APPLICATION U/O 7 RULE 11 C.P.C

APPLICATION U/O 7 RULE 11 C.P.C FILED BY THE

MANAGEMENT ON THE LAST DATE OF HEARING

Most Respectfully Showeth:-

1. That the first para is the matter of record.

2. That the second para is wrong and denied. It is denied that the said LCA is without any cause of action against the management, hence the same is liable to be rejected under the mandatory provisions of Order 7 rule 11 C.P.C. The rest of the para is ambiguous. It is submitted that there is very much cause of action against the management, hence LCA is very much maintainable.

3. It is a matter of record, however it is submitted that a case was registered against the petitioner wide FIR No. ..... U/S ...... IPC in P.S. ........... in which the petitioner was acquitted by the Hon’ble Court of Sh. Naveen Arora, MM, Patiala House Courts, New Delhi on dated 03-08-09.

4. The application is wrong and denied. It is denied that mere acquittal of workman in criminal court does not itself give rise to any cause of action to the workman against the management. It is further denied that his acquittal does not allow him any benefit in the independent department inquiry. It is further denied that the awarded punishment attained finality in the eyes of Law, unless the same is set aside by the Hon’ble Court. It is submitted that the acquittal of the petitioner shows that the petitioner was not guilty of wrong act and departmental enquiry cannot sustain.

5. That it is wrong as stated by the applicant. It is wrong and denied that the acquittal of the workman is of no consequence and the punishment awarded by the management stands legally valid. It is submitted that when the petitioner was not held guilty by the Hon’ble Court of Sh. Naveen Arora, MM, Patiala House Courts, New Delhi, then the management cannot hold the petitioner guilty of its own.

PRAYER

It is therefore prayed that the application of the applicant be dismissed with cost.

Date:

Place: Though Counsel

Complaint under section 156 (3) Cr.P.C

IN THE COURT OF SH. METROPOLITAN MAGISTRATE, DELHI

In the matter of

ABC Sharma Complaint

Versus

XYZ Sharma Defendant

APPLICATION UNDER SECTION 156 (3) Cr.P.C

Most Respectfully Showeth :

1. That the complaints have failed the accompanying complaint u/s 200 Cr.P.C. against the accused persons and the contents of the accompanying complaint may be read as part and person of this application and the same are not being repeated here for the sake of brevity.

2. That since the local police has failed to register FIR against the accused persons as per the offences committed by the accused persons are cognizable offences, it is just fit or proper and the local police may be directed to lodge/register on FIR u/s 380/448/506/34 IPC against the accused persons.

Prayer :-

It is, therefore, prayed that the local police of P.S. Connaught Place, New Delhi may be directed to investigate the matter and to lodge an FIR in the above case and report may be called from the SHO P.S Connaught Place, New Delhi. In the case u/s 156 (3) Cr.P.C in the interest of justice.

Delhi Complaint

Through

Place Counsel

COMPLAINT UNDER SECTION 200 Cr.P.C. BEHALF OF COMPLAINANT

In The Court of Sh. Chief Metropolitan Magistrates, Delhi

In The Matter of

ABC Complainant

Versus

XYZ Defendant

Memo of Parties

ABC …………………………….Complainant

F/F New Delhi

Versus

XYZ …………………………………Defendant

Street No.5 Delhi

U/S 380/448/506/34 IPC

P.S. New Delhi

COMPLAINT UNDER SECTION 200 Cr.P.C. BEHALF OF COMPLAINANT

Most Respectfully Showeth :

1. That the complainant is residing of the aforesaid address with his family.

2. That the complainant is also running a shop no. 38A ABC Complex CP. Under the name of rahul store ana selling the goods.

3. That the accused no.1 is the allottee of the aforesaid shop and the complaint has paid Rs. 4, 00,000.00/- to the accused no-1 for running the his shop peacefully and without any kind of obstruction.

4. That the on 03-11-10 at about 10 p.m. in the night the complaint went to his house after closing his shop and when on the next day He come to the shop at about 1.30 pm on 04/11/10, He found that the looks of his shop put by him, have been changed and when the complainant tried to see inside the shop he was surprised to see that his articles/goods lying in the ship was funnd removed and the aforesaid illegal and unjustified act were committed by the aforesaid accused persons and they have removed the articles of the complainant from his shop and kept the same in their shop and they also put their locks on the shop of the complaint.

It is, therefore, most respectfully prayed that this Hon’ble court may kindly be pleased to sommon the accused persons u/s 448/380/506/34 IPC. Punished them according to law in view at the facts and circumstances mentioned above in the interest of justice.

Delhi Complainant

Through

Dated Counsel

INTIMATION TO POLICE AUTHORITIES AFTER TAKING POSSESSION OF THE SURRENDER ASSET.

