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Court Case for Recovery of Money

The document is a case information format for a civil lawsuit filed by Mr. Akhileshwar Jha against Mr. Dhananjay Shahi and others for the recovery of money amounting to ₹2,10,000. It includes details about the plaintiff, defendants, their addresses, and the legal representation involved. The case is being heard in the Karkardooma District Court, Delhi, under Order XXXVII of the Code of Civil Procedure, 1908.

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0% found this document useful (0 votes)
147 views264 pages

Court Case for Recovery of Money

The document is a case information format for a civil lawsuit filed by Mr. Akhileshwar Jha against Mr. Dhananjay Shahi and others for the recovery of money amounting to ₹2,10,000. It includes details about the plaintiff, defendants, their addresses, and the legal representation involved. The case is being heard in the Karkardooma District Court, Delhi, under Order XXXVII of the Code of Civil Procedure, 1908.

Uploaded by

saurabh28th
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

@

co. ZX
CASE INFORMATION FORMAT
SEM IEE. CTE. U rue
ine crn? LY CHE. MUTE. COUNRTOE : <tiiinal|
i PLAINTIFF
secant
/ PETITIONER / COMPLAINANT
oo
/ APPELLANT / DECREE HOLDER
ee
ETC.
Ti«x
iNo.| PLEASE FILL UP ALL THE RELEVANT FIELDS & (*) FIELDS ARE MANDATORY) cay
4 | Name Of The Plainuft/| AA AZLESH OAC -— OXA/A
| | Complainant / Ete. 7 AAvocatc.\
=x - = a
2 | Slo W/o Dio [ti FICK SESH LIAR — Dod
3 | Address SD | a FOEK £7, DE t. SYA L
GARDEN, DELL — 1100957
4 Aadhar Card No. YJZo aGoqs I< 15 Pin Code: {76095

Gender Mate | =, aa Other Nationality|___!NDIAN_ 7


3 Other:
6 | Date of Birth Ah Og tf IGF S| Age eC)
7 | Mobile No. WS beF] usc SF e-mail: Ahi Lines i] pail fer
8 | Act/ Section ORDER 3 Aol 626,190, PRE
[2). , 251% 6dof— Court Fee Ascetair nae a 4 oe (—
8 Vaiuation of Suit
Court Fee paid / Dep: patter ey Ybe/—
1G | Potice Station Se CM PUZ ZL BS. __tn Criminat ae only
a1 | [Link]. No. & Year in Crimina! Matters only
|S. DEFENDANTS ACCUSED / RESPONDENT JUDGEMENT DEBATER ETC.
No.| PLEASE FILL UP ALL THE RELEVANT FIELDS & (*) FIELDS ARE MANDATORY).
Name Of The Jo des
1| DEFENDANTS ACCUSED ad Dharon y Shoh, A . Poles Slob
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2 Ve
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a | Adares | #-2-/ 969, Cob au; 21, Sadfumh dosed
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4 | Aadhar Card No. GIG) /92¢ 660 7 PinCode:; //20 ce ;
5 Gender | Niale (7 | Femate Other Nationality}. 7 (NOIAN =
6 | Date of Birth le / a ds ce Age vl ve
; GSHCTICETYA
7_| Mobile No. 93737 FCOCO2, 43754483, e-mait: Hh, Ai readline FraaiHlon
e ADVOCATE FOR PLAINTIFF / COMPLAINANT / PETITIONER / DECREE HOLDER | ETC,

1 IName Of The Advovate| °4CRALH AuprhR ZOCAPAL & Birt Mine.


Enrl. No.
N Office / Chamber No. | €-5O6, Kav kav colon, Sires
Tal FICT Court, dD
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ROBIE
COURT OF
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ANail:
1S6OW MES, Obhilno.2
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Og mal Can. i

Sue 196, Sec 62 NOIDRAPURAM


758 JIT KHAN rac gt5 TED BY :. SHURABH. ae LMWIE. 2,
Sect

Ch. No.
ies [Link] 69:
ee "o4 WW. ? (ACCUSED ( OTHER + ADVOCATE.
MODs PEA 4
mE 3 PpEraiwant
@
IN THE COURT OF HON’?BLE SENIOR CINIL”
JUDGE, (DISTRICT SHAHDARA), KARKARDOOMA DISTRICT
COURT, DELHI
CS CASE No. /2025

