DPC 1,0

DRAFTING, PLEADING & CONVEYANCING
ACKNOWLEDGEMENT
I would like to express my sincere gratitude to Dr. Bhavana Sharma for assigning the Drafting,
Pleading & Conveyancing (DPC) assignment. Her guidance and expertise in the field have
been invaluable throughout this assignment.I extend my heartfelt appreciation to Dr. Sharma
for her dedication in imparting knowledge and skills related to legal drafting. Her meticulous
explanations and insightful feedback have greatly enhanced my understanding of the subject
matter.I would also like to acknowledge the effort and commitment of Dr. Sharma in creating
a stimulating learning environment. The assignment provided an excellent platform for
practical application of theoretical concepts, allowing me to develop and refine my drafting
skills.
Furthermore, I am grateful for Dr. Sharma's patience and willingness to address my queries
and concerns. Her timely assistance and encouragement have been instrumental in overcoming
challenges and improving my overall performance in the assignment.
Lastly I thank you ma’am, for your exceptional instruction and mentorship.
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TABLE OF CONTENTS
S.NO NAME OF THE DRAFTS PAGE

NUMBER
1. Petition for Judicial Separation under Section 10 of the Hindu
Marriage Act, 1955
2. Suit for Ejectment and Damages for Wrongful Use and

Occupation
3. Plaint and Written Statement for Permanent Injunction (Theme -

restraining the Landlord from dispossessing the Tenant forcibly
and illegally)
4. Affidavit as a proof of Age showing the date of Birth of 'A'
5. APPLICATION FOR TEMPORARY INJUNCTION UNDER

ORDER XXXIX Rule 1 & 2
6. Suit for recovery under Order XXXVII (Summary Suit)
7. Petition for Dissolution of Marriage by Decree of Divorce under

Section 13 of the Hindu Marriage Act, 1955
8. Caveat under section 148-A of the Code of Civil Procedure, 1908
9. Transfer Petition (Civil) U/s 25 of the Civil Procedure Code, 1908
10. Application for the Execution of Decree
11. Petition for Grant of Probate in High Court
12. Petition for Restitution of Conjugal Rights under Section 9 of the

Hindu Marriage Act, 1955
13. Writ Petition under Article 226 of the Constitution of India
14. Writ Petition for Enforcement of Fundamental Rights under

Article 32
15. Special Leave Petition under Article 136 of the Constitution of

India
16. Application for Regular Bail
17. Application for Anticipatory Bail
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18. Complaint under section 138 of the Negotiable Instruments Act,

1881
19. Application under section 125 of the Code of Criminal Procedure,

1972
20. Will Deed
21. Sale Deed
22. Mortgage Deed
23. Partnership Deed
24. Deed of Dissolution of Partnership
25. General Power of Attorney
26. Notice under section 106 of The Transfer of Property Act, 1882
27. Gift Deed
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Petition for Judicial Separation under Section 10 of the Hindu Marriage Act, 1955.
IN THE COURT OF THE JUDGE: FAMILY COURT:

AT ROURKELA: ODISHA STATE
MATRIMONIAL CASE ___ of 2023
JASSDEV SINGH,
S/o. BALDEV SINGH,
Aged about 34 years, Hindu,
Occupation: Software engineer,
Address: K-69,
CHEND COLONY, ROURKELA……………….…………………………………………………………. PETITIONER
V.
RIDDHIKA SINGH,
W/o. BALDEV SINGH,

Occupation: Housewife,
Address: K-69,
CHEND COLONY, ROURKELA……….…………………………………………………………………RESPONDENT
PETITION FILED FOR JUDICIAL SEPARATION UNDER SECTION 10 OF THE HINDU MARRIAGE
ACT,1955
1. The marriage of the petitioner and the respondent was solemnized on 02/01/2020 at
4:00 pm according to Hindu rites and ceremonies. The marriage was registered with
the registrar of marriages at Rourkela. Certified copy of the extract from the
concerned register is attached herewith as Annexure P1.
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2. The petitioner and the respondent were living happily for about two years. Thereafter
the dispute and differences cropped up between the parties. The petitioner herein is
a sensitive person and he is known to be a man of good reputation by his colleagues
at work. He used to return late from his office in as much as he was engaged in some
meetings at his office. His wife was unhappy with his late comings and she was always
asking him to return early so that he can take her away for shopping. Since it was not
for him to come from the office early, he was trying to convince his wife to get things
done on her own and that he was prepared to pay her money for doing so, but she
was not happy with such proposition of her husband and therefore she was repeatedly
insulting him with unbearable acts and deeds. The husband developed mental agony
due to the cruel behaviour of respondent towards him which further led the petitioner
to the conclusion that he cannot continue his marital relations with the respondent.
The situation reached to such extent that either he must forego his job or to fulfil the
undue desires of his wife. Since it was not possible for the petitioner to continue
staying with his wife, he decided to live separately thereby presenting the petition for
judicial separation.
3. The cause of action arose on 03.02.2023 when the respondent abused her husband
and created lot of hue and cry like dragging the husband on to road from his house
when he came late from office due to important work in breach of promise to take his
wife to the picture. The cause of action arose on 06.07.2023 when the petitioner
declined the demand of the respondent to take her to the marriage party of her
relatives. The cause of action again arose on 08.09.2023 as the respondent teared off
all his appreciation letters which he received from his office, in vengeance to her
husband not taking her away to industrial exhibition in Rourkela. The cause of action
also, arose on 20.11.2023 when the petitioner husband got issued a legal notice
expressing his willingness to live separately from his wife and she has accepted for the
same.
4. The parties to the petition last lived together in Rourkela and the marriage also took
place in Rourkela. therefore, this hon’ble court has jurisdiction to entertain the
petition.
5. A court fee of Rs 10/- as valued under Odisha court fees amendment act,1939 has
been paid in this court.
6. That no other suit or petition is filed before any court or forum seeking same relief
and that there is no other effective alternative remedy available except to invoke the
jurisdiction of this Hon’ble court.
RELIEF
For the reasons mentioned above, it is humbly prayed that this Hon’ble court may be pleased
to pass a judgement and decree for judicial separation in favour of the petitioner and against
the respondent and to grant such other or further relief or reliefs as this Hon’ble court may
deem fit and proper in the facts and circumstances of the case.
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Place: Rourkela Sd/-

Date: 20.07.2024 Petitioner

Date: 20.07.2024 Counsel for the Petitioner
VERIFICATION
I, Jassdev the petitioner herein do hereby declare that what is stated in the above paragraphs
is true and correct to the best of my knowledge and belief. hence verified and signed on this
the 20th day of July 2024, at Rourkela.
Sd/-
Petitioner
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Suit for Ejectment and Damages for Wrongful Use and Occupation.
IN THE COURT OF THE SENIOR CIVIL JUDGE: SESSIONS COURT:

SUIT NO ___ of 2023
Karan Ahuja,
S/o. Balwant Ahuja,
Occupation: Chattered Accountant,
Address: Q-13,
CIVIL TOWNSHIP, ROURKELA……………….………………………...……. PLAINTIFF
V.
Balbir Singh,
S/o. Anmol Singh,
Occupation: Business,
Address: H-9,
CIVIL TOWNSHIP, ROURKELA……….……………………………………DEFENDANT
SUIT FILED FOR EJECTMENT AND DAMAGES FOR WRONGFUL USE AND
OCCUPATION
1. The plaintiff, as owners of H-9, Civil Township, Rourkela leased the property to
Defendant with a registered address at Q-13, CA office, Civil township, Rourkela,
New Odisha-769004, for a term of five years beginning on 07/01/2018 via an
unregistered Lease deed (copy attached as Annexure 'A'). The property had four
bedrooms, 1 kitchen, 2 washroom and a dining hall. and the transfer was done
simultaneously on 07/01/2018.
2. The defendant was a monthly tenant of the plaintiff in relation to the premises in civil
township (H-9), Rourkela and was asked to pay a monthly fee of Rs. 27,000. The
defendant violated norms of plaintiff rules while the property was leased as he further
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rented the property to the third party without the consent of the true owner and he
received Rs 18000 per month for letting out the property. The defendant used to host
certain events inside the property which would continue for 15 long hours and he would
receive Rs 15000 for organising each event. The property was damaged after 7 months
of defendant got the property at lease from the plaintiff and the transactions initiated
during his possession was not known to the plaintiff.
3. The cause of action arose on 09/01/2019 when the defendant denied to pay eight months
rent to the plaintiff starting from 07/01/2018 till 07/08/2018. The defendant only paid
1,08,000 instead of paying rent for 12 months i.e.; Rs 3,24,000. So, the plaintiff was
yet to receive 2,16,000 from the defendant. Secondly the cause of action arose on
23/03/2019 when the plaintiff came to know about the transactions that involved third
party along with the defendant. The cause of action arose on 12/06/2019 when the
defendant received an order from the owner to vacate the property as he already violated
certain norms to which he gently agreed while acquiring the possession of the property
from the plaintiff. The cause of action arose on 15/08/2019 when the defendant denied
the orders of the plaintiff and further said that he will stay for his whole tenure and then
he can vacate.
4. That during the eight-month period beginning on 2018, the defendant failed to pay rent
on the property. defendant became subject to eviction because of this default and for
the damages that occurred during the wrongful use of property by the defendant. So, a
suit has been filed for ejectment of defendant from the plaintiff’s property.
5. Since the property in question is in Rourkela, possession is sought. The Lease for the
premises was executed and possession was transferred in Rourkela and since the
premises are not subject to the Odisha Rent Control Act. The court has the authority to
hear and resolve this case.
6. A court fee of Rs …... as valued under Odisha court fees amendment act,1939 has
been paid in this court.
7. There is no bar to this particular suit and hence the case has been filed as per the
limitation act, 1963.
8. That no other suit or petition is filed before any court or forum seeking same relief
and that there is no other effective alternative remedy available except to invoke the
jurisdiction of this Hon’ble court.
PRAYER
In the circumstances mentioned herein above it is respectfully prayed that:
The Hon’ble Court may be pleased to –
(i) pass a decree for ejectment against the defendant and in favour of plaintiffs;
(ii) pass a decree for payment of damages @ Rs. 4,000/- per day for wrongful use and
occupation of the flat by the defendant;
(iii) Any other relief deemed fit and proper may also be given. Costs of the case may also be
given.
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Date: 17.06.2020 Plaintiff

Date: 17.06.2020 Advocate for the Plaintiff
VERIFICATION:
I, Karan the plaintiff herein do hereby declare that what is stated in the above 1-8 paragraphs
is true and correct to the best of my knowledge and belief. hence verified and signed on this
the 17th day of June 2020, at Rourkela.
PLAINTIFF
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Plaint and Written Statement for Permanent Injunction (Theme - restraining the Landlord
from dispossessing the Tenant forcibly and illegally).
IN THE COURT OF SENIOR CIVIL JUDGE
AT ROURKELA, ODISHA STATE
SUIT NO. ____OF 2020
DEEPAK TRIPATHY
S/o. BATWANT TRIPATHY,
Aged about 27years, Hindu,
Occupation: MEDICAL STUDENT,
Address: G-39,
CIVIL TOWNSHIP, ROURKELA……………………………………………………Plaintiff
Versus
SWARAJ BHOI
S/o. RAJESH BHOI,
Occupation: BUSINESSMAN,
Address: G-62,
CIVIL TOWNSHIP, ROURKELA…………………………………………………Defendant
PLAINT FOR PERMANENT INJUNCTION

