Friday, December 27, 2024

Petition for Stay of proceeding

 

In the Court of the Learned Chief Judicial Magistrate, at Alipore, South 24 Parganas

 

Misc. Execution No. 462 of 2018

                                                         

                                                          In the matter of ;

                                                          VandanaNarang,

                                                                             __________Petitioner

-      Versus –

 

Vijaybhai M. Narang,

                   ______Opposite Party

 

Petition for Stay of proceeding;

 

The humble petition on behalf of the above named Opposite Party Vijaybhai M. Narang, most respectfully;

 

Sheweth as under;

 

1.   That it is pertinent to states that in the month of September’ 2020, the petitioner entered into an Memorandum of understanding and thereby agreed to withdraw this execution case as well as other cases instituted by her before the concerned Court. The Petitioner used to reside with the Opposite Party as husband and wide at her matrimonial house at Gujarat, since the month of September’ 2020. The Opposite Party had taken care of everything including protection, care and education of the only female child at Gujarat.

 

2.   That since the Petitioner has not withdrawn the cases instituted by her, the said cases including this execution case is still pending even after absence of the petitioner. The Petitioner again came to Kolkata in the month of February’ 2024, and thereafter started to take participation in all those cases which was agreed upon by and between the petitioner and the opposite party to withdraw the cases instituted against each other.

 

3.   That on earlier occasion, the Petitioner did not communicate her facts before the Learned Court therefore the Learned Court was pleased to pass necessary order against the Opposite Party.

 

4.   That the Opposite Party preferred an appeal under Section 29 of the PWDV Act 2005, before the Learned District Session Judge, at Alipore, South 24 Parganas, challenging the proprietary & entirety of the Order dated 05-06-2024, passed in Misc. Execution No. 462 of 2018, by this Learned Court. The said Criminal Appeal has been registered as Cr. Appeal No. 156 of 2024, which has been taken up for hearing on 02-07-2024, by the Learned District Session Judge, at Alipore, South 24 Parganas, and thereby pleased to admit the said criminal appeal with a direction to serve notices on the opposite parties therein, and stayed the impugned Order dated 05-06-2024, passed in Misc. Execution no. 462 of 2018, by the Learned Chief Judicial Magistrate, at Alipore, South 24 Parganas on interim basis till next date. The next date fixed in the said Criminal Appeal is on 27-08-2024.

 

Photostat server copy of the Order dated 02-07-2024, passed in Criminal Appeal No. 156 of 2024, by the Learned District Session Judge, at Alipore, South 24 Parganas, is annexed herewith and marked as Annexure – “A” 

 

5.   That on 27-08-2024, the Opposite Party placed his extension petition for extending the stay order dated 02-07-2024, passed in Criminal Appeal No. 156 of 2024, by the Learned District Session Judge, at Alipore, South 24 Parganas, which has duly been considered and extended till the next dated fixed on 07/10/2024. The said Criminal Appeal transferred to the Learned 17th Court of Additional District Session Judge, Alipore, South 24 Parganas. The Petitioner herein has been appeared in the said Criminal Appeal on 27-08-2024.

 

Photostat server copy of the Order dated 27-08-2024, passed in Criminal Appeal No. 156 of 2024, by the Learned District Session Judge, at Alipore, South 24 Parganas, is annexed herewith and marked as Annexure – “B”

 

6.   in view of the facts of the stay of the operation of the Order dated 05-06-2024, passed in Misc. Execution No. 462 of 2018, by the Learned Chief Judicial Magistrate, at Alipore, South 24 Parganas, in the said Criminal Appeal No. 156 of 2024, vide Order dated 02-07-2024, and continuing by Order dated 27-08-2024. This Opposite Party seeks the stay of the present proceeding in the interest of administration of Justice.

 

7.   That unless the Order dated 02-07-2024 & 27-08-2024, passed in Criminal Appeal No. 156 of 2024, considered and taken on record in the present Execution proceeding, the Opposite Party will highly prejudice and suffer with irreparable loss and injury thereof.

 

8.   That the preponderance of balance of conveniences and inconveniences are in favour of the Opposite Party.

 

9.   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 allow this application and to stayed the present Execution proceeding till 07/10/2024, in pursuance of the Order dated 27-08-2024, passed in Criminal Appeal No. 156 of 2024, by the Learned District Session Judge, at Alipore, South 24 Parganas, 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.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Affidavit

 

I, ShriVijaybhai M Narang alias NarangVijaybhai,  Son of Sri MohanlalNarang aged about 46 years, by faith Hindu, by Occupation Service, residing at premises being no. B-103, Satellite Center Building, 10th Floor, Mansi Circle, Vastrapur, Ahmedabad – 380015, do hereby solemnly declare and affirm as follows :

 

  1. That I am competent to swear this affidavit.
  2. That I am the Opposite Party in the present proceeding, before the Learned Court.
  3. That I am conversant and acquainted with the material facts as stated in the foregoing paragraphs of this application.
  4. That the statements as made by me in the foregoing paragraphs in the application are true to the best of my knowledge and belief.
  5. That all the above statements are true to the best of my knowledge and belief.

 

 

 

 

DEPONENT

Identified by me,

 

Advocate.

Prepared in my Chamber,

 

Advocate

Date : __________________2024.

Place :Alipore Criminal Court.

NOTARY

 

 

 

 

No comments:

Post a Comment