IN THE MATTER OF:


Mr. AKHILESHWAR JHA ... PLAINTIFF

VERSUS
_ Mr. Dhananjay Shahi & ORS. ..D EFENDANTS
kaj

oe Al 20 AMUN HAA az INDEX


A

[s. PARTICULARS © [Link]


[Link] ">

ay
ad

MEMO OF PARTIES
PLAINT FOR RECOVERY OF MONEY (@).
2,10,000/- UNDER SUMMARY ete 7
PROCEEDINGS, ORDER 37 READ WITH
SECTION 151 OF C.P.C, 1908 ALONG
WITH AFFIDAVIT OF THE PLAINTIFF.
i LIST OF DOCUMENTS/RELIED ALONG
WITH ANNEXURE NO:P/1 — P/28

@2h
APPLICATION UNDER SECTION 151
OF THE CODE OF CIVIL PROCEDURE,
1908 ON BEHALF OF THE PLAINTIFF/
APPLICANAT SEEKING EXEMPTION FROM
252-254
FILING THE ORIGINAL/ TRUE TYPE OR
FAIR COPY OF THE ANNEXURES ALONG
WITH AFFIDAVIT OF PLAINTIFF.

Is CERTIFICATE UNDER SECTION 63(3)


OF THE BHARATIYA _SAKSHYA
255-256
ADHINIYAM, 2023,
ON BEHALF OF THE PLAINTIFF

iM VAK. AO EHALF O ey)

PLAINTIFF.
248).
20 (=
Duplicate copy of the suit
<br>

PLAINTIFF
AKHILESHWAR JHA
Place: DELHI
DATED: 29.8.2025

THROUGH

SOLAN
SAURABH KUMAR (BA, LLB,
INDIA
AdvocateSUPREME COURT OFNOIDA
Secc62
No. 202, H-196,KHAND
62 1, INDRAPURAM
Ch. 1057,. NITI
[Link]@[Link]
E-mail : 9456934987
Mob.:
[Binay Kumàr andSaurabh Kumar Solanki &
ASSOT.]
ADVOCATE FOR THE PLAINTIFF
E-506, KKD COURT, DELHI
Mobile No. 9560714537
E
mail: akhilno.2@[Link],
IM IA HOM BLES. Covey oe SENIOR. CINMILGLag
CPLSTETLT SHAH DAE AD, kAPF KA Deepa fate
vet HI
CS L4be por f 242°

GOVERNMENT OF NCT OF DELHI


e-Court Fee

DATE & TIME : ‘ 29-AUG-2025 11:43:04


NAMES OF THE ACC/ REGISTERED USER : SHCIL
LOCATION : . ' SUPREME COURT'OF INDIA
NAME OF LITIGANT : AKHILESHWAR JHA
e-COURT RECEIPT NO: DLCT2901H2542L092
e-COURT FEE AMOUNT : %4400
( Rupees Four Thousand Four Hundred Only)

DLCT2901H2542L092 2

Statutory Alert : The authenticity of this e-Court fee receipt should be verified 4 [Link] . Any discrepancy in, the|

details on this receipt and as available on the website renders it invalid. In case . of any discreparicy please inform the Competent]

¥ Authority. This recelpt is valid only after verification & locking by the Court Official. } “df

y na rs e: a “—" ™ qj * ~~
&

IN THE COURT OF Hon’ste CE NDT OR: CIVIL


3 7 JUDGE, (DISTRICT SHAHDARA),
KARKARDOOMA DISTRICT COURT, DELHI
CS CASE No. /2025

IN THE MATTER OF:


Mr. AKHILESHWAR JHA ... PLAINTIFF

VERSUS

Mr. Dhananjay Shahi &O RS. ...DEFENDANTS


MEMO OF PARTIES

Mr. AKHILESHWAR JHA ~


age about Z@years.
R/o: 38- B, SG Pocket,
DDA Flats,
Dilshad Garden,
Delhi - 110095
Mobile No: 9560714537 ... PLAINTIFF
Versus
(1): Mr. Dhananjay Shahi
S/o Late Shri Vishvanath Shahi
age about 52 __~years
MOBILE NO: 9873770002 AND 9810940743
E’maibaddress: shahiroadlines@[Link]
.. shahidhananjay12@[Link]
(2): M#"ADARSH SHAHI, ,,,
S/o Mr. Dhananjay’Shahi
age about 22 years
MOBILE NO: 9873770003
(3): Mrs MUNNI SHAHI
W/o Mr. Dhananjay Shahi
age about 48 years
MOBILE NO: 9873770002 AND 9810940743