The Plaintiff in the above-captioned case, respectfully states as follows:
1. The Plaintiff is the lawful tenant of the property located at G-39, civil township
(hereinafter referred to as the "Property") under a valid lease agreement with the
Defendant.
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2. The Defendant, who is the Landlord of the Property, has been attempting to dispossess
the Plaintiff from the Property forcibly and illegally, in violation of the terms of the
lease agreement and applicable laws.
3. The Defendant's actions in attempting to dispossess the Plaintiff from the Property
forcibly and illegally have caused and continue to cause irreparable harm and injury to
the Plaintiff's rights and interests as a lawful tenant.
4. The Plaintiff has repeatedly requested the Defendant to refrain from such illegal actions,
but the Defendant has failed to comply with the Plaintiff's requests.
5. The Plaintiff seeks a permanent injunction from this Honourable Court restraining the
Defendant, his agents, employees, or any other person acting on his behalf, from
forcibly and illegally dispossessing the Plaintiff from the Property and interfering with
the Plaintiff's peaceful possession and enjoyment of the Property.
6. The Plaintiff further prays for such other and further relief as this Honourable Court
may deem just and proper in the circumstances.
PRAYER
a) A permanent injunction restraining the Defendant, his agents, employees, or any other person
acting on his behalf, from forcibly and illegally dispossessing the Plaintiff from the Property
and interfering with the Plaintiff's peaceful possession and enjoyment of the Property.
b) Such other and further relief as this Honourable Court may deem just and proper in the
circumstances.
Date: 10.03.2020 Plaintiff
Date: 10.03.2020 Counsel for the Plaintiff
VERIFICATION
I, Deepak the plaintiff herein do hereby declare that what is stated in the above paragraphs is
true and correct to the best of my knowledge and belief. hence verified and signed on this the
10 th day of march 2020, at Rourkela.
Sd/-
Plaintiff
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IN THE COURT OF SENIOR CIVIL JUDGE
AT ROURKELA, ODISHA STATE
SUIT NO. ____OF 2020
DEEPAK TRIPATHY
S/o. BATWANT TRIPATHY,
Aged about 27years, Hindu,
Occupation: MEDICAL STUDENT,
Address: G-39,
CIVIL TOWNSHIP, ROURKELA……………………………………………………Plaintiff
Versus
SWARAJ BHOI
S/o. RAJESH BHOI,
Address: G-62,
CIVIL TOWNSHIP, ROURKELA…………………………………………………Defendant
WRITTEN STATEMENT FOR PERMANENT INJUNCTION

I, Swaraj, the Defendant, by and through my undersigned counsel, respectfully submit this
Written Statement in response to the permanent injunction lawsuit filed by Deepak, the
Plaintiff, seeking to restrain me from dispossessing the tenant, on the following grounds:
1. I deny the allegations made by the Plaintiff in the plaint. I specifically deny that I have
forcibly or illegally attempted to dispossess the tenant from the property in question.
2. I assert that I am the lawful owner/landlord of the property in question and I have the
right to take possession of my property in accordance with the applicable laws and
regulations.
3. I further assert that the Plaintiff, who is claiming to be a tenant, is not a lawful tenant
of the property. The Plaintiff has failed to pay rent for a prolonged period, has violated
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the terms and conditions of the lease agreement, and has caused damages to the
property.
4. I have followed the due process of law and have initiated legal proceedings for the
lawful eviction of the Plaintiff as per the applicable tenancy laws.
5. The Plaintiff has not approached the Court with clean hands and is attempting to misuse
the process of law to unjustly restrain me from exercising my legal rights as the
landlord.
6. The Plaintiff is not entitled to the relief of permanent injunction as sought in the plaint
because the Plaintiff's claim is baseless and without merit.
PRAYER
I pray to this Hon'ble Court to dismiss the Plaintiff's claim for permanent injunction and allow
me to exercise my lawful rights as the owner/landlord of the property. The court may pass any
other relief as it may deem just and proper in the circumstances.
Date: 20.03.2020 Defendant
Date: 20.03.2020 Counsel for the Defendant
VERIFICATION
I, Swaraj, the defendant herein do hereby declare that what is stated in the above paragraphs is
true and correct to the best of my knowledge and belief. hence verified and signed on this the
20th day of march 2020, at Rourkela.
Sd/-
Defendant
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Affidavit as a proof of Age showing the date of Birth of 'A'.
BIPLAV TRIVEDI,
CIVIL TOWNSHIP,
770033,
[email protected],
04/02/2023.
AFFIDAVIT as a proof of Age showing the date of Birth of 'SHUBHAM TRIVEDI'

I, Biplav, being of sound mind and legal age, do hereby make this affidavit to attest to the date of birth
of 'A' as follows:
1. I am personally acquainted with 'Shubham' and have known him for 15 years.
2. 'Shubham' is a person whose date of birth I am well aware of, as I have witnessed the event
and have obtained the information from reliable sources.
3. Based on my personal knowledge, 'Shubham' was born on 17th October, 2008, and therefore,
as of the date of this affidavit, 'Shubham' is 15 years old.
4. I declare under penalty of perjury that the information provided in this affidavit is true and
correct to the best of my knowledge and belief.
5. I am willing to testify to the authenticity of the information provided in this affidavit in any
legal proceeding, if required.
6. This affidavit is being executed for the purpose of establishing the date of birth of 'Shubham'
for any lawful and legitimate purposes.
Biplav Trivedi
Your Signature
Sworn to and subscribed before me on this 4th day of march, 2023.
Notary Public
Notary Seal/Stamp
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APPLICATION FOR TEMPORARY INJUNCTION UNDER ORDER XXXIX Rule 1 & 2.
BEFORE THE SENIOR CIVIL JUDGE OR DISTRICT JUDGE AT
ROURKELA, ODISHA STATE
CIVIL SUIT NO. ____ OF 2021
IN THE MATTER OF:
Mr. Ashok Chaturvedi
S/o. Birbal Chaturvedi,
Occupation: CONTRACTOR
Address: CHEND COLONY,
ROURKELA………………………………………………………………………………………………. PLAINTIFF/ APPLICANT
VERSUS
Mr. Manish Agarwal
s/o Ramesh Agarwal
aged about 49 years, Hindu
occupation: Businessman
Address: Basanti colony
ROURKELA………………………………………………………………………………………… DEFENDANT/ RESPONDENT
INJUNCTION APPLICATION
MOST RESPECTFULLY SHOWETH:
The Plaintiff / Applicant, above named, respectfully submits as under:
1. The Plaintiff has filed a lawsuit against the Defendant/Respondent for the specific performance
of an Agreement to Sell and Memorandum of Understanding dated 21/11/2021, which is
currently pending before this Hon'ble Court.
2. By the Agreement to Sell, the Defendant/Respondent agreed to sell and transfer the Suit
Property, as described in the Plaint. Copies of the said agreement and Memorandum of
Understanding have been attached to the Suit.
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3. The Plaintiff paid the Defendant a sum of Rs 45000 by Cheque No____ dated as earnest money,
and the balance of Rs. 45000 was to be paid at the time of execution and registration of the
Sale Deed.
4. At the time of execution of the said agreement, the Defendant put the Plaintiff in possession
of the property.
5. The Sale Deed was supposed to be executed and registered on 07/08/2021. However, on the
given date, the Plaintiff visited the office of the Sub-Registrar with the balance sale
consideration of Rs. 45000, but the Defendant did not show up at the office. The Plaintiff filed
an application to mark his appearance at the office of the Sub-Registrar.
6. Subsequently, the Plaintiff served a legal notice on the Defendant through his Advocate on
09/10/2021 via registered post, but no reply has been received so far. All attempts by the
Plaintiff to persuade the Defendant to complete the transaction as per the agreement have
failed.
7. The Plaintiff has always been ready and willing to perform his part of the contract.
8. The Plaintiff has a prima facie case in his favor, and the balance of convenience also lies in his
favor.
9. The suit property is located within the jurisdiction of this Hon'ble Court, and based on the
cause of action narrated above, this Hon'ble Court has jurisdiction to entertain and try this,
Suit.
10. The Plaintiff has learned that the Defendant is attempting to dispose of the Suit Property, and
some persons have contacted him through a property dealer for this purpose. If the Defendant
is not restrained from disposing of or creating third-party interests in the Suit Property during
the pendency of the Suit, the Plaintiff will suffer irreparable injury and loss that cannot be
compensated in monetary terms. Any such transaction would also result in multiple
proceedings.
11. In view of the aforementioned facts and circumstances, the Plaintiff respectfully requests that
this Hon'ble Court be pleased to:
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Suit for recovery under Order XXXVII (Summary Suit).
SUIT NO ___ of 2023
IN THE MATTER OF:
SHYAM MITTAL,
S/o. KISHORE MITTAL,
Address: UDITNAGAR
NEAR CIVIL TOWNSHIP, ROURKELA……………….………………………...…………………………………………. PLAINTIFF
V.
KHUSWANT SINGH,
S/o. BALWANT SINGH,
Occupation: WHOLESELLER,
Address: SAHEJ PRESTIGE,
CIVIL TOWNSHIP, ROURKELA……….……………………………………………………………………………………DEFENDANT
SUIT UNDER ORDER XXXVII OF THE CODE OF CIVIL PROCEDURE, 1908 FOR RECOVERY OF Rs.
49572/- (RUPEES 49,572)
SUIT FOR DEBT RECOVERY PURSUANT TO ORDER XXXVII OF THE CODE OF CIVIL PROCEDURE, 1908
The Plaintiff identified above asserts the following:
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1. The Plaintiff is is a person, specifically a 65-year-old Hindu businessman residing at Udit Nagar
near Civil Township in Rourkela. The plaintiff in this case w was a partner of the defendant,
who was a wholesaler dealing with electronic products.
2. The defendant was a partner of the plaintiff, who specialized in dealing with electronic
products as a wholesaler.
3. On 06/09/2021, the Plaintiff and the Defendant entered into an agreement for selling of
electronics as a co-partnership firm dealing with electronics. A copy of the aforementioned
agreement is attached as Exhibit A.
4. According to said agreement, the Defendant was required to pay the Plaintiff 49572.
5. Despite numerous requests and demands from the Plaintiff, the Defendant has not paid the
stated amount.
6. The Plaintiff has no effective recourse other than to file this summary action pursuant to Order
XXXVII of the Code of Civil Procedure of 1908.
7. The cause of action for this lawsuit arose on 23/10/2021.
8. The Plaintiff has valued this lawsuit at ……….. rupees for purposes of jurisdiction and court
fees.
9. The Plaintiff asserts that the amount asserted in this lawsuit is not in dispute.
10. The Plaintiff does not oppose to the Defendant's right to defend against the lawsuit.
11. The Plaintiff agrees to pay the court-ordered costs of this lawsuit.
12. The Plaintiff has submitted this lawsuit in accordance with Order XXXVII of the 1908 Code of
Civil Procedure.
PRAYER
The Plaintiff therefore requests that this Honourable Court enter a decree in favour of the Plaintiff and
against the Defendant for the recovery of Rs. 49572, plus interest at 30 percent per annum from
23/10/2021 until the date of realisation, as well as the costs of this suit.
SHYAM MITTAL
through
Advocate for the Plaintiff
VERIFICATION
I, SHYAM MITTAL hereby certify that, to the best of my knowledge, information, and belief, paragraphs
1 through 13 of the aforementioned complaint are true and accurate. Verified at ROURKELA on
23/10/2021.
SHYAM MITTAL
23/10/2021
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Petition for Dissolution of Marriage by Decree of Divorce under Section 13 of the Hindu Marriage
Act, 1955.
IN THE COURT OF THE JUDGE: FAMILY COURT:

MATRIMONIAL CASE ___ of 2023
SHREYA AGARWAL,
d/o. ANUPAM AGARWAL,
Occupation: housewife,
Address: kuarmunda,
ROURKELA……………….………………………………………………………………………………………. PETITIONER
V.
SHAILENDRA AGARWAL,
S/o. KAMLESH AGARWAL,
Occupation: Software eingeeneer,
Address: kuarmunda,
ROURKELA……….…………………………………………………………………………………………………RESPONDENT
APPLICATION UNDER SECTION 14 OF HINDU MARRIAGE ACT, 1955
I, Shreya agarwal, aged 34years, and a resident of kuarmunda, solemnly declare and proclaim the
following:
1. That I married Shailendra agarwal on 06/11/2015 at Mayfair, Rourkela in accordance with

