505 - 10985 - 214216010125055 Dpcej

SYMBIOSIS LAW SCHOOL, PUNE
Care | Courage | Competence | Collaboration
CONSTITUENT OF
SYMBIOSIS INTERNATIONAL (DEEMED

UNIVERSITY)
Reaccredited by NAAC with 'A' Grade
Symbiosis Campus, Opp. Pune International Airport,

Symbiosis Road, Viman Nagar, Pune 411 014.
DRAFTING, PLEADING AND CONVEYANCING

(CLINICAL COURSE - I)
PRACTICAL TRAINING - II
B.A. / B.B.A., LL.B. (Hons), FIFTH YEAR
Academic Year : 2020-2021
SEMESTER - IX
Name of Student: Nikita Jaitly
Roll No.: 055 Div.: A
Batch: 2016-21 Programme: B.A. L.L.B.(Hons.)
PRN No.: 16010125055 Mobile No.: 7309228064
E-mail ID: nikita.jaitly@symlaw.ac.in

CLINICAL COURSE I
INDEX
INDEX ............................................................................................................................................ 1
Assignment 1: Drafting Of Legal Notice ........................................................................................ 2
Assignment 2: Petition For Divorce ............................................................................................... 4
Assignment 3: Service Contract...................................................................................................... 7
Assignment 4: Plaint/Suit for Recovery of Money ....................................................................... 12
Assignment 5: Maintenance Application ...................................................................................... 15
Assignment 6: Leave and License Agreement.............................................................................. 18
Assignment 7: Anticipatory Bail Application............................................................................... 23
Assignment 8: Regular Bail Application ..................................................................................... 26
Assignment 9: Franchise Agreement ............................................................................................ 29
Assignment 10: Consumer Complaint .......................................................................................... 32
Assignment 11: Joint Venture Agreement .................................................................................... 35
Assignment 12: Petition for Public Interest Litigation ................................................................. 39
Assignment 13: Appeal to High Court.......................................................................................... 44
Assignment 14: Writ of Habeas Corpus ....................................................................................... 46
Assignment 15: Special Leave Petition ........................................................................................ 50
Assignment 16: Public Notice ...................................................................................................... 53
Assignment 17: Power of Attorney............................................................................................... 54
Assignment 18: Special Power of Attorney .................................................................................. 56
Assignment 19: Petition for Divorce ............................................................................................ 58
Assignment 20: Development Agreement with Important Clauses Between Land Owner And
Developer ...................................................................................................................................... 60
Assignment 21: Lease Deed.......................................................................................................... 66
Assignment 22: Civil Suit To Claim Damages For Defamation .................................................. 70
Assignment 23: Dissolution of Partnership Deed ......................................................................... 73
Assignment 24: Promissory Note ................................................................................................. 75
Assignment 25: Mortgage Deed ................................................................................................... 77
Assignment 26: Deed of Will ....................................................................................................... 80
Assignment 27: Sale Deed ............................................................................................................ 82
Assignment 28: Draft Affidavit .................................................................................................... 85
Assignment 29: Interlocutory Application.................................................................................... 87
Assignment 30: Agreement Regarding Licensing Of Trademarks ............................................... 89
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CLINICAL COURSE I
ASSIGNMENT 1: DRAFTING OF LEGAL NOTICE
LEGAL NOTICE UNDER SECTION 138 OF THE NEGOTIABLE INSTRUMENTS ACT
Ms. Nikita Jaitly B-5, 402,
B.A. LLB. (Hons.) Camelot Society, Viman Nagar
ADVOCATE Pune- 411014
Phone: 020-2531457/2356127
Dated: 21st September 2018
(BY REGISTERED A.D)

Without Prejudice
To,
Mr. Sumeet Narang,
M/s Abdc Enterprises,
K-42, Metro Plaza
Viman Nagar, Pune -411014
Subject:- Notice under Section 138 of the Negotiable Instruments Act, 1881 for dishonour of
cheque due to ‘Insufficiency of Funds’
Sir,
Under instructions from and on behalf of my client, Mr. Ajit Dixit of 101, Shaniwar Peth,
Pune 411011, I am serving you with the following legal notice in unequivocal terms:
1. That you are the owner of M/s Abdc Enterprises which is a sole share broking and trading
firm.
2. That my above said client Mr. Ajit Dixit, being an investor in the share market, invested
money in share market though the Share broking Firm owned by you.
3. That on 5th August, 2018 Mr. Ajit Dixit instructed you to sell 200 shares at Rs.550/- each.
4. That as per the instructions of Mr. Ajit Dixit, you sold the shares and handed over one
cheque to Mr. Ajit Dixit.
5. That the cheque handed over to Mr. Ajit Dixit was for an amount of Rs. 1,10,000/- dated
10th August 2018 bearing no. 882345 drawn on HDFC Bank, Viman Nagar, Pune Branch.
6. That my above said client when presented the above said cheque with State Bank of India
on 13th August 2018, the cheque was returned to him with the information that you do not
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have sufficient amount in your account and with the endorsement “Dishonor for
insufficient balance” on 17th August, 2018.
7. That you had given the aforesaid cheque knowing fully and with the ulterior motive to
cheat my client. Thus you have made yourself liable for commission of offence under
section 138 of Negotiable Instruments Act, 1881 and Section 420 of Indian Penal Code,
1860 for which my client reserves his right to lodge FIR against you.
8. That my client does hereby call upon you to make the payment of the said amount of Rs.
1,10,000/- along with bouncing charges in cash with interest at 24% per annum WITHIN
FIFTEEN DAYS from the receipt of this notice, failing which my client will be
constrained to take against you an appropriate legal action including filing of a criminal
complaint, which you may please note.
9. That since your illegal behavior has necessitated the issue of this notice, you are hereby
charged with its costs, i.e. Rupees Fifteen Thousand Only (Rs. 15000/-), which also you
may please further note.
Yours faithfully,
[Ms. Nikita Jaitly]
ADVOCATE
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CLINICAL COURSE I
ASSIGNMENT 2: PETITION FOR DIVORCE
IN THE COURT OF THE PRINCIPAL JUDGE, FAMILY COURT, PUNE
AT PUNE
H.M. PETITION NO. 135 OF 2013
IN THE MATTER OF:

Shri AAA,
Age 38 years,
S/o Shri KKK,
C-7684, Azziano, Rustomjee Urbania, Majhiwada, Thane(w) ............................Petitioner 1
AND
Smt. BAA,
Age 36 years,
W/o Shri MMM,
D/o Shri CCC,
R/o 318/10C, ADC Heights Building, Pune…..…………………………………Petitioner 2
Joint petition under Section 13-B, of the Hindu Marriage Act, 1955 for the dissolution of
marriage by decree of divorce by mutual consent.
THE PETITIONERS ABOVE NAMED MOST RESPECTFULLY SHOWETH,

1. That the parties to this present petition are Hindus by religion and faith and their marriage
was solemnized as per Hindu rites/customs at Pune on 17th June, 2008 and the said marriage
still exists. A certified copy of the relevant extract from the Hindu Marriage Register is
duly filed herewith.
2. The status and place of residence of the parties to the marriage before the marriage and at
the time of filing the petition were as follows:
Husband Wife
Place of Place of
Status Age Status Age Residence
Residence
(i) Before 1702, A1 Society,

Hindu 33 Hindu 31
Marriage Majestica Walkeshwar,
(ii) At the time of Building, Teen Batti,
filing this Hindu 38 Casa Royale, Hindu 36 Mumbai
petition Thane West
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3. That the parties after their marriage resided together at the residence of the Petitioner No.1,
that Petitioner No. 2 was, prior to the solemnization of marriage, was known by her maiden
name as BAA Matthews and would pursuant to this petition crave to revert to the said
maiden name, and that there has been no resultant change in the name of Petitioner No. 1
pursuant to the marriage.
4. That there is no issue out of the wedlock of the parties.
5. That due to unavoidable circumstances, including incompatibility between the parties to
this petition, the parties over time began to find it impossible to live together as husband
and wife this eventually led to irretrievable breakdown of their marriage. The parties agree
that temperamental differences are the root cause of this separation of the parties.
6. That in light of the aforementioned mental incompatibility and temperamental differences,
the parties, have in spite of their best efforts at reconciliation, not been able to live together
as husband and wife.
7. That Petitioner no. 2 has left the company and cohabitation of the Petitioner No. 1 on 3rd
May 2012 and the parties have been living separately since then.
8. That considering that the marriage between the parties has come to an irretrievable
breakdown in spite of the best efforts on their part to save the same, the parties have
mutually agreed to dissolve their marriage.
9. That the efforts of reconciliation between the parties to continue in this marriage have failed
and there are no further chances of reconciliation between the parties.
10. That it is further submitted that stridhan and all the other belongings of petitioner No. 1 are
in her own possession and there is no question of any claim with regard to stridhan or any
such thing whatsoever.
11. That with regard to the financial claims of the parties in respect of alimony and
maintenance, it is stated that in light of the financial status of the parties and the peculiar
circumstances of this matter, whatever was mutually determined to be due to each party
has already been handed over to each party by the other party and there remains no further
claim on any one of mentioned articles or things from the other party with regard to dowry,
stridhan, visitation rights or any other right whatsoever, except whatsoever has been
already stated above.
12. That the petitioner No. 2 being a practicing medical officer in a private hospital, is in a
position to maintain herself and she, out of her volition is of a view to waive her right to
maintenance in respect of herself against the petitioner no. 1.
13. That the marriage was solemnized within the local limits of the jurisdiction of this Hon’ble
Court and both the petitioner No 2 is presently residing within the territorial jurisdiction of
this Hon’ble Court and therefore, this Hon’ble Court has territorial jurisdiction to hear the
present petition.
14. That this petition has not been preferred as a result of any collusion between the parties,
and the mutual consent with which this petition has been forged has not been obtained by
way of force, fraud, coercion or undue influence of any sort or manner.
15. That there has not been any unnecessary or improper delay in instituting the proceedings.
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16. That there are no divorce proceedings pending before any court and therefore there are no
legal impediments which could afflict the grant of the decree of divorce to the parties on
the basis of mutual consent.
17. That the petitioners, therefore, humbly pray that-
a. Their marriage be dissolved by a decree of divorce without passing any orders as to the
costs and maintenance, and
b. Any other orders in the interests of justice be kindly passed.
Place: Pune ________________

Dated: 28th August, 2013 Shri AAA
Place: Pune ________________

Dated: 28th August, 2013 Smt BAA
Verification
We, Shri AAA and Smt. BAA the present petitioners, do hereby state on solemn affirmation that
the contents of this petition from paras 1 to 16 are true to their knowledge and true to the
information received and believed to be true by them. The above contents have been read over to
us in Hindi and we have understood the same hence we have signed hereunder on 28 th August,
2013 at Mumbai.
Verified at Pune
________________
Dated: 28th August, 2013 Shri AAA & Smt BAA
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CLINICAL COURSE I
ASSIGNMENT 3: SERVICE CONTRACT
USERS ARE INSTRUCTED TO CAREFULLY READ AND UNDERSTAND THE
FOLLOWING TERMS AND CONDITIONS BEFORE USING THIS WEBSITE,
NAMELY LAPTOPTRACER.COM
THIS AGREEMENT represents a Service Level Agreement (“SLA” or “Agreement”) made on

the 6th day of November 2020 at Pune, India for the provisioning of IT tracking services required
to trace and retrieve stolen /misplaced laptops via a tracking chip and an anti-theft software
BETWEEN
WEB Vigilante Pvt. Ltd. having its registered office at 209, 3rd Floor, Phoenix Marketcity, Viman
Nagar, Pune, India hereinafter referred to as ‘Service Provider’ which expression shall, unless the
context otherwise requires, include its permitted successors and assignors;
AND
‘______’, age-___, s/o____, Occupation ________, residing at _____, hereinafter referred to as

‘Customer’ (Individual Member/Real Person).
OR
‘__________’, incorporated on ‘_________’, having Registered Office at ‘______’, holding CIN

‘________’ hereinafter referred to as ‘Customer’ (Firm/Company/Other Legal Person).
Each of the parties mentioned above are collectively referred to as the ‘Parties’ and individually
as a ‘Party’.
Now wherefore the parties being desirous of entering into this Service Level Agreement, agree as
follows:
1. Acknowledgement & Acceptance
1.1 By enrolling and/or using the services provided through the website http://laptoptracer.com
service, the Customer agrees that the Customer has read and understood this Agreement
and that the Customer’s membership in the www.laptoptracer.com shall conform to the
terms and conditions ("Terms") herein stipulated as may be amended from time to time at
the sole discretion of the Service Provider.
1.2 This Agreement is between the Customer and the Service Provider. It is hereby informed
to the Customer that the website www.laptoptracer.com is completely and independently
managed and endorsed by the Service Provider and it is the engineers and management of
the Service Provider that control and co-ordinate the services within the same i.e
www.laptoptracer.com.
1.3 www.laptoptracer.com Customers do hereby agree to enroll to receive e-mail alerts and
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advertisement of our (Service Provider’s) services from time to time upon the agreed period
at the time of User sign up.
1.4 The charge or payment to be made by the customer for enrolling with
www.laptoptracer.com would be in accordance with the 'Plan' that the customer would
prefer to be subscribed with.
1.5 The Service Provider reserves the right to limit Service enrolment at any time in the event
of government affecting the same, natural disaster, force majeure or even if it comes to our
notice that you as a user have failed to comply with any one or all of our Terms and
Conditions.
2. Service Description
2.1 laptoptracer.com is an online service (the “Service”) developed by WEB Vigilante Pvt Ltd
Ltd. (Service Provider) which allows remote tracking and monitoring of laptop devices (the
“Devices”) through a web interface (the “Control Panel”). Devices connect through an
Internet connection to a centralized host (the “Server”) and send information, such as their
current location, model number and using an installed Software (the “Agent”), which can
also perform different actions if requested by the Server.
2.2 The Control Panel is administered by each Customer from any browser with Internet
connection, enabling to customize the behavior to be followed by his device(s) using all or
some of the available actions. The Agent for Mac, Linux, and Windows platforms is
licensed under the GPLv3. The Control Panel is an application that is currently not
licensed, and has been developed, administered and maintained only by the Service
Provider.
3. Our Service Privacy Policy
The Service Provider takes utmost care possible from its end to maintain the privacy of
your personal information. The full extent of this commitment can be found in the Privacy
Statement. By enrolling and using the Service, the Customer agrees to be bound by the
terms of the Privacy Statement.
4. Terms of Participation
4.1 Parties must be at least 18 years old to become a Customer.
4.2 The Agent is only to be installed on Devices OWNED by the Customer or where the
Customer has in respect of any device the EXPLICIT PERMISSION to install the said
Agent software. Any misuse of this Service will result in the Account being suspended.
Any illegal use of this service will be reported and the Service Provider will comply with
and assist all the law enforcement regarding the misuse. By installing the Software on your
Device, you also agree to only plug your computer or Device into systems with which you
have legitimate access to, activating the Agent on a system or account that you do not have
legitimate use of is considered misuse. If you have installed the Agent on a device that has
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been sold and you are no longer the owner, you must uninstall the software and remove the
Device from your Control Panel Account, so that all gathered data is destroyed.
4.3 You must agree to comply with all local, state, province, country or regional laws that may
be applicable to your use of the Internet and your membership with www.laptoptracer.com.
5. Termination of Membership
The Customer is solely responsible for properly canceling his/her/its account. An email
request to cancel the Customer’s account is not considered cancellation as per this
Agreement. The Customer can cancel his/her/its account at any time by using the website
namely www.laptoptracer.com. All of the Customer’s Content will be immediately deleted
from the Service upon cancellation. This information cannot be recovered once the
Customer’s account is cancelled. If the Customer cancels the Service before the end of
his/her/its current paid up month, the cancellation will take effect immediately and the
Customer will not be charged again for any future period. The Service Provider, in its sole
discretion, has the right to suspend or terminate the Customer’s account and refuse any and
all current or future use of the Service, or any other service offered by the Service Provider
as available at present or as may be introduced by the Service Provider, for any reason and
at any time. Such termination of the Service will result in the deactivation or deletion of
the Customer’s Account or discontinuation of access to the Customer’s Account, and the
forfeiture and relinquishment of all content in the Customer’s Account. The Service
Provider reserves the right to refuse service to anyone for any reason and at any time.
6. Non-Transferability
Customers are not allowed to share their account with any other individual. Nor is the
Customer allowed to transfer account to someone else. The Customer’s membership will
terminate immediately in the event of the Customer’s death. Service accounts are not
transferable upon death or otherwise by operation of law.
7. Modifications
The Service provider reserves the right to change this Terms and Conditions document.
Current members will be informed of any and all changes to the Terms and Conditions by
email, however it is also the Customer’s responsibility to check this document periodically
for any changes or modifications and the customer must not rely on the afore stated e-mails
as the sole source of information regarding this agreement or the Customer’s membership.
The Customer’s continued use of http://laptoptracer.com constitutes an affirmative
acknowledgement of the Terms and Conditions and any subsequent modifications made to
it and the Customer’s agreement to abide and be bound by the Terms and Conditions
document in its modified form.
The Service Provider reserves the right to modify or discontinue the Service with or
without notice to the Customer. The Service Provider shall not be liable to Customer or
any third party in respect of any act or exercise of the afore-stated right of modification or
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discontinuation of the Service.
8. Intellectual Property
The Customer acknowledges that the Service Provider or the associated third parties own
all right, title and interest in and to the Software and Service, portions thereof, or software
or content provided through or in conjunction with the Software or Service, including
without limitation all intellectual property rights. Except for the license GPLv3 indicated
in Clause 1, all rights in and to the Software and Service are reserved, and no implied
licenses are granted by the Service Provider.
9. Limitation of Liability
9.1 Under no circumstances shall the Service Provider, or its Suppliers, Resellers, Partners or
their Respective Affiliates be liable for any indirect, incidental, consequential, special,
exemplary, or punitive damages arising from or related to the software or Service, whether
such claim is based on warranty, contract, tort (including negligence), or otherwise, (even
if the Service Provider has been advised of the possibility of such damages).
9.2 Without limiting the foregoing, the total aggregate liability of the Service Provider, and its
Suppliers, Resellers, Partners and their Respective Affiliates arising from or related to this
agreement shall not exceed the amount, if any, paid by the Customer to the Service Provider
for the Software or Services. If the Software and Services are provided without charge, the
Service Provider and its suppliers shall have no liability to the Customer whatsoever.
9.3 The foregoing limitations of liability shall apply whether the damages arise from use or
misuse of and reliance on the software or service, from inability to use the software or
service, or from the interruption, suspension, or termination of the software or service
(including such damages incurred by third parties). Such limitation shall apply
notwithstanding a failure of essential purpose of any limited remedy and to the fullest
extent permitted by law.
9.4 TERMS AND CONDITIONS and the relationship between the Customer and the Service
Provider shall be governed by the laws of the State of Maharashtra without regard to its
conflict of law provisions. The Customer and Service Provider hereby agree to submit to
the personal and exclusive jurisdiction of the courts located within Pune, Maharashtra.
9.5 This Agreement constitutes a complete and exclusive understanding between the parties
relating to the subject matter hereof and supersedes all prior or contemporaneous
understandings, agreements, communications, and/or advertising with respect to such
subject matter provided that nothing in this Agreement seeks to limit or exclude any right
either party may have in respect of fraudulent misrepresentation.
9.6 Failure to exercise or enforce any right or provision of this Agreement by the Service
Provider shall not constitute a waiver of such right or provision unless such waiver has
been acknowledged by the Service Provider in writing.
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10. Severability
If any part of these Terms is unenforceable (including any provision by which the Service
Provider excludes its liability to the Customer), the enforceability of any other part of these
Terms will not be affected.
IN WITNESS WHEREOF, each party to this agreement has caused it to be executed at

(PLACE OF EXECUTION) on the date indicated above.
(WEB Vigilante Pvt. Ltd.) (Customer)
____________________ ________________
(Authorized Sign) (Authorized Sign)
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ASSIGNMENT 4: PLAINT/SUIT FOR RECOVERY OF MONEY
SUIT FOR RECOVERY OF MONEY
IN THE COURT OF CITY CIVIL COURT SENIOR DIVISION, MUMBAI
Civil Suit No.: 760 of 2020
(Under Order XXXVII of the Code of Civil Procedure, 1908)
Date of Institution: 15.11.2020
Plaintiff:
ABC Pvt. Ltd.
Through, Mr. Prem Ratan,
Managing Director and CEO,
11/2 Lower Parel, Mumbai- 400015
Versus
Defendants:
Mr. Akash Motwani,
Partner, XYZ & Sons
3rd Floor, Town Sqaure, Viman Nagar Pune
Suit for the recovery of Rs. 11,00,000 along with cost and interest @ 24% pa
Court Fee paid Rs. 26439/-
PLAINT UNDER ORDER XXXVII OF THE CODE OF CIVIL PROCEDURE 1908 AS

