WS Ms Rakhi Baghel

IN THE HON’BLE COURT OF MS NEELAM SINGH, LD.
DISTRICT JUDGE (COMMERCIAL COURT)-02, SOUTH EAST

SAKET COURTS, NEW DELHI
IN REF: CS (COMM) NO. 460/2023

IN THE MATTER OF:-
M/S FASTSURANCE CONSULTANTS PVT. LTD. ---PLAINTIFF
VERSUS
RAKHI BAGHEL ---DEFENDANT
NDOH: 01-08-2023
WRITTEN STATEMENT’TO THE PLAINT/COMMERCIAL
SUIT FOR RECOVERY OF RS. 14,16,000/- INCLUDING
INTEREST @24%P.A. TILL 31-12-2022 ALONGIWTH PENDENT
LITE AND FUTURE INTEREST @24% P.A. , ON BEHALF OF
THE DEFENDANT/RAKHI BAGHEL.
MOST RESPECTFULLY SHOWETH:
PRELIMINARY OBJECTIONS/SUBMISSIONS:-
1. That present suit is not maintainable as the plaintiff has not come
before the Hon’ble Court with neat and clean hands and also
concealed the true facts from the Hon’ble Court so the same suit is
liable to be dismissed in favour of the defendant.
2. That the present suit is not maintainable as the plaintiff has no right
to recover the amount of the suit as no specific agreement (verbally
or non-verbally) regarding recovery amount made ever between the
plaintiff and defendant and the defendant had not also given any
assurance to give the recovery amount after receiving the insurance
claim which was obtained after death of her husband.
3. That INSURANCE SAMADHAN namely registered in the name
of ‘Fastsurance Consultants Private Limited’ usually cheated
through its mobile App. ‘POLIFYX’. The plaintiff usually asks his
clients to download such app in his mobile phone and make
registration with his details of insurance policy for which they
collect the registration fee of Rs. 500/- as consultation or assistance
fee. It is very important the plaitniff specifically doesn’t
tell/convey about your high commission 12% of received insurance
claim with GST during whatsapp chatting or mobile
communication.
4. That the plaintiff has just filed the present suit only for making
harassment of the defendant and her old aged father in law Sh.
Ram Avtar Pal and blackmail them. The plaintiff cheated the
defendant/applicant in the name of helping/assistance (Insurance
Samadhan) to get obtained the insurance claim from ‘HDFC Life’
after death of her husband. The plaintiff has committee the offence
under section 420 of IPC and liable to be punished.
5. That it is specifically submitted that the husband of the defendant

namely Sh. Aditya Pal S/o Sh. Ram Avtar Pal R/o B-116 Peeli
Kothi, New Ashok Nagar, Vasundhra Enclave, Delhi-110096 took
an insurance policy ‘HDFC Life Click 2 Protect 3D Plus’ vide
Policy No. 20306584 sum assured Rs. 1,00,00,000/- (policy term
40 years) from ‘HDFC STANDARD LIFE INSURANCE
COMPANY LIMITED LIFE’ commenced from 20-04-2018. The
husband of the defendant made nominee in such policy his father
and wife as SH. RAM AVTAR PAL and SMT. RAKHI BAGHEL
(defendant) respectively. Unfortunately the husband of the
defendant expired on 30-07-2020 due to heart attack suddenly in
Corona period so the postmortem was also done in ‘Dr. Ram
Manohar Lohiya Chikitsalaya, Farukkhabad, UP’ on 30-07-2020.
On 21/10/2022 the insurance claim of Rs. 50,00,000/- each was
credited by HDFC Bank in the accounts of the defendant Smt.
Rakhi Baghel and her father in law Sh. Ramavtar Pal, from
thereafter the plaintiff seeking fee/commission @12% with GST of
the aggregate amount from the defendant and continuously
blackmailing and also threatening the defendant and consequently
the plaintiff filed the false present suit only for making harassment
and torturing by mentally and economically.
6. That after death of the husband of the defendant, the father in law
of the defendant and defendant made severally attempts to get
insurance claim of her husband policy from HDFC bank but the
HDFC bank pretext every time whenever the defendant made
requests and delayed to sanction the insurance claim. Then some
person advised to visit’ Insurance Samadhan’ to get their insurance
claim immediate.
7. That it is specifically submitted that he father in law of the

defendant namely Sh. Ramavtar Pal visited the office of the same
at NOIDA and sought advice to get sanctioned insurance claim
then the employee of ‘Insurance Samadhan’ asked to pay only
Rs.500/- including GST @ 18% as consultation fee or registration
charges for making cooperation & assistance to get obtained the
insurance claim as soon as possible. Further the plaintiff asked the
defendant to download the mobile app Polifyx or login
www.insurancesamadhan.com for making the registration with the
details of your policy, as per assurance the defendant login on such
website and also download such mobile app. and made the
registration and upload the required documents.
8. That the plaintiff never demanded the recovery amount as Fee @

12% with GST of the aggregate amount as well as the plaintiff
never told the defendant about his fee mentioned above before
registration of the case during consultation. It is also proved by the
chatting made between the defendant and the plaintiff. The official
of the Insurance Samadhan only claimed Registration charge of
Rs.500/- including GST as consultation fee, the same was paid
before obtaining the amount of insurance claim. Now suddenly the
plaintiff started to demand the commission @ 12% with GST of
the aggregate amount after receiving the insurance claim amount
and they are continuously making harassment of the defendant and
her father in law.
9. That the present suit is also not maintainable as the valuation of the
suit for the purpose of court fees and jurisdiction is overvalued to
Rs. 14,16,000/- while correct valuation of the suit for the purpose
of court fee and jurisdiction is 7,08,000/- as the defendant
received only 50,00,000/- as insurance claim after death of her
husband as nominee No.2 of Policy of her husband vide Policy
No. 20306584 and the appropriate court fee is not filed by the
plaintiff as per correct valuation of the present suit. The plaintiff
intentionally paid the Ad-valorem court fee of Rs. 16,120/- for
more recovery under the malafide intention while requisite court
fee of Rs. 8,060/- only is to be filed, therefore, the suit/ plaint is
liable to be rejected or returned under order VII rule 11 of C.P.C.
due to the deceitful valuation of the suit, in the interest of justice.
10.That the defendant Ms. Rakhi Baghel never visited the office of the
plaintiff as well as consulted the plaintiff or not even accepted any
service agreement or any terms and conditions with the plaintiff. It
is specifically submitted that no agreement or contract was made
between the plaintiff and defendant at any occasions. It is also
specifically submitted that the alleged “Online Service Agreement
dated 20-08-2022” annexed as page no. 24-37 with the plaint is
false and fabricated by the plaintiff for blackmailing and harassing
the defendant. As per the Indian Contract Act of 1872 the
following conditions must be met for an agreement to be
considered a valid contract: 1.Offer and Acceptance, 2. Free
consent, 3. Capacity 4. Lawful consideration. It is specifically
submitted that E-Contract is that the contract is accepted by
means of electronic signature so the alleged online service
agreement dated 20-08-2022 does not bear the electronic
signature of the defendant nor any lawful acceptance or free
consent.
11. That it is submitted that according to section 10 of the Indian

Contract Act “all agreements are contracts if they are made by
the free consent of parties competent to contract for a lawful
consideration and with the lawful object.” Accordingly Section
10(A) of the IT Act, 2000 states, “where in a contract formation,
the communication of proposal, the acceptance of proposals, the
revocation of proposals and acceptance, as the case may be, are
expressed in electronic form or by means of an electronic record.”
It is submitted that no communication proposal was made by the
plaintiff to the defendant and no acceptance or free consent was
given by the defendant to the plaintiff by manually or
electronically(online)
12.That the plaintiff has not come before the Hon’ble Court with clean
hands in as much as there is averment of false, molded and
concocted story as such he is not entitled for any relief. The
plaintiff had sent the false legal notice dated 11-01-2023 and also
filed a false pre-institution mediation application before South-East
DLSA against the defendant, the same was replied through her
counsel Ms. Mamta Baghel, Adocate by way of filing reply dated
27-02-2023 in DLSA.
13.That it is submitted that the suit of the plaintiff is not maintainable

and liable to be dismissed with heavy cost as the defendant never
came into agreement or contract with the plaintiff company
‘Insurance Samadhan’ or with ‘Fastsurance Consultant Pvt. Ltd.’
The plaintiff is cleverly engaging the defendant Smt. Rakhi Baghel
in this case although she never consulted them or nor agreed on
any terms and conditions with the plaintiff and never
communicated with the plaintiff regarding the issue/fee. The
defendant did not avail any service from the plaintiff or never
consented to the fee of the plaintiff @ 12% with GST of the total
settlement insurance claim amount. The bill for service invoice no.
162/2022-2023 dated 24-12-2022 sum of Rs. 14,16,000/- is false
and fabricated and generated by the plaintiff under evil eye.
14.That the present suit is bad for non-joinder of necessary parties

namely Sh. Ramavtar Pal, so the present suit is liable to be
dismissed in view of non-joinder of the necessary parities. It is
submitted that defendant/wife is the second nominee of the policy
holder which was bought by her husband and for that the first
nominee is father of policy holder namely Sh. Ramavtar Pal who
also got the 50% insurance claim of the policy.
15.That the present suit of the plaintiff is not maintainable as no cause

of action ever arose in favour of the plaintiff and against the
answering defendant as such suit is liable to be dismissed being
without cause of action qua answering defendant. The present
suit/plaint is liable to be rejected under order VII rule 11 of the
Code of Civil Procedure, 1908 so the plaintiff is not entitled to get
any relief in the present matter based on false and frivolous facts.
REPLY TO PARAWISE:-
1. That the contents of para no. 1 of the plaint/commercial suit for

recovery are not concerned to the answering defendant so there is
no need to comment.
2. That the contents of para no. 2 of the plaint/suit are not concerned to
the answering defendant so there is no need to comment
3. That the contents of para no. 3 of the plaint/suit are wrong, false and
hence denied. The plaintiff must put to the strict proof of the same.
It is specifically denied that the defendant approached the plaintiff
to avail the consultancy services of the plaintiff in resolving
grievances in the field of General Insurance as she was having
disputes with HDFC life Insurance Company Ltd. In one having
policy number 20306584. It is submitted that the preliminary
objections and submissions may also be read as part and parcel of
this answering para of the plaint.
It is specifically denied that the defendant had communicated its
requirements to the plaintiff and it was agreed by the plaintiff to
provide its services for resolving issues related to consumer
grievances for insurance claim in HDFC Life Insurance company
Ltd. In one having Policy number20306584. It is submitted that the
preliminary objections and submissions may also be read as part
and parcel of this answering para of the plaint.
hence strongly denied. The plaintiff must put to the strict proof of
the same. It is specifically denied that the defendant had consented
to pay the Fees, which are equal to 12% + GST of the total
settlement of the claim awarded post the successful completion of
service as per the terms of services agreement for the consultancy
services availed.
It is specifically submitted that the plaintiff himself generated
ID of the answering defendant and made the registration of the
complaint himself on the basis of documents/details of Rakhi
Baghel provided by the First Nomine of the Policy Sh. Ram Avtar
Pal who is necessary party of the case. The answering defendant
had never given her consent by physically or electronically/online to
pay the fee @12% plus GST of the total aggregate amount. It is
submitted that the preliminary objections and submissions may also
be read as part and parcel of this answering para of the plaint.
It is specifically denied that as per the procedure of the plaintiff,
defendant was initially supposed to pay the registration fee of Rs.
500/- which was paid by the defendant against the proper
acknowledgement on 20-08-2022.
It is submitted that the plaintiff asked to pay Rs. 500/- only as
registration or consultation fee and accordingly the same was paid
by the father in law of the answering defendant as per knowledge.
Nothing was remained. No information regarding consultation fee
@ 12 % +GST was provided to the father in law Sh. Ramavtar Pal
before registration in the office situated at R-104, Greater Kailash-I,
Delhi-110048 during visitation and communication. It was only
fixed as agreement to pay only Rs.500/- as fee for providing the
consultation and services. It is submitted that the preliminary
It is specifically denied thereafter various documents in respect to
HDFC Life Insurance Company Ltd. in one having policy number
20306584 were shared which were verified and thereafter plaintiff
had decided to pursue. It is submitted that the preliminary
hence strongly denied. The plaintiff must put to the strict proof of
the same. It is specifically denied that the defendant after discussing
the merits of services to be availed decided to accept the services
Agreement on 20-08-2022 through online portal of plaintiff and
thereby agreed to avail the consultancy services of the plaintiff.
It is submitted that the service agreement dt. 20-08-2022 is
false and fabricated. It is specially submitted that the plaintiff never
discussed the merits of the services to be availed as well as fee
@12% +GST. The plaintiff intentionally neither tells about such fee
nor online service agreement. The plaintiff cheats his clients in the
garb of online services agreement and its terms and conditions
which was neither readout by the client nor to get understood by the
plaintiff to the customer. Like this it is total fraud in the name of
insurance service. It is submitted that the preliminary objections and
submissions may also be read as part and parcel of this answering
para of the plaint.
It is specifically denied as per the procedure the plaintiff gave its
utmost services and various correspondence were exchanged
between the defendant and the insurance companies which were
duly drafted and handled by the plaintiff herein on behalf of the
defendant. Further denied that Email sent on behalf of the defendant
to the insurance companies plaintiff herein was always used to be in
BCC while sending the email to the Insurance Company. It is
10.That the contents of para no. 10 of the plaint/suit are wrong, false
and hence denied. The plaintiff must put to the strict proof of the
same. It is specifically denied that the defendant after availing the
full services of the plaintiff had received a sum of Rs. 1,00,00,000/-
by the HDFC Life Insurance Company Ltd. It is submitted that the
answering defendant received Rs. 50,00,000/- only as second
nominee of her husband’s policy after his death. It is submitted that
the preliminary objections and submissions may also be read as part
and hence denied except received only Rs. 50,00,000/- in the bank
account of the answering defendant. The plaintiff must put to the
strict proof of the same. It is specifically denied that this was also
confirmed by the defendant via phone call by the executive of the
plaintiff namely Priyanshi Aggarwal having employee ID
INSA0015 from Mobile No. 9717733545 on mobile number of the
defendant herein i.e. 9870244826 on 24-12-2022 at 1.59PM and
further denied that it was also confirmed on the said phone call that
amount received is in two branches of Rs. 50,00,000/-. It is
same. It is specifically denied that as per service agreement dated
20-08-2022 after successfully receiving the sum of Rs.
1,00,00,000/- by the HDFC bank the defendant was obligated in
accordance with the terms of said service agreement, to pay the
plaintiff 12%alongwith IGST @18% as the fee for using the
plaintiff’s service within seven days of the date the fund were
credited from insurance companies to the defendant’s bank account.
It is submitted that the preliminary objections and submissions may
also be read as part and parcel of this answering para of the plaint.
same. It is specifically denied that the plaintiff on 24-12-2022 itself
has raised an invoice no. 1652/2022-23 for services to the defendant
for a total amount of Rs. 14,16,000/- including IGST18% in policy
number 20306584 of HDFC life insurance company ltd. It is
same. It is specifically denied that as per service agreement date 20-
08-2022 if the defendant fails to pay the due amount within period
of seven days after receiving the amount then defendant shall be
liable to pay interest on the value of fee which accrues to the
consultant at the rate of 24% per annum. It is submitted that the
same. It is specifically denied that the defendant failed to adhere to
repayment schedule as agreed in said service agreement dated 20-
08-2022 and started defaulting the terms of the service agreement as
agreed upon. It is submitted that the preliminary objections and
para of the plaint.
and hence denied except legal notice was received by the answering
defendant. The plaintiff must put to the strict proof of the same. It is
specifically denied that the plaintiff was constrained to issue legal
notice dated 11-01-2023 to the defendant, thereby directing the
defendant to pay the agreed amount within 7 days of receipt of the
notice.
It is submitted that the above said legal notice was false and
fabricated and only way to grab the money from the defendant in
the name of service provider. It is submitted that the preliminary
same.
and hence denied. It is submitted that the plaintiff is not entitled to
get the above said fee as consultation fee. It is submitted that the
same. It is specifically denied that the plaintiff is also entitled to
pendent lite its actual realization. And further denied that the
plaintiff is also entitled to costs and expenses incurred by the
plaintiff, in addition to the above mentioned outstanding amounts. It
is submitted that the preliminary objections and submissions may
also be read as part and parcel of this answering para of the plaint.
and hence denied except the plaintiff has filed the pre-institution
mediation application on 28-01-2023 before South East DLSA
Saket . The plaintiff must put to the strict proof of the same. It is
specifically denied that none has appeared on the behalf of
defendant. It is submitted that the defendant filed her reply to the
above said application before South-East DLSA on 27-02-2023 via
Email. Through her counsel Smt. Mamta Baghel, Advocate. (Copy
of Reply is enclosed herewith). It is submitted that the preliminary
same. It is specifically denied that the any cause of action for filing
the present suit has been arisen and cause of action is still
subsisting. It is submitted that the preliminary objections and
para of the plaint.
22.That the contents of para no. 22 of the plaint/suit are matter of

record as jurisdiction of the Hon’ble Court so there is no comment.
23.That the contents of para no. 23 of the plaint/suit are matter of

record as limitation so there is no comment.
and hence strongly denied as the valuation of the suit is overvalued
on which the recovery is sought and court fee is paid. It is submitted
that the preliminary objections and submissions may also be read as
part and parcel of this answering para of the plaint.
and hence strongly denied. The plaintiff must put to the strict proof
of the same. It is specifically denied that the transaction entered into
between plaintiff bank and defendant is commercial transaction
which come under section 2(I)(c)(x) of commercial Court Act and
as such the plaintiff is entitled to pendent lite and future interest at
the contracted rate with monthly rests as on the date this case. It is
The last para as Prayer Clause {sub-clause (i), (ii), (iii)} of the
plaint/suit is also wrong, false and hence strictly denied, so it is
liable to be dismissed with cost.
PRAYER:
It is, therefore, most respectfully prayed to the Hon'ble court
that keeping in view of the above stated true facts and
circumstances, the present Suit for Recovery of Rs. 14,16,000/-
filed by the plaintiff may kindly be dismissed with cost in favour of
the defendant , in the interest of justice.
RAKHI BAGHEL
(Defendant)
Through counsel:
MAMTA BAGHEL
Advocate
Delhi
Dated: 31-07-2023


IN THE MATTER OF:
VERSUS
RAKHI BAGHEL --DEFENDANT
AFFIDAVIT
I, RAKHI BAGHEL W/o Late Sh. Aditya Pal R/o Village-Gariya

(Dhilawal) Post-Bhopat Patti, Dhilawal, Farrukhabad, Uttar Pradesh-
209625, do hereby solemnly affirm and declare as under:
1. That the deponent is the defendant in the above noted suit and fully
conversant with the facts of the same and she is competent to swear
this affidavit.
2. That the accompanying Written Statement/Reply to the commercial

suit for Recovery has been drafted by my counsel under my
instructions and contents of the same have been read over to me in my
vernacular and the same are correct.
DEPONENT
VERIFICATION:
Verified at Delhi on this 31st day of July, 2023, that all the contents
of above affidavit are correct and true to the best of my knowledge and
nothing material has been concealed therefrom.
DEPONENT

IN THE MATTER OF:
VERSUS
LIST OF DOCUMENTS FILED BY THE DEFENDANT
SL. PAGE
NO. PARTICULARS NO.
1 Copy Aadhar Card of Rakhi Baghel Aadhar Card of
Aditya Pal and his death certificate dated18-08-2020
2 Copy of documents regarding Policy No. 20306584 of
policy holder Late Sh. Aditya Pal
3 Copy of Reply dated 27-01-2023 to the application made
by the plaintiff before DLSA South-East
4 Terms and conditions of Mobile App. namely ‘Polifyx’
5 Terms and conditions of www.isnurancesamadhan .com
6
Delhi
Dated: 31-07-2023
RAKHI BAGHEL
(Defendant)
Through counsel:
MAMTA BAGHEL
Advocate
IN THE MATTER OF:-
VERSUS
APPLICATION UNDER SECTION 5 OF ‘THE LIMITATION

ACT, 1963’ FOR CONDONATION OF DELAY FOR FILING
WRITTEN STATEMENT, ON BEHALF OF THE DEFENDANT.
MOST RESPECTFULLY SHOWETH:
1. That the applicant has filed present application U/S 5 of the