Hindu customs and rituals. Attached as Annex A is a copy of the marriage certificate.
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2. We lived together for 8 years, but our marriage has irretrievably broken down, and there is
no possibility of reconciliation between us. Consequently, I am compelled to file for a divorce
under Section 13 of the Hindu Marriage Act of 1955.
3. During our marriage, the respondent was vicious to me and made my life intolerable. The
respondent subjected me to physical and mental abuse, causing me immense suffering and
anguish. Despite my efforts to reconcile and save the marriage, the respondent persisted in
treating me cruelly, and I was forced to abandon my marital home due to the constant
harassment and torture.
4. That the respondent also refused to fulfil his/her marital duties to me and abandoned me
without cause. The respondent has given me no financial assistance and has left me to fend
for myself.
5. To the best of my knowledge, I have not filed any other dissolution of marriage or annulment
proceedings between the parties.
6. This Honourable Court's authority to hear and consider this petition is predicated on the
following:
i. The parties were married in accordance with Hindu customs and rituals at mayfair
and have lived together at block b, kuarmunda, rourkela since their wedding.
ii. The respondent currently resides at kuarmunda rourkela, which falls within the
court's jurisdiction.
7. I am willing to comply with the court's rulings in this matter.
PRAYER
Therefore, I respectfully request that this Honourable Court:
 Issue a divorce decree dissolving my marriage to the respondent in accordance with Section
13 of the Hindu Marriage Act of 1955.
 Grant me maintenance and alimony as this Honourable Court deems appropriate.
 Please award me the costs of this petition.
 Grant any additional relief that this Honourable Court deems just and appropriate.
VERIFICATION
I, Shreya agarwal, solemnly affirm that the information presented in paragraphs 1 to Para No 7 of the
Petition is true to the best of my knowledge, and that the preceding statements are accurate to the
best of my knowledge and belief. Verified at rourkela on 09/02/2023.
ROURKELA
09/02/2023
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Caveat under section 148-A of the Code of Civil Procedure, 1908.
SUIT NO ___ of 2023
IN THE MATTER OF: –
XYZ
S/o ABC
R/o ……………………………………………………………………………………………………………………………………CAVEATOR
V
XYZ
S/o ABC
R/o……………………………………………………………………………………………………………………………NON-CAVEATOR
CAVEAT IN TERMS OF SECTION 148-A OF CPC
The disclaimer respectfully submits the following: –
1. That a civil action titled "damages for breach of contract" has been filed by the Caveator
against the Non-Caveator in the court of the Learned District Magistrate.
2. That the caveator fears that the non-caveator may file a false and frivolous suit against the
caveator regarding property owned and possessed by the caveator's mother, and that the
non-caveator wishes to encumber the property by filing the aforementioned suit in this
Honourable Court.
3. That if the non-caveator obtains an ex-parte order against the caveator by filing a lawsuit,
appeal, revision, or petition, the caveator will suffer an irreparable loss.
4. That in the event of the filing of any of the aforementioned lawsuits, the caveator has the right
to be heard prior to the court proceeding.
5. This copy of the Caveat has been sent to the non-caveator via registered mail; the original
postal receipts are enclosed. A copy of the postal receipts is attached and labelled as Annex
A.
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In light of the above, the caveator respectfully requests that if the non-caveator files the
aforementioned suit, the caveator be granted an opportunity to be heard before any orders are passed
in the interest of justice. This application is made on behalf of the caveator through their legal
representative, the undersigned counsel, and is dated as per the details provided.
CAVEATOR
THROUGH COUNSEL
DATED:-
ADVOCATE
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Transfer Petition (Civil) U/s 25 of the Civil Procedure Code, 1908.
IN THE SUPREME COURT OF INDIA ORIGINAL CIVIL JURISDICTION TRANSFER PETITION (CIVIL) NO.
_____ OF 2017
(UNDER SECTION 25 OF THE CODE OF CIVIL PROCEDURE, READ WITH ORDER XXXVI, SUPREME
COURT RULES.)
IN THE MATTER OF:
TUSHAR LODHA
…….Petitioner
VERSUS
RAJEEV SRIVASTAV
…..Respondent
AND IN THE MATTER OF:
TRANSFER OF CIVIL WRIT PETITION NO.______ FILED BY THE PETITIONER

AGAINST THE RESPONDENTS PENDING IN THE HIGH COURT OF DELHI AT
12/03/2023, TO THE HIGH COURT OF JUDICATURE AT 27/03/2023.
To,
The Hon’ble Chief Justice of India, And his Companion Justices of the Hon’ble Supreme Court
of India at New Delhi.
The Humble Petition of the above-named Petitioner sincerely shows:

1. That the Petitioner is the business partner of Mr. Rajeev srivastav in the above-
mentioned case, which is pending before the High court of Delhi.
2. That the Respondent is the [relationship or status] of [party name] in the aforementioned
case.
3. That the cause of action for the above-mentioned case arose in delhi and the above-
mentioned case was brought before High Court of Delhi.
4. That the Petitioner has filed twice application with the said court, but it is no longer
possible to receive a fair and impartial hearing there due to bar on the limitation as the
petitioner was suffering from bronchitis due to which he was hospitalized for more than
a month.
23
5. That the Petitioner has no choice but to petition this Honourable Court for transfer of
the above-mentioned case to the high court of odisha.
6. That the transfer of the above-mentioned case will not prejudice or inconvenience the
Respondent, as it is in the best interests of justice for the case to be heard in a neutral
and impartial forum.
7. That the Petitioner has not previously filed a transfer petition with the same or similar
prayers before this Honourable Court.
8. In the interest of justice and equity, the Petitioner respectfully requests that the above-
named case be transferred from the high court of delhi to high court of odisha.
9. That the Petitioner further requests that any other order or direction that this Honourable
Court deems appropriate be passed in his favour.
10. Furthermore, due to the significant backlog of cases, it is improbable that the writ
petition No._______ will be disposed of in the foreseeable future. Annexure P-1
contains a copy of the civil writ petition No._______.
PRAYER
In light of the preceding facts and circumstances, it is respectfully requested that this Honourable
Court:
a) To issue an order for the transfer of the Civil Writ Petition No. _________ lodged by the
Petitioner against the Respondent titled _________ from the High Court of Delhi at
_________ to the High Court of Judicature at _________.
b) Additionally, any other and further order deemed appropriate may be passed.
Filed By
Advocate for the petitioner
Date & Place:
24
Application for the Execution of Decree.
APPLICATION FOR EXECUTION OF DECREE

Respectfully submitted,
1. This Honourable Court ruled in favour of the Applicant in the above-mentioned case
on [insert date of ruling].
2. That despite having been served with the decree, the Respondent has failed to comply
with its terms and conditions.
3. That the Applicant has waited without success for the Respondent to voluntarily comply
with the decree.
4. That the present application is submitted to execute the judgement against the
Respondent.
5. The following properties owned by the Respondent are subject to seizure and
sale:[include information about the properties to be affixed and sold, such as their
location and estimated value]
6. That the Applicant hereby requests that this Honourable Court: a) Issue necessary
instructions to the concerned authorities for the attachment and sale of the above-
mentioned properties of the Respondent;
a) Reimburse the Applicant for the application's costs;
b) Issue any other order that the court deems appropriate under the circumstances.
PRAYER
In light of the foregoing, it is humbly prayed that this Honourable Court be pleased to order the
execution of the decree and issue necessary directions for the attachment and sale of the
properties of the Respondent as mentioned above, award the costs of this application to the
Applicant, and pass any other order that this Honourable Court may deem appropriate under
the circumstances.
25
Petition for Grant of Probate in High Court.
IN THE COURT OF THE JUDGE: HIGH COURT:

AT CUTTACK: ODISHA STATE
PROBATE CASE NO ___ of 2020
Petition for probate of the will of (a)_______Deceased.
IN THE MATTER OF
ASHOK CHATURVEDI
S/O MANOJ CHATURVEDI
Aged about 65 years, Hindu
Occupation – businessman
Block C, 514, lotus boulevard
Bhubaneshwar…………………………………………………………………………………………………..PETITIONER
Versus
SOHAN CHATURVEDI
S/O AJAY CHATURVEDI
Aged 73 years, hindu
Occupation- Real estate owner

G block, Z1 HEIGHTS
Bhubaneshwar……………………………………………………………………………………………….……DECEASED
Petition for probate of the will of (a) sohan Chaturvedi Deceased.
Most respectfully showeth:
26
1. That, late of real estate owner, sohan Chaturvedi , died on [08/06/2020], leaving
behind a Last Will and Testament executed on [17/04/2020], which has been
presented for probate to this Hon'ble Court.
2. That the deceased had left behind the following property and assets:
Land- 40 acres of land, 5 four wheelers, bank balance of 12 crores.
3. That ashok chaturvedi is identified as the Executor of the deceased's Last Will and
Testament and is seeking probate from this Hon'ble Court.
4. That the deceased's Last Will and Testament was carried out in line with the law and
is legitimate and enforceable on all parties involved.
5. That the petitioner has conducted all necessary inquiries and is unaware of any
alternative Will or codicil that revokes the deceased's Last Will and Testament.
6. That the petitioner is willing to take over all of the Executor's responsibilities and
duties, as well as file all necessary accounts and inventories as required by law.
7. As a result, the petitioner requests that this Hon'ble Court give probate to the
deceased's Last Will and Testament and appoint the petitioner as Executor of the
estate.
8. That the petitioner will provide the appropriate bond and other documentation for
probate.
PRAYER:
In light of the foregoing, it is most humbly requested that this Hon'ble Court:
i. Grant the petitioner probate of the deceased's Last Will and Testament.
ii. Appoint the petitioner as Executor of the deceased's estate.
iii. Make any additional order(s) as this Hon'ble Court considers appropriate in the
circumstances.
And the petitioner, as a duty-bound person, will always pray for this act of charity.
PETITIONER
THROUGH
______________., Advocate
Place :
Date :
VERIFICATION BY THE APPLICANT

I, Ashok chaturvedi the above-named petitioner, do hereby declare and say that the
statements contained in paragraphs 1 to 8 of the above petition are true to my best
27
knowledge.
Verified at Cuttack on :21/09/2020

PETITIONER
DECLARATION OF WITNESS
I, SHYAM GOYAL one of the witnesses to the last will and testament of sohan Chaturvedi
the testator stated in the above petition, do say and declare that I was present on the
17/04/2020 at Bhubaneshwar and saw the testator affix his hand/signature or mark to said
will, marked A per Affidavit of _______________ instituted herewith (or that the said
testator admits the writing enclosed to above petition and marked A, to be his last
will/testament in my presence).
Solemnly affirmed by the said shyam goyal witness this on 21/09/2020 at the High court of
odisha.
Sign
Before me
Commissioner/Magistrate/Oath Officer
28
Petition for Restitution of Conjugal Rights under Section 9 of the Hindu Marriage Act,
1955.
IN THE COURT OF THE SENIOR CIVIL JUDGE: SESSIONS COURT
MATRIMONIAL CASE NO. __________ OF 2020
IN THE MATTER OF:
Mr. ARJUN ROY
s/o KAMALNATH ROY
Aged about 37 years, Hindu
Occupation- software engineer
D-706, Civil township
ROURKELA………………………………………………………………………………………………………………………PETITIONER
VERSUS
MRS. SMITA ROY
D/o JASON ROY
Aged about 34 years, hindu
Occupation – fashion designer
D-706, civil township
ROURKELA…………………………………………………………………………………………………………………. RESPONDENT
PETITION UNDER SECTION 9 OF HINDU MARRIAGE ACT 1955 FOR RESTITUTION OF CONJUGAL
RIGHTS
The above-mentioned Petitioner states:
29
1. The Petitioner and Respondent's marriage was solemnised on 05/02/2016 at mayfair, Rourkela
according to Hindu rites and procedures. The marriage was registered with the Marriage Registrar in
rourkela. Annexure P1 contains a certified copy of the extract from the relevant registration.
2. That the following is the status and place of residence of the parties to the marriage prior to the
marriage and at the time of filing this petition:
 Previous residence before marriage
 Residence at the time the Petition was filed
3. The couple had one boy, who was aged six, as a result of their marriage.
4. That the Petitioner and his wife were living happily together at our home. That the respondent went
to her father's residence at Jamshedpur on 15/04/2020. She promised to return in 20 days, but she
did not keep her word and is yet to return. The Respondent, for no apparent reason, is living in her
father's home.
5. That the petitioner went to his father-in-law's residence at Jamshedpur several times to bring the
respondent, but on one excuse or another, she refused to accompany the petitioner to his house.
6. That, finally, the petitioner went to the respondent's father's residence at Jamshedpur on
22/06/2020 and urged the respondent to return with him, but she refused.
7. That the respondent abandoned the petitioner or resigned from his company for no reasonable or
legal reason. As a result, the petition became necessary.
8. The Petition is not being presented with the Respondent's knowledge.
9. The Petition is being presented without the Petitioner's unwarranted or inappropriate delay.
10. There is no other legal reason why the decree of restitution of marital rights should not be given
to the Petitioner.
11. That no prior litigation has occurred between the Petition's parties.
12. This Hon'ble Court has jurisdiction to entertain and try this Petition as the marriage was solemnized
at Mayfair, Rourkela and the parties last resided together at civil township, Rourkela and even presently
the respondent is residing within the Jurisdiction of this Hon'ble Court.
13. That the cause of action accrued to the petitioner against the respondent, within the jurisdiction
of this Court, on 28/09/2020 when the respondent left for her father’s house at Jamshedpur and it
continues to accrue from day to day till the respondent comes back to the home of the petitioner and
resumes his company.
14. In the facts and circumstances of case mentioned herein above this Hon'ble Court may graciously
be pleased to:
PR AY E R
As a result, the Petitioner requests:
a) for the issuance of a decree restoring conjugal rights in favour of the Petition and against the
Respondent; and
b) The petitioner is additionally granted any other relief or reliefs that the court deems appropriate
under the circumstances.
30
VERIFICATION
I, the above named petitioner, do hereby verify that the contents of this petition in Para 1 to 14 are
true to my personal knowledge and those in Para No 1 to Para No 14 are believed by me to be true.
Signed and verified this 28/09/2020 at Rourkela.
PETITIONER
31
Writ Petition under Article 226 of the Constitution of India.
IN THE HIGH COURT OF JUDICATURE OF TELENGANA STATE
AT HYDERABAD: TELENGANA STATE
WRIT PETITION NO. /2021
BETWEEN:
Smt. K. Sita.
W/o. K. Ram, aged about 33 years, Hindu, Occupation: Housewife,
Address: Plot No. 40/40/40, Banjara Hills,
Hyderabad-500034,
Telangana State…………………………………………………………………………………………………………………. Petitioner
AND
State of Telangana,
Represented by its Secretary,
Department of Home Affairs,
Secretariat,
Hyderabad-500 024. Telangana State.
AND TWO OTHERS…………………………………………………………………………………………. Respondents No.1 to 3
AFFIDAVIT FILED ON BEHALF OF THE PETITIONER
1. Smt. K. Sita, W/o. K. Ram, aged about 33 years, Hindu, Occupation: Housewife, Address: Plot No.
40/40/40. Banjara Hills, Hyderabad-500.034, do hereby solemnly affirm and sincerely state on oath as
follows:
1) I am the petitioner herein and, as such, I am well acquainted with the and circumstances of the case.
Hence, I am deposing through this affidavit.
2) Thumbly submit that my husband Sri Ram, S/o. Sattiah, aged about 40 years, Occupation: Reporter,
Andhra Weekly, Hyderabad was taken away by some unknown persons claiming to be police on
3.5.2005 without assigning any reasons or without informing any other details in spite of my request
to that effect. My husband did not return home even by 6 O'clock in the evening of that day. Therefore,
32
I and my near relatives made enquiries about the whereabouts of my husband not only in the nearby
places but also in the nearby police station, but to no avail.
3) I humbly submit that the people who have taken away my husband are undoubtedly police people
inasmuch as two days prior to the incident, few people claiming to be belonging to the Sri Saira mana
Nursing Home, came to our residence asking my husband not to go ahead with filing of legal
proceedings against the said hospital, failing which to face adverse consequences,
4) I humbly submit that it is pertinent in this connection to bring to the notice of this Hon'ble Court
that I have undergone a tubectomy operation for adopting small family norm at the said Sri Sai Ramana
Nursing Home of 18.12.2003 and the operation has failed and I got pregnancy. Therefore, land my
husband decided to initiate necessary legal proceedings against the said hospital. The people who
came to our residence on 3.4.2005 had tried to convince us to withdraw the proposed legal action
against the hospital. They also informed us that they are the near relatives of one of the Ex-Director
Generals of Police of the State of Telangana. As such I believe that my husband was taken away by the
police at the instance of the management personnel of the said hospital in retaliation to our move of
filing a case against them.
5)I humbly submit that the husband of the petitioner is working as a Chief Reporter in the Andhra
Weekly and he has neither any bad habits nor indulged in any anti-social activities. There are no civil
or criminal proceedings either contemplated or pending against him either in this State or outside the
State.
6) It is humbly submitted that my husband is the only earning male member of our family and in his
absence, I and my small minor children and near and dear relatives are facing lot of mental agony,
frustration and disappointment. We are in a doubt that there may be a threat to his life. Hence this
present writ petition is filed inter alia, on the following:
GROUNDS
(1) That the taking away of the husband of the petitioner from her residence without intimation or
further details, is illegal, arbitrary and against the constitutional guarantees and settled principles of
law and judicial decisions. The police who have taken away the husband of the petitioner have not
followed any of the procedural rules and guidelines laid down under the Criminal Procedure Code and
by the Supreme Court from time to time.
(ii) That the local police and the State has miserably failed either to tract the whereabouts of my
husband for 10 days and there is every possibility of a threat to his life in the hands of the police on
the instigation of the management of the said hospital.
(i) That in the absence of the husband of the petitioner, the petitioner, her children and other friends
and relatives are suffering with uncalled for mental
6) I humbly submit that I have no other effective alternative remedy except to invoke the extraordinary
jurisdiction of this Hon'ble Court under Art. 226 of the Constitution of India.
7) I humbly submit that I have not filed earlier any other writ, suit, or other proceedings either in this
Hon'ble Court or in any other Court of law or authority in respect of the subject-matter covered by this
present writ petition. In view of the foregoing facts and circumstances, it is humbly prayed that this
Hon'ble Court may be pleased to issue a writ of habeas corpus or any other appropriate writ, order or
direction, directing the Respondents 1 to 3 to produce the husband of the petitioner, Sri Ram, S/o.
33
Sattiah, before this Hon'ble Court forthwith and on such production to release him without any bond
or security and to pass such order or further order or orders as this Hon'ble Court may deem fit and
proper in the facts and circumstances of the case.
Sd/-
Deponent
Solemnly affirmed and signed on this the 14th day of August, 2006 at Hyderabad in my presence.
Before me
Sd/-
Advocate,
Hyderabad
VERIFICATION
1. Smt. K. Sita, Petitioner in the above Writ Petition do hereby state the contents of the Writ
Petition/Writ Affidavit are true to my personal kno edge; those of paras 1 to 6 etc., are believed to be
correct and thos grounds as also paras 6 to 7 etc., are based on legal advice believed to be correct.
Sworned and signed this at Hyderabad on the 14th day of August 2006.
Sd/-
Deponent
34
Writ Petition for Enforcement of Fundamental Rights under Article 32.
IN THE SUPREME COURT OF INDIA SPECIAL ORIGINAL JURISDICTION (FILED UNDER ART.32 OF THE
CONSTITUTION OF INDIA) WRIT (CIVIL) NO. 1 OF 2006
IN THE MATTER OF:
Prabhu Raksha, Rep. by its Secretary,
Rafi Marg, New Delhi……………………………………………………………………………………………………………Petitioner
AND
1) Union of India,
Rep. by its Cabinet Secretary, Anusandhan Bhavan, New Delhi-110001.
2) Secretary to Govt. of India, Department of Environment & Forests,
Ministry of Environment & Forests, new Delhi ……………………………………………. Respondents Nos. 1 to 2

A PETITION UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA READ WITH ORDER XXXV, RULE 1
& 2 OF THE SUPREME COURT RULES, 1966 FOR THE ENFORCEMENT OF PETITIONER'S FUNDAMENTAL
RIGHTS GUARANTEED UNDER ARTICLES 14 AND 21 OF THE CONSTITUTION OF INDIA
To
The Hon'ble Chief Justice of India and his Companion Justices of Supreme Court of India
The humble petition of the above named.
1) That the petitioner society is a registered non-Government society working for the welfare of the
poor and downtrodden people. 2) Government of India issued an order No. 10 dated 5.6.2006 under
the
Environment (Protection) Act, 1986 wherein the Government has put an house failing which the owner
of the house will be liable to penalty. The penalty obligation on the citizens to compulsorily plant not
less than five trees in each wone year imprisonment or Rupees one lakh fine or both and the
responsibility to grow the trees is vest on the house owner, The Government order also contained a
provision that the house owner shall also be liable if any dust material or garbage is found around his
or her house. The penalty for it is 10,000. fine However, people with an income less than Rs. 10,000/-
are exempted from the provisions of the said GO. Conveyancing.
QUESTIONS OF LAW
1) Whether the impugned Government Order is violative of Articles 14 and 21 of the Constitution of
India? and
2) Whether the impugned Government Order involves public interest?
Facts leading to filing of the instant petition area as under.
35
The impugned Government Order is issued without taking into consideration the negative impact it
may have on the common man of the country. The Petitioner here has made requisite representations
to the respondent authorities on 12-2-2006 and 12-6-2006 for the withdrawal of the said G.O., but to
no avail. Hence the present Writ Petition.
GROUNDS
1) The impugned Government order cannot be enforced especially in urban areas where a majority of
the poor fraction of the society live in slums who will have no space in growing the requisite five trees.
2) The impugned GO. does not provide for any reasonable exceptions from the applicability of the
provisions thereof. The only exception given is in respect of persons whose income is less than Ten
thousand rupees per month. Interlinking income with the growth of minimum of five trees per house
is irrelevant and illogical.
3) The enforcement of the said impugned Government order is also not possible even in rural areas
where houses in the villages are constructed in a congestive unplanned manner. There is no check by
the concerned Town Planning Authorities either in cities or in villages in planning the house
construction. As a result, houses are constructed without applying mind as to the legal requirements
relating to any set back area and proper roads for free flow of traffic and for meeting emergency
hazards. In such circumstances it is impossible for citizens to grow a minimum of five trees around
their residences.
4) The petitioner has brought the above aspects to the notice of the Respondent authorities but to no
avail.
5) The enforcement machinery authorized to enforce the said Government order have already started
initiating penal actions against the citizens who failed to plant the requisite number of trees for want
of sufficient open yard. As a result a hoe and cry in the society is reverberating thereby attracting the
immediate attention of the Respondent authorities to withdraw the said GO that there is no hope that
the Respondent authorities will any heed to the wds and problems of the people, well before it
becoming law and order problem beyond control 6) The Respondent Government has issued the
impugned order arbitrarily and without issuing any public notice. 7) Neither under the provisions of
the Constitution of India nor the provisions of the Environment (Protection) Act do permit the
appropriate Government to is such a GO. containing harsh penalties.
8) The action of the respondent authorities is arbitrary, unreasonable and
9) The action of the respondent authorities clearly amounts to interference with the right to life of the
citizens guaranteed under Art. 21 of the Constitution and the impugned order conflicts with such right
inasmuch as protection of environment also forms part of the requirements of Art. 21 of the
Constitution. When there is a clash relating to same subject on different occasions the benefit of law
should be given to the citizens.
10) The petitioner has no other effective alternative remedy except to filing the present Writ Petition
under Article 32 of the Constitution of India. 11) The Writ Petition is filed since the action of the
Respondent authorities is in violation of Articles 14 and 21 of the Constitution of India.
12) The Petitioner has not filed any other Writ Petition.
36
PRAYER:
It is, therefore, most respectfully prayed that this Hon'ble Court may be pily pleased:
(A) to issue a writ or direction or order declaring the G.O.No. 10 dated 5.6.2006 issued by the
Department of Environment and Forests, Ministry of Environment and Forests, Government of India,
New Delhi, as being illegal, arbitrary and violative of the fundamental rights of the petitioner as well
as the citizens of the country, and
(B) to issue any other writ or order or direction declaring the GO.No. 10 dated 5.6.2006 as being not
operative against the petitioner as well as the citizens and non-citizens of the country, and
(C) to pass such other order or further order or orders as this Hon'ble Court may deem fit and proper
in the facts and circumstances of the case. For this act of kindness, the petitioner, shall as in duty bound
ever pray.
New Delhi
Filed on. 20.07.2006.
Drawn by: sd/-
Filed by: Sd/-
Counsel Advocate for the petitioner
37
Special Leave Petition under Article 136 of the Constitution of India.
IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION

SPECIAL LEAVE PETITION (Under Article 136 of the Constitution of india)
S.L.P(CIVIL) NO. 1 OF 2006
BETWEEN
Sri Mukund Rao,
Slo. Sri Chandrasekhar Rao,
Aged about 35 years. R/o. H.No. 86/C/10,
Narayanaguda,
Hyderabad, Andhra
Pradesh………………………………………………………..Appellant……………….Petitio
ner
AND
1) Government of Andhra Pradesh, Rep. by its Chief Secretary, Secretariat,

Hyderabad. A.P..
2) Secretary to Government, Department of Medical, Health Family Welfare, Government of
Telangana State,
Hyderabad. A.P..
3) Director of Medical, Health and Government of Andhra Pradesh,
Family Welfare,
Koti, Hyderabad. A.P…………………………………………………Respondents No.1 to 3/
Respondents No.1 to 3
To,
The Chief of India and his Companion Justices of Supreme Court of India
The humble petition
of the above named.
38
1)The petitioner above named respectfully submits this petition socking Special Leave to
Appeal against the final judgment and order of the Division Bench of the Andhra Pradesh High
Court in Writ Appeal No 4 of 2006 dated 29.5.2006 in Writ Petition No. 14 2006 dated 25,2006
dismissing the said writ petition of the petitioner.
2) The petitioner is deprived of the genuine and lawful benefit that accrues not only to the
petitioner but also to all other people living in the State of Andhra Pradesh in view of passing
of the impugned judgement dated 29.5.2006. Hence the petitioner seeks to file the present
Special Leave Petition
QUESTIONS OF LAW:
The following questions of law arise for consideration by this Hon'ble Court
(A) Whether the High Court while exercising its power under Art. 226 of the Constitution of
India can dismiss the Writ Petition filed questioning the failure of the Government in protecting
and safeguarding public health and welfare when there is an emergency created by the
spreading of the disease of Chikun Gunya fever affecting life and health of thousands of people
on the ground that the petitioner is not a public spirited person to take up the public issue before
the High Court?
(B) Whether the petitioner/appellant can take up the present matter which falls within the legal
and constitutional obligation of the Government in protecting and safeguarding public health
and welfare?
DECLARATION IN TERMS OF RULE 4(2):
The petitioner states that no other petition seeking Leave to Appeal has been filed in the matter
covered by the impugned judgment and order.
DECLARATION IN TERMS OF RULE 6:
The Annexures P/1 to P/15 submitted along with SLP and true copies of the
pleadings/documents form part of the records of the case in the Court below against whose
order the present Leave to Appeal is sought for in this petition.
GROUNDS:
Leave to Appeal is sought for on the following grounds:
(1) Because the impugned judgment and order passed in W.A. No. 4 of 2006 dated 29.05.2006
in W.P. No. 14 of 2006 dated 02.05.2006 is contrary to law, weight of evidence and probabilities
of the case.
(2) Because the impugned judgment passed by the Hon'ble High Court is erroneous inasmuch
the Hon'ble Court totally erred in dismissing the Writ Petition when public health is in a serious
stake.
39
(3) Because the Hon'ble High Court totally failed to take into consideration the adverse impact
created the spreading of the Chikun Guniya fever which has already attacked thousands of
people in the State and the Government has become a mere spectator and failed to do its duty
under the Constitution of India in protecting the life and health of the people from that decease.
MAIN PRAYER:
It is most respectfully prayed that this Hon'ble Court may be pleased to:
(A) Grant Special Leave to Appeal against the impugned final judgment and order dated
29.5.2006 of the High Court of Judicature of Andhra Pradesh at Hyderabad passed in Writ
Appeal No. 4 of 29.5.2006 Petition No. 14 of 2006 dated 2.5.2006; and
(B) Pass any order or further order or orders as may be deemed fit and proper in the facts and
circumstances of the case. For this act of kindness, the petitioner, shall as in duty bound ever
pray.
New Delhi
Drawn on: 15-01-2007
filed on: 15-01-2007
Drawn by: Sd/-
Filed By: Sd/-
Advocate for the petitoner
CERTIFICATE
Certified that the Special Leave Petition is confined only to the pleadings before the High Court
of Andhra Pradesh at Hyderabad, whose judgment and order is challenged and the other
documents relied upon in those proceedings. No additional facts, documents or grounds have
been taken therein or relied upon in the Special Leave Petition. It is further certified that the
copies of the documents/Annexures attached to the Special Leave Petition are necessary to
answer the questions of law raised in the petition or to make out grounds urged in the Special
Leave Petition for consideration of this Hon'ble Court. This Certificate is given on the basis of
the instructions given by the petitioner and authorised by the petitioner whose affidavit is filed
in support of the Special Leave Petition.
New Delhi
Drawn on: 15-01-2007
Filed On: 15.01.2007.
Sd/-
Advocate for the petitioner.
40
Application for Regular Bail.
IN THE COURT OF THE VII METROPOLITAN MAGISTRATE: CYBERABAD: AT L.B. NAGAR: TELANGANA
STATE
Cr.M.P. No. of 2005
C.C.No. of 2005
BETWEEN:
Ramoji
S/o. Sri Narayana,
Aged about 50 years, Occupation: Proprietor, Anjali Jewellery Shop.
Hayatnagar, R.R. District……………………………………………………………………………………..... Petitioner/Accused
AND
1) State of Telangana.
Through Hayathnagar Police Station,
Represented by the Public Prosecutor.
Criminal Court Premises, Cyberabad,
L.B.Nagar, L.B.Nagar,
Telangana State……………………………………………………………………………Respondent/Defacto Complainant
Petition filed on behalf of the Accused under Section 437 Cr.P.C.
(Offences Under Sections 148, 149, 355, 356 and 418 of IPC.)
The address for service of summons, notices and processes etc. on the above-named
Petitioner/Accused is the same as that of his Counsel Mr. (Give the address of the Counsel. For
example: Shri Ram Kumar, Advocate, Advocates Association. Ranga Reddy District Court Premises,
LB.Nagar, R.R.District.)
The address for service of summons, notices and processes of the above-named De facto
Respondent/Complainant is the same as that mentioned in the above cause title.
41
The above-named Petitioner/Accused humbly submits as follows: Hon'ble Court, and is alleged to have
committed the offence under Sections 1) The Petitioner is accused in C.C. No. 10 of 2005 on the file of
this H’onble court and is alleged to have committed the offence under sections 148, 149, 355, 356 and
418 of IPC.
2) The petitioner humbly submits that he is the owner and Proprietor of the Anjali Jewellery Shop and
running the same since twenty years. The present investment value in the shop is about Rs. 20 crores.
He hails from a good and respectable family without having any criminal background.
3) It is submitted that a complainant has been made against the petitioner and the same is pending
for enquiry before the Court of the VII Metropolitan Magistrate, Cyberabad, L.B.Nagar, R.R.District,
Telangana State.
4) The petitioner/accused humbly submits that he is not guilty of any of the offences alleged by the
respondent/complainant. He is an innocent person.
5) The Petitioner is remanded to judicial custody on 25-12-2004.

6) The present petition is the first, and no other similar petition is either filed or pending before any
other court including the Hon'ble High Court of Telangana State.
7) The petitioner/accused submits that he is ready and willing to furnish any sureties as may be
directed by this Hon'ble Court, if he is released on bail. For the reasons mentioned above it is humbly
prayed that this Hon'ble Court may be pleased to release/enlarge the petitioner/accused on bail in C.C.
No. 10 of 2005 on the file of this Hon'ble Court pending trial on such terms and conditions and with or
without any surety or security as this Hon'ble Court may deem fit and proper in the interest of justice
and fair play.
Place: L.B.Nagar Sd/-
Date: 5.2.2005. Petitioner/Accused.
Place: L.B. Nagar Sd/-
Date: 5.2.2005. Counsel for the Petitioner/Accused.
42
Application for Anticipatory Bail.
IN THE COURT OF THE VII METROPOLITAN MAGISTRATE: CYBERABAD: AT L.B. NAGAR: TELANGANA
STATE
Criminal petition No. of 2006
BETWEEN:
Ramoji
S/o. Sri Narayana,
Aged about 50 years, Occupation: Proprietor, Anjali Jewellery Shop.
Hayatnagar, R.R. District……………………………………………………………………………………..... Petitioner/Accused
AND
1) State of Telangana.
Through Hayathnagar Police Station,
Represented by the Public Prosecutor.
Criminal Court Premises, Cyberabad,
L.B.Nagar, L.B.Nagar,
Telangana State………………………………………………………………………………Respondent/Defacto Complainant
Petition filed on behalf of the Accused under Section 438 Cr.P.C.
(Offences Under Sections 148, 149, 355, 356 and 418 of IPC.)
The address for service of summons, notices and processes etc. on the above named petitioner-
Accused is the same as that of his Counsel Shri Ram Kumar, Advocate, Advocates' Association, Ranga
Reddy District Court Premises, Kothapet, Telangana State.
The address for service of summons, notices and processes on the abovenamed
Respondent/Complainant is the same as that mentioned in the above cause title.
The above named petitioner/accused humbly submits as follows: 1) The petitioner herein is accused
in Crime No. 10 of 2005 on the file of the Hon'ble Court of VII Metropolitan Magistrate, Cyberabad, at
L.B.Nagar, RR.District, Telangana State, alleged to have committed the offence under Sections 148, 149,
355, 356 and 418 of IPC.
43
2) The petitioner/accused humbly submits that he is the owner of the Anjali Jewellery Shop and
running the same for twenty years. The present investment value in the shop is about Rs. 20 crores.
He hails from a good and respectable family without any previous criminal background. He is falsely
implicated in the present case.
3) While things stood thus a complaint has been made against the petitioner and the same is pending
for enquiry before the Court of the VII Metropolitan Magistrate, Cyberabad, L.B.Nagar, R.R.District,
Telangana State.
4) The petitioner/accused humbly submits that he is not guilty of any of the offences alleged by the
respondent/complainant.
5) The Petitioner humbly submits that he has not filed any other similar petition either before this
Hon'ble Court or before any other Court.
6) The petitioner humbly submits that he is ready and willing to furnish any sureties as may be directed
by this Hon'ble Court, if he is released on anticipatory bail, in the event of his arrest on the said
accusations.
For the reasons mentioned above it is humbly prayed that this Hon'ble Court may be pleased to release
the petitioner on anticipatory bail in the event of his arrest in C. No. of 2006 on the file of the Court
of the Hon'ble VII Metropolitan Magistrate, L.B.Nagar, Ranga Reddy District, Telangana State, with our
without sureties and to pass such other or further order or orders as this Hon'ble Court may deem fit
and proper in the interest of justice and fair play.
Place: L.B.Nagar Sd/-
Date: 10.12.2005. Petitioner/Accused.
Place: L.B. Nagar Sd/-
Date: 10.12.2005. Counsel for the Petitioner/Accused.
44
Complaint under section 138 of the Negotiable Instruments Act, 1881
45
46
Application under section 125 of the Code of Criminal Procedure, 1972.
47
48
Will Deed.
THIS IS THE LAST WILL of mine, namely, Venkateswar Rao, Slo (Late) Sri Tirumaleswar Rao,
Aged about 70 years, Occupation: Business, Address: 1-2A, Chikkadpally, Hyderabad-500020,
Telangana State, made and executed on this the 13th day of September, 2006 voluntarily and while I
am in a sound state of mind.
Whereas I am the absolute owner and possessor of the house building property bearing House No. 1-
2A, situated at Chikkadpally, Hyderabad-500020, Telangana Stae, consisting of a plinth area of 1200
Sft. constructed on a total landed area of 300 Sq. yds. (hereinafter referred to as the said property the
detailed description of which is given in the below mentioned Schedule and also delineated in RED
colour in the Plan annexed hereto).
Whereas Sri Rangachari Rao, aged about 40 years. Occupation: Government employee, Address:
H.No. 1-5-7, Narayanaguda, Hyderabad- 500020, Telangana State, is my only natural born son.
Whereas I am now 70 years of old and keeping indifferent health for a few months since, although I
am mentally sound.
Whereas I am anxious to make necessary arrangements for transfer of my said house building property
in favour of my said son for his use and enjoyment absolutely and for ever with all rights, titles,
privileges, appurtenances etc. Therefore, I am executing this last testament of mine with my free will
and without any coercion or fraud.
I NOW DECLARE AS FOLLOWS:
i) I hereby revoke all my earlier Wills and codicils made by me, if any, any time earlier.
ii) I have my living wife Smt. Malleswari, aged about 65 years, Hindu, who requires maintenance and
special care if I pre-decease her. My wife is not given any share in the said property, under this Will.
My said son has to look after my wife after my death in the same manner as to I could have seen her
had I been alive.
iii) I hereby bequeath all the said house building property bearing No. 1- 2A, Chikkadpally, Hyderabad-
500020, Telangana State, in favour of my said son absolutely and forever to hold and enjoy the same
with full and absolute rights, titles, privileges etc. including the power of alienation, after my death.
iv) I hereby declare that in case my said son predeceases me, the said scheduled property shall vest in
the name of my said wife for her absolute enjoyment with all rights and privileges till her death and
thereafter the same shall vest in my daughter-in-law Smt. Saritha, my daughter-in-law and the wife of
my said son, aged about 35 years, absolutely and for ever with all rights, titles and privileges.
SCHEDULE OF THE PROPERTY

All that part and parcel of house building property bearing Municipal No. 1-2A, situated in
Chikkadpally, Chikkadpally Mandal, Hyderabad-500020, Telangana State, 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' Public Road
East: Neighbour's house bearing No. 1-14
49
West :15 Public Road.