MENTIONED IN THE SUIT
The plaintiff Respectfully Submits:
1. That the present suit is being filed under the specific provisions provided under Order
XXXVII of the Code of Civil Procedure, 1908.
2. That no relief, which does not fall within the ambit of these rules, has been claimed in the
plaint.
3. That the plaintiff is in the business of manufacturing automobile spare parts and is
headquartered in Mumbai. The defendant, running a business of retail sale of automobile
spare parts at Pune, purchased spare parts worth Rs.11,00,000 consisting of tyres, engines,
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exhaust pipes etc from the plaintiff , the same was delivered to the defendant at their office
in Pune.
4. That the defendant issued the Cheque bearing No. 884579 dated 06.08.2018 for the sum of
Rs. 11,00,000 drawn at The Corporation Bank, Viman Nagar, Pune, IFSC Code: 4578, to
the plaintiff towards the consideration of the above spare parts purchased from the plaintiff.
5. That the plaintiff presented the cheque through his own bankers, ie; The Corporation Bank,
Mumbai IFSC Code: 3760, but the same was returned unpaid, on 10.10.2020 with the
endorsement of insufficiency of funds in the account of the defendant as per the remarks
of the banker of the defendant.
6. That the other necessary particulars are as mentioned hereunder for the convenience of this
Hon'ble court:-
a. Date of the cheque: 06.10.2020
b. Date of presentation: 8.10.2020 (within 6 months from 06.10.2020)
c. Date of dishonour of Cheque: 10.10.2020
d. Date of receipt of Memo of dishonour of Cheque: 13.10.2020
e. Date of sending of Notice: 20.10.2020 (within 30 days from 10.10.2020)
f. Date of service of Notice: 22.10.2020
g. Date when cause of action: 06.11.2020 arose (15 days after service on 22.10.2020)
7. That it is apparent from the facts afore stated that the Defendant has issued the cheque
without caring to ensure that adequate funds were lying to the balance of his account and
knowing fully well that the Cheque thus issued was liable to be returned unpaid and thus
with the ulterior motive to cheat the plaintiff.
8. That the memo to that effect was duly communicated to the plaintiff by its banker on
13.10.2020.
9. That the said cheque drawn by the defendant was issued for the discharge of the above said
debt/liability in respect of the goods delivered to the Defendant by the Plaintiff.
10. That the said cheque has been returned by the bank unpaid, because of the amount of money
standing to the credit of account of the defendant is insufficient to honour the cheque or
that it exceeds amount arranged to be paid from that account by an agreement made with
that bank.
11. The cheque has been presented to the bank within a period of six months from the date on
which it is drawn i.e. on 06.10.2020.
12. That the plaintiff in due course of the cheque, has made a demand for the payment of the
said amount of money by giving a notice in writing to the defendant within statutory period
of thirty days of the receipt of information by him from the bank regarding return of the
cheque as unpaid. The said notice was sent on the correct address of the defendant through
a Registered Post/AD letter as well as through UPC on 20.10.2020 and the said registered
letter has been received back with the endorsement "Unclaimed", as is evident from the
endorsement of post office seal on the it which legally is presumed to have been served as
otherwise also the UPC has not been received back and the same has been duly delivered
to the defendant.
13. That the defendant has failed to make the payment of the amount of money to the plaintiff
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in due course of the cheque within fifteen days of the receipt of the said notice.
14. That it is pertinent to mention here that the debt/liability, for which the cheque was issued
by the defendant to the plaintiff is a legally enforceable debt/liability.
15. The cause of action accrued to the plaintiff on 10.10.2020, when the cheque was dishonored
and thereafter on 20.10.2020 when the legal notice was sent to the defendant through
registered letter and UPC.
16. That the plaintiff is permanently residing within the jurisdiction of this Hon'ble court and
all the correspondence from the defendants were received at his home address and the
office/residence of the defendant is located in the territory of this Hon'ble Court, hence this
Hon'ble Court has each and every jurisdiction to try and entertain this suit.
17. That the value of the suit for the purposes of jurisdiction has been fixed for Rs. 11, 00,000/-
and for the purposes of recovery and correct and authorized court fee stamp of Rs. 500 has
been affixed on the plaint.
18. It is, therefore, most respectfully prayed that a decree for recovery to the effect that plaintiff
is entitled to recover a sum of Rs. 11, 00,000/- along with interest @ 24% w.e.f. 06.10.2020
till the date of realization of amount along with cost of this suit, be passed in favour of
plaintiff and against the defendants. Such other reliefs as deemed fit and proper in the facts
and circumstances of the case may also be passed in favour of the plaintiff and against the
defendants in the interest of justice.
AND FOR THIS ACT OF KINDNESS, THE HUMBLE PLAINTIFF AS IN DUTY BOUND
SHALL EVER PRAY.
Counsel for plaintiff Plaintiff
VERIFICATION:
I, Prem Ratan, Managing Director and CEO, ABC Pvt Ltd am the authorized representative in the
present suit do hereby verify that the contents of the above plaint from paras 1 to 18 are true and
correct to the best of my knowledge and belief, and no part of it is false and nothing material has
been concealed therein.
Verified at Pune this the 15th day of November 2020.
ON BEHALF OF THE PLAINTIFF
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ASSIGNMENT 5: MAINTENANCE APPLICATION
IN THE COURT OF THE PRINCIPAL JUDGE, FAMILY COURT, HYDERABAD
AT HYDERABAD
SPECIAL MARRIAGE PETITION NO. 17 OF 2020
IN THE MATTER OF:

Smt. Jacinta Patil,
Age 34 years,
W/o Shri Manish Patil
D/o Mr. Himanshu Sharma,
H-89, Club Royale, Panjim, Goa..................................................................................Applicant
V.
Shri Manish Patil,

Age 37 years,
S/o Mr. Swaroop Patil,
450/14, Jubilee Hills, Hyderabad…………………………………..……………….Respondent
APPLICATION FOR MAINTENANCE PENDENTE LITE AND EXPENSES OF

PROCEEDINGS UNDER SECTION 36 OF THE SPECIAL MARRIAGE ACT, 1954
The Applicant above named most respectfully showeth,

1. That the Applicant was married to the Respondent at Hyderabad on the 16th day September,
2009 and the marriage was solemnized duly registered by the Marriage Officer bearing no.
176/2002, and the said marriage is subsisting.
2. That the Applicant has initiated proceedings for divorce under Section 28 of the Special
Marriage Act, 1954 is pending between the parties before this Hon’ble court as case no.
897/2019.
3. That the next day of hearing is fixed as 29th December, 2020.
4. That the parties were happily married for 9 years and have two children from their
marriage. The Couple have a daughter, Jessi who was 8 years old at the time of first filing
of divorce and a son, Jis who was 4 years old at the time. The parties have been living
separately since 26th January, 2012 due to severe misunderstandings and have despite some
attempts been unable to adjust or reach an amicable understanding with each other.
5. That their marriage has broken down irretrievably and all efforts of reconciliation between
the parties have failed.
6. That the applicant has no independent source of income sufficient for her maintenance as
well as to meet the legal proceedings brought by her since she has been a housewife since
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her marriage. The applicant also only has a degree of B. com and therefore is in no position
to take up a job that would sustain herself as well as her two young children.
7. That the Applicant and her two children Jessi and Jis, are dependent on the Applicant’s
father Mr. Himanshu Sharma ever since they moved out of matrimonial home at Hyderabad
and have been residing in Goa along with the Applicant’s parents.
8. That the Applicant has no livelihood, no source of income and does not own any
immovable property, being that her current residence belongs to her parents.
9. That the Respondent is an employee of a Software Company named “Techlock” drawing
a gross monthly salary and allowance of Rs. 1,50,000/- (One lakh, Fifty Thousand only)
per month.
10. That the Respondent has a house and landed properties at Hyderabad wherefrom he derives
Rs. 50,000/- (Fifty Thousand only) as rent and owns further properties which are not being
put to any use for now and as mentioned below:
a) House property at Row House No. 38, Rohan Mithila, Upper Parijat, Viman Nagar,
Pune worth Rs. 2,00,00,000 (Rupees two crore only).
b) Land spread across 12 hectares in Plot no. 32, Sector 19, Siliguri, West Bengal –
700045 worth Rs. 12,00,00,00 (Rupees 12 crore only).
11. That the applicant submits that in spite of repeated requests, the Respondent has not made
any provision for the maintenance of the Applicant or their children.
12. That the Applicant therefore submits that taking into consideration the financial position
of the Respondent and the requirements of the Applicant, A monthly sum of Rs. 90,000
(rupees ninety thousand only) be kindly granted to the Applicant as Alimony pendent lite
towards the sustenance of care and lifestyle of her and their children, including expenses
for education.
13. That the Applicant has incurred litigation expenses of Rs. 90,000/- in bringing the above
proceedings and therefore a lump sum amount of these costs may also be granted towards
expenses for litigation costs pending before this Hon’ble court.
14. That the amount claimed in the application by the Applicant are just and proper.
15. Relief
a) That the applicant humbly prays before this Hon’ble Court to order the respondent
to pay the said sum of Rs. 90,000/- as expenses for the above proceedings and Rs.
90,000/- per month as maintenance during the proceedings for maintenance.
b) That any other order that the court may deem fit and proper in the interests of
justice, may kindly be passed.
AND FOR THIS ACT OF KINDNESS, THE APPLICANT AS IN DUTY BOUND, SHALL
EVER HUMBLY PRAY.
Hyderabad Sd.
Dated: November 3rd, 2020 Applicant
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Sd.
Advocate Nikita Jaitly
VERIFICATION
I, Mrs. Jacinta Patil, above named applicant state on solemn affirmation that paras 1 to 14 of the
petition are true to my knowledge and true to the information received and believed to be true by
me and in witness whereof, I have signed on this 3rd Day of November, 2020 at Hyderabad.
Verified at Hyderabad
Applicant
(Jacinta Patil)
Dated 03.11.2020
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ASSIGNMENT 6: LEAVE AND LICENSE AGREEMENT
Leave and License Agreement
THIS AGREEMENT of Leave and License is made and entered into at Pune this 20th day of
October, 2020
Between
ABC Private Ltd., a company incorporated under the Companies Act, 2013, having its registered
office at 15, Dorabjees, Town Square, Viman Nagar, Pune hereinafter referred to as ‘the Licensor’
(which expression shall, unless it be repugnant to the context or meaning thereof, be deemed to
mean and include its successors and permitted assigns) of the One Part
And
M/s XYZ & Associates, a partnership firm registered under the Partnership Act, 1932, having its
principal office at R-3401, Rohan Mithila, Viman Nagar, Pune hereinafter referred to as the
‘Licensee’ (which expression shall, unless it be repugnant to the context or meaning thereof, be
deemed to mean and include its successors and permitted assigns) of the Other Part, as follows;
Whereas the licensor is absolute and clear owner and has seized and possessed of or otherwise
entitled to the premises at Shop No. 18F, First Floor, Plaza Shopping Centre, MG Road, Pune
(Admeasuring approximately 1000 square feet), hereinafter referred as the 'licensed premises'
AND WHEREAS the Licensee has approached the licensor with a request to allow the Licensee
to temporarily occupy and use the licensed premises of the said building for carrying on his
business of sale of mobile phones and accessories, on leave and license on conditions and terms
as agreed hereafter.
NOW THIS WITNESSTH AND IT IS HEREBY AGREED BY AND BETWEEN THE

PARTIES HERETO AS FOLLOWS:
1. Grant of License
1.1. That the Licensor hereby grants to the Licensee a non-transferable license to occupy
and use the Licensed Premises for a period of 48 months, hereinafter referred as
the “Licensed Period” with effect from 1st December, 2020.
1.2. That the Licensee shall pay to the Licensor a sum of Rs 40,000 per month as
‘License fee’ to be paid in advance for each month on or before the 3rd day of each
calendar month.
2. Renewal
That the parties shall be entitled and have the option to renew the agreement at the end of
the Licensed Period. In the event, the Licensee intends to exercise its option to renew this
License Agreement; the Licensee shall give to the Licensor a notice in writing of its
intention so to renew this License Agreement. In the event the Licensee has exercised its
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option to renew this License agreement as specified herein above; the Licensor shall
execute a fresh License Agreement in favour of the Licensee at the cost and expenses of
the Licensee. All such further/fresh License Agreement and the renewed License
transaction shall be completed within a period of thirty (30) days from the date of expiry
of the Licensed Period under this License Agreement and in such interim period the
Licensee shall be allowed to continue to occupy the premises as the licensee thereof.
3. Escalation and Interest
3.1. That the License fee shall enhance by 10% on the last paid license fee after every
12 months.
3.2. That the licensor is entitled, in circumstances of delayed payments made by the
Licensee, to an interest of 18% p.a. payable on the delayed payment, where delayed
payments of Licensee fee, and/or the hereinafter agreed Security Deposit.
4. Security Deposit
4.1. That the Licensee has agreed to pay to the Licensor, as refundable interest free
security deposit for due observance and performance of the terms and conditions of
this License Agreement, a sum of Rs. 2,00,000/- (Rupees two lakhs Only), 50% of
which, viz. Rs. 1,00,000/- shall be paid at the execution of this agreement and the
remaining 50% viz. Rs. 1,00,000/- after a period of 2 months from the execution of
this agreement.
4.2. That the Security Deposit shall be refunded by the Licensor to the Licensee within
a period of 1 month after deducting any dues towards unpaid electricity, telephone,
and broadband connectivity bills etc. at the time of vacating the Premises on the
expiry of this License Agreement by efflux of time or on its sooner determination /
termination as provided herein.
5. Taxes and Outgoings
5.1 That all the applicable taxes, utility and other charges including but not limited to
Municipal taxes and other such levies, relating to use of the premises and other
taxes and levies in respect of the licensed premises will be paid by the Licensee
alone.
5.2. The electric charges and water charges for electric and water consumption in the
said licensed premises will be paid by the Licensee to the authorities concerned and
the Licensor will not be responsible for the same. For the sake of convenience, a
separate electric and water meter if possible, will be provided in the said premises.
6. Furniture and Fixtures
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6.1. That the Licensor has provided, for the quiet and peaceful enjoyment of the
Licensee, electronic items such as air-conditioner, water cooler, coffee machine and
inverter. The licensee hereby agrees to take proper maintenance and care of these
items and is solely responsible for the up-keep and repair of such items.
6.2. That apart from the aforementioned electronic items, the premises are not furnished,
and licensee is free to make the interiors as per their requirements, but such
alterations/additions of interiors shall not be subjected to any set off against the
Licensee fee.
7. Indemnification
The Licensee hereby indemnifies and agrees to keep indemnified the Licensor saved,
defended and harmless from and against all and any costs, expenses, charges, outgoings
damages and risks at all times arising out of any suit, eviction, action, claim or demand
whatsoever in relation to the titles of the Premises and all covenants, representations and
warranties made by the Licensee.
8. Stamp Duty and Registration
That the stamp duty registration charges and other miscellaneous expenses payable
regarding the License Agreement including but not limited to the stamp duty charges as
per section 36A of schedule I of Bombay Stamp Act, 1958 and registration charges as per
section 55 of Maharashtra Rent Control Act, 1999 shall be borne by the parties equally.
9. Amendment
No modifications or amendments of this License Agreement and no waiver of any of the

terms or conditions hereof, shall be valid or binding unless made in writing and duly
executed by both Parties.
10. Occupancy and Use of the Licensed Premises
10.1. That the licensed premises are given to the Licensee on personal basis and the
Licensee will not be entitled to transfer or assign the benefit of this agreement to
anybody else or will not be entitled to allow anybody else to occupy the premises
or any part thereof. Nothing in this agreement shall be deemed to grant a lease and
the licensee agrees and undertakes that no such contention shall be taken up by the
Licensee at any time.
10.2. That the Licensee shall not be deemed to be in the exclusive occupation of the
licensed premises and the Licensor will have the right to enter upon the premises at
any time during working hours to inspect the premises.
10.3. That the Licensee agrees that the use and occupancy of licensed premises shall be
for commercial purposes only, restricted to sale of mobile phones and accessories.
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The Licensee shall also be entitled to use all the common areas, facilities and
amenities appurtenances and incidental to the said Premises.
10.4. That all necessary and incidental permits and licenses including necessary permits,
consents and authorizations required by any authority to be procured by the
licensee, without which licensee shall not be permitted to commence commercial
operations from the licensed premises.
11. Lock in Period and Termination
11.1. That the Licensee has the option of terminating this agreement only after the expiry
of the first term of 24 months from the date of execution of this agreement and the
Licensor has option of terminating this agreement only after the expiry of the
Licensed Period viz. 48 months from the date of commencement of this License
Agreement (the said period is ‘Lock In Period’ for the parties). In case any party,
serves notice before the expiry of the said Lock In Period except for notice served
for default/ breach in terms and consequences thereof, the party serving the Notice,
should reimburse the other party, liquidated damages equivalent to 3 months of the
License fees calculated herein before.
11.2. That in the event of default by the Licensor in respect of any of the covenant
contained herein including misrepresentation, suppression of material records or
breach of any terms of this License Agreement, the License Agreement may be
terminated by the Licensee by giving 30 days written notice of the same to the
Licensor. However, in that event any material breach noticed by the Licensor will
be brought to the Licensee’s notice in writing in the prescribed manner by giving a
month notice to verify and rectify the breach. In case the Licensee fails to rectify
the breach within this period, the Licensor will be entitled to terminate the license
by giving one month’s notice to the Licensee in writing and the Licensee shall
vacate and hand over peaceful and vacant possession to the Licensor, failing which
the Licensee shall pay liquidated damages of Rs 20,000/- (Rupees twenty thousand
only) per day to the Licensor for use and/or mere occupation immediately after the
period of termination
12. Jurisdiction
That in any dispute relating to this License Agreement shall be subject to jurisdiction of
Courts at Pune, Maharashtra and This agreement shall be governed and construed as per
the laws in force in India.
13. Notice
That any notice required to be given hereunder shall deemed to have been given if sent by
registered post acknowledgement due at the addressees mentioned as the registered address
of the parties
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IN WITHNESS WHEREOF THE PARTIES HAVE PUT THEIR SIGNATURES ON

THESEPRESENTS OF THE DAY MONTH AND YEAR FIRST ABOVE WRITTEN,
SIGNED AND DELIVERED by the

Within named Licensor
ABC Pvt. Ltd Co.)
Through its authorized signatory
Mr. Anuj Jaitly
In the presence of :
1. Mrs. Arnab Goswami
2. Mr. Ashok Singhania
SIGNED AND DELIVERED by the

Within named Licensee
M/s. XYZ & Associates
Through its authorized signatory
Mr. Ritesh Saraswat
As per the resolution passed on 20th October, 2020
In the presence of:

1. Mr. Ranveer Singh
2. Mrs. Deepika Sharma
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ASSIGNMENT 7: ANTICIPATORY BAIL APPLICATION
IN THE COURT OF SESSION JUDGE, MUMBAI
Bail Application 125/2011

Misc. Application no 256/2013
IN THE MATTER OF:-
Mr. Gaurav Kapoor, Age 56,

Son of Mr. Rajendra Kapoor,
Dy. Inspector General of Police, Maharashtra State,
Resident at F-502, Samrat Ashok Society, Malabar Hill, Mumbai……………………Applicant
Versus
State of the Maharashtra………………………………………………………….……Respondent
AN APPLICATION FOR THE GRANT OF ANTICIPATORY BAIL U/S 438 OF THE

CRIMINAL PROCEDURE CODE, 1973.
The Humble petition of the petitioner above named most respectfully showeth.
1. That the Applicant is an honourable citizen of India, granted numerous Medals for his service to
the country, and is entitled to fundamental rights under the constitution of India. That the Applicant
is in a part of the Indian Police Services and is of the rank of Dy. Inspector General of Police,
Maharashtra State, and has put in 19 years of service, and during this time has been awarded a
number of medals including the President’s Police Medal for Distinguished Service, Police Medal
for Gallantry, etc.
2. That the CBI Special Case no. 211/2011 stands registered at the Mazgaon police station against
the applicant, Mr. Gaurav Kapoor, Dy. Inspector General of Police, Maharashtra State.
3. That the said FIR is false on at the face of it as no remote distance between the Applicant and the
crime can be constructed.
4. That after the FIR for the offences under section 121 and 124-A of IPC was filed against the well
-known gangster and criminal by the name of “Ahmed”, operating in Maharashtra, Gujarat,
Rajasthan and Delhi; one of the IPS batch mates of the Applicant, Superintendent of Police
Deepak Joshi of Rajasthan Cadre, approached the applicant seeking the prior permission and
assistance to take the gangster into custody.
5. That based on the representation made by SP Deepak Joshi, the Applicant directed Senior Police
Inspector, Detection Crime Branch, Mumbai City, the co-accused (hereinafter referred to as the
Accused) to render necessary assistance to the Rajasthan Police so as to apprehend Latif. At that
time the Applicant was posted as Additional Commissioner of Police, Crime Branch, Mumbai.
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6. That under the orders of the Applicant, Senior Police Inspector GSR provider necessary assistance
to a police team of the Rajasthan Police Force headed by SP Deepak Joshi. Subsequently on
23/10/2011 the team assisted by Senior Police Inspector GSR arrested Ahmed from Nanashree
Grand Hotel in Mumbai.
7. That the Rajasthan Police requested the Applicant and the co-accused to provide them necessary
permit and the means to take Ahmed to Jaipur for the purposes of investigation.
8. That the Applicant directed the co-accused to accompany the Rajasthan Police Party and
accordingly they left towards Jaipur. As the convoy of vehicles reached Bhilad check post at
Gujarat State, The Rajasthan Police asked Senior Police Inspector GSR to go back to Mumbai as
they had reached Gujarat and would take assistance from Gujarat Police. Hence the Accused
returned to Mumbai from there. Later it was learnt that Ahmed was killed in an encounter.
9. That from the above stated facts it is evident that the Applicant was not directly or indirectly a part
of any criminal conspiracy and even if there was conspiracy, the acts performed by the Applicant
were well within the ambit of his professional duty. Since what he did was in the pursuance to
carry out his official obligations, hence he cannot be held liable for his action.
10. That there is no prima facie case made out against the applicant, who has been falsely implicated
in this matter. Also that it was only on representations made by accused no. 3 that the Applicant
assisted in Latif’s arrest, on the basis of true and honest belief of the truth and accuracy of the
representation so made.
11. That the Applicant is a Gazetted officer serving as the Dy. Inspector General of police, taking him
into custody would act as a demeanor not only for him in his professional capacity but also to the
State Administration. Further, if the Applicant is taken into custody the furtherance of the State
Administrative machinery will come at a standing halt as the post held by the Applicant is an
important one.
12. That in light of judgment of the Supreme Court in Sidharam Mhetre v. State of Maharashtra
[(2011) 1 SCC 694], power under section 438 of the code of criminal procedure, 1973 should be
exercised to strike balance between a person’s liberty and fair investigation and arrest should be
the last option.
13. That it is in the interest of justice that the applicant is admitted to anticipatory bail in the event of
his arrest.
14. That since the offence is cognizable in nature the applicant undertakes to abide any of condition
imposed by this court for admitting the applicant to anticipatory bail.
15. That the applicant has not preferred any application before this Hon’ble court or any other court
of law with respect to the subject matter.
Prayer
The applicant therefore humbly prays -
1. In the event of arrest of the Applicant, in connection with FIR no. 134/2011, the applicant may be
released on Bail on such terms and conditions as this Hon’ble Court may deem fit and proper;
2. Pending the hearing and final disposal of the present application, interim reliefs may be granted
directing the respondent not to arrest the Applicant;
3. Any other reliefs as the nature and circumstances of the case may require, may kindly be passed.
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Application
Through
Place…
Counsel
Date…
VERIFICATION
I, Gaurav Kapoor, Dy. Inspector General of Police, Maharashtra State, Mumbai City, Son of
Rajendra Kapoor, resident of F-502, Samrat Ashok Society, Malabar Hill, Mumbai do hereby
solemnly affirm and swear as under:
(1) That I am the accused petitioner above named and I am fully acquainted with the facts
and circumstances of my case.
(2) That the Statements in Paragraphs 1 to 15 of this petition are true to my knowledge and
belief.
(3) I have signed this verification on this 9th day of October 2013.
Solemnly affirmed by the said Accused on the 9th day of October 2013, at the Courthouse at
Mazgaon.
Before me
Notary/Magistrate
(Signature of the Petitioner)
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ASSIGNMENT 8: REGULAR BAIL APPLICATION
IN THE COURT OF THE LD. ADDITIONAL CHIEF METROPOLITAN MAGISTRATE,
MAZGAON COURT, MUMBAI
AT MUMBAI
Bail Application No. 1923/2011
During Police Enquiry under Section 437, Cr. PC
Mr. Gaurav Kapoor, Age 56,

