ANTICIPATORY BAIL APPLICATION

CRM NO. XXX/20**.

IN THE MATTER OF :-

XXXXX : PETITIONERS

V E R S U S

XXXXX : RESPONDENTS

D.O.H.: …………….

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANTS No.5 & 6.

PRELIMINARY SUBMISSION :-

1.   That assuring answering Defendants no.4 & 5 have no objection in the aforesaid petition filed by the petitioners and answering defendants admitted the facts of the petition.
   

REPLY ON MERITS :-

1.   That the contents of para 1 of the petition is matter of record, hence need no reply.
   

2.   That the contents of para 2 of the petition is admitted.
   

3.   That the contents of para 3 of the petition admitted, hence need no reply.
   

4.   That the contents of para 4 of the petition is admitted.
   

5.   That the contents of para 5 of the petition need no reply.
   

6.   That the contents of para 6 of the petition is admitted.
   

7.   That the contents of para 7 of the petition needs no reply.
   

8.   That the contents of para 8 of the petition needs no reply.
   

9.   That the contents of para 9 of the petition, needs no reply.
   

10. That the contents of para 10 of the petition, needs no reply for want of knowledge.
    

11. That the contents of para 11 of the petition is admitted.
    

12. That the contents of para 12 of the petition needs no reply.
    

13. That the contents of para 13 of the petition is admitted.
    

      Prayer clause of the plaint is admitted to this extent that the Plaintiff is only entitle for share of the suit property.

DELHI DEFENDANTS No.5&6

THROUGH

DATED

      COUNSEL

      Verified at Delhi on this ____ day of April, 2017 that the contents of the written statement paras 1 to 13 of my reply on merits are true and correct to my knowledge and para 1 of my submission are legal in nature and which are received on information and believe to be true and correct and the last para of my written statement is the reply to the prayer clause which is true and correct to my knowledge.

DEFENDANTS No.5 & 6

CRM NO. XXX/20**.

IN THE MATTER OF :-

XXXXX : PETITIONERS

V E R S U S

XXXXX : RESPONDENTS

1.   That I am the Defendant No.6 in the above said case and in that capacity I am well conversant with the facts and circumstances of the case and competent to swear this Affidavit.
   

2.   That the contents of the accompanying written statement has been drafted by my counsel under my instructions, and I have understood the meaning and implications of the facts stated and averments made therein and say that the same are correct and are not being reproduced herein to avoid repetition and the same may be taken as part and parcel of this affidavit.
   

DEPONENT

      Verified at Nagpur, on this _____, day of April, 2017 that the contents of this affidavit are true to my knowledge and nothing material has been concealed therefrom.

DEPONENT

CRM NO. XXX/20**.

IN THE MATTER OF :-

XXXXX : PETITIONERS

V E R S U S

XXXXX : RESPONDENTS

1.   That I am the Defendant No.5 in the above said case and in that capacity I am well conversant with the facts and circumstances of the case and competent to swear this Affidavit.
   

2.   That the contents of the accompanying written statement has been drafted by my counsel under my instructions, and I have understood the meaning and implications of the facts stated and averments made therein and say that the same are correct and are not being reproduced herein to avoid repetition and the same may be taken as part and parcel of this affidavit.
   

DEPONENT

      Verified at Nagpur, on this _____, day of April, 2017 that the contents of this affidavit are true to my knowledge and nothing material has been concealed therefrom.

DEPONENT