In witness whereof I put my hand and signed this Will on this the 20th day of September, 2006 at
Hyderabad with my free will and consent and without any coercion or fraud in the presence of the
following witnesses.
Sd/-
(Testator)
In our presence at the same time and each of us as in the presence of the testator signed his name
hereunder as an attesting witness:
Witnesses:
Sd/-
1. V. Malleswari
H.No. 1-2A
Chikkadpally
Hyderabad-500020.
Sd/-
2. K. Seetharamaiah
H.No. 2-2A
Chikkadpally
Hyderabad-500020.
50
Sale Deed.
THIS DEED OF SALE is made and executed on this the 11th day of September 2006 at
Hyderabad by:
Sri Venkateswar Rao, S/o. Sri Tirumaleswar Rao, Aged about 45 years, Occupation: Business,
Address: 1-2A, Chikkadpally, Hyderabad-500020, Telangana State (hereinafter referred to as
the "VENDOR" which expression shall mean and include all his successors/survivors/legal
heirs/representatives/ assignees etc.) as the first party.
In favour of
Sri Rangachari, S/o. Sri Venkatachari. Aged about 40 years. Occupation: Government
employee, Address: H.No. 1-5-7, Narayanaguda, Hyderabad- 500020, Telangana State
(hereinafter referred to as the "Vendee" which expression shall mean and include all his
successors/survivors/legal heirs representatives/assignees etc.) as the second party.
WHEREAS the vendor is the absolute owner and possessor of house building property
consisting of a plinth area of 1200 Sft. constructed on a total landed area of 300 Sq. yds. bearing
House No. 1-2A, situated at Chikkadpally, Hyderabad-500020, Telangana State, having
purchased the same vide Registered Sale Deed No. 12 of 2000, dated 12-01-2000 registered at
the office of the Sub-Registrar, Chickadpally, Hyderabad. The detailed description of the said
house building property is provided in the schedule given below and also demarcated and
delineated in red colour in the plan annexed hereto. (hereinafter referred to as the said
"SCHEDULED PROPERTY").
WHEREAS the vendor was in need of funds to meet his domestic expenses and therefore
offered to sell his said house building property to the vendee/purchaser herein free from all
encumbrances, taxes, liabilities, prior assignments etc. and with all rights, titles, benefits,
privileges, easements etc. for a total sale consideration of Rs. 10 lakhs (Rupees Ten lakhs only).
Whereas the vendee herein has agreed to purchase the said scheduled property for the said sale
consideration.
WHEREAS the vendee herein has paid a sum of Rs. 10 lakhs (Rupees Ten lakhs only) towards
the full and final settlement of the total sale consideration, the receipt of which amount is
hereby acknowledged by the vendor.
NOW THIS DEED OF SALE WITNESSETH AS FOLLOWS:
1) That in consideration of the payment of total sale consideration by the vendee, the vendor
herein has delivered peaceful and vacant possession of the said scheduled property with all
rights, titles, easements benefits and without any encumbrances, charges, prior assignments etc.
in favour of the vendee to have, vest in and enjoyed by the vendee absolutely and forever as of
its real owner and possessor, and the vendee herein has taken over the same accordingly.
2) That the vendor herein has agreed to indemnify the vendee in case of any defects in the title
of the said scheduled property.
3) That the vendee shall lawfully enjoy at all times and in all events the said scheduled property
peacefully and without any hindrance either from the vendor or from any third party, and the
51
vendor will indemnify the vendee in case of any loss or damage caused to the vendee due to
any defects in the rights and titles of the vendor.
4) That the vendor has handed over all the link documents in respect of the said scheduled
property. 5) That the vendor has already paid all the taxes and other revenues due and payable
to the concerned public authorities upto this date and the vendee should pay the same hereafter.
6) That the vendor has agreed to do at all times and on all reasonable requests made by the
vendee and at the cost of the vendee to do and execute or cause to be done and execute all such
acts, deeds and things whatsoever for further and more perfectly conveying and assuring the
rights and titles in respect of said the scheduled property in the favour of the vendee.
7) That the vendor hereby agreed that the said scheduled property is not under any charge, title,
claim, estate or other liability which will prevent the vendor from conveying perfect rights and
titles in respect of the said scheduled property in favour of the vendee.
8) That the vendor hereby declares that the said scheduled property is neither an assigned land
attracting the provisions of the law relating to assignment nor does it a property falling under
the Urban Land Ceiling.
Chikkadpally, Chikkadpally Mandal, Hyderabad-500020. Telangana State, consisting of a
plinth area of 1200 sft. constructed on a total landed area of 300 Sq. yds, and bounded by-

South: 30' Public Road
East : Neighbour's house bearing No. 1-14
West :15' Public Road.
In witness whereof the vendor herein has put his hand and signed on this deed of sale on the
day, month, year and place first above mentioned with his free Will and consent and without
any coercion or fraud, in the presence of the following witnesses:
Witnesses:
Sd/-
(Vendor)
Sd/-
1. K. Subba Rao
H.No. 20-1-A
52
Chikkadpally
Hyderabad-500020.
Sd/-
(Vendee)
Sd/-
2. V. Krishna
H.No. 15-3-2
Chikkadpally
Hyderabad-500020.
53
Mortgage Deed.
THIS DEED OF SIMPLE MORTGAGE is made and executed on this the 12th day of
September, 2006 at Hyderabad
BETWEEN
Address: 1-2A/A, Chikkadpally, Hyderabad-500020, Telangana State (hereinafter referred to
as the "MORTGAGOR" 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, Narayanaguda, Hyderabad- 500020, Telangana State
(hereinafter referred to as the "MORTGAGEE" which expression shall mean and include all
his successors/survivors/legal heirs/ representatives/assignees etc.) as the second party.
WHEREAS the mortgagor herein is the absolute owner and possessor of the house building
property bearing House No. 1-2A, situated at Chikkadpally, Hyderabad-500020, Telangana
State consisting of a plinth area of 1200 Sft. constructed on a total landed area of 300 Sq. yds.
(hereinafter referred to as the "Mortgage property" the detailed description of which is made in
the Schedule given below and is delineated with the Red colour in the Plan annexed hereto).
WHEREAS the mortgagor herein is in need of money and therefore offered to mortgage his
property to the mortgagee herein for a mortgage amount of Rs. 10 lakhs (Rupees Ten lakhs
only) repayable in three years from the date of this deed with a rate of interest of 8% per annum.
WHEREAS the mortgagee herein has agreed to lend the said money in mortgage of the said
scheduled property to the mortgagor at the said rate of interest and repayable within the
specified duration.
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 SIMPLE 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, 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 his liability against the
said mortgage property by invoking all or any of the remedies available in law relating to simple
mortgage.
2) The mortgagor hereby transfers by way of simple mortgage without possession all the said
Scheduled property, property bearing Municipal No. 1- 2A, Chikkadpally, Hyderabad-500020,
Telangana State, together with all rights, easements, benefits, etc. in favour of the mortgagee.
54
3) The mortgagor assures that the mortgaged property is free from all encumbrances and proof
of boundaries and that he is the full and absolute owner and possessor of the same and also that
he is entitled to mortgage the same.

All that part and parcel of house building property bearing Municipal No. 1-2A, situated at
Chikkadpally, Chikkadpally Mandal, Hyderabad-500020, Telangana State, 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
West :15 feet Public Road.
In witness whereof the parties herein have put their hands and signed this deed of simple
mortgage 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/-
1. S. Prasad (Mortgagor)
H.No. 3-3-55 Sd/-
Chikkadpally (Mortgagee)
Hyderabad-500 020.
Sd/-
2. K.V. Rao
H.No. 23-5-B
Chikkadpally
Hyderabad-500 020.
55
Partnership Deed.
This DEED OF PARTNERSHIP made this day of
Between
hereinafter called the partners of the first part and Second Part respectively
AND
A company registered under the provisions of the Companies Act 1956 and having its registered office
at hereinafter called the party of Third part
WHEREAS the Parties of First and Second Part by virtue of their partnership deed dated have been
carrying on the business of manufacturing and marketing paints, colors and varnishes etc. under the
name and style of with factories at under the same name and style.
AND WHEREAS the Party of Third Part Viz. the company is formed with the objects of manufacturing
dealing and marketing in paints, varnishes, colors etc.
AND WHEREAS the Party of the Second Part has expressed its desire and willingness through the
director to enter into Partnership and parties First, Second part have mutually decided that the Party
of the third Part shall be taken as Partner.
AND WHEREAS it is deemed necessary and desirable that a regular Deed of Partnership be reduced in
writing and executed on the terms and conditions mentioned hereunder.
NOW THIS DEED WINTESSETH AS UNDER: -
1. The Partnership shall come into effect from and shall be for an indefinite period unless it is
determined.
2.That the name and style of the Patnership firm hereby formed shall be with factories at under the
same names and style or with branch or branches at such place(s) as the parties may mutually decide.
3. That the business of the Partnership Firm hereby formed shall be that of manufacturing and
marketing of paints, colors and varnishes etc., as hereto before. The parties may, however, with their
mutual consent embark upon a new line or lines of business and may open branch or branches or new
factory.
4. That the amount standing to the credit of the personal accounts of the Parties of First and Second
Part in the books of above firm as on shall be treated as contribution by them to the capital of the
Partnership and the Party of the Third Part shall bring Rs. as his share towards the capital of the firm.
5. That further finance required for the purpose of business of the firm shall be contributed by the
parties in such rate as may be mutually agreed upon. Interest at the rate of or at a rate as may be
mutually agreed upon between the parties from time to time shall be allowed on the capital standing
to his/her credit for the time being in the books of the partnership.
6. That the regular accounts books shall be kept in due course of business in which shall be faithfully
recorded all the transactions enter into by the firm and such books shall be closed on or/on any other
convenient or auspicious day as may be mutually agreed upon between the parties hereto from time
to time.
56
7. That on closing the account books in the aforesaid manner, a regular profit & Loss Account shall be
prepared and a balance sheet shall be drawn up.
8. That the Profits & Losses shall be divided between and borne by parties hereto in the following
proportions: Partner % of share in Profits and Losses
9. That the partners will be paid a Salary of Rs.2500/- per month for the services rendered to the rim
and they will also be entitled to a bonus @ 12% on their salary.
10. That all the assets and liabilities of the firm as on tangible or otherwise, would be taken over by
the Partnership at its book value and shall be deemed to be assets and liabilities of this Partnership
and all the Parties hereto will have equal rights/liabilities thereon.
11. That all rights of the firm as on namely ISI marketing license, Trade marks, Sales Tax registration,
Telephone connections, Tenancy rights, Lease rights, Ownership right etc. shall be deemed to be the
rights of the partnership and all the parties hereto will have equal rights/liabilities thereon
12. That each partner shall: - (a) Diligently attend to the business of the Partnership and devote his/her
necessary time and attention thereto.
(b) Punctually pay her/his separate debts and indemnify the other partner and the Assets of the firm
against the same and all expenses therefore.
(c) Upon every reasonable request inform the other Partner of all letters, accounts, writings and such
other things which shall come to her/his hands or knowledge concerning the business of the
Partnership.
13.That neither Partner shall without the consent of the others: - (a) Lend any of the money or deliver
upon credit any of the goods of the firm to any person or persons whom the other Partners shall have
previously in writing forbidden her/him to trust.
(b) Raise or advance any loan in the name of or on behalf of the firm.
(c) Assign, charge or transfer her/his shares in assets or profits of the firm.
14. That the account in the name of the firm shall be opened with the Banks or bankers as the Parties
may mutually decide and the same shall be operated upon by the Parties hereto singly.
15.That any partner may retire from the Partnership firm, hereby formed by giving two months notice
in writing to the others but none shall leave the firm until or unless all the pending commitments are
carried out, liabilities paid off, assets realized and accounts are rendered fully and settled finally to the
entire satisfaction of each of the parties hereto.
16.That the parties hereto may, however, with their mutual consent pay remuneration to any of the
parties hereto at a rate that may be mutually agreed upon between them from time to time. They shall
be at liberty to increase or decrease such rate of remuneration with their consent from time to time.
17.That in the event of death or retirement of any of the parties hereto the partnership firm hereby
formed shall not dissolve, but shall continue. The legal heir or the representative of the deceased shall
step into her/his shoes.
18.That upon the dissolution of the partnership in any even not hereinafter provided for the said
business, the assets, goodwill and liabilities thereof should absolutely vest on any one partner
mutually decided by the parties to the partnership.
57
19.That it will always remain open to the parties hereto to amend, annul or change any term or terms
of this Deed of Partnership in the course of its business and in that event of amending, annulling or
changing any term or terms of this deed of Partnership no fresh deed shall be required to be executed.
20.That without prejudice to the above terms and conditions the parties hereto in all other matters
shall be governed by the provisions of Indian Partnership Act, 1932.
21.That all the disputes or differences arising out of it and connected with the Partnership shall be
referred to the arbitrator in accordance with the Indian Arbitration Act.
IN WITNESS WHRE OF, the parties of the first and Second parts here have put their respective hands
on this DEED OF PARTNERSHIP on the day, month and year first mentioned above.
IN WITNESSES WHEREOF, the common seal of the Third Partner viz. was pursuance to the resolution
of the Board of Directors passed in that behalf on here into affixed in the presence of and signed these
presents in token thereof in the presence of the Witnesses:
WITNESSESS: Partners
1. Rahul Tripathi
2. Riyan parag
3. Rahul tewatia
58
Deed of Dissolution of Partnership.
DEED OF DISSOLUTION OF PARTNERSHIP

