BEFORE THE HON’BLE COURT OF SENIOR CIVIL JUDGE,

SOUTH-WEST DELHI, JUDICATURE AT DWARKA DISTRICT

COURT
Civil Suit No. _____/2026

IN THE MATTER OF:

BHOLA PRASAD SINGH & ANR. …PLAINTIFFS
VERSUS
RANJU SINGH & ANR. ...DEFENDANTS

INDEX

[Link] Particulars Page No.

1. Index 1-2

2. Court fees 3-4

3. Memo of Parties 5-6

4. Synopsis 7-9

5. List of Dates & Events 9-10

6. Suit for Declaration U/s 34 Permanent U/s 37, 11-25

Mandatory U/s 39 of the Specific Relief Act and
Temporary Injunction U/s XXXIX of Code of Civil
Procedure along with Affidavits

7. Application U/O 39 Rule 1 and 2 read with 25-32

Section 151 of CPC along with Affidavits

8. ANNEXURE - 1 33-38
Copy of Legal Notice dated 27.09.2025 issued by
the Plaintiffs

9. ANNEXURE – 2 39-51
 Copy of Police Complaint lodged by the Plaintiffs
regarding harassment, threats and trespass

10. ANNEXURE - 3 52-64

Copy of Reply to Legal Notice sent by the
Defendants and Replication/Rejoinder thereto

11. ANNEXURE - 4 65-70

Copy of Special Power of Attorney executed by
the Plaintiffs

12. ANNEXURE - 5 71-79

Copy of Will dated 17.09.2025 executed by the
Plaintiffs

13. ANNEXURE – 6 80
Electronic evidence containing video recordings
showing harassment, intimidation and attempts
of trespass by the Defendants (along with
Section 63(4) Certificate)

14. True copy of the Aadhar Copy of the Plaintiffs 81-83

15. Vakalatnama 84

Place: Delhi
Date:
Through Counsel for the Plaintiffs

Dr Anupam Kumar Mishra

(D/4972/2015)
Lexis and Company
B1-639/4, 2nd Floor,
Janakpuri,
New Delhi – 110058
9051112233
lexisdelhi@[Link]
 BEFORE THE HON’BLE COURT OF SENIOR CIVIL JUDGE,
SOUTH-WEST DELHI, JUDICATURE AT DWARKA DISTRICT
COURT
Civil Suit No. _____/2026

IN THE MATTER OF:

BHOLA PRASAD SINGH & ANR. …PLAINTIFFS
VERSUS
RANJU SINGH & ANR. ...DEFENDANTS

COURT FEES
(Affixed on next page)

New Delhi
Date:
Through Counsel for the Plaintiffs

Dr Anupam Kumar Mishra

(D/4972/2015)
Lexis and Company
B1-639/4, 2nd Floor,
Janakpuri,
New Delhi – 110058
9051112233
lexisdelhi@[Link]
 BEFORE THE HON’BLE COURT OF SENIOR CIVIL JUDGE,
SOUTH-WEST DELHI, JUDICATURE AT DWARKA DISTRICT
COURT
Civil Suit No. _____/2026

IN THE MATTER OF:

BHOLA PRASAD SINGH & ANR. …PLAINTIFFS
VERSUS
RANJU SINGH & ANR. ...DEFENDANTS

MEMO OF PARTIES

1. BHOLA PRASAD SINGH

S/O Lt. SHRI RAM BARAT SIGNH
RZH-135, GALI NO. 9,
RAJ NAGAR PART 2,
PALAM COLONY,
BAGDOLA
SOUTH WEST DELHI,
Delhi-110077 …PLAINTIFF NO. 1

2. SHRI MANEESH KUMAR

S/O SHRI BHOLA PRASAD SINGH,
R/O RZH-135, GALI NO. 9, RAJ NAGAR PART-II,
PALAM COLONY, BAGDOLA,
SOUTH-WEST DELHI – 110077 …PLAINTIFF NO. 2

VERSUS

1. RANJU SINGH
W/O LATE AKHILESH KUMAR SINGH
R/O RZH-135,
 RAJ NAGAR-II,
GALI POLE NO. 9,
PALAM, NEW COLONY- 110045 …DEFENDANT NO. 1

2. AKILESH KUMAR SINGH

THROUGH HIS REPRESENTATIVES
S/O SHRI BHARAT SINGH
R/O RZH-135,
RAJ NAGAR-II,
GALI POLE NO. 9,
PALAM, NEW COLONY- 110045
…DEFENDANT NO. 2

Place: Delhi

Date:

Through Counsel for the Plaintiffs

Dr Anupam Kumar Mishra

(D/4972/2015)
Lexis and Company
B1-639/4, 2nd Floor,
Janakpuri,
New Delhi – 110058
9051112233
lexisdelhi@[Link]
 BEFORE THE HON’BLE COURT OF SENIOR CIVIL JUDGE,
SOUTH-WEST DELHI, JUDICATURE AT DWARKA DISTRICT
COURT
Civil Suit No. _____/2026

IN THE MATTER OF:

BHOLA PRASAD SINGH & ANR. …PLAINTIFFS
VERSUS
RANJU SINGH & ANR. ...DEFENDANTS

SYNOPSIS

That the Plaintiff no. 1 is the absolute owner and person in settled,
continuous possession of the suit property and is a senior citizen,
who along with his late wife, has been residing in the property
bearing no. S/O Lt. SHRI RAM BARAT SIGNH RZH-135, GALI NO.
9, RAJ NAGAR PART 2, PALAM COLONY, BAGDOLA SOUTH
WEST DELHI, Delhi-110077, for several decades.
That Defendant No. 1 is closely related to the Plaintiff no. 1 and,
taking advantage of the Plaintiff’s advanced age, emotional
dependence, and trust, managed to get certain documents
executed in her favour in the year 2017, without payment of any
consideration and without free, informed, or voluntary consent of
the Plaintiff no. 1.
That the said documents were obtained by fraud,
misrepresentation, undue influence, and abuse of fiduciary
relationship, and were never acted upon. Physical possession,
control, enjoyment, and maintenance of the suit property has at
all times remained with the Plaintiff no.1.
That after the demise of the Plaintiff’s wife and later the husband
of Defendant No. 1, the conduct of the Defendants changed
drastically and they started asserting false ownership claims,
interfering with the Plaintiff’s peaceful possession, and
threatening dispossession.
That bank recovery agents also visited the suit property after the
death of Defendant No. 1’s husband, revealing that loans had been
taken without the Plaintiff’s knowledge, thereby causing grave
mental trauma and exposing the fraudulent intent of the
Defendants.
That realizing the fraud played upon him, the Plaintiff no. 1
lawfully executed a registered Will dated 17.09.2025 and a Special
Power of Attorney, clearly asserting his ownership, possession,
and intention regarding the suit property, and also revoked and
repudiated the earlier fraudulent documents.
That the Plaintiffs, through his counsel, issued a detailed legal
notice dated 27.09.2025, calling upon the Defendants to desist
from interference and to acknowledge that they have no right, title,
or interest in the suit property. The Defendants sent a false and
misleading reply, which was duly rebutted by a
replication/rejoinder, clearly pointing out fraud, lack of
consideration, and absence of possession.
That despite repeated demands, the Defendants have continued
to assert illegal claims and have threatened to create third-party
interests, thereby giving rise to a clear and continuing cause of
action.
Hence, the present suit is being filed seeking declaration of title,
cancellation of fraudulent documents, and temporary, mandatory,
and permanent injunctions restraining the Defendants from
interfering with the Plaintiff’s peaceful possession or creating any
third-party rights in the suit property.

LIST OF DATES & EVENTS

[Link] Date Event

1. 2013 Plaintiff no. 1 became absolute owner
and has been in continuous possession
and enjoyment of the suit property
along with his wife

2. 24.08.2017 Certain documents were got executed in

favour of Defendant No. 1 without
consideration and by exercising undue
influence over the Plaintiff.

3. 26.05.2025 Husband of Defendant No. 1 expired;

thereafter bank recovery agents visited
the suit property for loans taken without
Plaintiff’s knowledge.

4. 17.09.2025 Plaintiff executed a registered Will and

Special Power of Attorney asserting
 ownership and revoking earlier
fraudulent arrangements.

5. 27.09.2025 Plaintiffs issued a legal notice to the

Defendants demanding cessation of
interference and acknowledgment of
Plaintiff’s title.

6. 10.10.2025 Defendants sent a false and misleading

reply to the legal notice

7. 24.11.2025 Plaintiffs sent a detailed

replication/rejoinder denying
Defendants’ claims and asserting fraud
and lack of consideration

8. Continuing Defendants continued threats of

dispossession and attempts to assert
illegal ownership rights.