The Hon'ble S.H.O Date:…………….

…………………………….. Ref:……………..

…………………………….

Dear Sir

SUB: INTIMATION TO POLICE AUTHORITIES AFTER TAKING POSSESSION OF THE SURRENDER ASSET.

AGREEMENT CODE :

EQUIPMENT MAKE :

REGN. NO :

NAME OF BORROWER/HIRER :

ADDRESS OF BORROWER/HIRER :

The above Borrower/Hirer has defaulted on the scheduled repayment of his installment(s) amounting of Rs……………../- as on ………………… and thereby has failed to confirm to the term and conditions of the said agreement executed between us.

Pursuant to our rights under the said Agreement, we have taken possession of the above vehicle/equipment without any consignment in it.

We have therefore repossessed the subject vehicle/equipment under the jurisdiction of your police station and there is no valuables/jewellery/cash/arms etc, in the said vehicle at the time of taking possession.

This communication is for your records and to prevent any confusion that may arise from any complaint that the Borrower / Hirer & /or his / her / their representative may lodge with you about the vehicle / equipment being stolen with or without any consignment whatsoever.

Thanking you,

Your Faithfully,

For ............................... Ltd.,

(Authorized Signatory)

Right To Information Act 2005 Format

To,

The Public Information Officer

M.C.D Shahdara (North East) Zone

Delhi-110032

Sub:- Application Under the provisions of the right to information act 2005.

Sir,

I want the information with documents about the .............................................. Delhi-110001 & questions:

1. Whether it is authorized construction?

2. Whether it is build up by Law?

3. Whether any site plan is passed?

4. If above mention property not authorized then what action was taken by the M.C.D.

I paid the fees of this information.

I enclosed Postal Order No.................... on dated................2011.

Thanking in anticipation.

XYZ

Rent Agreement Format for all purpose

RENT - AGREEMENT

This Rent-Agreement is made and executed at the place of Delhi on Dt. 08-Apr-10 between Sh. ................................... S/o. ............................ R/o. H.No. - ................................, Delhi-95, hereinafter to be referred as the Landlord/First Party,

AND

Sh. .............. S/o ............... R/o. H.No. - ..., Front/First Room, Ground Floor,.........., Delhi-95, hereinafter to be referred as Tenant/Second Party.

Whereas, the First Party is the Exclusive Owner and in lawful possession of entire property bearing number as H.No. - ..............................................................., Delhi-95.

Whereas at the request of the Second Party, the First Party has agreed to let out his Front/First Room of the Ground Floor of the abovesaid property to the Second Party, on the following terms and conditions:

1. THAT, the landlord is in position to share the abovesaid property for short term renting and tenant is agreeable to accept the same for residential purposes.

2. THAT, period of renting agreed by both the parties in the first instance is with effect from Dt. 8-Apr-2010 to 7-March-2011 for the period of eleven months of tenancy and the same can be renewed further with mutual consent of the parties in writing, however it is also being mutually agreed between the parties that if there the said term is not being extended in writing then the first party has given its expressed consent to extend the same for a minimum period of three months.

3. THAT, rent as per the mutual consent and settlement between/of the parties is fixed Rs. 2,600/- (Rupees Two Thousand Six Hundred Only) per month plus the Electricity charges, as may be agreed alongwith the water charges which shall be 50% of the water Bill and the same is payable in advance from the starting month and continuously payable on or before 10^th of every English calendar month.

4. THAT, the first party has delivered the vacant possession of the said Front/First Room in the ground floor with fully fitted fixtures, fans, lights, or moveable items of said property and the First Party has received/occupied the same.

5. THAT, the rented premises will be occupied and used by the tenant only for the purpose of residence and as the Second Party are the professionals, so as per the building bye-laws, they may use 30% of the said property for running their professional office/s etc.

6. THAT, the tenant shall keep the rented Front/First Room premises in good sanitary conditioned and the same shall be used in keeping/complying the prevailing rules/regulations/bye-laws of Delhi Municipal Corporation/NDMC/DDA. Etc.

7. THAT, the tenant without any prior consent of landlord will do no additions/alterations of any kind in the rented premises.

8. THAT, the landlord may inspect the rented premises at any reasonable hours / period of the working days only in the presence of the male members of the family of Second Party.

9. THAT, the First Party shall have a right to terminate the present agreement at any time after serving Second Party a three month prior notice of the same in writing and the same is applicable with the Second Party.

IN WITNESS WHERE OF: the parties to the present agreement, have set their respective hands on the Day, Month and Year, mentioned/Written First above.

WITNESSES :

LAND-LORD/FIRST PARTY

(.............................................)

1. Name & Address:

TENANT/SECOND PARTY

(....................................)

2. Name & Address: