Wednesday, April 30, 2025

Letter to Bajaj Finance Limited

 

WITHOUT PREJUDICE

 

Date : 22nd day of November’ 2024

 

 

To

BAJAJ FINANCE LIMITED

4th FLOOR BAJAJ FINSERV CORPORATE OFFICE, OFF

PUNE-AHMEDNAGAR ROAD, VIMAN NAGAR, PUNE - 411014

EMAIL :investor.service@bajajfinserv.in

 

Ref.: Loan Contract bearing No- P410FBO7780601, in favour of Sabita Singh.

 

Subject : Clarification on enhanced EMI’s from  Rs 9,729/- to Rs 16,719/- AND a sum of Rs. 1,575/-, which has never been Credited to my Account, AND The Original Insurance Policy for which you had taken a sum of Rs. 30,672/-.

 

Dear Sir/s, Madam/s,

 

Please take note that in the year 2023 your Sales person’s has approached me for providing loan of Rs 5,30,672/- within a short period of time, he communicated so many things including the loan tenure, rate of interest and the sum of money towards EMI and placed some of the printed forms, asking thereby for the signature. Those forms are appearing partially typed in English and Hindi and partially blanked. I put my signature and my husband Shri Lallan Singh also put his signature at the writing appeared as Co-borrower’s signature. Even after putting our signature on the forms given by the said Sales Person of yours. Since, We concerned about the rate of interest and the EMI’s, therefore, I declined to have the said Loan of Rs. 5,30,672/- suggested by your Sale’s person. However after few days, in the month of May 2023, I find that a sum of Rs 4,98,425/- has been credited into my current account No- 1676102000001243 lying with the IDBI Bank Ltd. And a sum of Rs. 1,575/- has never been credited to my account nor any clarification has ever been given by you as to for what shake such money is still lying with you, the same may be a processing charges towards the said loan given by you; But the same has never been affirmed by you. Thus I asked your Sale’s person what about such money “Why” and “How” such money credited in my account by the Bajaj Finance Ltd, then he told that he had already submitted my documents and the money has been credited. Initially, I started to repay the said Loan by way of paying EMI’s as of Rs 9,729/- every month. To my utter surprise, in the month of June 2024 the company asked for EMI’s as of Rs 16,719/- to which I tried to enquire about; but neither your said Sales Person nor your executive has ever given any satisfactorily answered to my query. However, I had paid such enhanced sum of money as of Rs 16,719/- towards EMI’s for the month of June 2024. Since the normal practices in paying EMI’s stand for Equal Monthly Instalment, though the Bajaj Finance Ltd asked for enhanced EMI’s as a sum of Rs 9,729/-, therefore I could not understand under which circumstances such EMI’s has been enhanced from Rs 9,729/- to Rs 16,719/-. I had tried my level best as to know how about such increment in EMI’s but as no explanation has ever been given or suggested by your executive I have decided not to make any payment of any EMI’s till the clarification on such enhanced EMI’s come to me.

 

Since the month of August no clarification has yet come to me. It is pertinent to say that the said Loan of Rs 5,30,672/-, I contacted you on several occasions regarding inconsistent loan rates and additional maintenance charges. However you have not responded. I asked you to  take immediate corrective action to rectify the issue by adjusting the interest rate to the initially agreed-upon rate of 10.85% and refunding any excess interest charged with additional maintenance charges. Until you resolved, I will withhold any further payments towards the loan repayment, as you refused to take repayment as in earlier terms being EMI’s as of Rs 9,729/- every month.

Presently few days back I had tried on your Website application to find the Loan agreement and sanctioned letter where from I find the PDF of Business and Personal Loan agreement having the Schedule Demand Promissory Note, Vernacular Confirmation Letter, Vernacular Declaration form and forms for Business Loan where I found that many Signatures appearing in those documents are not mine and my husband Shri Lallan Singh and the handwriting in filling of those forms and the documents are not in my handwriting or in the handwriting of my husband.

As the purported Loan amount has been credited in my current account of the business, I obliged to repay such Loan amount irrespective of irregularities but not in the manner which has never established by the prescribed provision of Law.

 

In the stated facts I am requesting you to Kindly provide me the clarity why and how such EMI’s being sum of Rs 9,729/- has been enhanced being new coming EMI’s as Rs 16,719/-, in-spite of regular payment EMI’s on being satisfaction of such clarification, if any, will continue to make the payment of EMI’s as a sum of Rs 9,729/- every month till the repayment of the entire loan amount.

 

Furthermore I want to know about Rs 30,672/- has been cited towards the Insurance money but till date I am not in receipt any Insurance Policy for which you have taken money while given the Loan amount of Rs 5,30,672/- therefore I am seeking to have an original Insurance policy for which you have debited the said sum of money of Rs 30,672/- while approving the Loan for the sum of Rs 5,30,672/-. Kindly provide Insurance Policy to me at the earliest.

 

The circumstances as appearing in the face of the documents given by you shows gross irregularities which tent-amount to unfair trade practices and deficiency in service in serving the Loan to me. However, I do believe that good sense will prevail on you therefore I am requesting you to give me the original Insurance Policy for which you have taken money without my consent so for and continue to take EMI’s as of Rs 9,729/- per month till the realisation of Loan amount. Kindly inform your concern in this regard at the earliest preferably within a period of fortnight from the date of receipt of this letter, otherwise I will take shelter of Law before the competent court.

 

Thanking you,

 

Yours’ faithfully,

 

 

 

SABITA SINGH,

Wife of Sri Lallan Singh,

Residing at Dakshin Para, Natun Pally, Purba Puttiary, Kolkata – 700093, and also at Premises being No. 232, Dhalipara Purba Putiary, Near Padmapukur, Kolkata – 700093.

 

Copy to;

 

BAJAJ FINANCE LIMITED, having its Branch Office at Premises being No.1201, 12th Floor, Infinity Benchmark, Block EP & GP, Salt Lake City Sector 5, Kolkata – 700091 (Near SDF More).

{For information & necessary action}

Reply

 

 

By Registered Post / Speed Post

                                                         

Ref.: PD / 3108-7438/ CS/2024          Date : 26th day of November’ 2024

 

WITHOUT PREJUDUICE

To,

Bipasha Sur, Advocate

Barrackpore Sub Divisional

Court Complex (Civil & Criminal)

Cantonment Barrackpore,

Kolkata – 700120,

District – North 24 Parganas,

Mobile No.: 9330142382.

 

                                                          Ref.: Your Letter dated 18/11/2024;

                                                         

Your Client : KRISHNA GOPAL SUR, Son of Late Subir Chandra Sur, residing at Premises being no. 5 no. Lane Sankha Banik Colony Ghosh Para Road, Police Station – Totagarh, District – North 24 Parganas, Pin – 700120.

 

My Client : SMT. CHAMPA SUR, Wife of Krishna Gopal Sur, Daughter of Biswanath Mistry, residing at Premises being No. 20, Vivekananda Road, Purba Jadavpur, Post Office – Santoshpur, Police Station Surve Park, Kolkata – 700075, District South 24 Parganas.

 

 

 

REPLY OF YOUR LETTER DATED 18/11/2024

 

Dear Madam,

 

Under instructions of my Client Smt. Champa Sur, Wife of Krishna Gopal Sur, Daughter of Biswanath Mistry, residing at Premises being No. 20, Vivekananda Road, Purba Jadavpur, Post Office – Santoshpur, Police Station Surve Park, Kolkata – 700075, District South 24 Parganas, I write you as follows;

 

1.        That my Client is in receipt your Letter dated 18/11/2024, as the same has been delivered by the Post Office to my Client. My Client astonished on bare perusal of the said Letter dated 18/11/2024, as the said Letter did not disclose the facts and true states of affair. Thereafter my client handed over the said Letter dated 18/11/2024, to me with specific instructions to reply of your Letter dated 18/11/2024.

 

2.        That Your Letter dated 18/11/2024, is an outcome of the false and concocted story given by your Client. Your Client never accommodate you with the true states of affair and the real facts, so far, which has been surfaced by and between my client and your client, ever during their abode together.

 

3.        That Since the day i.e. 19th day of March’ 2024, my client compelled to reside under the roof of her parent with her minor child as your client has driven out her with the minor child following his brutal physical and mental torture on my client after few months of their marriage.

 

 

 

 

4.        That the allegations leveled against my Client in your said purported Letter dated 18/11/2024, as “That meanwhile my client came to know that you have an ill relation with one person and when my client protested on such ill acts then you used to behave with my client in a very harsh and rude manner.” is a bald statement which has no significance in consonance with any real facts. Such a False character assassination allegation constitutes Matrimonial Cruelty, as reported in Santosh Sahay v. Hanuman Sahay, 2016 SCC OnLine Del 5503, decided on  07.10.2016, wherein the Hon’ble Delhi High Court’s Division Bench of Pradeep Nandrajog, Pratibha Rani, JJ. held that if a false character assassination allegation is made by either spouse it would invariably constitute matrimonial cruelty.

 

5.        That my Client live herself with her minor child at the mercy and kindness of her old aged parents, since the said unfortunate the 19th day of March’ 2024, being the day of driven out by your client to my client with the minor child, and the 8 months 7 days passes, your Client did not take any recourses for reconciliation, even did not pay any single penny towards the maintenance of my client as well as maintenance of the minor child. Your client did not even heed to see the minor child; But taken all recourses to inflict mental torture on my Client, continuously, and the present Letter dated 18/11/2024, is one of the recourses amongst others.

 

6.        That in the afore-stated circumstances your Letter dated 18-11-2024, cannot be termed as a Legal Notice, so far. Your letter dated 18-11-2024 is a futile ceremony arranged by your client to victimize my client once again. The threat to take shelter before the proper forum of law in search of Justice, based on a false character assassination allegation constitutes Matrimonial Cruelty to entitle other spouse to seek divorce.

 

 

I for and on behalf of my Client requesting you to ask your client to place apology to my client for the letter dated 18-11-2024, and to withdraw, rescind, & cancelled the said Letter dated 18-11-2024, with immediate effect upon due communication to my client, preferably within a period of seven days a week from the day of receipt of this reply to your client and restrained himself in repeating the same in near future, otherwise my client shall take appropriate legal recourses against your client at your client’s Cost & Peril, which please note, copy kept for future references.

 

Kindly do the needful & oblige.

 

Thanking you,

 

Yours’ faithfully,

 

 

Pritam Das

Advocate

High Court Calcutta

 

Copy to;

 

KRISHNA GOPAL SUR, Son of Late Subir Chandra Sur, residing at Premises being no. 5 no. Lane Sankha Banik Colony Ghosh Para Road, Police Station – Totagarh, District – North 24 Parganas, Pin – 700120.

 

{for necessary information only}

NO INSTRUCTIONS BY THE COMPLAINANTS

 

Before the Hon’ble District Consumer Disputes Redressal Commission,

South 24 Parganas, Baruipur,

Kolkata - 700144

 

Case no.CC/21/2020

 

                                                          In the matter of :

 

Mrs. Sandhya Rani Malla (Paul), & Another,

_______Complainants

-      Versus –

M/s. Green Heaven Realty, and Others,

_______Respondents

NO INSTRUCTIONS BY THE COMPLAINANTS;

 

The humble petition of the Learned Advocate for the Complainants, most respectfully;

Sheweth as under;

 

1.   That No Instructions has been derived from the Complainants to Conduct the Argument of their behalf. In absence of such instructions, the Learned Advocate is not able to conduct any argument in the present Consumer Case. It is pertinent to states that the BNA has already been submitted on earlier occasion in the present Consumer Case.

 

2.   That in view of the facts, the Hon’ble Commission, may be noted such facts and pass necessary order or orders, in the interest of administration of Justice.

 

3.   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 take note of the facts on record about the No Instructions by the Complainants to their Learned advocate, and to pass such other necessary order or orders in the interest of administration of Justice.

 

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

Tuesday, April 29, 2025

Vakalatnama in Civil Suit

 

 

 

 

 

 

 

 

VAKALATNAMA

 

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

South 24 Parganas

18, Alipore Judges’ Court Road, Alipore, Kolkata – 700027

 

Title Suit No.            of 2025

 

Nandita Mondal Bose,

                   __________Plaintiff

-      Versus –

Sri Vivek Bose, & Others

_______Defendants

 

KNOW ALL MEN by these presents that I / We Nandita Mondal Bose, Wife of Late Bimal Kumar Bose @ Bimal Bose, aged about ______years, residing at 3rd Floor, Block A, Holding Number 374, P.K. Guha Road, Gora Bazar, Police Station Dum Dum, Kolkata – 700028, District North 24 Parganas, Mobile No. 869754923, duly authorized by the Board Resolution, do hereby constitute and appoint the undermentioned Advocate, Pleader, Vakils, jointly and each of them severally to be pleader of take such steps and proceedings as may be necessary on my / our behalf and for that purpose to make sign, verify and present all necessary petitions, plaints, written statements and other documents and do nominate and appoint or retain senior counsels, vakil, advocates and other persons, lodge and deposits moneys and documents and other papers in the Ld. Court and the same again withdraw and to take out of Court and to obtain or grant as the case may be effectual receipts and discharge for the same and for all moneys which may be payable to me / us in the premises. To enter into compromise with my / our approval and withdraw, all moneys from the court AND GENERALLY  to act in the premises and proceedings arising there out whether by way of execution, review, appeal, or otherwise or in any manner contested there with as effectually and to all intents and purpose as I / We could act if personally present and such substitution and as pleasure to revoke I / We hereby ratifying and agreeing to confirm whatever may be lawfully done by virtue hereof.

In witness whereof this Vakalatnama has been executed by me / us.

 

This the …………………day of ………………2025.

 

Sanjib Saha, Advocate High Court Calcutta, Chamber : P-16, Purbasha Pally, Dr. A.K. Paul Road, Kolkata – 700034, Mobile Number : 9051570268 / 7003781930 Email : sanjibsaha.smc@gmail.com

Sri Ashok Kumar Singh, Advocate. High Court Bar Association Room No. 15, High Court at Calcutta. Mobile Number : 9883070666 / 9836829666, Email : aksinghadvocate@rediffmail.com

 

Sri Biplab Some, Advocate. Sri Pritam Das, Advocate. Miss Shewetalina Majumdar, Advocate. Sri Madhusudan Sardar, Advocate.

 

Title Suit for Declaration and Permanent Injunction

 

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

South 24 Parganas

18, Alipore Judges’ Court Road, Alipore, Kolkata – 700027

 

Title Suit No.            of 2025

 

                                                          In the matter of ;

 

Nandita Mondal Bose, Wife of Late Bimal Kumar Bose @ Bimal Bose, aged about __________years, residing at 3rd Floor, Block A, Holding Number 374, P.K. Guha Road, Gora Bazar, Police Station Dum Dum, Kolkata – 700028, District North 24 Parganas, Mobile No. 8697549234.

                   __________Plaintiff

-      Versus –

 

(1)  Sri Vivek Bose, Son of Late Bimal Kumar Bose @ Bimal Bose, residing at Premises being no. 36C, Motilal Gupta Road, Post Office Barisha, Police Station Haridevpur, Kolkata – 700008, District South 24 Parganas.

 

(2)  Smt. Binita Bose, Daughter of Late Bimal Kumar Bose @ Bimal Bose, residing at Premises being no. 36C, Motilal Gupta Road, Post Office Barisha, Police Station Haridevpur, Kolkata – 700008, District South 24 Parganas.