9. 2026 Cause of action persists, compelling the

Plaintiff to institute the present suit.
BEFORE THE HON’BLE COURT OF SENIOR CIVIL JUDGE,
SOUTH-WEST DELHI, JUDICATURE AT DWARKA
DISTRICT COURT
Civil Suit No. _____/2026

IN THE MATTER OF:

BHOLA PRASAD SINGH & ANR. …PLAINTIFFS
VERSUS
RANJU SINGH & ANR. ...DEFENDANTS

SUIT FOR DECLARATION U/S 34 OF SPECIFIC RELIEF

ACT, 1963 AND TEMPORARY INJUNCTION UNDER ORDER
XXXIX OF CODE OF CIVIL PROCEDURE, 1908,
PERMANENT INJUNCTION U/S 37 AND MANDATORY
INJUNCTION U/S 39 OF SPECIFIC RELIEF ACT, 1963

MOST RESPECTFULLY SHOWETH:

BRIEF FACTS
1. That the Plaintiff no. 1 is a senior citizen, law-abiding citizen
and the absolute owner and person in settled, peaceful and
continuous possession of the suit property bearing NO. RZH-
135, GALI NO. 9, RAJ NAGAR PART-II, PALAM COLONY,
BAGDOLA, SOUTH WEST DELHI (hereinafter referred to as
the “suit property”). The Plaintiff no. 1 has been residing in the
suit property along with his late wife for several decades and
has never handed over possession, control or enjoyment of the
suit property to any person whatsoever.
2. That Defendant No. 1 is the niece of the Plaintiff no. 1. Due
to old age, emotional dependence, loneliness, and medical
ailments of the Plaintiff no.1 and his wife, and as the Plaintiff’s
children were employed outside Delhi at the relevant time, the
Plaintiff no. 1 and his wife placed complete trust and
confidence in Defendant No. 1 and her late husband, treating
them as their own daughter and son.

3. That abusing the said trust, Defendant No. 1 and her late
husband deliberately manipulated the Plaintiff no. 1 by false
assurances of care, maintenance and support in old age and,
by exercising undue influence, fraud and misrepresentation,
got certain documents executed on 24.08.2017, namely a
General Power of Attorney, Agreement and Will, without any
monetary consideration and without the Plaintiff’s free,
informed or voluntary consent.

4. That the said documents were never intended to be absolute

or unconditional transfers. They were executed only on the
express and implied condition that Defendant No. 1 and her
late husband would look after the Plaintiff and his wife during
their lifetime. The said condition formed the very basis of
execution of the documents and failure thereof renders the
documents void, illegal and unenforceable.

5. That soon after execution of the said documents, the

conduct of Defendant No. 1 and her late husband changed
drastically. They started treating the Plaintiff no. 1 and his wife
with cruelty, neglect and humiliation. They failed to provide
food, medicines or emotional support and subjected the
Plaintiff and his wife to constant mental torture.

6. That Defendant No. 1 and her late husband openly

expressed their malafide intentions by making shocking
statements such as: “life kitni achchi ho jayegi agar ye buddha
aur uski patni mar jaaye”, “inko zindagi bhar koi khushi na
mile”, “inko itna pareshaan karungi ki zinda murde ban jaaye”,
and even threatened to poison the Plaintiff no. 1 and his wife,
and threats of poisoning the Plaintiff no. 1 and his wife, as
recorded verbatim in the legal notice dated 27.09.2025. A copy
of the legal notice dated 27.09.2025 is annexed herewith as
Annexure – P-1.

7. That on several occasions, when the Plaintiff’s children

questioned Defendant No. 1 and her late husband regarding
the suspicious documents, they were abused in filthy
language and threatened with dire consequences, including
statements such as “aagaye bhikhari”, “property toh nahi
milegi”, and threats to call antisocial elements to beat and kill
them. These threats clearly establish criminal intimidation
and fraudulent intent. (A copy of the police complaint is
annexed herewith as Annexure – P-2).

8. That despite the execution of the alleged documents,

Defendant No. 1 was never put in physical or legal possession
of the suit property. The Plaintiff no. 1 has remained in
exclusive possession and occupation at all times. The
Defendants have never paid any taxes, bills or maintenance
expenses of the suit property, nor have they exercised any act
of ownership.