limitation act for condoning the delay for filing the written
statement. The contents of the said written statement may be read
and considered as integral part of this application and the same are
not being repeated herein for the sake of brevity.
2. That it is specifically submitted that the applicant could not file the
written statement to the plaint/suit within stipulated period i.e. 30
days as per C.P.C. from receipt the summon for settlement of issue
alongwith the copy of the suit filed by the plaintiff due to as the
party/defendant had not intimated or contacted to the advocate after
just receiving the court summon. The defendant/applicant handed
over the copy of plaint just before one week to the undersigned for
preparing the reply/written statement and also engaged him for
making appearance in the Hon’ble court.
3. That the applicant wishes to challenge the present suit and to file
her reply to same as the present suit is absolutely false and
fabricated and the same is filed only for making the harassment of
the defendant and blackmail her and her father in law. The plaintiff
cheated the defendant/applicant in the name of helping/assistance
(Insurance Samadhan) to get obtained the insurance claim from
‘HDFC Lite’ after death of her husband. The plaintiff has also
committee the offence U/s 420 of IPC and liable to be punished.
4. That the delay is near about one month in filing the written
statement due to the reasons mentioned above. The delay for filing
the reply/written statement is not intentionally or deliberately but
due to the bonafide reasons as stated above and therefore the delay
in filing the present written statement may kindly be condoned. If
the delay is not condoned then the defendant will bear irreparable
loss which cannot be compensated.
PRAYER:
It is, therefore, most respectfully prayed that this Hon’ble Court

may kindly be pleased to allow the present application being condoning
the delay about one month for filing written statement to the plaint and
the present written statement also may kindly be taken on record, in the
interest of justice.
Pass any other order which this Hon’ble Court may deem fit and
proper in view of the facts and circumstances of the case in favour of the
applicant and in the interest of justice.
RAKHI BAGHEL
(Applicant/Defendant)
Through Counsel:
MAMTA BAGHEL
Advocate
Delhi
Date: 31-07-2023

IN THE MATTER OF:
VERSUS
AFFIDAVIT
I, RAKHI BAGHEL W/o Late Sh. Aditya Pal R/o Village-Gariya

(Dhilawal) Post-Bhopat Patti, Dhilawal, Farrukhabad, Uttar Pradesh-
209625, do hereby solemnly affirm and declare as under:
1. That the deponent is the defendant in the above noted suit and fully
conversant with the facts of the same and she is competent to swear
this affidavit.
2. That the accompanying Application U/S 5 of the Limitation Act for

condoning the delay for filing the written statement has been drafted
by my counsel under my instructions and contents of the same have
been read over to me in my vernacular and the same are correct.
DEPONENT
VERIFICATION:
Verified at Delhi on this 31st day of July, 2023, that all the contents
of above affidavit are correct and true to the best of my knowledge and
nothing material has been concealed therefrom.
DEPONENT

WS Ms Rakhi Baghel

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IN THE HON’BLE COURT OF MS NEELAM SINGH, LD.

DISTRICT JUDGE (COMMERCIAL COURT)-02, SOUTH EAST

IN REF: CS (COMM) NO. 460/2023

M/S FASTSURANCE CONSULTANTS PVT. LTD. ---PLAINTIFF

MOST RESPECTFULLY SHOWETH:

5. That it is specifically submitted that the husband of the defendant

7. That it is specifically submitted that he father in law of the

8. That the plaintiff never demanded the recovery amount as Fee @

11. That it is submitted that according to section 10 of the Indian

13.That it is submitted that the suit of the plaintiff is not maintainable

14.That the present suit is bad for non-joinder of necessary parties

15.That the present suit of the plaintiff is not maintainable as no cause

1. That the contents of para no. 1 of the plaint/commercial suit for

22.That the contents of para no. 22 of the plaint/suit are matter of

23.That the contents of para no. 23 of the plaint/suit are matter of

IN THE HON’BLE COURT OF MS NEELAM SINGH, LD.

IN REF: CS (COMM) NO. 460/2023

M/S FASTSURANCE CONSULTANTS PVT. LTD. ---PLAINTIFF

I, RAKHI BAGHEL W/o Late Sh. Aditya Pal R/o Village-Gariya

2. That the accompanying Written Statement/Reply to the commercial

IN REF: CS (COMM) NO. 460/2023

LIST OF DOCUMENTS FILED BY THE DEFENDANT

M/S FASTSURANCE CONSULTANTS PVT. LTD. ---PLAINTIFF

APPLICATION UNDER SECTION 5 OF ‘THE LIMITATION

MOST RESPECTFULLY SHOWETH:

1. That the applicant has filed present application U/S 5 of the

It is, therefore, most respectfully prayed that this Hon’ble Court

IN REF: CS (COMM) NO. 460/2023

M/S FASTSURANCE CONSULTANTS PVT. LTD. ---PLAINTIFF

I, RAKHI BAGHEL W/o Late Sh. Aditya Pal R/o Village-Gariya

2. That the accompanying Application U/S 5 of the Limitation Act for

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