 

(3)  The Branch Manager, Bandhan Bank, Joka Branch, IFSC : BDBL0002144, having Branch at Ground Floor, B- 4, Dist, Diamond Park, Joka, Kolkata – 700104, West Bengal.

 

 

(4)  The Branch Manager, ICICI Bank, Thakurpukur Branch,  IFSC Code: ICIC0001973, having Branch at Premises being no. 130C Diamond Harbour Road, Joka, Ps Thakurpukur, Kolkata - 700104, West Bengal.

 

(5)  The Branch Manager, Karur Vysya Bank, Joka Branch, IFSC Code: KVBL0003108 having its Branch at Diamond Park, Joka, Kolkata - 700104, West Bengal.

_______Defendants

 

Suit for Declaration and Permanent Injunction valued at Rs. 1,000/- (Rupees One Thousand) only.

 

The Plaintiff most respectfully submits as follows;

 

1.   The Plaintiff is married to one Sri Bimal Kumar Bose @ Bimal Bose of Premises being no. 36C, Motilal Gupta Road, Post Office Barisha, Police Station Haridevpur, Kolkata – 700008, District South 24 Parganas, and out of their wedlock one daughter namely Brishti Bose born. The plaintiff is the Second Wife of the said Sri Bimal Kumar Bose @ Bimal Bose. The said Bimal Kumar Bose @ Bimal Bose married this plaintiff on demise of his first wife. The said Bimal Kumar Bose @ Bimal Bose have one Son namely Vivek Bose and one daughter namely Binita Bose, out of his earlier wedlock with his first wife. Therefore the said Bimal Kumar Bose @ Bimal Bose died on 10-06-2024, leaving behind his legal heirs, and successors, as the Plaintiff Nandita Mondal Bose (Widower), Brishti Bose (Minor Daughter) and Vivek Bose (Son from the first wife), Binita Bose (Daughter from the first wife). Therefore the Plaintiff on demise of her husband Bimal Kumar Bose @ Bimal Bose on 10-06-2024, become successor for 50% (Fifty percent) of the property including money lying in the Bank Accounts as well as money in the form of the Fixed Deposit lying in the concerned Bank.

 

2.   The Plaintiff acquired knowledge that the deceased Bimal Kumar Bose @ Bimal Bose had have substantial money in the Saving Bank Account No. 52220042185611, with the Bandhan Bank, Joka Branch, IFSC : BDBL0002144, having Branch at Ground Floor, B- 4, Dist, Diamond Park, Joka, Kolkata – 700104, West Bengal. Saving Bank Account no. 19730002183, & Fixed Deposits with ICICI Bank, Thakurpukur Branch,  IFSC Code: ICIC0001973, having Branch at Premises being no. 130C Diamond Harbour Road, Joka, Ps Thakurpukur, Kolkata - 700104, West Bengal. Saving Bank Account & Fixed Deposit with Karur Vysya Bank, Joka Branch, IFSC Code: KVBL0003108 having its Branch at Diamond Park, Joka, Kolkata - 700104, West Bengal.

 

3.   The Plaintiff approached the defendants bank; but they did not co-operate on account that the respective accounts in the name of deceased Bimal Kumar Bose @ Bimal Bose has been assigned with Nominee, which stand in the name of Vivek Bose being Son of the first wife of the deceased Bimal Kumar Bose @ Bimal Bose. The defendants’ bank did not adhere to give any money to the plaintiff.

 

4.   The Plaintiff is the Second lawful wife of the deceased Bimal Kumar Bose @ Bimal Bose, who died on 10-06-2024. The Plaintiff is with her minor daughter Brishti Bose are the lawful Successors along with Vivek Bose (Son from the first wife), Binita Bose (Daughter from the first wife). But since the said Vivek Bose name has been given as Nominee in all the bank Accounts by the deceased Bimal Kumar Bose @ Bimal Bose, he used to take money at his own from the concerned Bank Accounts towards to gain of himself and his sister Binita Bose. Thus, the plaintiff and her minor daughter has duly been victimized at the behest of the defendants.

