Sunday, August 9, 2026

Affidavit in chief on behalf of the Opposite Party

 

Before the Ld District Consumer Disputes Redressal Commission Unit III Kolkata 

 

Ref: CC/654/2021 

Haripada Bhowmick 

.....Complainant. 

Vs 

1. M/S Chakraborty Associates 

2. Utpal Chakraborty 

Opp. Party 

Affidavit in chief on behalf of the Opposite Party named above

I, Utpal Chakraborty s/o Ullas Chakraborty Sole Proprietor of M/s Chakraborty Associates having its office at P-74 State Bank Park, P.S Thakurpukur, Kolkata 700063 and also residing, at 74 State Bank Park, P.S Thakurpukur, Kolkata 700053 aged, about years, by faith Hindu, by occupation business do hereby solemnly affirm and declare as follows:

1.            That I am the Opposite Party in the instant case. 

 

2.            I state that the complainant has filed the instant case to harass 

 

3.            . That I was approached by the complainant to develop his land  in consideration of owners allocation

 

4.            That I had entered into a Joint Venture Agreement with the complainant on 02.08.2014. 

 

5.            That subsequently a Supplement Agreement was signed between myself and the complainant on 02.08.2016 wherein the clauses of the Joint Venture Agreement were remodeled. 

 

6.            That the complainant for material gain had suppressed the Supplement Agreement. 

 

7.            That the complainant demanded his allocation as per the Joint Venture Agreement but not as per the Supplement Agreement. 

 

8.            That it is evident from the demand notice made by the Ld. Advocate Sri Rabindranath Das wherein demand has been made on the basis of Joint Venture Agreement and not as per the Supplement Agreemen

 

9.            That demand has been made in regard to 33% of the total constructed area and forfeit money of Rs. 1,00,000/- within 18 months from the date of sanction plan but whereas in the Supplement Agreement it has been already mentioned that the owner shall extend the stipulated period for another six months i.e. to 24 months instead of 18 months from the date of sanction of building plan. 

 

10.         That in accordance to the Supplement Agreement the owners allocation shall contain two bed room flat measuring 700 sq ft super built up area at South East side in the second floor building at 541 Tarapada Santra Sarani/ Chandal Para Road ward no 124 Kolkata-700063 and a sum of Rs 3,00,000/- cash consideration together with proportionate undivided share in the land instead of entire second floor and Rs. 1,00,000/- cash consideration. The complainant has filed the instant case with false and misleading fact and is liable to be rejected. 

 

11.         That the complainant has suppressed the fact that the Opposite Party has already paid a consideration amount of Rs. 35,000/- 

 

12.         That the complainant has made all his demands based upon the Joint Venture Agreement suppressing the Supplement Agreement and now trying to mix and match both the agreements which is not permissible in law and hence the complainants application is liable to be rejected. 

 

13.         That the complainant has suppressed material fact and is therefore engaged in unfair practice and hence the complainants application is liable to be rejected with costs. 

 

14.         That the complainant is in clear dilemma as to whether make his claim on the basis of the Joint Venture Agreement or on the basis of the Supplement Agreement and in the process trying to make a volatile mixture of both the agreements which is not permissible in law. 

 

15.         That the complainant has rescinded the Joint Venture Agreement by signing the Supplementary Agreement redefining the terms and conditions. 

 

16.         That it is not a fact that the Opposite Party is engaged in unfair trade practice. 

 

17.         That it is not a fact that the Opposite Party is deficient in 

service. 

18. That the complainant has no cause of action to file the instant 

case. 

19.  That the complainant is not liable to get any relief he has claimed for. 

 

20. That the complainants application is liable to rejected with 

costs. 

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