Petition for acceptance of Written Statement in Civil suit

 

In the Court of the Learned 5^th Civil Judge (Junior Division) at Alipore,

South 24 Parganas

 

Ref:- Title Suit No. 1606 of 2024

In the matter of;

Sri Rajkumar Gupta

......Plaintiff

-Versus-

Sri Shambhu Singh, and Others

.....Defendants

 

Petition for acceptance of Written Statement of the defendant no. 1

 

The humble petition on behalf of the above named defendant no. 1, Shambhu Singh, most respectfully;

Sheweth as under;

 

1. That the defendant no. 1, is in knowledge of the summons issued by the Learned Court in the above referred suit. The day of today i.e. 17^th day of December’ 2024, is the day, while the Learned Court asked by way of giving summons to appear and to submit the written statement of the defendant.

 

2. That the Defendant no. 1 obliged to take the directions as emphasized in the Summons given by the Learned Court. The defendant no.1 appeared through his appointed Learned Advocate in the present Suit matter and to submit his Written Statement being reply on the plaint in the present Suit.

 

3. That the defendant no.1 submitted his Written Statement on his First Appearance without any loss of time, before the Learned Court, in the interest of administration of Justice.

 

4. That in the given facts as stated herein above, the Written Statement of the defendant no.1 may kindly be accepted by the Learned Court and to make part of the record of the present Suit, in the interest of administration of Justice.

 

5. That unless the Learned Court accept the written statement of the defendant no.1 and to make part of the record of the present suit, the defendant no.1 will highly prejudice and suffer with irreparable loss and injury thereof.

 

6. That the preponderance of the balance of convenience and inconveniences are in favour of the defendant no.1 and the plaintiff will not prejudice.

 

7. That this application is made bonafide and in the interest of administration of justice.

It is therefore prayed that your Honour would graciously be pleased to accept the Written Statement and to make the part of the record of the present suit, in the interest of administration of Justice, and /or to pass such other necessary order or orders as Your Honour may deem, fit, and proper for the end of Justice.

And for this act of kindness, the Petitioner as in duty bound shall ever pray.

Verification

I, Sambhu Singh, being the defendant no.1 in the present Suit. I am well acquainted and conversant with the material facts as stated in the forgoing paragraphs of my Written Statement. I, verify & sign the Written Statement on 17^th day of December’ 2024, at Alipore Judges’ Court Premises.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

AFFIDAVIT

I, Shambhu Singh, Son of Late Subedar Singh, aged about _____years, by faith Hindu, by Occupation Medical Practitioner, residing at Premises being no. 3242, Vidyasagar Sarani, Police Station Haridevpur, Kolkata – 700063, Ward no. 124, Bara Bagan, near Sabuj Sangha Club, Vollybal Ground, Kolkata – 700063, District South 24 Parganas, do hereby solemnly affirm and says as follows;

1.           That I am the defendant no.1 in the present Suit matter. I am well acquainted and conversant with the material facts of the present Suit. I am competent to swear this affidavit.

 

2.           That the statements of the paragraph number 1, 2, & 3 are true to the best of my knowledge and belief, and the rests are my humble submissions before the Learned Court.

The statements made above are true to our knowledge and belief.

 

 

DEPONENT

Identified by me,

 

 

Advocate

Prepared in my Chamber,

 

 

Advocate

 

Date : 17^th December’ 2024;

Place :Alipore Judges’ Court;

 

N O T A R Y