9. That after the demise of the husband of Defendant No. 1 on

26.05.2025, several bank recovery agents started visiting the
suit property on a regular basis, demanding repayment of
loans allegedly taken by the deceased without the Plaintiff’s
knowledge or consent. The Plaintiff was publicly humiliated in
his locality and subjected to immense mental trauma, fear and
defamation.

10. That when the Plaintiff no. 1 confronted Defendant No. 1

regarding the said loans, instead of clarifying the issue, she
threatened the Plaintiff’s son and daughter-in-law with false
police complaints and forcible dispossession, leaving the
Plaintiff with no option but to lodge a police complaint seeking
protection of his life, dignity and property.

11. That upon discovering the fraud, breach of trust and

criminal conduct of Defendant No. 1, the Plaintiff no.1 lawfully
revoked all previous arrangements and executed a registered
Will dated 17.09.2025 and a Special Power of Attorney,
categorically disowning Defendant No. 1 and her late husband
and declaring that they have no right, title or interest in the
suit property.
12. That the Plaintiffs thereafter issued a detailed legal notice
dated 27.09.2025 calling upon the Defendants to treat the
documents dated 24.08.2017 as cancelled and void ab initio.
The Defendants sent a false, evasive and misleading reply,
which was duly rebutted by the Plaintiff through a detailed
replication exposing their fraud, lack of consideration and
absence of possession. Copies of the reply and replication are
annexed herewith as Annexure – P-3 (colly).

13. That despite the same, the Defendants are continuously

threatening the Plaintiff no.1, asserting illegal ownership
claims and attempting to create third-party interest in the suit
property with the sole intention to dispossess the Plaintiff,
giving rise to a continuing cause of action.

14. That the documents dated 24.08.2017 are liable to be

declared null and void under Section 34 of the Specific Relief
Act, 1963 as they were obtained by fraud, misrepresentation,
undue influence and without lawful consideration, and are
further hit by Sections 13, 17, 18 and 25 of the Indian
Contract Act, 1872.

15. That the Plaintiffs has a strong prima facie case. The
balance of convenience lies entirely in favour of the Plaintiffs,
a senior citizen in settled possession, and against the
Defendants who have no lawful title or possession. Irreparable
loss and injury will be caused to the Plaintiffs if the Defendants
are not restrained.

16. That this Hon’ble Court has territorial and pecuniary

jurisdiction to try the present suit and the suit is within
limitation, as the cause of action arose upon discovery of fraud
and continues till date.

CAUSE OF ACTION
17. That the cause of action for filing the present suit has
arisen on several occasions and is continuous, subsisting and
recurring in nature. The cause of action is detailed as under:

a. That the first cause of action arose on 24.08.2017, when

the Defendants, by exercising fraud, misrepresentation
and undue influence upon the Plaintiff, who is a senior
citizen, got executed certain documents without any
monetary consideration and without free and informed
consent, on the false assurance that they would take care
of the Plaintiff no. 1 and his wife during their lifetime.

b. That the second cause of action arose thereafter when the

Defendants deliberately violated the very foundation of
the said documents and subjected the Plaintiff no. 1 and
his wife to neglect, cruelty and mental harassment,
including making statements such as “life kitni achchi ho
jayegi agar ye buddha aur uski patni mar jaaye” and “inko
 itna pareshaan karungi ki zinda murde ban jaaye”, clearly
revealing their dishonest and malafide intent.

c. That the third cause of action arose on 26.05.2025, upon

the demise of the husband of Defendant No. 1, when bank
recovery agents repeatedly visited the suit property for
recovery of loans taken without the Plaintiff’s knowledge
or consent, thereby exposing the fraud practiced upon the
Plaintiffs and causing public humiliation, fear and severe
mental trauma.

d. That the fourth cause of action arose when the Plaintiff

no. 1 confronted Defendant No. 1 regarding the said illegal
acts, and instead of resolving the issue, the Defendants
threatened the Plaintiff’s son and daughter-in-law with
false police complaints and forcible dispossession,
compelling the Plaintiffs to lodge a police complaint for
protection of his life, dignity and property.

e. That the fifth cause of action arose when the Defendants

repeatedly attempted to unlawfully enter the suit
property, harass and intimidate the Plaintiff, and interfere
with his settled possession, which acts are captured in
video recordings in possession of the Plaintiff.

f. That the sixth cause of action arose on 27.09.2025, when

the Plaintiffs issued a legal notice calling upon the
Defendants to cancel the fraudulent documents, and
 again upon receipt of a false and misleading reply,
followed by continued threats and interference despite a
detailed replication.

g. That the cause of action is continuing and recurring till

date, as the Defendants are persistently asserting false
ownership claims, threatening dispossession and
attempting to interfere with the Plaintiff’s peaceful
possession and to create third-party interests in the suit
property.