Son of Mr. Rajendra Kapoor,
Dy. Inspector General of Police, Maharashtra State,
Resident at F-502, Samrat Ashok Society, Malabar Hill, Mumbai……………………Applicant
Versus
The State of Maharashtra……………………………………………………………Respondent
AN APPLICATION FOR THE GRANT OF BAIL U/S 437 OF THE CRIMINAL

PROCEDURE CODE, 1973.
The applicant above named submits this application, praying to state as follows:
1. That the Applicant is an honourable citizen of India and entitled to fundamental rights
under the constitution of India, the applicant is a respectable, law abiding and a decorated
officer of the State with 23 years of service who has been falsely implicated in the above
case.
2. The Applicant is known for his good track record over 23 years of detecting complicated
cases and was awarded, amongst other medals the reward for Best Investigation Officer for
4 consecutive years since 2008.
3. The facts of the case are as under:
a) That Ahmed was a well-known gangster active in Rajasthan and had criminal cases
registered in Rajasthan, Gujarat and Delhi against him.
b) That as part of the alleged conspiracy to kill Ahmed in a fake encounter, a co-accused
(hereinafter referred to as Accused) approached the Applicant for assistance in arresting
Ahmed.
c) That the Applicant then activated his network of informers and on 23/10/2011, he
received information from his secret informers that Ahmed was staying in Nanashree
Grand Hotel, Carter Road, Bandra, Mumbai. Subsequently the applicant and his team
along with the Rajasthan Police arrested Ahmed.
d) That Ahmed was brought to Bandra Crime Unit and arrest formalities were completed
as evidenced by the station diary and the arrest Panchnama. Thereafter, he was taken
to Jaipur. The applicant was instructed by his senior to accompany the Rajasthan Police
Force.
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e) That the Bhilad Check Post in Gujarat, the Rajasthan Police Force told the Applicant
to return to Mumbai since they intended to take the assistance of the Gujarat Police
force.
f) That later it came to the knowledge of the Applicant that Ahmed had been killed in a
fake encounter on 24/10/2011 near Navsari, via the widespread publicity in the media.
g) That on a writ petition, the Supreme Court directed the CBI to conduct investigation.
The CBI arrested accused 1 to 8 and on public hue and cry, filed a supplementary
charge-sheet against the Applicant and the Accused before this Hon’ble Court on 11th
July, 2013.
h) That the applicant was arrested by the police on 15th July, 2013 in lieu of the
supplementary charge sheet filed against him before the Addl. C.M.M., Mazgaon
Court, Mumbai, on grounds of suspicion and sent up for remand to custody in the above
case.
4. That the applicant has been in custody for past two months but no evidence of substance
has been brought forth by the Respondent.
5. That applicant submits that he should please be granted bail as he is completely innocent
and that the charges levied against are baseless and concocted by the Respondent in
response to the pressures exerted by the political parties and the human rights
organizations.
6. That the applicant submits that he has had a good track record in his service and in case the
bail is not granted by this Hon’ble Court to the applicant, he shall suffer irreparable loss
and injury and also shall be subjected to heavy mental tension and excruciating tortures for
no fault on his part.
7. That no prima facie case is made out against the Applicant and as per Gurcharan Singh v.
Delhi Administration [AIR 1978 SC 179], the Supreme Court has stated that a prima facie
case must be made out, based on the investigation so far.
8. That the applicant respectfully submits that he will obey and abide by the orders and terms
and conditions as may be imposed by this Hon’ble Court, and he will not abscond, but on
the contrary extend full cooperation to the police and face the trial to vindicate his
innocence.
9. That the proper Court fees is paid herewith and the applicant is applicable prepared to
furnish the bail.
Prayer
The applicant therefore humbly prays that:
1. This Hon’ble Court be pleased to release the applicant on Bail in connection with MCR
no. 2345 of 2013 registered with the respondent, on any such terms and conditions as the
court deems fit and proper;
2. This Hon’ble court may be pleased to release the applicant on provisional cash bail and
further time of eight weeks may kindly be granted to furnish security ;
3. Any other just and equitable reliefs that this Hon’ble court may deem fit and proper may
be granted.
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[Mr. Gaurav Kapoor]

APPLICANT
Mumbai,
Dated 15th September 2013
ADVOCATE FOR THE APPLICANT
VERIFICATION
I, Mr. Gaurav Kapoor, Dy. Inspector General of Police, Maharashtra State, son of Mr. Rajendra
Kapoor, resident of F-502, Samrat Ashok Society, Malabar Hill, Mumbai do hereby solemnly
affirm and swear as under:
(1) That I am the accused petitioner above named and I am fully acquainted with the facts
and circumstances of my case.
(2) That the Statements in Paragraphs 1 to 9 of this petition are true to my knowledge and
belief.
(3) I have signed this verification on this 20th day of September 2013.
Solemnly affirmed by the said GSR on the 20th day of September 2013, at the Courthouse at
Mazgaon.
Before me
Notary/Magistrate
(Signature of the Petitioner)
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ASSIGNMENT 9: FRANCHISE AGREEMENT
Franchise Agreement
THIS AGREEMENT is made at Pune on the 25th day of October, 2020, By and Between:—
M/S ABC CONFECTIONERY, A PARTNERSHIP FIRM, HAVING ITS PRINCIPAL PLACE OF BUSINESS
AT PUNE, INDIA (HEREINAFTER CALLED “THE FRANCHISER”);
AND
Y PRIVATE LIMITED, A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 1956 AND
HAVING ITS PRINCIPAL PLACE OF BUSINESS AT PUNE, INDIA (HEREINAFTER CALLED “THE
FRANCHISEE”).
W H E R E A S:—
a) The Franchiser has been carrying on Confectionery Business under the brand name of “ABC
Confectionery” in India.
b) The Franchiser is the registered owner of trade mark/brand “ABC” and the substantive goodwill
and reputation attaching to the said business as referred to above.
c) Pursuant to the discussion between the parties, the Franchiser wishes to appoint the Franchisee
as the Franchisee and distributor for the sale of the products of the confectionary traded by
Franchiser under the brand name of ABC.
d) Franchisee is willing to act as the Franchisee and distributor of the products manufactured by
ABC Confectionary under the brand name of “ABC” in certain parts of Pune on the specific
terms and conditions appearing hereinafter.
IT IS HEREBY AGREED AND RECORDED AS FOLLOWS:—
TERRITORY:—
1. The Franchiser hereby appoints the Franchisee as its Franchisee to sell and promote the sale of
the products under the brand name of ABC in Pune.
2. The Relationship between Franchiser and Franchisee shall be solely that of the seller and buyer
and Franchisee shall have no right or authority to create or assume any obligations or
responsibility of any kind in the name of or on behalf of Franchiser. Franchisee shall not have
any right to represent Franchiser for any purpose whatsoever unless otherwise agreed to in
writing on a case-to-case basis.
The Franchiser has granted the Franchisee the license to use the trademark and logo of “ABC”
under this agreement.
3. The Franchisee at its own cost will advertise and popularize the product in its local territory
with the approval of Franchiser only to maintain uniformity in the advertisements.
4. The initial period of the present arrangement shall be for a period of 5 [Five] years commencing
from 1st November 2020 and expiring on 31st October 2025.
The Franchisee will pay to the Franchiser a One Time Franchise Fee of Rs. 5,000,000 [Rupees
Five Million Only]
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On the expiry of the initial period, the parties may periodically renew the franchise agreement for
a period of 3 [Three] years for which the franchisee will have to pay the franchiser a Periodic
Renewal Fee of Rs. 3,000,000 [Rupees Three Million Only].
5. The Franchisee will set up a new outlet at Viman Nagar. The Franchisee shall set up, decorate
and furnish the outlet at its own expenses as per the design and layout provided by the
Franchiser. Franchisee shall put up the ABC name board on its showroom as per the logo
provided by the Franchiser. The Franchiser shall also provide carry bags design advertisements
commercials and logos at the cost of Franchisee.
6. The goods will be exported from ABC Confectionary by the Franchiser only. The Franchisee
will place the orders at Franchiser’s principal place of business by making cash payment at the
wholesale price. The Franchiser may give goods worth Rs. 1,000,000 [Rupees One Million
Only] on credit for 60 days. In the event of delay the Franchisee shall pay compensation to the
Franchiser in the form of liquidated damages @ 1.5% per month on the outstanding amount till
payment.
7. PROHIBITION:
a) The franchisee will at no time make any claim or express any right, title and interest in the
ownership of the trademark and logo “ABC” as the same is exclusively owned by the
Franchiser.
b) The Franchisee will only store and sell the products

of the Franchiser only at the “ABC Confectionary” store located at Viman Nagar
shall not directly or indirectly deal with any other confectionary products.
c) The Franchisee has no rights of Sub-assignment or sub-franchsing under this agreement.
d) The Franchisee will not do any acts, deeds, things, etc., whereby the name and goodwill of the
Franchiser is disturbed and/or affected and/or degraded in any manner but will always promptly
and diligently take all steps and measures to protect and safeguard the Franchiser’s said
mark/name/brand “ABC” and Franchiser’s goodwill and reputation attached thereto.
8. Franchisee shall regularly furnish information and reports such as sales, inventory, market
conditions and any other available information to the Franchiser. Franchiser shall have the right
to inspect the showroom maintained for the Franchiser’s products by the Franchisee with
regards to the quality of the goods and services provided by the Franchisee as also shall have
right to inspect the relevant books and all other records maintained by the Franchisee.
9. Franchisee hereby acknowledges that any and all patents, utility models, trademarks, designs
and any other marks used or embodied in the products shall remain the sole property of the
Franchiser. Franchisee shall not use directly or indirectly in part or whole Franchiser’s patents,
utility models, trademarks, designs and any other marks except in the manner and to the extent
the Franchisee expressly consents in writing.
10. The Franchiser shall have the right to terminate the agreement in the event if there is any delay
in payment or the Franchisee does not maintain adequate stock or does not provide good after
sale services or does not meet the minimum stipulated turnover or if he sub-assigns or sub-
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franchises or if he is found to sell goods not purchased from the Franchiser or commits breach
of this agreement. This agreement shall terminate automatically if and when the Franchiser does
so.
11. In the event of termination:—
a) The Franchisee shall as early as possible but not later than 30 days from the date of termination,
directly or indirectly stop using word/name/mark “ABC” or any similar name resembling to
“ABC” as to be likely to cause confusion or deception in any manner including the using for its
trade name.
b) The Franchisee shall accordingly change the names of the outlet.
c) The Franchisee shall make forthwith payment of all the dues payable to the Franchiser as
recorded herein.
d) The Franchisee shall withdraw and deliver to the Franchiser all advertising material and other
documentation relating to the business, trade name/mark of the said goods.
12. In the event of any disputes and differences between the parties, the courts at Pune alone shall
have jurisdiction to try and entertain the same.
(FRANCHISER) (FRANCHISEE)
WITNESS:
1. Mrs. Sunita Dubey
2. Mr. Ajit Poval
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ASSIGNMENT 10: CONSUMER COMPLAINT

Consumer Complaint
BEFORE THE HON’BLE DISTRICT CONSUMER DISPUTES REDRESSAL FORUM, PUNE
AT PUNE
Complaint No. 478/ 2018
In the matter of:
Mr. Rakesh Thanekar

Age: 56 years, Occupation: Business,
R/o: B5-402, Camelot Society, Mhada Colony
Viman Nagar, Pune 411 014. ……………….………………………………………Complainant
V/s.
Zigma (India) Pvt. Ltd Co.

Registered office at 30th Cross Road, Dr. KB Hegdewar Road,
Mumbai - 400 017.
Head Office at 11, Kapa Street, South Korea
Represented through
Mr. Gurpreet Singh
Age: 49, Occupation: Business,
Address: as above ………………………………………………………………..Opposite Party
Complaint under section 12 of the Consumer Protection Act, 1986
Respectfully Showeth:
(1) Introduction
1.1 That the complainant is a Management and Motivational Trainer at Success Defined situated
Pune.
1.2 That the Opposite party is a company based in South Korea engaged in manufacture of laptops
and other electronic items.
1.3 That the Opposite Party has its regional registered Office at Mumbai and is represented through
Mr. Daksh Grover.
(2) Transaction
2.1 That the said laptop was bought by Mr. Shekhar Gupta from Delhi and the same was
manufactured by Zigma Ltd. on 1st of June, 2018.
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2.2 That the Complainant was gifted the laptop by his friend Mr. Shekhar Gupta for his personal
and non-commercial use on 8th of June, 2018.
2.3 That a sum of Rs. 47,000/- was paid as full and final price for the laptop, and the Cash-Memo
for the sale has been annexed as “Annexure A”.
(3) Defect
3.1 That after one week of use, the laptop became defective and failed to perform various
functions.
3.2 That the laptop started becoming overheated within one week and stopped responding and
shutting down automatically.
3.3 That the said fault caused a considerable loss to the Complainant, including loss of important
documents and other files relevant to the Complainant’s official work.
3.4 That the Complainant registered his grievance with the Service Call Centre of Zigma Ltd. and
was assured of expedite rectification/exchange of the faulty laptop.
3.5 That despite subsequent repeated calls to the Service Centre, there was no advancement in the
repair/exchange of the defective laptop.
3.6 That the Complainant served several notices annexed as “Annexure B” to the registered office
of the Opposite Party but received no reply or response from the same.
3.7 That the laptop carried a Warranty Card annexed as “Annexure C” claiming expedite servicing
in cases of minor defects and complete exchange/ restoration for material defects.
(4) Jurisdiction
4.1 That the Hon’ble Forum has jurisdiction to try the present complaint as the cause of action viz.
the defect in the laptop occurred at Pune.
4.2 That the Relief claimed in the complaint is within the pecuniary jurisdiction of the Hon’ble
Forum.
(5) Limitation
5.1 That the present complaint is being filed within the period prescribed under section 24Aofthe
Act
(6) Relief Claimed
It is most humbly prayed before this Hon’ble Forum that wherefore in the light of the
aforementioned circumstances, may this Forum be pleased to direct the Opposite Party to
replace the defective laptop with immediate effect and grant a compensation of Rs. 20,000/-
towards the loss caused to the complainant and Rs. 5,000/- as costs for the present complaint
and/or pass any order that it deems fit in the interest of Justice.
Place - Pune
Dated – 10th October 2018
Complainant
Through ~.
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(Advocate Nikita Jaitly)
Verification
I, Rakesh Thanekar, am the complainant above named do hereby solemnly verify that
the contents of my above complaint are true and correct to my knowledge, no part of it
is false and nothing material has been concealed therein.
Verified this 10th day of October 2018 at Pune.
Complainant
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ASSIGNMENT 11: JOINT VENTURE AGREEMENT
JOINT VENTURE AGREEMENT
THIS JOINT VENTURE AGREEMENT is made and entered into on this 1st day of November
2020 at Pune, India by and between:-
Shakti a company registered in India, under the Companies Act, 1956 and having its registered
office at UG-19, East Court, Viman Nagar, Pune , INDIA, (hereinafter referred to as the "Shakti")
which expression shall unless repugnant to the context include the Party of the First Part's
permitted successors and assigns
AND
Zukunaki a company incorporated under the the companies act, and having its Registered Office
at 59, Kawaki Street, Tokyo, Japan (hereinafter referred to as "Zukunaki") which expression shall,
unless repugnant to the context include the Party of the Second Part's permitted successors and
assigns.
WHEREAS the parties are desirous to set up a project to manufacture, distribute and sell
motorbikes in India
AND WHEREAS, each party understand that the creation under the laws of India of a limited
liability company jointly owned by the parties or their approved associates or nominees will be
instrumental to the accomplishment of their objective.
AND WHEREAS, the parties have mutually agreed to incorporate a new joint venture company
(“JVC”) with limited liability under which the project to manufacture motorbikes shall be taken
up.
AND WHEREAS, each party upon agreed ratios, terms and conditions is willing to provide the
required capital, technology, equipments and services for the manufacture of motorbikes in the
JVC so incorporated.
NOW THEREFORE, in consideration of the premises and mutual covenants herein contained,
Shakti and Zukunaki agree as follows:-
The parties shall undertake to incorporate and form a JVC to be registered in India under the
Companies Act, 2013 by the name of Shakti-Zukunaki Motorbikes The registered office of the
JVC will also be its headquarters and will be located at E5, Town Square, Viman Nagar, Pune.
Objective:
The main objective of the JVC shall be the manufacture and sale of motorbikes in India. THE JVC
shall take up any other objects as specified in the Memorandum of Association and Articles of
Association subject to applicable laws, only after having the consent of both the parties in writing.
Share Capital:
The initial authorised capital of the JVC will be Rs. 1,00,00,000/- divided into 10,00,000 equity
shares of Rs. 10 each. Shakti and Zukunaki have agreed to subscribe the share capital of the
proposed JVC in the proportion of 3:2, i.e., Shakti to take 30,000 equity shares of the aggregate
value of Rs. 3,00,000 and Zukunaki to take 20,000 equity shares of Rs.10/- each of the aggregate
value of Rs. 2,00,000/-.
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In addition to the initial subscription mentioned hereinabove, the parties agree to subscribe to the
further issue of share capital of the JVC as may be required in the proportion of 3 : 2, i.e., Shakti
60% and Zukunaki 40%.
Registration:
On signing this Agreement, the parties agree to take necessary action for the registration of the
Joint Venture Company within 30 (thirty) days hereafter.
Management:
The JVC shall be owned, operated and managed by the parties jointly in accordance with this
agreement and the Memorandum and Articles of Association.
The JVC shall have a Board of Directors composed initially of 5 directors, three of which shall be
of the choice of Shakti and two of whom shall be of the choice of Zukunaki.
The Chairman of the Board of Directors shall, for the first accounting period of the JVC, be one
of the members of the Board of Directors appointed by Shakti and for the duration of the 2nd
accounting period be one of the members appointed by Zukunaki, where after the parties shall
alternatively have the right to appoint the chairman during the subsequent accounting periods of
the company.
Parties shall ensure that the appointment and termination of directors is done with mutual consent.
case any director vacates his office due to any reason, including operation of law, the party which
had appointed such director shall have the right to fill in such vacancy by appointment of another
director to fill such vacancy and parties shall ensure that the Board fills such vacancies as provided
above.
All major policy matters of the JVC shall be decided by the Board of Directors of the JVC. The
day to day implementation of the projects and operations shall be controlled by the Managing
Director of the Company. In the meeting of Board of Directors, normally all matters should be
decided unanimously. However, in case of difference of opinion, matters shall be decided by a
majority of directors present at the meeting. However, following matters shall be decided only by
the affirmative vote of the holders of at least 3/4ths of the equity shares of the company or of, at
least one vote in favour from the group of directors appointed by Shakti and one vote in favour of
the directors appointed by Zukunaki, it being the intent of the parties that the following matters
will not be decided by the Board of Directors without the consent of at least one director appointed
by Shaktiand one director appointed by Zukunaki:
• Amendment of Articles of Association of the Company