 

5.   The Plaintiff submits that nomination made in Bank accounts or Fixed Deposits does not confer any ownership right upon the nominee. As per settled law, the nominee acts only as a trustee for the legal heirs of the deceased account holder. Therefore, the entire amount lying in the said Bank Accounts and Fixed Deposits of Late Bimal Kumar Bose @ Bimal Bose ought to devolve equally among his legal heirs, namely — the Plaintiff (widow), Brishti Bose (minor daughter), Vivek Bose (son from the first marriage), and Binita Bose (daughter from the first marriage). However, the Defendant Nos. 1 and 2, in connivance with the Defendant Bank officials (Defendant Nos. 3, 4, and 5), have illegally withdrawn, or are attempting to withdraw, the entire sum, thereby depriving the Plaintiff and her minor daughter of their legitimate shares.

 

6.   The Plaintiff further submits that despite repeated requests and representations to the concerned Bank Branches, the said Banks have failed and neglected to protect the interests of all the legal heirs of the deceased Bimal Kumar Bose @ Bimal Bose. The Banks have wrongfully allowed Defendant No.1, namely Vivek Bose, to deal with the accounts and Fixed Deposits without insisting upon a Succession Certificate, Probate, or Letter of Administration, which is mandatory under the law for disbursal of funds when there are multiple legal heirs.

 

7.   The Plaintiff also states that she is constrained to approach this Hon’ble Court for necessary reliefs by way of Declaration and Permanent Injunction to protect her and her minor daughter’s share in the estate left behind by Late Bimal Kumar Bose @ Bimal Bose.

 

  1. The cause of action for the present suit arose on the death of Sri Bimal Kumar Bose @ Bimal Bose on 10-06-2024, and subsequently when the Plaintiff was denied her lawful claim over the bank accounts and Fixed Deposits. The cause of action is continuing as the Plaintiff and her minor daughter are being wrongfully deprived of their rightful share.

 

  1. This Hon’ble Court has the jurisdiction to entertain and try the present suit as the properties in question, namely the Saving Bank Accounts and Fixed Deposits, are situated within the jurisdiction of this Hon’ble Court, and the Defendant Nos. 1 and 2 also reside within the territorial jurisdiction of this Hon’ble Court. Furthermore, the cause of action wholly or in part has arisen within the jurisdiction of this Hon’ble Court.

 

  1. For the purpose of Court fees and jurisdiction, the Plaintiff values the relief for Declaration and Permanent Injunction at Rs. 1,000/- (Rupees One Thousand only), and affixes the appropriate Court fee as per the provisions of the Court Fees Act, 1870. The Plaintiff undertakes to pay any additional Court fees if so directed by this Hon’ble Court.

 

 

 

 

 

In the premises aforesaid, the Plaintiff humbly prays for the following reliefs;

(a) A Declaration that the Plaintiff and her minor daughter Brishti Bose are entitled to succeed to the estate of Late Bimal Kumar Bose @ Bimal Bose, including the amounts lying in the Saving Bank Accounts and Fixed Deposits mentioned herein, along with the other legal heirs.

(b) A Permanent Injunction restraining Defendant Nos. 1 and 2 from exclusively operating, withdrawing, or dealing with the Saving Bank Accounts and Fixed Deposits standing in the name of Late Bimal Kumar Bose @ Bimal Bose without accounting for the Plaintiff’s and her minor daughter's shares.

(c) A Direction upon Defendant Nos. 3, 4, and 5 (the Banks) to freeze the accounts and Fixed Deposits in the name of Late Bimal Kumar Bose @ Bimal Bose until the estate is lawfully partitioned amongst the legal heirs, or till a Succession Certificate/Probate/Letter of Administration is obtained.

