IN THE COURT OF SH. SANJAY SHARMA, P.O.M.A.C.

T,

KARKARDOOMA COURTS, DELHI.

In the matter of: -

Neeraj Jain ….. Petitioner

Versus
Sunil & Ors. ………..Respondents

REPLY/WRITTEN STATEMENT TO THE DAR ON BEHALF OF

THE DRIVER AND THE OWNER OF THE VEHICLE BEARING
NO.DL-3C-AE-2951

MOST RESPECTFULLY SHOWETH:

PRELIMINARY OBJECTIONS:

1. That the petition of the petitioner is liable to be dismissed as

the same has been filed without cause of action because no
such alleged accident took place.
2. That the petition of the petitioner is liable to be dismissed as
the answering respondent was not driving the alleged
offending vehicle and the police called the answering
respondent and implicated him in the said accident.
3. That the petition is liable to be dismissed as the same has
been filed by concealing the material facts as the alleged
accident did not take place due to any negligence and rash
driving of the answering respondent.
4. That answering respondent is entitled take all defenses
available under section 154 of M.V. Act.
REPLY ON MERITS:-

1 - 14. That the contents of para no. 1 to 14 of the FORM II Part-

1 are Detail Accidental Report/ Claim petition are matter of
records and the same are denied for want of knowledge and
require strict proof. It is submitted that no such accident took
place by the answering respondent as he was not driving the
alleged offending vehicle rashly and negligently.

15. That the contents of para no. 15 of the Part-II of Detail

Accidental Report/ Claim petition are wrong and denied for
want of knowledge. However, it is submitted that no accident
took place due to the negligence of the driver of the vehicle
bearing registration no.DL-3C-AE-2951 is falsely implicated in
the above said accident with collusion of the police persons.
The petitioner is liable to put to strict proof of the same
averments made in these paras.

16. That the contents of para no. 16 of the Part-II are Detail
Accidental Report/ Claim petition are wrong and denied. The
petitioner is liable to put to strict proof of the same averments
made in these paras. It is also strictly denied that the no
accident has been occurred by the driver of the abovesaid
discussion and it is also denied that no such site plan can be
mentioned due to the above said reasons.

17- 23. That the contents of Para no. 17-23 Part-III of Detail
Accidental Report/ Claim petition are wrong and denied for
want of knowledge and the same are required to be put to
strict proof .

24-25. That the contents of Para no. 24-25 Part-III of Detail

Accidental Report/ Claim petition are matter of record.

26. That the contents of Para no. 26 of Part-III of Detail

Accidental Report/ Claim petition are wrong and denied for
want of knowledge and the same are required to be put to
strict proof .
27. That the contents of Para no. 27 of Part-III of Detail
Accidental Report/ Claim petition are wrong and denied.

28. That the contents of Para no. 28 Part-III of Detail Accidental

Report/ Claim petition are wrong and denied for want of
knowledge and the same are required to be put to strict proof .

29. That the contents of Para no. 29 Part-III of Detail Accidental

Report/ Claim petition is strictly wrong and denied because
the accident of the above said case was not occurred due to
influence of Liquor and drugs by driver. It is further denied
that the concerned authorities did not take any strong
evidence against the driver.

30-32. That the contents of Para no. 30-32 Part-III of Detail

Accidental Report/ Claim petition are wrong and denied for
want of knowledge and the same are required to be put to
strict proof

33-34. That the contents of Para no. 33-34 PART-IV of Detail

Accidental Report/ Claim petition are matter of record.

35-41. That the contents of Para no. 35-41 Part-IV of Detail

Accidental Report/ Claim petition are wrong and denied for
want of knowledge and the same are required to be put to
strict proof .

42-49. That the contents of Para no. 42-49 Part-V of Detail

Accidental Report/ Claim petition are matter of record and the
above said vehicle is insured with Future General Insurance
Co. Ltd vide policy no. 2017-V-5298898-FPV of the period of
12.10.2017 to 11.10.2018.

50-54. That the contents of Para no. 50-54 PART-VI of Detail

Accidental Report/ Claim petition are matter of record/not
denied.
55. That the content of Para no. 55 of Detailed Accidental
report/ Claim petition are matter of record.