• Increase of share capital of the Company
• Terms relating to engagement of Managing Director of the Company
• Declaration of dividends
• Merger of the Company
• Dissolution or winding up of the Company or disposition by the Company substantially
all of its assets
• Secrecy and Non-competition
Meetings:
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The Board of Directors shall meet regularly at least four times a year, i.e., once in each quarter.
At least 21 days prior notice shall be given to all directors of the Board whether residing in India
or otherwise. Each notice shall set out in sufficient detail, the Agenda of items to be transacted at
each meeting. A meeting may be held at shorter notice if it is agreed by all the directors in writing.
The quorum necessary for transacting any business of or taking any decision of the Board of
Directors shall consist of at least 4 members, of whom at least 2 shall have been those appointed
by Shakti and 2 by Zukunaki.
Confidentiality and Non- Compete:
It is agreed by the parties that during the term of this agreement they shall hold in confidence and
shall not disclose to any third party without mutual agreement, any technical know-how, advice,
statistical or other data or information that the parties or the Company may receive and possess.
Parties hereto agree and undertake during the term of this agreement not to compete with each
other in India directly or indirectly of the business of the JVC.
Records:
The JVC shall keep true and accurate accounting records of all operations and such records shall
be open for inspection to the parties or to their authorized representatives at all reasonable times.
Audit and financials:
The Auditors of the JVC shall be M/s ___________________ or such firm of Chartered
Accountants as may be agreed by the parties hereto.
The bankers of the JVC shall be _______________ , having its office at ___________________
or such other bank or banks as may be agreed to by the parties hereto.
The JVC may offer further shares in the share capital of the Company to the public only by written
agreement of each of the parties hereto.
Parties shall not pledge, hypothecate or encumber their shares in the JVC except with the prior
consent in writing of the other party.
Term:
The terms of this Agreement shall remain in force as long as the parties hold the shares in the JVC.
In case any party hereto transfers all or any shares to any other party, then this Agreement shall be
deemed to have been terminated.
Arbitration and governing law:
In the event of any dispute arising between the parties in respect of their duties, rights and
obligations under or arising out of this Agreement, such disputes shall be resolved by arbitration
to be held in accordance with the Indian Arbitration Act.
This Agreement will be governed by and construed in accordance with Indian law.
IN WITNESS WHEREOF THE PARTIES hereto has put their respective hands and seal the day
and the year first hereinabove written.
SIGNED, SEALED AND DELIVERED
Shakti
Through the hands of Mr. Arjun Kanoongo
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In the presence of Mr. Sudhish Mishra
Zukunaki
Through the hands of Mr. Pawan Singh
In the presence of Mr. Rakesh Verma
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ASSIGNMENT 12: PETITION FOR PUBLIC INTEREST LITIGATION
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
PUBLIC INTEREST LITIGATION NO. 343 OF 2020
In the matter of Articles 14, 15(3) and 21 of the Constitution of India;
And
In the matter of the Convention on Elimination of all forms of Discrimination against Women Act,
1989;
And
In the matter of the Protection of Women from Domestic Violence Act, 2005
And
In the matter of The Vienna Conference, 1994;
And
In the matter of The Beijing Declaration and The Platform for Action 1995;
Priya Tiwari
D/o Vijay Tiwari
Founder of NGO ‘Apna Haq’
Having its registered office at 46, Colaba Causeway,
Mumbai- 400041………………………………………………………………………….Petitoner
V.
1. The State of Maharashtra, through the Chief Secretary having his office at Mantralaya,
Mumbai – 400032……………………………………………………………....Respondent No. 1
2. The Municipal Corporation of Greater Mumbai, having its office at Municipal Head Office,
Mahapalika Marg, Mumbai – 400001………………………………………….Respondent No. 2
3. The Revenue Officer, having his office at Revenue Head Office, Mahapalika Marg,
Mumbai – 400001………………………………………….…………………..Respondent No. 3
To,
The Hon’ble Chief Justice and his companion Judges of the High Court.
MOST RESPECTFULLY SHOWETH:
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1. The Petitioner is an Indian Citizen, lawyer and founder of an NGO named ‘Apna Haq’ with
a registered office at 46, Colaba Causeway, Mumbai near Naturals ice cream parlour. The
Petitioner has 190 members in his NGO currently. Respondent No.1 is the State of
Maharashtra. Respondent No.2 is the Municipal Corporation of Greater Mumbai
(“MCGM”), a statutory authority incorporated under the provisions of the Bombay
Municipal Corporation Act, 1888. Respondent No.3 is the Revenue Officer for Greater
Mumbai who exercises powers and functions under various statutes.
2. In this Petition filed in public interest, the Petitioner is complaining of the inaction on the
part of the Respondents for appointing full time protection officers u/s 8 of the Domestic
Violence Act, 2005 to provide assistance to the aggrieved woman with respect to the
medical examination, facilitating legal aid, safe shelter, for implementation of court orders
etc. However, the State of Maharashtra has given the additional responsibility to other
revenue officers who are already burdened with their work and unable to do the needful to
aggrieved women.
3. The facts giving rise to this Petition are as under:
i. The Petitioner is the founder of an NGO named ‘Apna Haq’ which actively fights for
various causes including human rights, women’s rights, violence against children and
women, child rights, human trafficking, child trafficking, slave trade, body trade etc.
ii. In the past few months, while on a project, the Petitioner for the first time witnessed
the situation as it was on 15th November 2020. Several Women were aggrieved with
respect to the medical examination and check-up, facilitating legal aid, safe shelter,
clothing, food and water, for implementation of court orders etc.
iii. The Respondent No.1 has not appointed a full-time protection officer as required by
u/s 8 of the Domestic Violence Act, 2005.
iv. These women, who previously scared of the results of standing up for their rights, have
finally come out in the open to voice their opinions.
v. However, the failure on the part of Respondent No.1 has resulted in gross violation of
the fundamental rights of these women. Being no officer appointed in charge, justice is
not only delayed, it’s denied.
vi. Further Respondent No.1 has given the additional responsibility to other revenue
officers who are already burdened with their work and unable to do the needful to
aggrieved women.
4. The Petitioner submits that their right to protection against violence at the place of home
must be safeguarded by the State, the same has been enshrined in Article 14, 15(3) and 21
of the Constitution of India. This is the well settled legal position. As such it is the duty
of the various authorities and functionaries of the State to ensure that the Petitioner and
other persons realize this right, which is the most fundamental of rights that should be
accorded to every woman of the State.
5. The Petitioner submits that apart from the Constitution there are various statutory
provisions enacted by the Parliament as well as the State Legislature to ensure that the right
to protection of women is realized by every resident in India. Some of these statutory
provisions are set out below:-
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i. Convention on Elimination of all forms of Discrimination against Women, 1989:
Resolutions 1325 and 1820, and CEDAW share the following agenda on women's human
rights and gender equality:
a. Demand women’s participation in decision-making at all levels

b. Rejection of violence against women as it impedes the advancement of women and
maintains their subordinate status
c. Equality of women and men under the law; protection of women and girls through
the rule of law
d. Demand security forces and systems to protect women and girls from gender-based
violence
ii. The Beijing Declaration and Platform for Action, 1995:
Acknowledging the voices of all women everywhere and taking note of the diversity of
women and their roles and circumstances, honouring the women who paved the way and
inspired by the hope present in the world's youth, Recognize that the status of women has
advanced in some important respects in the past decade but that progress has been uneven,
inequalities between women and men have persisted and major obstacles remain, with
serious consequences for the well-being of all people.
iii. The Vienna Conference, 1994 :
Expansive view of human rights, with efforts made to highlight women's rights, indigenous
peoples' rights, minority rights, and more in the context of universal political and economic
rights. Women's rights in particular gained a strong and effective presence at the
conference. The key result of the World Conference on Human Rights was the Vienna
Declaration and Programme of Action.
iv. The Protection of Women from Domestic Violence Act, 2005:
The draft Act provides for appointment of Protection Officers and NGOs to provide
assistance to the woman w.r.t medical examination, legal aid, safe shelter, etc.
Appointment of Protection Officers.
In the circumstances aforesaid the Petitioner says and submits that the inaction/failure on the part
of the Respondents to appoint a full time protection officer is illegal and unconstitutional on the
following amongst other grounds which are without prejudice to one another:-
GROUNDS
a. The Petitioner submits that by virtue of the various provisions of the Constitution of
India and other statutes, conventions referred to above the Petitioners have the right to
protection against domestic violence.
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b. The Petitioner submits that by virtue of the provisions of The Protection of Women
from Domestic Violence the petitioners have the right to appointment of a full time
protection officer.
c. The Petitioner says that the Respondents have a statutory duty to ensure that the life
and dignity of all women within the State must be preserved. This includes not only the
physical aspect but also any form of mental violence that may be inflicted upon a
woman.
d. The Petitioners say that the Respondents have a duty to appoint a full time protection
officer to ensure the safety and dignity of all women
6. In the circumstances, the Petitioner says and submits that this Hon’ble Court be pleased to
issue a writ of Mandamus or a writ in the nature of Mandamus or any other appropriate
Writ, Order, or Direction under Article 226 of the Constitution of India against the
Respondents, directing the Respondents, their subordinate officers, servants and agents to
take all such steps and actions as may be necessary.
i. to assist the aggrieved person in making a compliant under the Act. If the aggrieved
person so desires;
ii. to assist the aggrieved person and any child in obtaining medical aid at a medical
facility including providing transportation to get the medical facility;
iii. to provide her information on the rights of aggrieved persons under the Act.
iv. to prepare a “Safety - action Plan” including measures to prevent further domestic
violence to the aggrieved person after making an assessment of the dangers involved
in the situation and on an application being moved under section 12;
v. to provide legal aid to the aggrieved person, through the State Legal Aid Services
Authority;
vi. to assist in obtaining transportation for the aggrieved person and any child to the
shelter;
vii. to provide all possible assistance to the aggrieved person and the children to ensure that
the aggrieved person is not victimized or pressurized as a consequence of reporting the
incidence of domestic violence;
7. The Petitioners say and submit that pending the hearing and final disposal of the Petition,
this Hon’ble Court be pleased to issue a mandatory Order and Injunction ordering and
directing the Respondents, their servants and/or agents to take all such steps and actions as
may be necessary.
8. The Petitioners submit that unless and until the ad-interim and interim reliefs in the above
terms are granted, grave and irreparable harm, loss and injury will be caused to the
Petitioner.
9. The Petitioner has no other alternative remedy. In these circumstances, the remedy by way
of a writ and orders prayed for herein will be complete and effective.
10. The Petitioner has not filed any other Petition relating to the subject matter of the present
Petition either in this Hon’ble Court or in any other High Court or in the Supreme Court.
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11. The Respondents have their offices in Mumbai. The said NGO is located in Mumbai. The
entire cause of action has arisen in Mumbai. This Hon’ble Court, therefore, has jurisdiction
to entertain and try this Petition.
12. The Petitioners have paid the fixed court fees of Rs.1000/- on this Petition.
THE PETITIONERS, THEREFORE PRAY:
a) This Hon’ble Court be pleased to issue a Writ of Mandamus or a Writ in the nature of
Mandamus or any other appropriate Writ, Order, or Direction under Article 226 of the Constitution
of India against the Respondents, directing the Respondents and their subordinate officers, servants
and agents to adopt and take up necessary steps as this Hon’ble Court deems fit.
b) Pending the hearing and final disposal of the Petition, this Hon’ble Court be pleased to
issue a mandatory Order and Injunction ordering and directing the Respondents their servants
and/or agents to take all such steps and actions as may be necessary.
c) for ad-interim reliefs in terms of prayer clause (b);
d) Costs of the Petition be provided for;
e) For such further and other Writs, Orders and directions under Article 226 of the
Constitution of India as this Hon’ble Court may deem fit and proper.
DATE: 25th day of November, 2020
PLACE: MUMBAI
FOR APNA HAQ. (NGO)
FOUNDER
ADVOCATE FOR THE PETITIONER
VERIFICATION
I. Priya Tiwari the above-named deponent do hereby verify at Mumbai at this Twenty Fifth
day of November 2020 that the contents of paragraphs 1 to 2 above of the affidavit are true to my
personal knowledge and belief and that I have not suppressed any material fact.
DEPONENT
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ASSIGNMENT 13: APPEAL TO HIGH COURT
IN THE HIGH COURT OF BOMBAY AT MUMBAI
CRIMINAL APPEAL No. 674 OF 2020
UNDER SECTION 374(2), Code of Criminal Procedure, 1973
Viren, Rajesh, Amit, Deepak and Raju……………………..…………………………. Appellants
VERSUS
State of Maharashtra…………………………………………………………………..Respondent
APPEAL AGAINST ORDER OF THE LEARNED

SESSION’S JUDGE 1459 of 2020 in
Sessions Trial No. 6166 of 2020 State of Maharashtra v. Viren and Ors.
To,
The Hon’ble Chief Justice and his companion Judges of High Court. The Appellants most
respectfully submit against the aforesaid order of the learned Sessions Judge convicting the
accused under section 392 of Indian Penal Code 1860, the statement of appeal and grounds thereof
as follows:
1. That the appeal aforesaid arises out of the impugned judgement and order passed by the
sessions court on 01.09.2020 and the facts leading up to this appeal are as follows:
2. That appellants in this appeal are the accused No.1 being Viren, Accused No.2 Rajesh,
Accused No. 3 Amit, Accused No. Deepak and Accused No. 5 Raju who are alleged to be
present at the premises of Rakshandha Jewellery Store on the night of 20th May, 2020 when
there occurred a scene of robbery in the store.
3. The case of the accused persons are that they were not involved in the robbery at the
Rakshandha Jewellery store and this entire sequence of events was planned and executed
by some rivals of the accused persons as they were told by one person, Aditya Mohta to
come opposite to the store urgently and upon doing so they saw that the store glass was
broken and gold ornaments were missing hence they began to run away from the scene.
4. The call logs and relevant text and WhatsApp messages have been attached herewith as
Exhibit A.
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5. The Sessions judge without appreciating the same held the accused persons guilty under
section 392 of Indian Penal Code 1860 and sentenced them to imprisonment. Hence, this
appeal.
Grounds of Appeal
(1) The judgement or order of the learned Sessions Judge is patently wrong and the evidence
attached herewith proves otherwise.
(2) The conviction and sentence are not maintainable in law and facts on record as per plaint
attached as Exhibit B.
PRAYER
It is most respectfully prayed that the appeal may be allowed and the conviction and
sentence passed against the accused persons may be set aside and the accused be acquitted.
Sd/-
Place: Pune Appellants
Dated: 08.10.2020 Sd/-
Counsel for Appellant
VERIFICATION
(Of all the appellants)
We, the present appellants, do hereby state on solemn affirmation that the contents of this
petition in paragraphs 1 and 5 are true and correct to the best of our knowledge and beliefs,
and so we have signed hereunder.
Sd/-
Appellants
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ASSIGNMENT 14: WRIT OF HABEAS CORPUS
BEFORE THE HON’BLE HIGH COURT OF BOMBAY,
AT MUMBAI
Original Writ Jurisdiction
W.P. No. _____ of 2020
Mr. Sunil Mishra
Aged-27 years
S/o Mr. Vinod Mishra
R/o 120B/420, CPC Royale, Pune……………………………………. ………………..Petitioner
V.
1. The State of Maharashtra,
through the Principal Secretary,
Department of Home, Govt. of Maharashtra
Mumbai, Maharashtra
2. The Superintendent of Police,
Mazgaon, Mumbai
3. The Station House Officer,
Nagpada Police Station, Mazgaon, Mumbai
4. The Senior Superintendent of Police,
Nagpada Police Station, Mazgaon, Mumbai
5. Station House Officer,
CPC Royale Police Station, Pune
6. Mr. Sandeep Bansal,
Aged-59 years
S/o Mr. Ajeet Bansal
R/o 45, Colaba Street, Mumbai
7. Mrs. Shobha Bansal,
Aged-52 years
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W/o Mr. Ajeet Bansal
R/o 45, Colaba Street, Mumbai
8. Mrs. Ruchika Mishra
Aged 22 years
W/o Mr. Sunil Mishra ...………………………………………………….. Respondents
Writ Petition under Article 226 of the Constitution of India, 1950
The humble petition of the above-named Petitioner most respectfully showeth:
1. That the petitioner is a Civil Engineer by profession and is currently employed by the
Larsen & Turbo.
2. That the petitioner got legally married to the Respondent No. 8 under Special Marriage
Act, 1954 at Mumbai.
3. That this petition is not directed against any particular order. The petitioner filing this writ
Petition for issuing writ of Habeas Corpus directing the Respondents 1 to 7 to produce
before this Hon’ble Court, his wife, the respondent No. 8, Mrs. Ruchika Mishra, who has
been illegally detained by the Respondent No. 6 and 7 at Pune and have not been allowed
the company of his wife with whom he is legally wedded, nor have they allowed the
petitioner to meet his wife despite repeated requests.
4. That the petitioner has reported the matter to the police to Respondent No. 3 but no
substantial advancement was made by him.
5. That the petitioner also approached the higher police authorities Respondent No. 2 and
Respondent No. 4 but unfortunately, there was neither any concrete action adopted by them
nor any significant efforts to bring back his illegally detained wife.
6. Facts of the case:
That the petitioner most humbly submits as under:
a. The petitioner is a resident of Pune. He was married to Respondent No. 8 and the
marriage was registered under the Special Marriage Act at Mumbai.
b. The marriage certificate with respect to the registration of marriage between the
Petitioner and Respondent No. 8 was issued by the Marriage Officer, a copy of
which is enclosed as Annexure A. The marriage was performed without any dowry
or exchange of gifts.
c. The couple was residing happily and peacefully at Pune and there was no dispute
between the couple.
d. On invitation by the Respondent No. 6 and 7, the petitioner and Respondent No. 8
visited their residence in Colaba Street, Mumbai. During the visit the petitioner and
Respondent No. 8 stayed along with his in-laws.
e. That throughout a day the petitioner was taken at various places in Mumbai and at
the evening when the petitioner tried to inquire about his wife he was beaten and
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threatened ‘to forget her and not to return to ask about her otherwise he shall face
dire consequences.’
f. That the petitioner tried several times to contact his wife, but he received
threatening replies from Respondent No. 6 and 7.
g. That the petitioner, thereafter approached Respondent No. 3 to lodge a complaint
against his illegally detained wife but to no avail.
h. That subsequently, the petitioner also approached higher authorities Respondent
No. 2 and 4 but no significant advancement was made by them either.
i. From the aforementioned facts it is evident that Respondents No. 6 and 7 have
illegally detained Respondent No. 8 and have threatened the petitioner for life.
j. That the petitioner was left with no alternative but to approach this Hon’ble Court
for issuing a writ of habeas corpus directing the Respondents No. 3, 6 and 7 to
produce Respondent No. 8 before this Hon’ble Court, and she be allowed to stay
with the petitioner and appropriate action against Respondent No. 6 and 7 be
directed to be initiated in accordance with law for their illegal act of detaining his
wife.
7. That the petitioner declares that there is no delay in filing this petition which requires any
explanation.
8. Grounds
a. That the act of Respondent No. 6 and 7 in detaining the wife of the petitioner and
not permitting them to come back is illegal.
b. That inaction on the part of police authorities Respondents No. 2, 3 and 4 on the
report of the petitioner is per se illegal
c. That for the repeated requests of the petitioner to the Respondents 6 and 7 to send
his wife to Pune and allow him to meet them did not work and the petitioner was
compelled on account of repeated threats to life of the petitioner and of sending his
wife out of India. The Respondents 6 and 7 have thus committed an offence
punishable under the Indian Penal Code, 1860.
9. Reliefs
a. The Hon’ble High Court may be pleased to issue a writ of habeas corpus directing
respondents 2 to 7 to immediately produce the respondent No. 8 Smt. Ruchika
Mishra, wife of the petitioner before this Hon’ble Court.
b. The Hon’ble High Court may be pleased to issue appropriate writ or order directing
respondent No.8 to accompany the petitioner and the respondent authorities be
directed to give protection to them.
c. The Hon’ble High Court may be further pleased to direct the respondent authorities
to take appropriate action against respondents 6 and 7 for their illegal act of
detaining the wife of the petitioner and not permitting her to come back and for
their act of not permitting the petitioner to meet his wife
d. Any other order or direction deemed just and proper in the facts and circumstances
of the case may also be passed, with cost of these proceedings.
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10. That the petitioner declares that no other petition or application is pending before any
authority or Hon’ble Court in respect of the subject matter of this petition.
11. The petitioner further declares that he has no other alternative efficacious remedy available
to him except approaching this Court.
12. Enclosures are annaexed as per index
13. An affidavit in support of the petition is filed herewith.
Place: Pune
Dated: 08.10.2020
COUNSEL FOR PETITIONER
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ASSIGNMENT 15: SPECIAL LEAVE PETITION
IN THE SUPREME COURT OF INDIA
SPECIAL LEAVE PETITION (CRIMINAL) OF 2020
(UNDER ARTICLE 136 OF THE CONSTITUTION)
(Arising out of the impugned judgment and final order dated 09340 passed by the Honourable
High Court of Judicature at Mumbai in Misc. Crl. C No. 3017 of 2020)
IN THE MATTER OF:
Mr. X ...Petitioner
Versus
State of Maharashtra and Ors. …Respondent
THE HON’BLE THE CHIEF JUSTICE OF INDIA AND HIS COMPANION JUDGES OF THE
SUPREME COURT OF INDIA
THE HUMBLE APPLICATION OF THE
APPLICANT/PETITIONER ABOVE NAMED
1. MOST RESPECTFULLY SHOWETH:-
By this Petition under Art. 136 of the Constitution of India Special Leave to Appeal is sought
against the final judgment and order dated 15.09.2020 passed by the Hon’ble Court of Judicature
at Mumbai in Miscellaneous Criminal Case No. 3017 of 2020 wherein the appeal filed by the
applicant was dismissed and the accused was convicted for the murder of one Mr. Raghavan
Kumar, under S.300 and 302 of IPC and causing grievous hurt to one Mr. Ramanna, under S. 326
of IPC.
2. Brief Facts for filling of the present Petition are as under:

1. The petitioner Mr. X is a resident of Mumbai, who runs a small enterprise in Dadar.
2. The petitioner, Accused No.3, is an old friend of Mr. Y, the Accused No.2, and an
acquaintance of Mr. Z, Accused No. 1.
3. The petitioner comes from a dignified middle class family and has made a decent name
for himself in the locality where he works. Mr. Z, however, is the son of a local political
leader who has considerable influence in the city. Mr. Y is Mr. Z’s cousin brother who
became friends with the petitioner in school.
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4. The deceased Mr. Raghavan Kumar and Mr. Ramanna were partners in a flourishing
textile business and had sought to attract revenue by offering Mr. Z partnership. Mr. Z
being inexperienced struck a bargain without any due diligence on his part.
5. The partners having exploited Mr. Z, did not hold their end of the bargain.
6. The petitioner on the night of the alleged incident received a phone call from Mr. Y
requesting the former to meet him at Mr. Z’s house.
7. The petitioner, having so obliged, reached Mr. Z’s residence, whereupon, he found the
dead body of Mr. Raghavan Kumar and saw Mr. Y gagging Mr. Ramanna and an
enraged Mr. Z stabbing him in his stomach and shoulder.
8. In the belief that Mr. Lohit had died, the two siblings handed the peritioner the knife
used for the murder and stabbing the other and asked him to help burn the bodies and
other evidences.
9. At the same time, police learnt about the events from a local informant.
10. While the petitioner was stunned by the events and all of a sudden, he heard the police
barge in through the door. Having panicked the petitioner ran with the knife in his
hands.
11. The police apprehended all the accused and trial was initiated and evidence framing
the petitioner were brought forward.
12. Accused No. 1 and 2, with the help of the former’s father’s influence were able to
manipulate evidence and create alibi.
13. The police investigation was conducted in a faulty manner
14. The High Court on the basis of insufficient evidence acquitted the two accused and
convicted the petitioner on circumstantial grounds.
15. It was argued by the petitioner that the witness’ that testified in favour of Accused 1
& 2 acquittal are parties that are highly interested in the present case and their
testimony should not be relied upon.
3. Ground
A. Because the applicant is innocent and has been falsely implicated. The police and others
have been systematically harassing him and his family.
B. Because the entire case is misrepresented and is based on circumstantial evidence, of
the petitioner holding the knife, the petitioner should be acquitted as there was no
motive in the present instance. Even though motive is not important, however, it has
been held in Wakkar v. State of U.P (2011) 3 SCC 306, that in cases based on
circumstantial evidence motive is important.
C. Because the testimonies that secured the acquittal of the Accused 1&2 were given by
parties that have a vested interest in the case as their concerns shall be affected if the
said accused were convicted. One of the witness being the father of Mr. Z, who is a
political leader, his reputation will be severely affected if his son were to be convicted.
D. Because grant of the petition is the privilege of the Hon’ble Court, it is asserted that
there exists substantial question of law in the above case.
4. Prayer
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The Petitioner, therefore, most respectfully prays that this Hon’ble Court may be pleased
to:
a. grant special leave to appeal to the Petitioner against the Final Judgment and order
dated passed by the Hon’ble High Court of Judicature at Mumbai in Misc. Cri. C 3017
of 2020.
b. pass any such order or further order as this Hon’ble Court may deem fit in the facts and
circumstances of this case.
AND FOR THIS ACT OF KINDNESS THE PETITIONER AS IN DUTY BOUND SHALL
EVER PRAY
FILED BY:
Drawn by:
Drawn on:
Filed on:
Advocate for the Petitioner
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ASSIGNMENT 16: PUBLIC NOTICE
Public Notice
TAKE NOTICE THAT the Vendors Mr. Ratlesh Kumar and Mr. Naresh Kumar from Pune,
Maharashtra are intending to sell and our client is intending to purchase the property described in
the Schedule hereto below free from all encumbrances.
Any person having any claim or right in respect of the said property by way of inheritance, share,
sale, mortgage, lease, lien, licence, gift, possession or encumbrance howsoever or otherwise is
hereby required to intimate to the undersigned within 14 days from the date of publication of this
notice of his such claim, if any, with all supporting documents failing which the transaction shall
be completed without reference to such claim and the claims, if any, of such person shall be treated
as waived and not binding on our clients.
THE SCHEDULE ABOVE REFERRED TO:
Open piece of non- agricultural land Gate No. 12/2 admeasuring 4000 sq. ft. located at Koregaon
Park, Pune, Maharashtra and bounded as follows:
On or towards East: Nagar Road
On or towards West: Kalyani Nagar
On or towards South: Gate no 12, Orchid Royale
On or towards North: Gate no. 1, Sahara Golf City
Dated this 25th day of November, 2020.
Advocates for the Intending Purchaser,
Mr. Anannd Rao
C-504, Mumbai Heights
Near Marine Drive, Mumbai
Maharashtra - 421201
Dated: 25.11.2020
Place: Pune
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ASSIGNMENT 17: POWER OF ATTORNEY
Power of Attorney
TO ALL TO WHOM THESE PRESENTS SHALL COME: I, Manish Shah Shah of P-143.
Mukti House, Tollygunge, Kolkata - 700056, Indian Inhabitant, SEND GREETINGS:
W H E R E A S—
(a) I am desirous of appointing Mr. Bhavesh Shah of New Delhi, Indian Inhabitant
(hereinafter called “the Attorney”), who is a fit and proper person to act for me and manage and
look after the matter of the disputed joint property, that is, our ancestral home bearing address, D-
16, Lajpat Nagar II, New Delhi, 110012, in any dispute contested by any other relatives in civil
suit no. 26 0f 2020 pending before the High Court of Delhi (hereinafter called “the Suit”), which
the Attorney has consented to do.
NOW KNOW YE ALL AND THESE PRESENTS WITNESSETH that I do hereby

nominate, constitute and appoint Mr. Bhavesh Shah of New Delhi, Inhabitant to be my true and
lawful attorney to act for me and in my name and do all acts, deeds and things in connection with
the Suit by and/or against me that is to say;
1. To sign, declare and verify Plaints, Statement of Claims, Written Statements, Defences,
Counter-Claims, Appeals, Reviews, Applications, Affidavits, Authorities, Vakalatnamas
and writings of every description as may be necessary to be signed, verified and executed
for the purpose of the Suit before the High Court of Delhi and to do all acts and
appearances and applications in the Suit brought or commenced by Mr. Bhilai Shah and
to defend, answer or oppose the same or suffer Judgments or Decrees to be passed taken
or pronounced or to consent to the same in the Proceedings and to execute such Decrees
or orders as the said Attorney shall be advised or think proper.
2. To appoint and engage Advocates, Solicitors, Counsel in the Suit and to agree to pay and
pay their fees and cost.
3. To do all necessary acts, deeds, steps etc. to properly prosecute and/or defend (as the case
may be) the Suit including giving of evidence on my behalf.
4. To apply for inspection and inspect documents and records, to obtain copies of documents
and papers.
5. To compromise the Suit in such manner as the said attorney shall think fit.
6. To do generally all other acts and things for the conduct of the said suit as I could have
done the same if I were personally present.
7. And for removing any doubt as to the true meaning of these presents or as to the
construction or application of the powers, authorities and discretion hereby conferred, I
do hereby declare that the powers, authorities and discretions hereby conferred shall not
in any case be deemed to be limited to the transactions and matters as are herein expressly
mentioned but the same shall in all cases extend to any other matters or transactions not
herein precisely mentioned or defined and which may be exercised in the course of all
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acts done to secure my interest in the Suit.
8. And I do hereby declare that the powers and authorities and discretion hereby conferred
upon the Attorney shall be available for exercise by him both during my absence as also
at the same time and place along with myself.
AND I DO HEREBY for myself, my heirs, executors and administrators agree to ratify and
confirm all and whatsoever my said Attorney shall or purport to do or cause to be done by virtue
of these presents.
IN WITNESS WHEREOF I have hereunto set my hand at this twenty-first day of October
2020.
SIGNED AND DELIVERED by the )
Within named _______________________ )
in the presence of ……………… )
Before me,
Identified by me; Notary
Advocate
Accepted by me;
(Attorney)
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ASSIGNMENT 18: SPECIAL POWER OF ATTORNEY
SPECIFIC POWER OF ATTORNEY
THIS POWER OF ATTORNEY is made on 14th day of October, 2020 by (1) Mr. Aditya and (2)
Smt. Radhika, resident of B-202, Rohan Mithila, Viman Nagar, Pune.
WHEREAS by this Power of Attorney we do hereby nominate, constitute and appoint Mr.
Dhanesh, who is a software engineer by profession, as our Constituted Attorney to do the following
acts, deeds and things:
1. To pay the bills and any other charges due on the property (hereinafter referred to as “the
said property”), fully described in the Schedule written hereunder.
2. To obtain the No-Objection Certificate from the Society in order to make a legal sale of
the property.
3. To appoint, engage on our behalf Advocates or Solicitors whenever our said Attorney shall
think proper to do so and to discharge and/or terminate their appointments.
4. To execute a sale deed with respect to the said property to any purchaser or purchasers at
such price which my said Attorney in his absolute discretion thinks proper, to agree upon
and to enter into any agreement or agreements for such sale or sales and/or to cancel or
repudiate the same and to negotiate the terms for the same.
5. To receive from the purchaser or purchasers any earnest money and also the balance of
purchase money or consideration and to give good valid receipt and discharge for the same.
6. Upon such receipt as aforesaid in our names and as our acts and deeds, to sign and execute
any conveyance or conveyances of the said property in favour of the purchaser or
purchasers or his/their nominee or assignee.
7. To sign and execute all other deeds, instruments and assurances which he shall consider
necessary and to enter into such covenants as our said Attorney may consider necessary for
fully and effectually conveying the said property as we could do ourselves, if present.
8. To present any such conveyance or conveyances for registration, to admit execution and
receipt of consideration before the Sub-Registrar/ District Registrar or Registrar having
authority for conveying the said property to the said purchaser or purchasers as fully and
effectually in all respects as we could do the same.
9. And we do hereby agree to ratify, confirm all and whatever other act or acts our said
Attorney shall lawfully do, execute or perform or cause to be done, executed or performed
in connection with the sale of the said property under and by virtue of these presents and
all acts, deeds and things lawfully and bona fide done by our said Attorney shall be
construed as acts, deeds and things done by us to all intents and purposes as if we were
personally present notwithstanding the fact that no special power in that behalf is contained
in these presents.
SCHEDULE OF PROPERTY ABOVE REFERRED TO:
ALL THAT the piece or parcel of land hereditaments and premises measuring more or less
3000 square feet with the existing building and structure comprised in enter address and
delineated in the Map or Plan annexed hereto and bordered therein red and butted and
bounded in the manner following, that is to say:
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ON THE NORTH: By Scheme Plot No. 098
ON THE SOUTH: By Scheme Plot No. 130
ON THE EAST: Main Gate, Camelot Royale
ON THE WEST: Society Park
IN WITNESS WHEREOF we have hereunto set and subscribed our respective hands and
seals this on the 14th day of October 2020.
SIGNED SEALED AND DELIVERED at MUMBAI in the presence of:
WITNESSES:
1. Prakriti Jain
2. Ram Pandey
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ASSIGNMENT 19: PETITION FOR DIVORCE
PETITION FOR OBTAINING DIVORCE ON GROUND OF CRUELTY (CONTESTED)
IN THE COURT OF DISTRICT JUDGE, PUNE
M.J. Petition No.122013 of 2013.
Mrs. XY
Housewife
Age: 36
B7-204, Camelot Society, Viman Nagar, Pune…..……………………………...…….….Plaintiff
Versus
Mr. X
Civil (Road) Contractor
Age: 39
J-502, Rohan Mithila, Viman Nagar, Pune……………………………………………..Defendant
Petition under Section 13 of the Hindu Marriage Act, 1955.
The above-mentioned petitioner respectfully submits as under that:
1. The Petitioner and the Respondent were lawfully married according to Hindu rituals on 1st
of January, 2010 at Pune with the help of the marriage bureau and the Registrar of
Marriages.
2. The Petitioner and the respondent were Hindus by religion before the marriage and are
Hindus after their marriage and are domiciled in India.
3. The petitioner completed her B. Com and in 2011 and got selected for the post of a bank
clerk in a bank in Pune. The Respondent on the other hand is a civil road contractor in Pune
4. The petitioner and the respondent have had no issue of their said marriage until the
petitioner started working in the bank. The respondent and the petitioners in- laws saw her
many times with her male colleague working in the same branch escorting her to the bus
stop.
5. The petitioner was then repeatedly harassed on suspicion on her character on mere
assumption that the company of a male colleague implies a flaw in the petitioner’s
character. The petitioner has been beaten up repeatedly by the respondent and his parents.
6. The petitioners’ family made repeated efforts by way of meetings to curb the suspicions of
the respondent and his family. The petitioners colleague merely escorted her to the bus stop
which doesn’t imply any ill-will on the petitioners’ part.
7. The respondent and his family have made an issue where there exists none. The petitioner
has been treated in a cruel manner with no fault of her own.
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8. The petitioner being a graduate, is capable enough to support herself without any assistance
from the respondent and thus seek no maintenance unless the court is of the opposite view
in this instance.
9. There had been no proceedings in respect of the marriage in this Court or in any other
Court before this petition expect the filing of a complaint for domestic violence for the
purpose of acquiring a protection order to safeguard the petitioner from repeated assaults.
10. The petitioner is filing for contested divorce as due to the excessive cruelty and annoying
behavior on the part of the respondent, the petitioner has no option but to seek divorce from
the court of law.
11. The petitioner’s marriage with the respondent was solemnized at Pune which is within the
local limits of the jurisdiction of this Hon’ble court and, therefore, this court has got the
jurisdiction to grant appropriate relief.
12. The notional value of this petition in Rs. 50/- for the purposes of the jurisdiction and the
Court fees, and the fixed court fee, stamps has been affixed hereon.
13. The petitioner, therefore prays:
a) that the Hon’ble court be pleased to grant a decree of divorce to the petitioner on
ground of cruelty under Section 13, Hindu Marriage Act, 1955;
b) that the costs of the petition may be awarded;
c) that any other relief(s), which may be proper in the interest of the justice may be
provided.
Petition drawn by
Sd/- Sd/-
Petitioner’s Advocate Petitioner
VERIFICATION
I, Mrs. XY, the petitioner, above-named do hereby solemnly state and declare that the contents of
para 1 to para 12 are true to my own knowledge and the contents of remaining paras are based on
the information supplied to me and I believe the same to be true.
Solemnly affirmed as aforesaid
At Pune
12th April 2013.
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ASSIGNMENT 20: DEVELOPMENT AGREEMENT WITH IMPORTANT CLAUSES
BETWEEN LAND OWNER AND DEVELOPER
DEVELOPMENT AGREEMENT BETWEEN OWNER AND DEVELOPER
THIS AGREEMENT is made here at Hinjewadi, Pune on this 18th day of November between Mr.
Ashok Malhotra hereinafter referred to as "The Owner" of the One Part,
AND
M/S Sai Developers through its Builder Mr. Ramesh Mirchandani hereinafter referred to as
"The Developer" of the Other Part;
The expression of the terms Owner and the Developers, whenever they occur in the body of this
Agreement shall mean and include their respective heirs, executors, administrators and assign
unless and until is repugnant to the context or meaning thereof.
WHEREAS –
a. The Owner is absolutely seized and possessed of a Plot No. 4208 admeasuring 70,000 sq.
feet, the leasehold plot which was registered on 13th October, 2009 at Hinjewadi and which
is more particularly described in the Schedule hereunder written.
b. The Developer has requested the Owner to allow him to develop the said land described in
the Schedule hereunder written.
c. The Owner is desirous of developing the said property and has approached the Developers
for the same. The Owner has agreed to permit the Developers to develop the said property
on the terms and conditions recorded hereinafter.
d. The said land proposed to be developed is shown on a plan hereto referred to as Annexure
- I in the agreement
e. The Owner has agreed to authorize the Developer to develop the said land described in the
Schedule hereunder written, by demolishing the existing buildings or structures thereon if
any and constructing new buildings thereon on Flat Ownership basis and the Owner is
agreeable to directly convey the said land with the new buildings thereon and other
structures to any Co-operative Housing Society or other body that will be formed by the
Purchasers of flats and other premises in such building.
f. The parties hereto are desirous of recording the said terms and conditions in the manner
hereinafter appearing.
NOW THIS AGREEMENT WITNESSETH AND IT IS HEREBY MUTUALLY AGREED BY

AND BETWEEN THE PARTIES HERETO as follows:-
1. With a view to develop the said land described in the Schedule hereunder written
(hereinafter referred to as "the said property") as may be permitted by all concerned
authorities, the Owner hereby agrees to entrust and hand over to the Developer the
work and right of Development of the said property described in the Schedule
hereunder written on the terms hereinafter contained.
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2. The Developer hereby agrees to develop and/or cause to be developed the said property
on the terms mentioned herein and as permitted by the concerned authorities by
constructing one or more buildings thereon on flat and other premises on ownership
basis. The Developer agrees that he will obtain whatever permissions are required to
develop the properly at his own costs and on his own responsibility but in the name of
the Owner.
3. In consideration of the Owner having agreed to entrust to the Developer the
development of the said property described in the Schedule hereunder written and to
confer upon the Developer the rights, powers, privileges and benefits as mentioned
herein, the Developer agrees to pay to the Owner a sum of Rs 5,00,00,000 (Rupees Five
crores only) in the following manner.
a. Rs. 1,00,00,000/- (Rupees one crore only) as and by way of earnest money or
deposit shall be paid on or before the execution of these presents (the payment
and receipt whereof the Owner doth hereby admit and acknowledge);
b. Rs. 1,00,00,000/- (Rupees one crore only) within 30 days from the date on
which the Owner maks out free and marketable title to the said property.
c. Rs. 1,00,00,000/- (Rupees one crore only) to be paid in equal installments of
Rs. 4,16,667/- payable every two months after the installment in Sub-Clause
(b) becoming due.
d. Rs. 1,00,00,000/- (Rupees one crore only) to be adjusted against the allotment
of a flat to the owner by the Developers as mentioned in Clause 4 hereunder
written;
e. The balance Rs. 1,00,00,000/- (Rupees one crore only) shall be paid against
execution of Deed of Conveyance as provided hereinafter.
4. On completion of the construction of the building on the said property, the Developers
shall as part of the consideration allot and handover to the Owner on what is commonly
known as ownership basis a tenement/flat therein of admeasuring 1200 sq.ft. of carpet
area on the third floor of the proposed new building and which flat is mutually valued
at concessional amount of Rs. 75,00,000/- (Rs. 75 Lakhs only) and which is forming
the part of the total consideration of Rs. Rs. 1,00,00,000/- (Rupees one crores only) and
which amount is to be adjusted out of the said total consideration payable as provided
in clauses 3(e) above.
5. The Developers have agreed to develop the said premises as aforesaid free from all
encumbrances and reasonable doubts of whatsoever nature and with the free, clear and
marketable title but subject to the existing occupants/tenants on the ground and first
floor premises of the said property. The Developers shall after demolishing the existing
structure be fully entitled to acquire TDR (Transfer of Development Rights) and
use/consume the same on the said property by putting further and additional
construction/structure
6. The development of the said property by construction of building or buildings thereon
shall be at the entire costs, expenses and risk and on the entire account of the Developer.
All buildings to be constructed on the said property and all dwelling units thereon will
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be in accordance with the scheme of the Competent Authority/State Government under
the said Urban Land (Ceiling & Regulations) Act, 1976 and other relevant Acts and
also in accordance with the Development Rules and Regulations for the time being in
force. The Developer shall be at liberty to make necessary applications for the purpose
to the authorities concerned at his own cost and expenses in the name of the Owner and
the Owner shall join, in such applications but the responsibility of obtaining such
permissions will be on the Developer and at his costs.
7. The Developer shall not start any work of development on the said property unless the
building plans are sanctioned by the Municipal Corporation & Commencement
Certificate are issued in favor of the Owner.
8. The Owner gives license and permission to the Developer to enter upon the said
property described in the Schedule hereunder written or any part thereof as aforesaid
with full right and authority to commence, carry on and complete development thereof
in accordance with the permissions herein mentioned. However, if the Developer or his
agents commit any breach of any term or conditions of this Agreement then the Owner
shall be entitled to terminate this Agreement and to forfeit all moneys paid under this
Agreement and on such termination the license and permission given to the Developer
as aforesaid shall stand revoked.
9. The said license to develop the said property will be personal to the Developer and
under no circumstance the Developer will assign his right, title and interest to any other
party without the consent of the Owner
10. If the Developer will make default in payment of any instalment of the balance amount
on the due date thereof as aforesaid then and in that event the Owner shall become
entitled to terminate this Agreement and to forfeit all moneys paid hereunder and, on
such termination, the license to develop the property given to the Developer shall stand
revoked
11. The Owner shall at the request and costs of the Developer sign and execute from time
to time the plans and other applications for layouts, sub division, construction of the
building and structures on the said property for being sanctioned and approved by the
Municipal Corporation or other authorities provided that, all costs, charges and
expenses including Architect's fees in this connection shall be borne and paid by the
Developer alone and the Developer shall indemnify and keep indemnified the Owner
from and against all actions, suits, proceedings fines, penalties. Architects' fees and all
costs, charges, expenses and damages incurred or suffered by the Owner. The Owner
shall, if required by the Developer execute a power of attorney in favour of the
Developer or his delegate giving all necessary powers required to carry out the work of
development in all respect as contemplated by these presents.
12. The Developer shall be entitled to carry out at his own costs, charges and expenses in
all respects all or any items of work for development of the said property including
laying of drainage, cables, water pipes and other connections and lighting of roads and
other items as per the terms and conditions imposed by the Municipal Corporation
while sanctioning the layout scheme and the said plans and also other items of works
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as may be required to carry out for the purpose of making the said property fit for
construction of buildings and structures therein. All finances for completion of the said
items of works shall be provided and borne and paid by the Developer alone.
13. The Owner hereby agrees to render all assistance and co-operation that may be required
by the Developer from time to time to carry out the Development work in respect of
the said property and construction provided that, the Owner shall not be liable to incur
any financial obligations in that behalf.
14. The Developer shall be at liberty to sell and/or allot the dwelling units or flats and/or
any other tenements and/or rights in the buildings and structures to be constructed on
the said property and/or to enter into any package deal or arrangement for allotment of
buildings and structures to be constructed on the said property at such price and on such
terms and conditions and provisions as the Developer may think fit, and any terms
which may be imposed by any authority or authorities, provided always that the
Developer shall not be released or discharged from his liabilities and obligations
hereunder to the Owner. All such allotments shall, however, be made by the Developer
at his own costs and account and at his risk, the intention being that the Developer shall
alone be liable and responsible to such party or parties in connection with all dealings
between the Developer and such party or parties.
15. The Developer will be entitled to permit any of the premises to be occupied by any of
the allottees of dwelling units or flats or buildings erected on the said property by the
Developer only after the instalments due and payable by the Developer to the Owner
in respect thereof and the full consideration is paid to the Owner or the payment is
otherwise secured to the Owner by a Bank Guarantee as may be agreed upon between
the parties hereto.
16. The Developer shall be entitled to put up and permit to be put up advertisement boards
upon the said property, but without involving the name of the Owner in any manner,
and which the Owner will be entitled to remove forthwith if the Developer has
committed any breach of this Agreement.
17. Upon payment to the Owner of the full consideration amount mentioned in Clause 3
hereinabove, or the payment thereof or any part thereof remaining unpaid being secured
to the Owner as may be agreed upon between the parties hereto as aforesaid and upon
the full development being carried out by construction of buildings and sale of flats,
the Developer shall hand over the property formally to the owner and then the Owner
shall directly execute and deliver any one or more Deeds of Conveyance in favor of
one or more Co-operative Society or Societies or Companies or Condominium of the
Purchasers of flats, tenements and premises in the new buildings to be erected by the
Developer. The Developer hereby agrees to join in such Deed as confirming party if
required. Such Deed or Deeds of Conveyance shall be prepared by the Advocates for
the Owner and approved by the Advocates for the Developer or the flat purchaser.
18. The Owner shall sign all applications or papers for the necessary permission and
sanctions of the Competent Authority or State Government under the provisions of the
Urban Land (Ceiling & Regulation) Act of 1976 for the development of the said
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property described in the Schedule hereunder written. However, it shall be the
responsibility of the Developer to file applications with the concerned authorities and
pursue the said applications and obtain the said permission of the State Government
/Competent Authority at his own costs and expenses.
19. It. is agreed that after the date of this Agreement the Developer shall pay and discharge
all taxes and outgoings including Municipal Taxes, and all other charges, rates, cess,
taxes that may be levied by any Public Body or authorities in respect of the said
property and which would be payable by the Owner as owner. The Developer shall
indemnify and keep indemnified the Owner from and against nonpayment thereof. In
the event of the Developer paying any refundable deposits to the Municipal
Corporation and other concerned authorities in the course of the development of the
said property in the name of the Owner, the Developer shall be entitled to the refund of
such deposit in his own name.
20. The Owner declares that no notice from the Government or any local Body or authority
including the Municipal Corporation has been received by or served upon the Owner
or any person interested in the said property.
21. The Owner declares that the Owner is entitled to enter into this Agreement with the
Developer and he has full right and authority to sign and execute the same.
22. That the Owner has not agreed, committed or contracted or entered into any Agreement
for sale or lease of the said property or any part thereof to any persons or person other
than the Developer and that he has not created any mortgage charge or any other
encumbrances on the said property as mentioned herein.
23. That the Owner has not done any act, deed, matter or thing whereby or by reason
whereof, the development of the said property may be prevented or affected in any
manner whatsoever.
24. The Developer declares that he has entered into this Agreement after fully satisfying
about the title of the owner.
25. All out-of-pocket expenses of and incidental to this Agreement and the transactions in
pursuance thereof including the Deed/Deeds of Conveyance and other assurance in
respect thereof including stamp duty and registration charges shall be arranged to be
paid by the Developer so that the Owner will not be required to pay the same. The
Owner and the Developer shall pay their respective Advocates' fees.
26. The Developer shall indemnify and keep indemnified the Owner against all losses,
damages, costs, charges expenses that will be incurred or suffered by the Owner on
account of or arising out of any breach of any of these terms or any law, rules or
regulations or due to accident or any mishap during construction or due to any claim
made by any third party in respect of such construction or otherwise howsoever.
27. The Developer shall be entitled to enter into separate contracts in his own name with
building contractor, architects and others for carrying out the said development at his
risk and costs.
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IN WITNESS WHEREOF the parties have put their respective hands on this 18th day of
November, 2020 first hereinabove written. In presence of the following witnesses
SCHEDULE HEREABOVE REFERRED TO THE
SIGNED AND DELIVERED BY THE )

