached as ANNEXURE – I and Copies
of complaints filed in the state of Madhya Pradesh are attached as ANNEXURE – II )
3. That caveator has reasons to believe/apprehend that Non- Caveator may file or
challenge or put in question any order passed by any Hon'ble Count by filing Appeal,
Petition, Revision, or any other type of proceedings or may file a separate writ petition on
the ground of distorted facts/ misrepresentation and cooked up story and may succeed
in obtaining some relief/order at her back/ ex-parte against the Caveator and in such
eventuality the Caveator will be put to an irreparable loss and inconvenience.
4. That the interests of justice demand that no order in ex-parte be passed without giving
an opportunity of being, heard to the Caveator through his Counsels or the Caveator
himself, depriving of the right of being heard will put the caveator exposed to irreparable
loss & in-convenience and may be condemned unheard.
5. Affidavit in support of the caveat petition is appended.
6. That the Caveator apprehends that the Caveatee may institute a suit with false
allegations against the Caveator and they may try to obtain ex-par tee order against
the Caveator. The Caveatee may come to the Hon’ble court at any time with a false
suit. Therefore, the Caveator is forced to file this caveat petition.
7. Let nothing be done without notice to the Caveator in respect of any suit or
application likely to be filed by the Caveatee against the Caveators. The Caveators

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undertake to serve the caveat notice to the Respondents through registered post with
acknowledge due.
8. A fixed court fee of Rs. /- is herewith paid.

PRAYER

It is most humbly prayed that in view of the facts mentioned above and this
honorable court may in the interest of justice :
1. That this Hon’ble court may be pleased to lodge this caveat in the above matter.
2. That in a condition where the Caveatee files any Petition /Complaint, Appeal, Revision
or any other prayer against the Caveator this Hon’ble court may be pleased to inform
the Caveator and be given an opportunity to hear the other side before passing any
order.
3. That this Hon’ble Court may be pleased to direct the Caveatee to legally and effectively
inform this Hon’ble court and the caveator before initiating any legal proceedings
against the Caveator.
4. Pass any other and further order as this Hon’ble court may deem fit and proper under
the facts and circumstances of this case

VERIFICATION

Verified on this ______ day of _______2022, that the facts stated in paras 1 TO 8
hereinabove are true to my personal knowledge. No part of this Application is false and
nothing material is concealed there from.

DEPONENT
Petitioners / Caveators
PLACE:
DATED: Through COUNSEL:
(1) SRISHTI SURYAVANSHI
(2) RAHUL MACHEVAR

4
IN THE COURT OF HON'BLE HIGH COURT OF MADHYA
PRADESH, PRINCIPAL BENCH, JABALPUR (M.P.)

Caveat No.             /2022

Nasir Ahmad Wani


S/O Shafeeq Ahmad Wani
Aged about 34 years,
R/O H. No. 262, Mohammadiya Colony,
Bemina, Srinagar (J&K) ……….……Petitioners / Caveators

-Versus-

1. Shiv Sharma alias Aashiya Wani


W/o Nasir Ahmad Wani
Currently R/O 33/B, Vikas Nagar,
Near Royal Higher Secondary School,
Govindpura, Bhopal (M.P).

2. Dr. Shakti Sharma


W/O Late K.C. Sharma
R/O 170, Jawahar-Nagar.
Neemuch, (M.P.) ………Respondent / Caveatee

AFFIDAVIT

1. I Nasir Ahmad Wani S/O Shafeeq Ahmad Wani Aged about 34 years/O H. No. 262,
Mohammadiya Colony, Bemina, Srinagar (J&K).
2. I hereby give in writing on affidavit that the facts stated in paras 1 TO 8 and the
statement stated in the prayer from Para 1 to 4 hereinabove are true to my personal

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knowledge. No part of this Application is false and nothing material is concealed there
from.

DEPONENT

VERIFICATION

Verified on this _____ day of ______________2022 that the facts stated in paras 1 to 2
hereinabove are true to my personal knowledge, no part of this Affidavit is false and nothing
material is concealed there from.

DEPONENT

IN THE COURT OF HON'BLE HIGH COURT OF MADHYA


PRADESH, PRINCIPAL BENCH, JABALPUR (M.P.)

Caveat No.             /2022

Nasir Ahmad Wani


S/O Shafeeq Ahmad Wani
Aged about 34 years,
R/O H. No. 262, Mohammadiya Colony,
Bemina, Srinagar (J&K) ……….……Petitioners / Caveators

-Versus-

1. Shiv Sharma alias Aashiya Wani


W/o Nasir Ahmad Wani
Currently R/O 33/B, Vikas Nagar,
Near Royal Higher Secondary School,
Govindpura, Bhopal (M.P).

2. Dr. Shakti Sharma


W/O Late K.C. Sharma
R/O 170, Jawahar-Nagar.
Neemuch, (M.P.) ………Respondent / Caveatee

LIST OF DOCUMENTS

6
S.N NAME OF DOCUMENT ATTACHED AS
o
1. Copies of Complaints filed in ANNEXURE - I
Jammu & Kashmir.
2. Copies of complaint filed in ANNEXURE - II
Madhya Pradesh.

Petitioners / Caveators
PLACE:
DATED : Through COUNSEL:

1.SRISHTI SURYAVANSH
2. RAHUL MACHEVAR

VAKALATNAMA
IN THE COURT OF HON'BLE HIGH COURT OF MADHYA PRADESH, PRINCIPAL BENCH, JABALPUR (M.P.)

Caveat No.             /2022

Nasir Ahmad Wani


S/O Shafeeq Ahmad Wani
Aged about 34 years,
R/O H. No. 262, Mohammadiya Colony,
Bemina, Srinagar (J&K) ……….……Petitioners / Caveators

-Versus-

1. Shiv Sharma alias Aashiya Wani


W/o Nasir Ahmad Wani
Currently R/O 33/B, Vikas Nagar,
Near Royal Higher Secondary School,
Govindpura, Bhopal (M.P).

2. Dr. Shakti Sharma


W/O Late K.C. Sharma
R/O 170, Jawahar-Nagar.
Neemuch, (M.P.) ………Respondent / Caveatee

I/We the A Applicant, Appellant, Petitioner or Non-Applicant, Respondent, Defendant named below do hereby
appoint, engage and authorize advocate(s), named below to appear act of plead in a aforesaid case/proceessings, which
shall include application for restoration, setting aside of exparty orders corrections, modifications, review and recall of
orders passed in these proceedings, in this court in which the same may be tried/heard/proceeded with and also in the
appellate, revision or executing court in respect of proceedings as per agreed terms and conditions and authorize
him/them to sign and file pleadings appeals cross objections, petitions, applications, affidavits or other documents as may

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be deemed necessary or proper for the prosecutions/deference of the said case in all its stages and also agree to rectify
and confirm act done by him/them as if done by me/us.

In witness where of I/We do hereby set my/our hand to these present, the contents of which have been duly
understood by me/us this ………….. day month of ………………. 201…………

PARTICULARS OF EACH PARTY EXECUTING VAKALATNAMA


Sr. No. Name & Father’s/ Registered Address E-mail if any Phone No. if Status in Full Signature or
Husband’s name any Case Thumb Impression

PARTICULARS OF EACH ADVOCATE ACCEPTING VAKALATNAMA


Sr. Name & Enrollment No. Address for Service E-mail if any Phone No. if Full
No. any Signature

1 Rahul Machevar & E-7/14 Lalalajpat Rai [email protected] 8390899526


Society Arera Colony
MP/1257/2016 Bhopal.

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