56-57. That the contents of Para No.56-57 Part VII of Impact of

Accident on the victim need no reply.

58. That the content of Para no. 58 of Part VIII

of Detailed Accidental report/ Claim petition is wrong and
denied.

59-75. That the contents of para 59-75 of Part VIII of Apparent

Contributing Circumstance are wrong and denied.

76. That the contents of para76 of Part IX of DAR need no reply.

77-83. That the contents of para of 77-83 of Part X of DAR need

no reply.

84-109. That the contents of para of 84-109 of Part XI of DAR are

wrong and denied as all the documents mentioned in the para
under reply have not been supplied to the answering
respondent and answering respondent reserves his right to
amend his reply on the availability of the said documents .
 PRAYER

It is most respectfully prayed that this Hon’ble Court

may be pleased to dismiss the petition/DAR of the
petitioner with cost as the same has been filed by the
petitioner in collusion with the police.
.

RESPONDENT
THROUGH

COUNSEL FOR THE RESPONDENT

DELHI
DATED B.B.Sharma
Advocates
Ch. No. 274(A), Civil Wing,
Tis Hazari Courts, Delhi-110054.

VERIFICATION:

Verified at Delhi on this day of 2018 that the

contents of the above said written statement are true and correct to
the best of my knowledge and belief and nothing material has been
concealed there from.

RESPONDENTS
 IN THE COURT OF SH. MANOJ KUMAR NAGPAL, P.O.M.A.C.T,

PATIALA HOUSE COURTS, DELHI.

In the matter of: -

Baljeet Singh ….. Petitioner

Versus

Balbeer Singh & Ors. ………..Respondents

AFFIDAVIT OF SH. SAHAB SINGH, S/O SH. VIJAY PAL

SINGH, R/O H.NO- 53, SECTOR-23, RAJ NAGAR, GHAZIABAD,
U.P.

I, Sahab Singh the aforesaid deponent do hereby solemnly affirm and

declare as under:-

1. The deponent submits that he is one of the respondents

in the aforesaid matter and as such being aware with the
facts and circumstances of the case, competent to depose
herein.

2. That the accompanying written statement in the

aforesaid matter has been drafted by my Counsel, under
my instructions and the contents contained therein,
except the legal one, are true and correct to my
knowledge.

3. That the contents of the said written statement has been

read over and explained to me and each and every
contents of the said written statement is correct and the
contents of the said written statement be treated as part
and parcel of the present affidavit as the same are not
reproduced herein for the sake of brevity.
 DEPONENT

VERIFICATION:-

Verified at Delhi on the day of 2018 that the

contents contained in this affidavit are true and correct to
the best of my knowledge and belief and nothing has been
concealed therein.

DEPONENT
 IN THE COURT OF SH. SANJAY SHARMA, P.O.M.A.C.T,

KARKARDOOMA COURTS, DELHI.

In the matter of: -

Neeraj Jain ….. Petitioner

Versus

Sunil & Ors. ………..Respondents

AFFIDAVIT OF SH. MAHESH, S/O SH. SHIV CHARAN,

R/O H.NO-100/7, PILAY QUARTER, LOHIYA NAGAR,
GHAZIABAD, U.P.

I, Mahesh Pawan the aforesaid deponent do hereby solemnly affirm

and declare as under:-

1. The deponent submits that he is one of the respondent in

the aforesaid matter and as such being aware with the
facts and circumstances of the case, competent to depose
herein.
2. That the accompanying written statement in the
aforesaid matter has been drafted by my Counsel, under
my instructions and the contents contained therein,
except the legal one, are true and correct to my
knowledge.
3. That the contents of the said written statement has been
read over and explained to me and each and every
contents of the said written statement is correct and the
contents of the said written statement be treated as part
and parcel of the present affidavit as the same are not
reproduced herein for the sake of brevity.

DEPONENT
VERIFICATION:-

Verified at Delhi on the day of 2017 that the

contents contained in this affidavit are true and correct to
the best of my knowledge and belief and nothing has been
concealed therein.

DEPONENT