Within named Mr. Ashok Malhotra, )
in the presence of )
SIGNED AND DELIVERED by the )

Within named M/S. Sai DEVELOPERS )
Through its Builder Mr. Ramesh Mirchandani )
WITNESSES:
1. Mr. Amit Agarwal
2. Mr. Harsh Kumar
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ASSIGNMENT 21: LEASE DEED
Commercial Property Lease Deed
THIS INDENTURE of lease is made at Pune, this 21st of November, 2020 between Mr. Manohar.
Gokhale, Son of Sri Hari. Gokhale, resident of 33, SBI Colony, Deccan, Pune, 411009, (hereinafter
called “the Lessor”, which expression shall, unless repugnant to the context and meaning include
his heirs, successors, administrators and assigns) of the ONE PART
And
Mr. Aman Udit, Proprietor of Goodwill Ice Cream Parlour, resident of 14, 2nd Floor, Adarsh
Colony, Kothrud, Pune, 411009, (hereinafter called “the Lessee”, which expression shall, unless
repugnant to the context and meaning, include its successors and assigns) of the OTHER PART.
WHEREAS the lessor is absolutely seized and possessed or otherwise well and sufficiently entitled
to the premises at Shop No. 69, 2nd Floor, City’s Big Mall, Tilak Road, Pune, 411049 with a total
area of 320 square feet.
AND WHEREAS on the request of the Lessee, the Lessor has agreed to grant lease in respect of
the demised premises for a term of FIVE (5) YEARS in the manner hereinafter appearing.
NOW THIS DEED WITNESSETH AS FOLLOWS:
1. In pursuance of the said agreement and in consideration of the rent hereby reserved and of the
covenants, conditions and stipulations hereinafter contained and on the Lessee’s part to be
paid, observed and performed, THE LESSOR HEREBY DEMISES UNTO THE LESSEE
ALL THAT the premises situated at Shop No.15 , 2nd Floor, City’s Big Mall, Tilak Road, Pune,
411049 and hereinafter called as the demised premises, TOGETHER WITH ALL the fixtures
and fitting therein, TOGETHER WITH the electrical installations and together with the right
for the Lessee, its employees, servants, agents, customers and persons authorized by the lessor
to use the entrances, doorways, entrance hall, staircases, landings and passages in the demised
premises for the purpose of ingress thereto, TO HOLD the demised premises unto the Lessee
for the period of FIVE (5) YEARS only commencing from 1st of December,2020 and
determined on 21st of November, 2020 but determinable earlier as hereinafter provided
PAYING therefor unto the Lessor during the said term monthly rent of Rs. 15, 000/- payable
by the 5th of each succeeding calendar month to which it relates, and a one term, single payment
of Rs. 1,00, 000/- as security deposit.
2. The lessee hereby covenants with the lessor as follows:
a. To pay the rent as aforesaid on the days and in the manner aforesaid.
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b. To pay the electricity bills for the electricity consumed for lighting the demised
premises and for operation of air conditioners, fans, computers and electrical appliances
in the demised premises.
c. Not to make any structural alterations into or upon the demised premises or make any
alterations or additions to the external appearance or any part of the demised premises
without the previous consent of the Lessor in writing.
d. To use the demised premises for office purposes of the Lessee.
e. Not to do or suffer to be done in or upon the demised premises or other parts of the said
building in common with other persons anything whatsoever, which may be or become
a nuisance or annoyance to or in any way interfere with the quite or comfort of the
Lessor or other Lessees and occupiers of the said building.
f. Not to place or keep or permit to be placed or kept on the demised premises any
offensive, dangerous or highly inflammable or explosive material or any other article
or things, which may constitute a danger, nuisance or annoyance to the demised or
surrounding premises or the owners or occupiers thereof.
g. Not to sub-let, transfer, assign or part with the possession of the demised premises or
any part thereof.
h. To permit the Lessor, his servants, employees or agents duly authorized by him to enter
into and upon the demised premises at all reasonable times for viewing the condition
of the demised premises or doing such works or things as may be requisite or necessary
for any repairs, alterations, servicing or improvements to the demised premises.
i. To hand over the peaceful possession of the demised premises at the end or the sooner
determination of the said term together with all the Lessors fixtures and fittings in as
good condition as received, fair wear and tear, damage by fire, acts of God, riots or
other civil unrest, war, enemy action and/or other cause not within the control of the
Lessee, being excepted.
j. Not to obstruct or suffer to be obstructed the entrance hall, entrances, doorways,
passages, staircase or lifts.
k. To replace all broken fittings and fixtures by equally good or better substitutes.
l. To insure and keep the demised premises insured against loss or damages by fire with
an insurance company approved in writing by the Lessor for an amount which shall not
be less than
3. To Lessor doth hereby covenant with the Lessee as follows:
a. That on the Lessee paying the rent on the due dates thereof and in the manner herein
provided and observing and performing the convents, conditions and stipulations herein
contained and on his part to be observed and performed, shall peaceably and quietly
hold, possess and enjoy the demised premises during the term without any interruption,
disturbance, claim and demand by the Lessor or any person lawfully claiming under or
trust for the Lessor.
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b. To keep the interior, exterior of the demised premises, the drainage thereof in good and
tenable repair and condition.
c. To keep the entrance, doorways, entrance halls, staircases, lobbies and passages in the
said building leading to demised premises well and sufficiently cleaned and lighted at
his own expense.
d. To pay rates, taxes, assessment, duties, cess, impositions, outgoings and burdens
whatsoever payable to State or local or other authority, which may at any time or from
time to time during the term hereby created be imposed or charged upon the demised
premises.
4. It is hereby agreed and declared that these presents are on the express condition, that if the rent
or any part thereof payable in respect of the demised premises shall be in arrears for a period
of two month OR by if the Lessee shall omit to perform or observe any covenants or conditions
on the Lessee’s part herein contained, the Lessor may re-enter upon the demised premises
provided that the Lessor has served a notice to the Lessee and a period of one month has elapsed
after the issue of such notice, the Lessee does not pay the rent or does not perform or observe
the covenant or condition and thereupon this demise and all rights of the Lessee hereunder
shall be determined.
5. This Lease Deed shall be executed in duplicate. The original shall be retained by the Lessor
and the duplicate by the Lessee.
IT IS HEREBY EXPRESSLY AGREED BETWEEN THE PARTIES AS FOLLOWS:
a. The lessee shall be entitled to erect fittings, fixtures, wooden partitions, cabins or make
any such additions or alterations, as may be necessary for its use by the Lessee;
provided that the lessee shall remove the said fittings, fixtures, wooden partitions,
cabins, additions or alterations and restore the demised premises to the Lessor on the
expiry of the term of sooner determination of the lease in the same condition as existed
before making such changes.
b. If the lessor fails to pay the taxes, charges, assessments payable by him, or fails to carry
out the necessary repairs and other work which he has to carry out as provided herein,
the Lessee may after one month notice in writing, pay, discharge and carry out the same
at its own cost and the Lessee may set off the same from the rent payable to the Lessor
under these presents.
IN WITNESS WHEREOF, the Lessor has set its hands unto these presents and a duplicate hereof
and the Lessee has caused its common seal to be affixed hereunder and a duplicate hereof on the
day, month and year first hereinabove written.
For Lessor, For Lessee,
Mr. Manohar Gokhale Mr, Aman Udit
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33, SBI Colony 14, 2nd Floor, Rohit Colony
Deccan Kothrud
Pune, 411009 Pune, 411009
Witness 1: Witness 2:
Mr. Prakash Kaul Mr, Suryansh Goel

235, Camelot Society E5-402, Rohan Mithila E1-E9
Pune, 411014 Pune, 411014
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ASSIGNMENT 22: CIVIL SUIT TO CLAIM DAMAGES FOR DEFAMATION
IN THE HIGH COURT OF JUDICATURE AT BOMBAY
ORDINARY ORIGINAL CIVIL JURISDICTION
(SUIT FOR DAMAGES AND DEFAMATION)
SUIT NO. _____ of 2020
Ms. Preeti Singh

24, Bhulabhai Desai Road,
Mulund (E), Mumbai 400081……………………………………………………………Plaintiff
V.
Ms. Rosy Abraham

230, New Link Road,
Prabhadevi, Mumbai – 400025………………………………………………..................Defendant
THE PLAINTIFF ABOVENAMED STATE AS FOLLOWS:
1. Ms. Preeti Singh has a chain of three beauty parlours and is well known for her amenable
nature and first-class services.
2. She has, under her employment, several persons. One of her employees, Ms. Rosy D’Souza
was working as a hair dresser in the Mahim Branch of her beauty parlours. She is the named
accused in the matter.
3. On 30 October, 2020, it was business as usual in the Mahim Branch of Ms. Preeti Singh’s
beauty parlours. At 3:30, one Ms Rekha came into the parlour for her hair cutting
appointment. Ms. Rosy was the hair dresser assigned to Ms. Rekha as per the availability
of hair dressers in the beauty parlour at the time.
4. Ms. Rosy and Ms, Rekha discussed on the hair style that should be given to Ms. Rekha.
Ms. Rosy suggested to Ms. Rekha that she could also try to give herself a new look by
colouring her hair. Ms. Rekha liked the idea and decided to go ahead with the hair colour.
5. Ms. Rosy applied the hair colour and left it on Ms. Rekha’s hair after which she stepped
outside the beauty parlour for a cup of tea and some snacks.
6. As per the instructions on the box, Ms. Rosy was supposed to leave the hair colour on only
for 40 minutes. However, Ms. Rosy ended up taking a longer time to eat than expected.
When she returned, the colour had been on Ms. Rekha’s hair for more than 50 minutes.
7. As she washed the colour application from Ms. Rekha’s hair, Ms. Rekha’s hair was
damaged and discoloured due to the strong chemicals in the hair colour.
8. Ms. Rekha was extremely upset at the damage done to her hair and immediately asked to
meet Ms. Preeti.
9. Ms. Preeti arrived at the parlour 30 minutes later. She was shocked at the carelessness of
Ms. Rosy and immediately asked her to apologise to Ms. Rekha.
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10. Ms. Rosy refused to apologise and instead became hysterical calling names to Ms. Rekha
and Ms. Preeti accusing them of trying to sabotage Ms. Rosy’s career as a hairdresser.
11. Finally, Ms. Preeti asked Ms. Rosy to leave the job immediately.
12. On 5th November, 2020, Ms. Preeti came across some posts on Facebook and Instagram,
whereby Ms. Preeti was described as a “monstrosity” who was terrible to her employees
and wanted to “torture her employees by making them work long hours and not pay enough
money.” There were tweets of similar nature using the hashtag
“#Preetiisadisgracetowomen”.
13. On 6th November, 2020, Ms. Preeti also found pamphlets calling for a riot against Ms.
Preeti’s beauty parlours. These pamphlets were being distributed by Ms. Rosy in areas
adjoining the three beauty parlours.
14. Accordingly, Ms. Preeti has filed a suit before the Hon’ble High Court of Bombay.
The Plaintiff, therefore, prays:
1. The Court order that Ms. Rosy immediately take down all defamatory posts posted by her
on Facebook and Instagram and delete all tweets on Twitter.
2. The Court order that Ms. Rosy immediately call of the riots as mentioned in her defamatory
pamphlets and stop further circulation of the pamphlets.
3. The Court order that Ms. Rosy pay a compensation to Ms. Preeti for the loss caused to her
by the defamatory posts, tweets and pamphlets.
4. The Court pass any order that may be deemed fit in the spirit of justice, equity and good
conscience.
Plaint drawn by us:
For Ms. Preeti Singh
VERIFICATION
I, Preeti Singh, aged 45 years, of Mumbai, Indian Inhabitant, the Plaintiff abovenamed, having her
residing at 24, Bhulabhai Desai Road, Mumbai 400081, do hereby solemnly declare that what is
stated in paragraph Nos. 1 to 13 of the foregoing Plaint is true to my own knowledge.
Solemnly declared at Mumbai
On this day 8th November 2020
Before me,
Identified by me,
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For. Ms. Preeti Singh
Ms. Nikita Jaitly
Advocate for the Plaintiff
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ASSIGNMENT 23: DISSOLUTION OF PARTNERSHIP DEED
DEED OF DISSOLUTION OF PARTNERSHIP BETWEEN TWO PARTNERS
THIS DEED OF DISSOLUTION made and entered into at Mumbai this 5th day of November
2020
BETWEEN
Shri Bhawesh Singh, Indian Inhabitant, having address at 15 Platinum Apartments, Bandra (W) ,
Mumbai - 400050 (which expression shall, unless it be repugnant to the context or meaning thereof
include his heirs, executors and administrators), hereinafter called “First Party” of the One Part;
AND
Shri. Ritesh Das, Indian Inhabitant, having his address at 23A, Sea View Apartments Juhu Road,
Mumbai – 400049 (which expression shall unless it be repugnant to the context or meaning thereof,
include his heir, executors and administrators) hereinafter called “Second Party” of the Other
Part;
WHEREAS:—
i. THE PARTIES HERETO WERE CARRYING ON BUSINESS IN PARTNERSHIP IN THE FIRM NAME AND STYLE
OF M/S. MAX FRUIT PROCESSORS UPON THE TERMS AND CONDITIONS CONTAINED IN THE DEED OF
PARTNERSHIP DATED 1ST FEBRUARY 1998
ii. THE SHARES OF THE PARTNERS IN THE SAID PARTNERSHIP WERE AS FOLLOWS:-
a. Shri Bhawesh Kapoor ... 60% Share
b. Shri Ritesh Sharma … 40% Share
It has been mutually decided between the parties that the said partnership shall be dissolved,
and the said trade and business shall be wound up and the stock-in-trade, assets and credits realized
and called in, and the net proceeds after payment and satisfaction of all debts and liabilities divided
between the partners according to the covenants in this behalf appearing in the deed of partnership.
NOW THIS DEED WITNESSES that in pursuance of the said agreement it is hereby
declared and agreed by and between the parties hereto as follows, that is to say:
1. The said partnership between the partners hereto under the deed, dated 1st February 1998 hereunto
appended shall be determined and stand dissolved as from the 5th day of November 2020. And the
parties hereto singly or jointly shall not carry on the business of the said firm of Max Food
Processors under the said name and style for a period of 5 years hence.
2. The parties hereto shall on the aforesaid date sign notices of the dissolution and forthwith advertise
in the local Official Gazette the fact of dissolution as required by Section 45 of the Indian
Partnership Act AND shall also intimate the fact of dissolution to the Registrar of Firms under the
provision of Section 63 of the said Act.
3. Within 60 days after the dissolution of the partnership a full and general account and balance sheet
shall be taken and made of the property, assets and liabilities of the partnership; and a full and
particular inventory and valuation of all the machinery, plants, tools, utensils, stock in hand, office
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equipment, materials and effects belonging to the firm shall be made by the parties or such other
person as the partners may choose to appoint, whose decision shall be final and binding upon the
partners, and all debts owing to the firm shall be collected and got in by the parties or such other
persons as the parties may by instrument in his behalf appoint.
4. That as soon as may be, after the property, assets and liabilities have been got in and disbursed the
parties or such other person or persons whom the parties may have appointed under the foregoing
clause shall divide and apportion the share of the parties, in the proportion of the contribution of
the parties towards the capital. In such division any amounts paid earlier or due to the parties
according to the books of the partnership shall be taken into account. That the cost of liquidation
proceedings shall also be deemed to be a liability of the partnership and paid from the funds of the
partnership.
5. That in case the winding up shows a loss or the assets of the partnership are insufficient to meet
the liabilities and debts of the partnership then the partners shall forthwith pay such losses in the
proportion of their contribution to the capital.
6. Each of the parties shall, so soon as the others or any of them, or their or his representatives, shall
have executed and done all the assurances, acts or things hereby agreed to be done by them
respectively and at the request and cost of such other or others, or their or his representatives
execute to them or him such releases, indemnifies, and assurances as may be reasonable and
proper;
IN WITNESS WHEREOF, the parties hereto have executed this agreement, in duplicate, the day
and year first hereinabove written.
Bhavesh Kapoor Ritesh Sharma
______________ __________________
In the presence of 2 [Two] Witnesses;
(1) Signature: ________________________
Name: Manish Paul
Address: 8-F, Orchid Towers,
Andheri (w), Mumbai - 400047
(2) Signature: ________________________
Name: Abhishek Kumar
Address: D-98, Ganga Residence
Borivali (e), Mumbai – 400066
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ASSIGNMENT 24: PROMISSORY Note
Promissory Note
For Purchase of Cement for Sai Samarth Builders
Golden Silver Pvt. Ltd. (Creditor) had sold building material worth Rs. 2,50,000/- only. Sai
Samarth Builders (Debtor) has made this Promissory Note (“Note”) as of 5th day of Novemberr,
2020. Creditor is supplying building materials on credit to the Debtor pursuant to the terms and
conditions of this Note. The Creditor is making the Supply to Debtor in consideration of Debtor
making this Note and delivering it to Creditor.
The Creditor hereby promises to pay the Debtor, the sum of Rs. 2,50,000/- together with interest
of 12% per annum on the unpaid balance. The entire unpaid principal and any accrued interest
shall be fully and immediately payable UPON DEMAND of any holder hereof.
Upon default in making payment within 30 days of demand, and provided this note is turned over
for collection, the undersigned agree(s) to pay all reasonable legal fees and costs of collection to
the extent permitted by law. This note shall take effect as a sealed instrument and be enforced in
accordance with the laws of the payee's state. All parties to this note waive presentment, notice of
nonpayment, protest and notice of protest, and agree to remain fully bound notwithstanding the
release of any party, extension or modification of terms, or discharge of any collateral for this note.
TERMS OF PROMISSORY NOTE
1. This Note evidences the obligation of Debtor to Creditor for repayment amount due on demand.
2. If the amount demanded under this Note is not received by Creditor within fifteen (15) calendar
days after demand is made, Debtor shall pay to Creditor a late charge of five percent (5%) of such
amount. Such late charge shall be immediately due and payable without demand by Creditor.
3. Upon occurrence of any one or more of the following, Creditor may, at its sole discretion, declare
all unpaid principal immediately due and payable, together with all unpaid interest at the stated
rate from the date of the advancement of the credit, subject to applicable cure periods, if any:
a. Debtor defaults in the payment of any principal or interest when due.