(d) An Ad-interim Order of Injunction in terms of prayer (b) above during the pendency of the suit.

(e) Leave under Order 2 Rule 2 of the Code of Civil Procedure’ 1908.

(f) Cost of the Suit.

(g) Any other relief or reliefs as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case.

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

 

 

 

 

 

 

 

 

SCHEDULE REFERRED TO ABOVE

(i)           Saving Bank Account No. 52220042185611, with the Bandhan Bank, Joka Branch, IFSC : BDBL0002144, having Branch at Ground Floor, B- 4, Dist, Diamond Park, Joka, Kolkata – 700104, West Bengal, of Late Bimal Kumar Bose @ Bimal Bose.

 

(ii)          Saving Bank Account no. 19730002183, & Fixed Deposits with ICICI Bank, Thakurpukur Branch,  IFSC Code: ICIC0001973, having Branch at Premises being no. 130C Diamond Harbour Road, Joka, Ps Thakurpukur, Kolkata - 700104, West Bengal, of Late Bimal Kumar Bose @ Bimal Bose.

 

(iii)        Saving Bank Account & Fixed Deposit with Karur Vysya Bank, Joka Branch, IFSC Code: KVBL0003108 having its Branch at Diamond Park, Joka, Kolkata - 700104, West Bengal, of Late Bimal Kumar Bose @ Bimal Bose.

 

Verification

I, Nandita Mondal Bose, Wife of Late Bimal Kumar Bose @ Bimal Bose, residing at 3rd Floor, Block A, Holding Number 374, P.K. Guha Road, Gora Bazar, Police Station Dum Dum, Kolkata – 700028, District North 24 Parganas, do hereby verify that the contents of paragraphs 1 to 8 are true to my knowledge and belief and that I have not suppressed any material facts.

Verified at Kolkata on this the ___ day of _______, 2025.

 

 

Nandita Mondal Bose (Plaintiff)

 

 

 

 

 

 

 

 

 

 

 

 

AFFIDAVIT OF THE PLAINTIFF

 

AFFIDAVIT

 

I, Nandita Mondal Bose, Wife of Late Bimal Kumar Bose @ Bimal Bose, aged about ___ years, by faith Hindu, by occupation Housewife, residing at 3rd Floor, Block A, Holding Number 374, P.K. Guha Road, Gora Bazar, Police Station Dum Dum, Kolkata – 700028, District North 24 Parganas, do hereby solemnly affirm and declare as under;

 

  1. That I am the Plaintiff in the present suit and am well conversant with the facts and circumstances of the case, and hence, competent to affirm this Affidavit.

 

  1. That the statements made in paragraphs 1, 2, 3, 4, 5, & 6, of the Plaint are true and correct to my knowledge and belief, and the statements made in the remaining paragraphs are based on legal advice, which I believe to be true and correct.

 

  1. That I have not suppressed any material facts nor made any false statement in the Plaint.

 

  1. That I am filing this Affidavit in support of the Plaint for Declaration and Permanent Injunction.

 

Solemnly affirmed and declared by the said Nandita Mondal Bose at Kolkata on this ___ day of _______, 2025.

 

 

 

Nandita Mondal Bose

(Plaintiff)

DEPONENT

Identified by me,

 

 

Advocate

Drafted & Prepared in my chamber,

 

 

Advocate

Date : ___________________2025

Place : Alipore Judges’ Court

 

N O T A R Y

 

 

 

 

 

List of Documents

{Relied on by the Plaintiff}

 

1.   Death Certificate of Deceased Bimal Kumar Bose @ Bimal Bose;

2.   PAN & AADHAR CARD of Deceased Bimal Kumar Bose @ Bimal Bose;

3.   PAN & AADHAR CARD of the Plaintiff;

4.   Credential / Birth Certificate of the Minor Bristi Bose;

5.   Credential / Marriage Certificate of the Plaintiff;

6.   Letter of the Plaintiff;

7.   Letter of the Learned Advocate of the Plaintiff;