(Involving immovable property)
THIS DEED OF DISSOLUTION Is made at ... this day ... between Mr. A residing
at ... hereinafter referred to as 'the Party of the First Part' and Mr. 'B' residing at ... hereinafter
referred to as 'the Party for the Second Part' and Mr. 'C' residing at ... hereinafter referred to
as 'the Party of the Third Part,'
WHEREAS the Parties hereto have been carrying on business of... in partnership
in the Firm name of M/s. XYZ & CO on the terms and conditions recorded in the Deed of
Partnership dated ... entered into by and between the parties hereto. since the ... day of ...
AND WHEREAS as certain differences have arisen between the parties hereto (or
as the parties do not desire to continue the said partnership for diverse reasons the parties)
have agreed to dissolve the said partnership as from the ... day of ... on the terms herein
recorded.
AND WHEREAS the assets of the partners consist of (i) the land and premises
purchased and belonging to the Party of the First Part and brought inby the Party of the
First Part as his contribution to the capital of the Firm (ii) the lands and premises described
In the Second and Third Schedules hereto purchased or otherwise acquired by the Firm in
the course of Its business. (iii) and the goodwill, the stock-in-trade, furniture and other
articles and things and bank balances and outstandings.
AND WHEREAS accounts of the partnership business have been made upto the date
of dissolution and the total value of the assets have been ascertained to be Rs... including
Bank balances, and outstanding debts and
59
excluding therefrom the debts and liabilities of the Firm.

AND WHEREAS each partner is entitled to an equal share in the assets and profits
of the firm, under the said Deed of Partnership.
AND WHEREAS it is agreed that the property described In the First Schedule will
be returned back to the Party of the First Part in lieu of his share In the said assets, the
property described In the Second Schedule will be assigned to the Party of the Second Part
in lieu of his share in the said assets and the property described in the Third Schedule will
be retained by the Party of the Third Part in lieu of his share in the said assets.
AND WHEREAS for equalisation of shares the Party of the Third Part will pay to
the Parties of the First and Second Parts in cash a sum of Rs... in the manner hereinafter
provided. --
AND WHEREAS it is agreed that the business of the firm will be continued by
the Party of the Third Part alone in the same name and he will be entitled to retain not only
the property described in the Third Schedule but all the stock-in- trade, furniture, articles
and moneys in lieu of his share in the assets subject to payment of the said sums payable
to the Parties of the First and Second Part and subject to all debts and liabilities of the Firm
and that the Parties of the First and Second Part will be deemed to have retired from the
partnership
AND WHEREAS the parties have agreed to record the terms of and effectuate the
dissolution of the Firm In the manner following.
NOW THIS DEED WITNESSETH AS FOLLOWS:
60
1. It Is agreed and declared that the partnership between the parties heretoin the
name of M/s ... be and it is hereby dissolved with effect from the ... day of ,
2000.
2. The accounts of the business and assets, profits and losses of the said partnership
firm till the date of dissolution have been made and settled and signed by the Parties
and the Parties confirm the same and except ashereinafter provided no party is
liable to the others in respect thereof.
3. The business of the Firm shall be continued to be carried on by the Party of the
Third Part alone and as the sole proprietor thereof as from the said date and the
Parties of the First and Second Part shall be deemed to have retired from the
partnership and shall have no claim thereto except to the extent hereinafter
mentioned.
4. The property described In the First Schedule hereto shall cease to be a part of the
assets of the Firm and shall continue to belong to the Party of the First Part in his
own personal capacity and the Parties hereto of the Second and Third Part hereby
release and renounce all their right, title and Interest therein or thereto as partners
of the Firm.
5. The property described in the Second Schedule hereto shall also cease to be a part
of the assets of the Firm and shall belong to the Party of the Second Part alone and
in his own personal right and the Parties of the First and Third Part hereby grant,
transfer and release all their respective shares, right, title and interest therein
together with the appurtenances thereto To Have and To Hold the same unto and
to the use of the Party of the Second Part absolutely subject to the payment of the
taxes, rates, assessments, dues and duties payable in respect thereof to the
61
Government or Municipal Corporation or any other public body.
6. The Parties of the First and Second Part also release or renounce in favour of the
Party of the Third Part all their share, right. title and interest, claim and demand in
or to the stock-in-trade. furniture and other articles and moneys belonging to the
Firm, the goodwill, thereof and in or to allthe debts and outstandings belonging
to the Firm.
7. The property described in the Third Schedule hereto shall belong to the Party of the
Third Part alone and the Parties of the First and Second Part hereby grant, transfer
and release all their respective shares, rights. title and interest therein To Have And
To Hold the same unto the use of the Party of the Third Part absolutely subject to
the payment of all the taxes, rates, assessments, dues and duties In respect thereof
payable to the Government or the Municipal Corporation or any other public body.
8. The Party of the Third Part agrees and covenants to pay to each of the parties of the
First and Second Parts a sum of Rs... by quarterly equal instalments with Interest
thereon at ... % p.a. the first of such instalments to be paid on the ... day of ... and
each subsequent instalments on the ... day of each subsequent quarter provided that
in default of payment of anytwo instalments the whole of the said amount or any
part thereof then remaining due shall become payable forthwith and provided
further that, the payment of the said amounts shall remain charged on the property
described in the Third Schedule hereto and allotted to the Party of the Third Part.
9. The Party of the Third Part covenants with the Parties of the First and Second Part
that he will pay and is liable to pay all the debts and
62
liabilities of the Firm subsisting on the date of dissolution including liabilities of

Firm's income-tax and other taxes and Government dues and shall indemnify and
keep indemnified the Parties of the First and Second Parts against the said liability
and against all loss, costs, charges and expenses incurred by any of them on account
of such debts and liabilities or any of them or any part thereof being required to
be paid by them orany of them.
10. Each of them the Parties hereto hereby releases the other or others from all
proceedings. accounts, claims and demands in respect of the said partnership but
without prejudice to any rights or claims and remedies in respect thereof under
these presents.
11. The Parties of the First and Second Part hereby jointly and severally appoint,
nominate and constitute the Party of the Third Part their attorney or agent with
authority to collect all the assets and property of the partnership and to ask, demand,
sue for and recover and receive and to sign and give discharge for all the debts.
estate and effects or other moneys due or owing or in any wise belonging to the
said partnership and to settle accounts. reckoning, matters and things whatsoever
relating thereto and to compound or release all or any of the debts or claims
belonging to the partnership and to Institute any suit or legal action or other
proceedings for compelling payment, discharge or delivery of any moneys or other
property belonging to the partnership and for any of the purposes aforesaid from
time to time to appoint any substitute or substitutes and at any time to remove him
or them, to sign, declare pleadings. applications and other papers as may be
required for the purpose. and generally to do all such acts and things as may be
necessary or expedient for the purpose of recovering All debts and
63
liabilities of the Firm or for vesting in the Party of the Third Part thepremises
hereby assigned or released to him.
12. The Parties of the First and Second Part shall not for a period of one year from the
date hereof carry on or engage or be concerned or interested either directly or
indirectly in the same business carried on by the said partnership in the city of ...
13. The benefits of or rights to all permits licenses held by the said Firm shall belong
to the Party of the Third Part alone and the Parties of the First and Second Part will
have no right or claim thereto.
14. Each of the parties hereto agrees and undertakes to sign all applications. documents,
and other papers as may be. required to properly transfer the properties and other
assets allotted, assigned or released to the other or others including all licenses and
permits in the Government or Municipal records or otherwise but the costs, charges
and expenses in respect thereto will be borne by the party requiring such documents
to be signed.
15. Each of the parties hereto assures the others that except as recorded in the books of
account of the Firm and other record, any of them has not received. collected or
discharged or compromised any claim demand or credit due or to become due to
the Firm or incurred any debt or liability or obligation that may now or hereafter
directly or indirectly charge or affect the partnership or any of Its property and
assets.
16. The notice of the dissolution of the firm in the prescribed form will be given by
the Party of the Third Part within prescribed time as required by the Partnership
Act and Rules made thereunder and the Party of the Third
64
Part will publish the dissolution in the Government Gazette as early as

possible.
17. All the expenses of and incidental to stamp and registration of this Deed will be
borne by the parties hereto in equal shares.
18. The original of this Deed will remain in the custody of the Party of the Third Part
and will be produced by him to the other or others whenever required for inspection
or production before any Court. any Govt. Officer, Central or State, including the
Offices of the Income tax and Sales Tax Department. One duplicate signed copy of
this Deed will remain with each of the other two parties hereto.
19. Notwithstanding anything hereinbefore contained all the liability for income-tax on
the personal Income including capital gains tax of any party hereto including any
interest thereon and penalties imposed In respect thereof incurred before
dissolution or after will be that of the party whose Income it is and such party shall
indemnify and keep indemnified the other parties against such liability and costs.
charges and expenses incurred on that account.
IN WITNESS WHEREOF the parties have put their respective hands theday and
year first hereinabove written.
THE FIRST SCHEDULE ABOVE REFERRED TO THE

SECOND SCHEDULE ABOVE REFERRED TOTHE
THIRD SCHEDULE ABOVE REFERRED TO
65
Signed and delivered by the withinnamed Party of the