b. Creditor discovers that Debtor, in any application to Creditor in connection with the
transaction, had failed to disclose or misrepresented any fact that would have prevented
Debtor from being eligible for the credit.
c. Creditor discovers that Debtor has made any misrepresentations or has intentionally
withheld any fact in the making of this credit, the knowledge of which could have affected
the decision of Creditor to allow the credit.
d. Debtor defaults or breaches any of the terms of the transaction or this Note.
e. The occurrence of any of the following:
i. Debtor becoming insolvent or bankrupt or being unable or admitting, in writing,
Debtor’s inability to pay debts as they mature or making a general assignment of
or entering into any restructure payment arrangement with creditors.
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ii. Proceedings for the appointment of a receiver, trustee or liquidator of the assets of
Debtor or a substantial part of such assets, being authorized or instituted by or
against the Debtor.
iii. Proceedings under any bankruptcy, reorganization, readjustment of debt,
insolvency, dissolution, liquidation or other similar law of any jurisdiction being
authorized or instituted against Debtor.
iv. No waiver of any default or breach by Debtor under this Note shall be implied
from any omission by Creditor to take action on account of such default, and no
express waiver shall affect any default, other than the default specified in the
waiver. Such waiver shall be in writing and shall be operative only for the time
and to the extent therein stated.
v. Debtor may prepay this Note in full or in part at any time, without any
prepayment penalty being charged by Creditor.
4. During the existence of default or delinquency under the terms of this Note or the Trust Deed,
the Creditor is expressly authorized to apply all payments made on this Note to the payment
of all or part of the delinquency, as it may elect.
5. Debtor shall pay to Creditor all costs of enforcement of all or any portion of this Note, including
attorney's fees, witness fees, investigator fees and court costs, incurred by Creditor, whether or
not litigation is commenced.
IN WITNESS WHEREOF, Debtor has executed this Note as of the Credit Date.
Debtor:
Sai Samarth Builders
By:
_______________________________________
Kanan Gill,
Owner,
Sai Samarth Builders
Authorized Representative
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ASSIGNMENT 25: MORTGAGE DEED
DEED OF MORTGAGE
This Deed of Mortgage made at Lucknow this 26th day of November 2020 Between Nadeem
Lakdawalla, son of Heera Nath Lakdawalla resident of 279/13, Sector-J, Aashiyana Colony,
Lucknow 226012 hereinafter called as a mortgagor of the ONE PART and Mr. Bobby Merchant,
son of Saleem Merchant, resident of C-16, Sector H, Lucknow 2206012 hereinafter called as a
mortgagee of the OTHER PART.
NOW THIS DEED WITNESSETH that in consideration of Rs. 50,00,000/- (Rs. Fifty Lakhs) this
day paid to the said mortgagor by the said mortgagee (the receipt whereof the said mortgagor does
hereby acknowledge) he the said mortgagor as beneficial owner thereof doth hereby mortgage unto
the said mortgagee, his heirs and assigns a house absolutely and solely owned by him the said
mortgagor situated at Khazana Market, Aashiyana, Lucknow 226012 and bounded as follows
North - A-402, Khazana Residency
South – Empty Land
East – Staircase of A wing
and West – A-403, Khazana Residency
together with all lands and appurtenances attached or appertaining to the said house, to hold the
same unto and the use of the said Mortgagee, his heirs and assigns, provided always that if the said
Mortgagor shall pay to the said Mortgagee on or before day of 15th November, 2028 the said sum
of Rs. 50,00,000 /- (Rs. Fifty Lakhs) with interest thereon at the rate of 10 % per annum then the
said Mortgagee will at any time thereafter upon the request and the cost of the said Mortgagor
release and re-transfer the said house unto the said Mortgagor, his heirs and assigns or as he or
they shall direct;
AND IT IS FURTHER AGREED BY THE MORTGAGOR doth hereby covenant with the said
Mortgagee that the said Mortgagor will pay to the said Mortgagee on the 15th November, 2028,
the said sum of Rs. 50,00,000/- (Rs. Fifty Lakhs) with interest for the same in the meantime at the
rate of 10% per cent. per annum; and that if the said sum of Rs. 50,00,000/- (Rs. Fifty Lakhs) or
any part thereof shall remain unpaid after that day he will pay to the said Mortgagee so long as the
said sum or part thereof remain unpaid, interest at the rate aforesaid on the same by equal half-
yearly payments on 15th day of May and on 15th day of November every year, the first of such
payments to be made on 15th day of May 2021.
AND IT IS FURTHER PROVIDED that the said Mortgagor shall be at liberty, at any time or
times, on giving to the said Mortgagee at least one calendar month’s notice in writing of his
intention to do so, to pay off all or the part of the principal money for the time being owing on the
security of this mortgage-deed, so that not less than Rs. 2,50,000/- (Rs. Two Lakh Fifty Thousand
Only) shall be so paid at any one time, and that upon such payment of principal, the interest on the
principal sum so paid off may also be fully paid up to the time of payment; and also that such
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partial payment shall not interfere with the payments in regular course of the instalments of
principal and interest subsequently payable in pursuance to the provision hereinbefore contained
but shall only have the effect of accelerating the ultimate payment of moneys remaining on the
security of this mortgage-deed: or
AND IT IS FURTHER PROVIDED that the said Mortgagor shall not be at liberty to pay the
principal money due hereunder before the said 15th day of November, 2023 and that if he desires
to pay the principal amount due hereunder before the aforesaid day, he shall at the same time pay
to the said Mortgagee interest on the whole of the said sum of Rs. 50,00,000/- ( Rs. Fifty Lakhs
only) at the aforesaid rate of 10% per annum for the whole period from the date hereof to 15th day
of November, 2028
AND IT IS FURTHER AGREED BY THE MORTGAGOR that he shall be entitled to redeem the
Mortgagee hereby created only on the payment of the aforesaid principal sum of Rs. 50,00,000/- (
Rs. Fifteen Lakhs only) and interest thereon at the aforesaid rate up to the15th day of
November,2028 should he desire to redeem the same before that day;)
AND IT IS HEREBY AGREED AND DECLARED that the Mortgagor shall so long as any
monies remain unpaid on the security of this mortgage deed keep all the said mortgaged property
in good and substantial repair and insured against loss and damage by fire in some Insurance
Company approved of in writing by the said Mortgagee for the sum of Rs 30,00,000 (Rs. Thirty
Lakhs Only) at least and will pay all premiums and sums and moneys necessary for such purposes
on the first day on which the same ought to be paid and will on demand produce to the said
Mortgagee the policy or policies of such insurance and the receipt for every such payment and will
apply all monies received by virtue of any such policy in making good the loss or damage to the
mortgaged property and also that if default shall be made in keeping the said property so repaired
or insured it shall be lawful for the said Mortgagee to repair and to keep in substantial repair the
said mortgaged property or to insure or keep insured the same in any sum not exceeding Rs.
30,00,000 (Rs. Thirty Lakhs Only).
AND IT IS HEREBY AGREED AND DECLARED that the Mortgagor will on demand repay to
the said Mortgagee all monies, expended by him for any such purpose with interest thereon at the
rate aforesaid from the time of the same respectively having been expended and that until such
repayment the same shall be a charge upon the said mortgaged property;
AND IT IS FURTHER PROVIDED that the expression the Mortgagor hereinbefore used shall
include the said Mortgagor his heirs, executors, administrators and assigns and the expression the
(Mortgagee) hereinbefore used shall include the said Mortgagee his heirs, executors,
administrators and assigns.
AND IT IS FURTHER AGREED THAT the Mortgagor can grant lease of the said house with the
consent of the Mortgagee in writing.
AND IT IS FURTHER AGREED BY THE Mortgagor that he shall bear stamp duty, registration
charges and other out of pocket expenses for the execution and registration of this deed and
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reconveyance deed but however each party will bear cost and professional charges of his
Solicitor/Advocate.
IN WITNESS WHEREOF the parties have put their hands the day and year first hereunder written.
Name of the Mortgagor
Mr. Nadeem Lakdawalla
279/13, Sector-J, Ashiyana
Lucknow – 226012
Name of the Mortgagee
Mr. Bobby Merchant,
C-16, Sector H
Lucknow – 2206012
WITNESSES;
1. Mrs. Vishakha Saraswat
2. Mr. Vijay Sharma
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ASSIGNMENT 26: DEED OF WILL
Last Will and Testament
I, Vir Bahadur Jai Singh of Indian Inhabitant, residing at 280/14, Sector-J, Aashiyana,
Lucknow 226012, hereby revoke any previous will and/or Testamentary Writing
that I may have executed and declare this to be my last Will and Testament:—
1. I appoint (1) Mr. Chandan Singh and (2) Mr. Virat Sharma to be the Executors of my Will.
They shall hereafter be called “My Executors”.
2. I hereby authorize and direct my executors to spend a sum to the extent of Rs. 1,00,000 /- (Rupees
One Lakh only) out of my Estate for my funeral and obituary rites. They shall not be liable for
rendering any account to anyone for the moneys so spent by them for the said ceremonies.
3. I have my grandson Mr. Kartikey Sharma and granddaughter Ms. Gowri Sharma as my legal
heirs.
4. Amongst my properties movable and immovable are the followings:—
a. All my equity shares in Reliance Industries Ltd. having its registered office at 3rd
Floor, Maker Chambers – IV Nariman Point, Mumbai 400 021. I am the major
shareholder of the said company. The said company has also got immoveable
properties.
b. Ownership Flat bearing No. 20 on 2nd Floor of the building known as ‘Tulip
Garden’ of Maha Housing Society at Bandra (e) -400041 along with five shares of
the said Maha Housing Society Ltd. representing ownership of the said Flat. The
said flat is my self-acquired property.
c. Houses bearing Nos. 80 and 81 of Sushant Golf City in Lucknow.
d. Land at Lucknow, Uttar Pradesh the details whereof are as under:- Plot No. 12,
Nirman Vihar, BHEL , Lucknow - 226012
e. The Ownership offices/premises bearing Nos. 25 & 26 at Megmala, Malahr (w),

Mumbai- 400049. The said offices exclusively belong to me and are my self-
acquired properties.
f. Bank accounts; shares; securities; debentures; investments in Unit Trust of India,

National Saving Scheme, Public Provident Fund Scheme and jewellery etc.; and
g. Any other residuary estate standing in my name or belonging to me or inherited or

bequeathed to me or acquired by me at any time hereinafter or otherwise.
5. I hereby give Devise and Bequeath the estate mentioned in aforesaid Clauses 4(a), 4(c), and
4(d), solely and absolutely to my granddaughter Ms. Gowri Sharma. My granddaughter shall be
fully entitled to deal with the same in the manner as she deems fit and proper and at her own
discretion. If my granddaughter predeceases me in that event, the said estate shall go to my
grandson.
6. I hereby give Devise and Bequeath the estate mentioned in aforesaid Clause 4(b) above solely
to my granddaughter Ms. Gowri Sharma for her life time and thereafter the same shall belong to
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my grandson Mr. Kartikey Sharma. My granddaughter during her life time will not be entitled to
deal with the said flat without the written and specific consent from my grandson.
7. I hereby give Devise and Bequeath the estate mentioned in aforesaid Clause 4(e) above solely,
exclusively and absolutely to my grandson Mr, Kartikey Sharma.
8. I hereby give Devise and Bequeath the assets and estate mentioned in aforesaid Clause 4(f) and
Clause 4(g) respectively to my grandson Mr, Kartikey Sharma and my granddaughter Ms. Gowri
Sharma in equal proportion.
9. I have made this Will in my good and sound health and after fully understanding the same in all
aspects.
IN WITNESS WHEREOF I the said Mr. Virbahadur Jaysingh have hereunto set my hand at
Bhopal this 11th day of November 2020.
SIGNED AND DECLARED BY )
Mr. Virbahadur Jaysingh, )
the Testator abovenamed as )
and for his last Will and )
Testament in the presence of )
us present at the same time )
who at his request in his )
presence and in the presence )
of each other have hereunto )
set and subscribed our respective )
names as witnesses: )
1. Ms. Mamta Jaitly
2. Ms. Vijaya Tiwari
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ASSIGNMENT 27: SALE DEED
SALE DEED
This DEED OF ABSOLUTE SALE executed at Pune on this the 9th day of October,
2013 by Mr. Chandan Nakhate aged about 40 years s/o Mr. Anil Nakhate residing at S.No.11,
Maruti Mandir, Nakhate Niwas, Pirangut, Pune -410030, hereinafter called the VENDOR of the
one part which expression shall include his executors, administrators, legal representatives,
successors etc.
TO AND IN FAVOUR OF
Mr. Rocky Topiwala aged about 39 years s/o Mr. Sunny Topiwala residing at Sylven
hights, Baner, Pune- 411045, hereinafter called the PURCHASER of the Other Part which
expression wherever the context so requires shall mean and include his heirs, executors,
administrators, legal representatives, successors etc.
WHEREAS the VENDOR herein has purchased the said property more fully
described in the Schedule hereunder from Mr. Ram Sharma in and by sale deed dated 10.05.2000
and registered on 12.05.2000 as Document No.FP3058 of 2000 of Book 1 volume No. 12 filed at
pages 242 to 245 on the file of the Sub Registrar of Pune.
WHEREAS the VENDOR herein has been in exclusive possession and enjoyment of
the property more fully described in the Schedule hereunder.
WHEREAS the VENDOR is the exclusive owner of the property more fully described
in the Schedule hereunder and he has absolute right to dispose of the same as in the manner he
wishes.
AND WHEREAS the VENDOR is in need of funds in order to meet his personal
commitments and family expenses and has decided to sell the property more fully described in the
Schedule hereunder for a sum of Rs. 52,80,000/- (Rupees Fifty Two Lakhs Eighty Thousand only)
and the PURCHASER herein has also agreed to purchase the same for the said price and to the
effect they entered into an agreement to sell dated 9th October 2013.
NOW THIS DEED OF SALE WITNESSETH
• THAT in pursuance of the aforesaid agreement and in consideration of a sum of Rs.

52,80,000/- (Rupees Fifty Two Lakhs Eighty Thousand only) received by the VENDOR
via cheque Number 5678 dated 15th October, 2013 and the receipt of the said entire
consideration of Rs. 52,80,000/- (Rupees Fifty Two Lakhs Eighty Thousand only), the
VENDOR doth hereby admit, acknowledge, acquit, release and discharge the VENDOR
from making further payment thereof and the VENDOR doth hereby sell, convey, transfer,
and assigns unto and to the use of the PURCHASER, the property more fully described in
the Schedule hereunder together with the water ways, easements, advantages and
appurtenances, and all estate, rights, title and interest of the VENDOR to and upon the said
property TO HAVE AND TO HOLD the said property hereby conveyed unto the
PURCHASER absolutely and forever.
THE VENDOR DOTH HEREBY COVENANT WITH THE PURCHASER AS
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FOLLOWS:
• That the property more fully described in the Schedule hereunder shall be quietly and
peacefully entered into and held and enjoyed by the PURCHASER without any
interference, interruption, or disturbance from the VENDOR or any person claiming
through or under him.
• That the VENDOR has absolute right, title and full power to sell, convey and transfer unto
the PURCHASER by way of absolute sale and that the VENDOR has not done anything
or knowingly suffered anything whereby his right and power to sell and convey to the
PURCHASER the property hereby conveyed.
• That the property is not subjected to any encumbrances, mortgages, charges, lien,
attachments, claim, demand, acquisition proceedings by Government or any kind
whatsoever and should thereby and the VENDOR shall discharge the same from and out
of his own funds and keep the PURCHASER indemnified.
• That the VENDOR hereby declares with the PURCHASER that the VENDOR has paid
all the taxes, rates and other outgoings due to Local bodies, revenue, urban and other
authorities in respect of the property more fully described in the Schedule hereunder up to
the date of execution of this sale deed and the PURCHASER shall bear and pay the same
hereafter. If any arrears are found due to the earlier period, the same shall be discharged
by the VENDOR
• That the VENDOR has handed over the vacant possession of the property more fully
described in the Schedule hereunder to the PURCHASER on and delivered the connected
original title document in respect of the schedule mentioned property hereby conveyed on
the date of execution of these presents.
• That the VENDOR will at all times and at the cost of the PURCHASER execute, register
or cause to be done, all such acts and deeds for perfecting the title to the PURCHASER in
the property hereby sold and conveyed herein.
• That the rights, titles, interests, easements, privileges, appurtenances, liberties, enjoyments
and possessions are hereby transferred and subsist in favor of the PURCHASER
absolutely and forever.
• That the VENDOR do hereby covenants and assures that the PURCHASER is entitled to
have mutation of his name in all public records, local body and also obtain patta in the
name of the PURCHASER and undertakes to execute any deed in this respect.
• That all expenses of this sale deed such as stamp duty, execution and registration fee, etc.
has been paid by the PURCHASER
• There is no House or any constructions in the said site. If any structure is found there the
parties herein may be prosecuted under Section 27 read with Sec. 64 of Indian Stamp Act
besides the recovery of the deficit stamp duty
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SCHEDULE OF PROPERTY
The Market Value of the Property is Rs. 50,00,000/- (Rs. Fifty Lakhs only)
Type of Deed Sale Deed
Land Under Sale Gat No. 10/2, Nakahte Farm A/p- Pirangut T/D-
Pune
Land Area Transfer 5 Hectares 0 Ares
Land Use Agricultural land
Consideration of Land Rs. 50,00,000/-
Stamp duty Rs. 2,50,000/-
Registration fee Rs. 30,000/-
Total Amount to be paid Rs. 52,80,000/-
In witness where of the VENDOR and the PURCHASER have set their signatures on the day
month and year first above written.
All that piece and parcel of the site admeasuring 5 Hectares 0 Ares. Survey no Gat No. 10/2
Ward No PNE/W/98/5.
Situated at Gat No. 10/2, Nakahte Farm A/p- Pirangut T/D-Pune
Which is more fully described in the plan annexed hereto and marked in RED colour and
bounded as under
NORTH: Gat no, 9/2, Open Land
SOUTH: Gat no, 11/2, ZP School
EAST: Remaining portion of Gat No, 10/2
WEST: Main road
In the above property undivided share of 5 Hectares 0 Ares
Witnesses:
1) Mr. Navin Agarwal VENDOR
2) Mr. Shobhit Kumar THE PURCHASER
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ASSIGNMENT 28: DRAFT AFFIDAVIT
AFFIDAVIT: IN SUPPORT OF PETITION UNDER SECTION 125 OF THE CODE OF
CRIMINAL PROCEDURE, 1973
IN THE COURT OF METROPOLITAN MAGISTRATE, PUNE
In
Criminal Complaint No. 456 of 2020
Ms. Reshma Tripathi
D/o Aseem Tripathi
74, Hinjewadi Road
Pune – 411 011………………………………………………………..............Petitioners No. 1
Mrs. Lata Kapoor

D/o Rishi Kapoor
24, Hinjewadi Road
Pune – 411 011………………………………………………………................Petitioner No. 2
Vs.
Mr. Dinesh Kapoor
S/o Amit Kapoor
B-303, Skyvie Society, Viman Nagar
Pune – 411 014……………………………………………………………………Respondent
AFFIDAVIT of Mrs. Lata Kapoor, D/o Rishi Kapoor aged 35 years, presently residing in 24,
Hinjewadi Road Pune – 411 011
The deponent abovenamed solemnly declares and affirms as follows:
1. That, I am petitioner No. 2 in the accompanying petition and I am fully conversant with the
facts and circumstances of the case. I am competent to swear to this affidavit.
2. That, I am the natural mother of petitioner No. 1 and the respondent herein is her natural
father.
3. That petitioner No. 1 is an infant girl of 2.5 months in my custody and care.
4. That, whatever I have stated in the accompanying petition under section 125 of the Code of
Criminal Procedure, 1973, has been read over and explained to me and I have understood
the contents of the same, which are true and correct to my knowledge and information
received. The same may kindly be read as a part of this affidavit to avoid repetition and for
the sake of brevity.
5. The said petition has been drafted by my counsel under my instructions.
Sd./
Deponent
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Verification
Verified at on this the 15th day of October, 2020 that the contents of the above affidavit are true
and correct to the best of my knowledge, belief and information and nothing material has been
concealed therefrom.
Sd./
Deponent.
Solemnly affirmed and signed before me by the deponent, who is personally
known to me, on this the 15th day of October, 2020.
Sd./
Counsel for the deponent.
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ASSIGNMENT 29: INTERLOCUTORY APPLICATION
INTERLOCUTORY APPLICATION - UNDER ORDER XXXIX, RULE I OF THE
CODE OF CIVIL PROCEDURE, 1908
BEFORE THE HIGH COURT OF JUDICATURE AT BOMBAY