Hence, the present suit.

VALUATION & COURT FEES

18. That the Valuation of the present suit is Rs. 592 and court
fees of Rs. 100 has been annexed as follows:
a. Rs. 130 for an order of Temporary Injunction and
therefore court fees of Rs. 13 have been affixed.
b. Rs 130 for an order of Mandatory Injunction and
therefore court fees of Rs. 13 have been affixed.
c. Rs. 130 for an order of Perpetual Injunction and therefore
court fees of Rs. 13 have been affixed.
d. Rs. 200 for an order of Declaration and therefore court
fees of Rs. 20 have been affixed.
e. Rs. 2 is affixed as court fees for the Application under
Order 39 Rule 1 and 2.
The Plaintiffs hereby also declare and undertake to pay any
deficit court fees as and when ordered by this Hon'ble court

JURISDICTION

19. That this Hon’ble Court has territorial jurisdiction to

entertain and try the present suit as the suit property bearing
No. RZH-135, Gali No. 9, Raj Nagar Part-II, Palam Colony,
Bagdola, South West Delhi is situated within the territorial
jurisdiction of this Hon’ble Court.
20. That this Hon’ble Court also has pecuniary jurisdiction,
as the valuation of the present suit is well within the pecuniary
limits of this Hon’ble Court.
21. That the cause of action, wholly and in substantial part,
has arisen within the territorial jurisdiction of this Hon’ble
Court, and the present suit relates to declaration of civil rights,
cancellation of fraudulent documents and protection of settled
possession, which are matters triable by this Hon’ble Court.

PRAYER

In view of the facts and circumstances stated hereinabove, it

is most respectfully prayed that this Hon’ble Court may be
pleased to:
a. Pass a decree of Declaration under Section 34 of the
Specific Relief Act, 1963, thereby declaring that the
documents dated 24.08.2017, including the alleged
General Power of Attorney, Agreement and Will purportedly
 executed in favour of the Defendants in respect of the suit
property, are null, void, illegal, inoperative, obtained by
fraud, misrepresentation and undue influence, without
consideration, and not binding upon the Plaintiff in any
manner whatsoever;
b. Pass a decree of Permanent Injunction under Section 37 of
the Specific Relief Act, 1963, restraining the Defendants,
their agents, associates, representatives or any person
claiming through or under them from selling, transferring,
alienating, mortgaging, leasing, parting with possession of
or creating any third-party interest in the suit property in
any manner whatsoever;
c. Pass a decree of Permanent Injunction restraining the
Defendants from forcibly dispossessing the Plaintiffs or
from interfering in any manner whatsoever with the
Plaintiff’s peaceful, settled possession, occupation and
enjoyment of the suit property;
d. Pass a decree of Mandatory Injunction under Section 39 of
the Specific Relief Act, 1963, directing the Defendants to
hand over and deliver to the Plaintiffs all original
documents, if any, pertaining to the suit property obtained
through fraud and misrepresentation, and to cease and
desist from asserting or claiming any right, title or interest
in the suit property;
e. Grant an order of Temporary Injunction under Order
XXXIX Rules 1 & 2 of the Code of Civil Procedure, 1908,
restraining the Defendants, during the pendency of the
present suit, from creating any third-party interest, from
 dispossessing the Plaintiff, and from interfering in any
manner with the Plaintiff’s peaceful possession of the suit
property;
f. Direct the Defendants to maintain status quo with respect
to title, possession and nature of the suit property during
the pendency of the present suit;
g. Award the costs of the suit in favour of the Plaintiff and
against the Defendants; and
h. Pass such other or further order(s) as this Hon’ble Court
may deem fit and proper in the facts and circumstances of
the present case.

New Delhi
Date:

Through Counsel for the Plaintiffs

Dr Anupam Kumar Mishra

(D/4972/2015)
Lexis and Company
B1-639/4, 2nd Floor,
Janakpuri,
New Delhi – 110058
9051112233
lexisdelhi@[Link]