First Part Mr. A in the presence of
Second Part Mr. B in the presence of

Third Part Mr. C in the presence of
66
GIFT DEED.
THIS DEED OF GIFT is made and executed on this the 13th day of September, 2006 at
Hyderabad
BETWEEN
Address: 1-2A/A, Chikkadpally, Hyderabad-500020, Telangana State (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 en
AND
Sri Rangachari, S/o. Sri Venkateswar Rao, Aged about 40 years.
Occupation: Government employee, Address: H.No. 1-5-7, Narayanaguda,Hyderabad-500020,
Telangana State (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.)
Whereas the donor herein is the absolute owner and possessor of the house building property
bearing House No. 1-2A, situated at Chikkadpally Hyderabad-500020, Telangana State,
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 property which is described in more detail in the
Schedule given below and also earmarked in RED ink in the Plan annexed hereto), as being its
individual owner having purchased the same vide registered Sale Deed No. 1212 dated
1.1.2008.
Whereas the donee herein is the natural born only son of the donor.
Whereas the donee having been married and residing separately from the donor is in need of
a residential house.
Whereas the donor out of his love and affection towards his said son and with a view to
providing for a convenient living accommodation to his said son, hereby offers the said
scheduled property by way of a gift to the donee free from all encumbrances, charges etc., with
peaceful possession thereof from this date to have and enjoy the same absolutely and forever
as of its true owner
Whereas the donee herein has agreed to take the said scheduled property as a gift accordingly.
NOW THIS DEED OF GIFT WITNESSETH AS FOLLOWS:
1) That in consideration of natural love and affection of the donor towards the donee, the donor
hereby grants, transfers, assigns, conveys and settles the said scheduled property by way of gift
to vest in the donee absolutely and for ever for his possession and enjoyment free from all
encumbrances, charges and other liabilities and with all rights and titles, easements, benefits,
appurtenances in respect of the said scheduled property along with ways, water courses and
other facilities.
67
2) That the donor has delivered the peaceful and vacant possession of the said scheduled
property to the donee with all rights, titles and benefits and the donee shall hold and enjoy the
same absolutely and for ever, without any interruption either from the donor or anyone claiming
through or under or in trust for the donor or from any third party, and the donee has taken over
the same accordingly.
3) The donor has already paid all the taxes etc: due and payable to the concerned Government
or other authorities till date and from today onwards the donee shall pay the same as being its
real owner.
4) The donor hereby declares that he is the sole and absolute owner of the said scheduled
property and that it does not form part of any ancestral or other such property.
5) The donor is free to get the title in the said scheduled property changed in his name in the
records of the respective Public Offices/Revenue Department etc. The land on which the said
house building property was constructed is neither an assigned land within the meaning of A.P.
Assigned Lands (Prohibition of Transfers) Act, 1977 nor does it belong to or under the
mortgage with Government or other agencies or persons nor does it fall under urban land
ceiling.
6) The market value of the property under gift, as on date, is assessed at Rs. 10 lakhs (Rupees
Ten lakhs only) and that the necessary stamp duty is deposited accordingly.
plinth area of 1200 sft. constructed on a total landed area of 300 Sq. yds. and bounded by-
South: 30 feet Public Road Unik
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 aforementioned with their free will and consent and without any
coercion or fraud in the presence of the following witnesses: noe mod louin vino
Witnesses:
Sd/- Sd/-
1.S.S. Rajaiah (Donor)
H.No. 10-2-A Sd/-
Chikkadpally (Donee)
Hyderabad-500020.
68
Sd/-
2. K.S. Pratap Reddy
H.No. 13-2-A
Chikkadpally
Hyderabad-500020,020.
69
GENERAL PWER OF ATTORNEY

Model Problem:
Based on the names and factual position relating to the problem given above for drafting a Sale
Deed, draft a Deed of General Power of Attorney, presuming that Sri Venkateshwara Rao being
the owner of the property appoints Sri Ranghachari as his General Power of Attomey Holder
to sell the property in question.
Model Solution:
DEED OF GENERAL POWER OF ATTORNEY
KNOW ALL MEN BY THESE PRESENTS THAT I, Venkateswar Rao, S/o. Sri
Tirumaleswar Rao, aged about 45 years, Occupation: Business, Address: 1-2A/A,
Chikkadpally, Hyderabad-500020, Telangana State, do hereby appoint Sri Rangachari, S/o. Sri
Venkatachari, Aged about 40 years, Occupation: Government employee, Address: H.No. 1-5-
7, Narayanaguda, Hyderabad-500000 Telangana State, as my ATTORNEY in my name and on
my behalf to do and execute all or any of the acts, deeds and things mentioned hereinbelow, as
I am not able to undertake the same personally due to my unavoidable pre-occupations.
WHEREAS I am the owner and possessor of House building property bearing Municipal No.
1-2A, Chikkadpally, Hyderabad-500020, Telangana State consisting of 1200 sft. plinth area
constructed on a total landed area of 300 $4 yards the detailed description of which is shown
in the Schedule given below (hereinafter referred to as the said scheduled property).
WHEREAS 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).
WHEREAS the said Sri Rangachari, S/o. Sri Venkatachari, has agreed to act as my attorney
holder holding the general power to sell away the said property for the said sale consideration
to any intending purchaser, as per the following form.
NOW THIS DEED OF GENERAL POWER OF ATTORNEY WITNESSETH AS
FOLLOWS:
I hereby authorise my said power of attorney holder to do and execute all or any of the
following acts, deeds, and things:
i) to offer and enter into any agreement for sale of the said scheduled property with any
intending purchaser for a total sale consideration of Rs. 10 lakhs (Rupees 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 receipts therefor to the intending 500 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;
70
v) to finalise and execute the sale deed, and to assist in the registration of the sale deed on my
behalf and at the cost of the intending purchaser;
vi) to hand over all the relevant connected title deeds in respect of the said scheduled property
to the intending purchaser.
vii) to deliver the vacant and peaceful possession of the said scheduled property to the intending
purchaser, or third parties;
viii) to appoint any advocate or others, in case of any dispute that may arise in respect of the
said scheduled property for ensuring transfer of a better title to the intending purchaser or to
settle the disputes and differences that may crop up with the intending purchaser:
ix) to file any case, civil, criminal, revenue, writ etc. and to appear and act in all Courts,
Tribunals or other such bodies including Revenue Authorities, registration officers, or any other
Government offices or Municipal Corporation of Hyderabad etc. in respect of any dispute or
difference in relation to the said scheduled property either with the intending purchaser or with
any third party:
x) to sign and verify any plaint, written statement, petition, application, representation with
respect to any claim or objection, or memorandum of appeal etc. of any kind and nature and to
file and pursue the same in any Court, office or authority or tribunal or quasi-judicial body as
the case may be on my behalf in respect of all matters relating to the said scheduled property:
xi) to compromise, compound or withdraw any case if so filed, or to confess to any judgment
and to refer cases to the arbitration wherever necessary.
xii) to do generally all the lawful acts, deeds and things necessary and expedient to sell away
the said scheduled property fully and perfectly to any intending purchaser and for any other
purposes which are contingent to or connected therewith.
2. I hereby further undertake to, and ratify all the acts, deeds and things as the case may be
lawfully done by my said attorney holder for and on behalf of me under these powers, and the
same shall be construed to be done by me if I attended personally.
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 : Neighbour's house bearing No. 1-14
West :15 feet Public Road.
In witnesseth whereof I have signed this deed of General Power of Attorney on this the 11th
day of September, 2006 at Hyderabad with my free Will and consent.
71
Witnesses:
Sd/- Sd/-
1. V. Narasing Rao (Executant)
H.No.4-5-210 Sd/-
Chikkadpully (Holder of the Power of Attorney)
Hyderabad-500 020.
Sd/-
2. K. Laxman Reddy
H.No. 565/A/2
Chikkadpally
Hyderabad-500020.
72
Notice under section 106 of The Transfer of Property Act, 1882.
BY REGD. POST/ACK. DUE
Y. Yadgiri
Advocate.
20-51/. Sharadanagar.
Hyderabad-500060.
Tel: 040-24044200.
Dated: ...
NOTICE
To:
SHUBHAM TIWARI
AGED ABOUT 30 YEARS, HINDU
Occupation- engineer
Babukhan lane, 305 D block,
Hyderabad
Sir,
Under instructions of my client, Shri…...Shubham Tiwari
S/o. Balwant Tiwari
Occupation- businessman
somajiguda,
Hyderabad
I give you the following legal notice:
(1) That my client is the owner of premises at ........ Under a written/oral agreement, my client had let
out the above premises to you on a monthly rent of Rs for a period of........... months/years for
residential/commercial purpose. with effect from
(2) My client informs that you have failed to pay the rent for.......... months and thereby made yourself
liable for eviction. (or, give any other cause which is relevant such as expiry of lease period, or wasting
the premises or sub-letting the premises, etc.) veli
73
(3) My client, therefore, hereby gives you 15 days notice to quit, vacate and deliver peaceful vacant
possession of the demised premises.
(4) Please note that your tenancy in respect of the demised premises and all your relationship with my
client as landlord and tenant shall stand determined with effect from the said date. In case you fail to
hand over vacant and peaceful possession on the said date, my client will be constrained to initiate
appropriate legal proceedings against you for appropriate relief for which you will be held personally
liable for the costs and consequences thereof, including mesne profits, damages, etc.
(Give particulars of demised premises)
………………………………….
………………………………….
………………………………….
Yours, etc.
Sd/-
ADVOCATE
74

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DRAFTING, PLEADING & CONVEYANCING

S.NO NAME OF THE DRAFTS PAGE

2. Suit for Ejectment and Damages for Wrongful Use and

3. Plaint and Written Statement for Permanent Injunction (Theme -

4. Affidavit as a proof of Age showing the date of Birth of 'A'

5. APPLICATION FOR TEMPORARY INJUNCTION UNDER

6. Suit for recovery under Order XXXVII (Summary Suit)

7. Petition for Dissolution of Marriage by Decree of Divorce under

8. Caveat under section 148-A of the Code of Civil Procedure, 1908

9. Transfer Petition (Civil) U/s 25 of the Civil Procedure Code, 1908

10. Application for the Execution of Decree

11. Petition for Grant of Probate in High Court

12. Petition for Restitution of Conjugal Rights under Section 9 of the

13. Writ Petition under Article 226 of the Constitution of India

14. Writ Petition for Enforcement of Fundamental Rights under

15. Special Leave Petition under Article 136 of the Constitution of

16. Application for Regular Bail

17. Application for Anticipatory Bail

18. Complaint under section 138 of the Negotiable Instruments Act,

19. Application under section 125 of the Code of Criminal Procedure,

20. Will Deed

21. Sale Deed

22. Mortgage Deed

23. Partnership Deed

24. Deed of Dissolution of Partnership

25. General Power of Attorney

27. Gift Deed

IN THE COURT OF THE JUDGE: FAMILY COURT:

MATRIMONIAL CASE ___ of 2023

CHEND COLONY, ROURKELA……………….…………………………………………………………. PETITIONER

Aged about 30 years, Hindu,

Place: Rourkela Sd/-

Place: Rourkela Sd/-

IN THE COURT OF THE SENIOR CIVIL JUDGE: SESSIONS COURT:

SUIT NO ___ of 2023

Place: Rourkela Sd/-

Place: Rourkela Sd/-

IN THE COURT OF SENIOR CIVIL JUDGE

AT ROURKELA, ODISHA STATE

SUIT NO. ____OF 2020

S/o. BATWANT TRIPATHY,

Aged about 27years, Hindu,

Occupation: MEDICAL STUDENT,

CIVIL TOWNSHIP, ROURKELA……………………………………………………Plaintiff

S/o. RAJESH BHOI,

Aged about 45 years, Hindu,

CIVIL TOWNSHIP, ROURKELA…………………………………………………Defendant

PLAINT FOR PERMANENT INJUNCTION

IN THE COURT OF SENIOR CIVIL JUDGE

AT ROURKELA, ODISHA STATE

SUIT NO. ____OF 2020

S/o. BATWANT TRIPATHY,

Aged about 27years, Hindu,

Occupation: MEDICAL STUDENT,

CIVIL TOWNSHIP, ROURKELA……………………………………………………Plaintiff

S/o. RAJESH BHOI,

Aged about 45 years, Hindu,

CIVIL TOWNSHIP, ROURKELA…………………………………………………Defendant

WRITTEN STATEMENT FOR PERMANENT INJUNCTION

Affidavit as a proof of Age showing the date of Birth of 'A'.