IA NO. 2556 of 2020
In Original Petition No. 338 of 2020
Nav Bharat Trust ……………………………………………………..………………… Petitioner

v.
Ram Rajan………………………………………………………………...…………Respondent
PETITION FOR INJUNCTION

To,
The Hon’ble Chief Justice and his Companion Judges of the aforesaid Hon’ble Court.
The humble application on behalf of the abovenamed applicant most respectfully showeth as
under:
1. The suit is filed, inter alia, for permanent prohibitory injunction restraining the respondent
from carrying out unauthorized activity on the suit property, bearing no. 145789.
2. A Public Religious and Charitable Trust where thousands of peoples visit every day, is in
the possession of land donated by a one of their disciple where an adjacent private owner
occupied the part of land and started to erect a temporary structures for a stall/shop and
unauthorized use of the land by debating/conflicting upon the lines of boundaries. Trusts
authorities have issued notices but proved in vain. Due to prima facie case, balances of
convenience, grave and irreparable loss trust authorities want to file the application to
obtain stay the acts of adjacent owner.
3. The land on which the private owner has carried out his activities had been donated for
purposes of the Trust and nothing else. Such unauthorized activity prevents the other
disciples from optimally utilizing the Trust area as promised for. If the relief is not granted
and the delay will be rendered infructuous and the purpose of the suit will be entirely
defeated.
4. It is respectfully submitted that if this Hon'ble Court grants the injunction sought, the
respondent will not be harmed in any manner whatsoever as the land in question where he
has erected his structures is not for his perusal, as opposed to the primary usage of the land
as a Trust property, which was frequented by large masses. The practice of granting an
order which practically gives the principal relief sought in the petition for no better reason
than that a prima facie case has been made out, without being concerned about the balance
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of convenience, the public interest and a host of other relevant considerations, as the
applicant would be compromising the utility of his property for unauthorized purposes, and
as the Trust is for public usage, the view of the petitioner should be taken into consideration
and the remedy sought under this application should be granted.
DECLARATION
The applicant above named hereby solemnly declare that nothing material has been concealed or
suppressed and further declare that the enclosures and typed set of material papers relied upon and
filed herewith are true copies of the originals or fair reproduction of the originals or true translation
thereof.
Verified at Mumbai dated this 10th day of November 2020.
Counsel for Applicant
VERIFICATION
I, Jahaan Kataria, wife of Krish Kataria age, 48 working as Co-Trustee in the office of Kataria
Trust resident of Mumbai do hereby verify that the contents of the paras 1 to 4 are true to my
personal knowledge / derived from official record ) and believed to be true on legal advice and
that I have not suppressed any material facts.
Date: 10th November, 2020 Place: Mumbai
Signature of the Appellant/Petitioner or authorized officer
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ASSIGNMENT 30: AGREEMENT REGARDING LICENSING OF TRADEMARKS
TRADEMARK LICENCE AGREEMENT
THIS TRADEMARK LICENCE AGREEMENT (the “Agreement”) is made with effect as of the
9th day of October, 2020 (the “Effective Date”),
BETWEEN:
ALEX CORPORATION, a corporation governed by the laws of the State of California and
having its registered office at #34, Park Street, California, USA (the “Licensor”)
AND:
BHS PVT. LIMITED, a company incorporated under the laws of Companies Act, 1956 having
its registered office at #23, Lavelle Street, Bengaluru, Karnataka, India (the “Licensee”)
WITNESS THAT WHEREAS:
A. The licensor and licensee agree to introduce their enterprise to the territory and economy of
Union of India and therefore seek to collaborate with regard to the same and have entered into a
Collaboration Agreement dated 09.10.2020;
B. To the Licensor’s knowledge the Licensor owns or holds certain rights in respect of those
trademarks listed in Schedule A attached hereto (collectively, the “Marks”);
C. To the Licensor’s knowledge the Licensor has the right and authority to licence to the Licensee
the right to use the Marks.
D. This agreement shall be registered with the Registrar of Trademarks
NOW THEREFORE in consideration of the representations, warranties, covenants and agreements

contained herein and in the Collaboration Agreement and other good and valuable consideration
(the receipt and sufficiency of which is hereby irrevocably acknowledged) the parties agree as
follows:
ARTICLE 1
TRADEMARK LICENCE TERMS
1.1: Grant of Licence. The Licensor hereby grants to the Licensee on the terms contained herein a
non-exclusive, royalty free licence (the “Licence”) to use the Marks throughout the territory of
India (the “Territory”) in association with the goods and services specified in Schedule A hereto
(the “Goods and Services”). The Licensee agrees to use the Marks only in accordance with terms
and conditions set out in this Agreement. The Licensor may itself use the Marks in the Territory
but may not grant licences to other persons to use the Marks. Schedule A may be amended to add
or delete Marks and/or Goods and Services from time to time, by way of written agreement
between the parties.
1.2: Permitted and Prohibited Uses. The Licensee will use the Marks only while the Licence is in
effect, only in the Territory, and only in association with the Goods and Services. The Licensee
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will use the Marks only in compliance with all applicable laws and regulations. Further, the
Licensee will use the Marks only in accordance with the policies, specifications, directions and
standards of the Licensor (as to the character and/or quality of the Goods and Services with which
the Marks are to be used, or otherwise) as may reasonably be stipulated by the Licensor to the
Licensee from time to time, including but not limited to those restrictions set out in Schedule B.
The Licensee will not, directly or indirectly, use the Marks in any other way and without limiting
the foregoing, the Licensee will not use the Marks as part of any composite trademark, that is, in
close proximity or in combination with any trademark(s) held by the Licensee or any third party.
The Licensor will notify the Licensee of any changes or alterations made to any of the Marks from
time to time during the term of this Agreement, and within thirty (30) days of receipt of such
notice, or as soon as reasonably practical, whichever is earlier, the Licensee will ensure that all of
its usage of any Marks so changed or altered complies with any such notice given.
1.3: Term. The Licence will commence as of the Effective Date and subject to earlier termination
pursuant to the terms of this Agreement, will expire upon the earlier of: (a) six (6) months from
the Effective Date; (b) the closing of the Asset Purchase Agreement between the Licensor and Ya
Zhu Silk, Inc. referenced in the Master Amending Agreement; or (c) such other date as is mutually
agreed to by the parties hereto.
1.4: Inspection and Approval. To assist the Licensor to verify and enforce the Licensee's
obligations under this Agreement, and in particular, to inspect the character and/or quality of the
Goods and Services with which the Marks are used, upon no less than three (3) days notice, the
Licensee will permit and assist the Licensor to:
(a) enter all premises where the Licensee uses the Marks or stores Goods or other materials bearing
any of the Marks; and
(b) observe the Licensee's activities relating to the Marks and inspect material on which any of the
Marks appear.
At the request of the Licensor, acting reasonably, the Licensee will promptly provide the Licensor
with samples of all packaging, advertising, company brochures and other material prepared by, for
or with the permission of the Licensee that bears or refers to any of the Marks. Further, the Licensee
will deliver to the Licensor samples of all proposed Goods that the Marks are proposed to be used
in association with at least 60 calendar days before any intended distribution date for any of the
same. Within 30 calendar days after it receives any such sample material, the Licensor will deliver
to the Licensee either a written notice of approval or a written notice of refusal. Any notice of
refusal will specify what must be changed and why. If the Licensee does not receive either a written
notice of approval or a written notice of refusal within such 30-day period, then the material will
be deemed to have been approved for distribution. If the Licensee receives a written notice of
refusal from the Licensor, the Licensee may revise the material and resubmit a sample of the
revised material to the Licensor for its approval, in which case, the approval procedure set out in
this Section will once again apply.
ARTICLE 2
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ROYALTY
2.1: In this Article 2, “Gross Revenues” shall mean the total amount of revenue produced deducting
the direct costs paid for producing the revenue.
2.2: In consideration of the rights granted under Article 1, the Licensee shall pay to the Licensor
royalties, within 30 days of the termination of the License, of one half of one percent of the Gross
Revenues earned by the Licensee during the term of this Agreement.
2.3: At the same time as payment of royalties falls due, the Licensee shall submit or cause to be
submitted to the Licensor a statement in writing recording the calculation of such royalties payable
and due.
2.4: The Licensee shall keep proper records and books of account and be open at all times to
inspection and audit by the Licensor (or its duly authorised agent or representative), who shall be
entitled to take copies of or extracts from the same. If such inspection or audit should reveal a
discrepancy in the royalties paid from those payable under this Agreement, the Licensee shall
immediately make up the shortfall and reimburse the Licensor in respect of any professional
charges incurred for such audit or inspection.
2.5: The provisions of this Article 2 shall remain in effect notwithstanding termination or expiry
of this agreement until the settlement of all subsisting claims by the Licensor.
ARTICLE 3
INTELLECTUAL PROPERTY RIGHTS
3.1: Preservation and Enhancement of the Licensor's Interest. The Licensee acknowledges the
validity of the Marks, and the Licensor's ownership of the Marks and the goodwill pertaining
thereto, and agrees that the benefit of and goodwill associated with use of any of the Marks by the
Licensee will enure entirely for the benefit of the Licensor. Should any right, title or interest in or
to the Marks or any part thereof or any copyright or trademark related thereto become vested in
the Licensee, the Licensee will hold the same in trust for the Licensor and will, at the request of
the Licensor forthwith unconditionally assign any such right, title or interest to the Licensor. All
rights in and to any new version, translation or arrangement of the Marks, or other change in the
Marks created by the Licensee, with the Licensor's prior written consent or otherwise, will be and
will remain the exclusive property of the Licensor, and the provisions of this Agreement will apply
to the same. The Licensee will cooperate with the Licensor for the purpose of protecting,
preserving and enhancing the Marks and the Licensor 's interest in them and in furtherance of such
obligations, the Licensee will promptly execute and deliver to the Licensor all documents and
instruments that the Licensor, acting reasonably, determines are necessary or prudent from time to
time. The Licensee will not itself and will not assist, permit,
or encourage any third party to:
a. attack or challenge the validity, ownership or enforceability of any of the Marks, any
registrations for any of the Marks, or the Licensor’s rights relating to any of the Marks or in
any such registrations;
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b. claim, use, or apply to register, record or file any trademark, trade name, business name,
corporate name, domain name, social media user name, email address, metatag, Adwords or
similar search term, copyright, or design that is identical with, confusingly similar to, clearly
derived from or based on or that includes any of the Marks; or
c. use any of the Marks in a manner which is likely to depreciate or cause material
harm to the goodwill attached to any of the Marks.
3.2: Contractual Rights Only. The Licensee acknowledges and agrees that the rights and licence
granted to the Licensee pursuant to this Agreement are of a contractual nature only, and no property
or other rights in or to any of the Marks are granted to the Licensee by virtue of this Agreement.
ARTICLE 4
TERMINATION
4.1 Automatic Termination. In addition and not in substitution to the provisions of Section 1.3,
this Agreement (including the Licence) will terminate immediately, and without notice, upon the
earliest of:
a) if the Licensee does or causes to be done or engages in any conduct which in the opinion of the
Licensor, acting reasonably, is detrimental to the Marks or any of them or to the goodwill
connected with them or any of them; or not in accordance with the policies, specifications,
directions or standards of the Licensor as to the character or quality of the Goods or Services or
both with which the Marks are to be used; and the Licensee fails to cease such conduct within 10
business days of receipt of notice from the Licensor requesting the Licensee to do so;
b) if the Licensee defaults in observing or performing any other of its obligations under this
Agreement and fails to correct such default within 30 days after receiving a written demand from
the Licensor to correct the same;
c) if the Licensee ceases to provide or perform any of the Goods or Services in association with
he Marks for a period of three (3) consecutive months or more.
4.2: Termination by Licensee. This Agreement (including the Licence) will terminate immediately
upon written notice by the Licensee to the Licensor of the Licensee’s desire to terminate.
4.3: Termination by Licensor. This Agreement (including the Licence) will terminate within 30
days written notice by the Licensor to the Licensee of the Licensor’s desire to terminate.
4.4: The Licensee's Rights and Obligations on Termination. Upon termination or expiration of
this Agreement for any reason, the Licensee will:
a. cease all use of the Marks;
b. destroy all materials bearing or referring to any or all of the Marks; and
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c. cancel all orders for materials bearing any or all of the Marks, including without limitation,
all advertising using or referring to any of the Marks; and will not:
d. attack or challenge the validity, ownership or enforceability of any of the Marks or of any
registrations for any of the Marks in the Territory, or the Licensor 's rights relating to any of
the Marks or in any such registrations; or
e. claim, use, or apply to register, record or file in any jurisdiction any trademark, trade name,
corporate name, domain name, email address, social media user name, metatag, Adwords or
similar search term, copyright or design that is identical with, confusingly similar to, clearly
derived from or based on any of the Marks or that includes any of the Marks.
This Section will survive the expiration or termination of this Agreement.
ARTICLE 5
THIRD PARTIES, INDEMNITIES AND INSURANCE
5.1: Infringement. If, during the term of this Agreement the Licensee becomes aware of use by any
other party (other than affiliates or licensees of the Licensor) in the Territory of a trade name,
trademark, domain name, email address, metatag, Adwords or similar search term, get up of goods,
or mode of advertising that might reasonably amount to infringement of any of the Marks or to
unfair competition or passing off in respect of any of the Marks, then, the Licensee will promptly
report particulars of such usage to the Licensor and provide relevant material if available.
5.2: Claims by Others. If the Licensee becomes aware that any person alleges that any of the Marks
or any registration for any of the Marks in Canada or elsewhere is invalid, infringes the rights of
any person, or is open to any other form of attack, then, the Licensee will not make any admissions
in respect of such allegation and will promptly report particulars of the matter to the Licensor and
provide all relevant materials if available. If, in the opinion of the Licensor, acting reasonably any
of the Marks is likely to or does become the subject of a claim for infringement, passing off or
otherwise, the Licensor may, without liability or obligation, terminate the Licence in respect of
any such Marks, effective immediately upon delivery of written notice to the Licensee. Upon any
such termination, the provisions of Section 4.4 will apply in respect of any such Marks.
5.3 Conduct of Proceedings. The Licensor will have sole conduct of all legal proceedings and
negotiations in respect of any actual, proposed or threatened legal proceedings relating to any of
the Marks unless the Licensee is actually sued by any third party for using any of the Marks, and
in any such event the Licensee will be entitled to institute proceedings in the Territory in respect
of its own interests and at its own expense, and will give the Licensor prior written notice of any
such proceedings and will deliver to the Licensor immediately upon creation or receipt, as
applicable, copies of all pleadings and documents filed in such proceedings. The Licensor will
have the right to intervene at its own expense in any proceeding conducted or defended by the
Licensee involving any of the Marks.
93 | P a g e
CLINICAL COURSE I
5.4 Cooperation. The parties hereby agree to cooperate with each other in the conduct or defense
of any legal action, and in the negotiations in respect of any legal action relating to any of the
marks and each will provide to the other all relevant data, information and material in its possession
which may be helpful in such action or negotiation, at the cost and expense of the party requesting
such data, information and material.
5.5 Indemnity for Liability. The Licensee will indemnify and save the Licensor and the Licensor's
directors, officers, employees and agents (collectively, “Licensor’s Personnel”) harmless from and
against any actual or threatened claims, actions or proceedings arising out of the exercise by the
Licensee of its rights under this Agreement and the Licensee's use of any of the Marks. The
foregoing indemnification does not apply insofar as any particular matter concerns whether or not
the Licensor had the right to grant to the Licensee the use of the Marks pursuant to this Agreement.
As concerns the foregoing indemnification, the Licensee will defend and save harmless the
Licensor and/or the Licensor's Personnel at no cost and expense to the Licensor and/or the
Licensor's Personnel whatsoever, against any damage, injury, liability, cost, loss or expense
whatsoever, including, but not restricted to all reasonable legal fees and costs as charged by a
lawyer to his own client, arising from or with respect to any claim, action or proceeding against
the Licensor and/or the Licensor's Personnel.
ARTICLE 6
GENERAL
6.1 Assignment and Sublicensing. Except as expressly provided in this Section, the Licensee will
have no right to assign, grant or create any interest in any of the Marks or their use to any person
and will have no right to sub-licence any of its obligations hereunder, without first obtaining the
express written consent of the Licensor, which consent may be withheld, delayed or conditioned
without reason. Regardless of whether consent is given on any particular occasion, consent must
also be obtained for any subsequent occasion. The Licensor may assign its rights and duties
hereunder, in whole or in part.
6.2 Disclaimer and Release. The licensor makes no representation or warranty to the licensee
regarding any of the marks or their validity in any country, and in particular, without limitation,
the licensor makes no representation or warranty regarding ownership of any of the marks or that
any of the marks do not infringe the rights of third parties. The licensee hereby waives and releases
any right or claim it might otherwise have against the licensor in connection with any or all of the
marks except for those relating to its express rights under this agreement.
6.3 Injunctive Relief Available. The Licensee agrees that in the event of a breach by the Licensee
of any provision of this Agreement, monetary damages may not be an adequate remedy and that
in such circumstances the Licensor will be entitled to injunctive or other affirmative relief, or both,
without such constituting an election of remedies or disentitling Licensor to each and every remedy
available at law and/or in equity for a breach of this Agreement.
6.4 Time of Essence. Time is of the essence of this Agreement and no extension of time will
94 | P a g e
CLINICAL COURSE I
constitute a waiver of this provision.
6.5 Waiver. If the Licensor waives a particular default, wrongful act or omission of the Licensee,
such waiver will not affect or impair the rights of the Licensor in respect of any other default,
wrongful act, or omission of the Licensee. If the Licensor delays or fails to exercise any rights in
connection with any default, wrongful act or omission of the Licensee, such delay or failure will
not affect or impair the rights of the Licensor in respect of any subsequent occurrence of that event
or any other default, wrongful act, or omission of the Licensee.
6.6 Survival. The provisions of Sections 2.1, 4.4, 5.5, 6.2, and 6.6 and all other sections necessary
for the interpretation or enforcement thereof will survive the termination or expiration of this
Agreement.
6.7 Notice. Any notice, demand, direction or other communication required or permitted to be
given under this Agreement must be in writing and will be sufficiently given if delivered or
telecopied as follows:
Notices to the Licensor will be addressed as follows:
ALEX CORPORATION USA
Attention:
IN WITNESS WHEREOF the parties hereto have executed and delivered this Agreement.
SCHEDULE A
MARKS
UNITED STATES
Trademark Application/Registration Application Filing

Number Date/Registration Date
ALEX CORP 1020023 10.09.2011
1020024 10.09.2011
International Class: 009, Status: Active

Goods/Services: Mobile Phones, Smartphones
95 | P a g e

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SYMBIOSIS LAW SCHOOL, PUNE

Care | Courage | Competence | Collaboration

SYMBIOSIS INTERNATIONAL (DEEMED

Reaccredited by NAAC with 'A' Grade

Symbiosis Campus, Opp. Pune International Airport,

DRAFTING, PLEADING AND CONVEYANCING

Name of Student: Nikita Jaitly

Roll No.: 055 Div.: A

Batch: 2016-21 Programme: B.A. L.L.B.(Hons.)

PRN No.: 16010125055 Mobile No.: 7309228064

E-mail ID: nikita.jaitly@symlaw.ac.in

Assignment 1: Drafting Of Legal Notice ........................................................................................ 2

Assignment 2: Petition For Divorce ............................................................................................... 4

Assignment 3: Service Contract...................................................................................................... 7

Assignment 4: Plaint/Suit for Recovery of Money ....................................................................... 12

Assignment 5: Maintenance Application ...................................................................................... 15

Assignment 6: Leave and License Agreement.............................................................................. 18

Assignment 7: Anticipatory Bail Application............................................................................... 23

Assignment 8: Regular Bail Application ..................................................................................... 26

Assignment 9: Franchise Agreement ............................................................................................ 29

Assignment 10: Consumer Complaint .......................................................................................... 32

Assignment 11: Joint Venture Agreement .................................................................................... 35

Assignment 12: Petition for Public Interest Litigation ................................................................. 39

Assignment 13: Appeal to High Court.......................................................................................... 44

Assignment 14: Writ of Habeas Corpus ....................................................................................... 46

Assignment 15: Special Leave Petition ........................................................................................ 50

Assignment 16: Public Notice ...................................................................................................... 53

Assignment 17: Power of Attorney............................................................................................... 54

Assignment 18: Special Power of Attorney .................................................................................. 56

Assignment 19: Petition for Divorce ............................................................................................ 58

Assignment 21: Lease Deed.......................................................................................................... 66

Assignment 22: Civil Suit To Claim Damages For Defamation .................................................. 70

Assignment 23: Dissolution of Partnership Deed ......................................................................... 73

Assignment 24: Promissory Note ................................................................................................. 75

Assignment 25: Mortgage Deed ................................................................................................... 77

Assignment 26: Deed of Will ....................................................................................................... 80

Assignment 27: Sale Deed ............................................................................................................ 82

Assignment 28: Draft Affidavit .................................................................................................... 85

Assignment 29: Interlocutory Application.................................................................................... 87

Assignment 30: Agreement Regarding Licensing Of Trademarks ............................................... 89

Ms. Nikita Jaitly B-5, 402,

B.A. LLB. (Hons.) Camelot Society, Viman Nagar

ADVOCATE Pune- 411014

Dated: 21st September 2018

(BY REGISTERED A.D)

[Ms. Nikita Jaitly]

H.M. PETITION NO. 135 OF 2013

IN THE MATTER OF:

THE PETITIONERS ABOVE NAMED MOST RESPECTFULLY SHOWETH,

(i) Before 1702, A1 Society,

Place: Pune ________________

Place: Pune ________________

THIS AGREEMENT represents a Service Level Agreement (“SLA” or “Agreement”) made on

‘______’, age-___, s/o____, Occupation ________, residing at _____, hereinafter referred to as

‘__________’, incorporated on ‘_________’, having Registered Office at ‘______’, holding CIN

1. Acknowledgement & Acceptance

3. Our Service Privacy Policy

4.1 Parties must be at least 18 years old to become a Customer.

‘____’, age-_, s/o, Occupation , residing at _, hereinafter referred to as

‘______’, incorporated on ‘_’, having Registered Office at ‘__’, holding CIN