ALL PRESENTLY AND PERMANENT RESIDENT AT:


R/o A-2/ 469, Gali No. 21,
Subhash Kansal Marg,
Harsh Vihar,
Delhi - 110093
<br>

F
HAVING OFFICE NAMELY AT:
R/o A-2/ 469, Gali No. 21,
Subhash Kansal Marg,
Harsh Vihar,
Delhi - 110093
GST NO. o DQp PS Y3b6 Di2P
...DEFENDANTS

Place: DELHI
PLAINTIFF
AKHILESHWAR JHA
DATED:29. 08 .2025
THROUGH

[Binay Kumar and Saurabh Kumar


Solanki & ASSOT.]
ADVOCATE FOR THE PLAINTIFF
E-506, KKD COURT, DELHI
Mobile No. 9560714537
E
mail: akhilno.2@[Link],

KUMAR SOLANKI
(BA, LLB,
LLM)
ŠAURABH OF INDIA
Advocate
SU UPREMECOUr2 NOIDA INDRAPURAM
Ch. No. 202, H-196,
NITI KHAND 1,
:[Link]@[Link]
1057,
E-mail
Mob.:
9456934987
@
IN THE COURT OF HoweBle SENWTOR: CINIL
JUDGE, (DISTRICT SHAHDARA),
KARKARDOOMA DISTRICT COURT, DELHI
CS CASE No. /2025
IN Re:-
Mr. AKHILESHWAR JHA
age aboutZ@ years.
R/o: 38- B, SG Pocket,
DDA Flats,
Dilshad Garden,
Delhi - 110095
Mobile No: 9560714537 ... PLAINTIFF
Versus
(1): Mr. Dhananjay Shahi
S/o Late Shri Vishvanath Shahi
age about 52 years
MOBILE NO: 9873770002 AND 9810940743
E mail address: shahiroadlines@[Link]
shahidhananjayi2@[Link]
(2): Mr. ADARSH SHAHI
S/o Mr. Dhananjay Shahi
age about 22 years
MOBILE NO: 9873770003
(3): Mrs MUNNI SHAHI
W/o Mr. Dhananjay Shahi
age about 48 years
MOBILE NO: 9873770002 AND 9810940743
ALL PRESENTLY AND PERMANENT RESIDENT AT:
R/o A-2/ 469, Gali No. 21,
Subhash Kansal Marg,
Harsh Vihar,
Delhi — 110093
HAVING OFFICE NAMELY AT:
R/o A-2/ 469, Gali No. 21,
Subhash Kansal Marg,
Harsh Vihar,
Delhi - 110093
GSTIN Number: 07DQDPS4366D1ZP ... DEFENDANTS
POLICE STATION: Seema Puri
<br>

2
SUIT UNDER ORDER XXXVII READ WITH SECTION 151 0F CPC,
1908 FOR RECOVERY OF MONEY WORTH (E), 2,10,000/
(RUPEES TWO LAKH AND TEN THOUSAND ONLY) ALONG WITH
THE INTEREST RATE OF 12% PER ANNUM FOR COMMITTING
DEFAULT BY NOT MAKING THE PAYMENT OF PROFESSIONAL
LEGAL FEES BILLS.
Most respectfully showth :
1): That the Plaintiff is law-abiding citizen of India and has deep faith
in the Law and Order. The Plaintiff is being practising
adVocate
registered with the Bar Council of Delhi and is practising before the
various Hon'ble Court of law which are situated within the sovereign
territory of Republic of India.

2): That the plaintiff is the man with good reputation in the society.
That, Plaintiff is the permanent resident of the above mention
address.

3): That the Defendant No.1is having the family relation with the plaintiff
since from a long time and the Defendants earlier was residing at
the same nearby locality of the plaintiff. That for the sake of the
convenience for this Hon'ble Court of Lawthe "Mr. Dhananjay Shahi
hereinafter referred as Defendant No. 1/defaulter No. 1" "Mr. Adarsh
Shahi hereinafter referred as Defendant No.2/defaulter No.2" "Mrs.
Munni Shahi hereinafter referred as Defendant No.3/defaulter
No.3"

4): That the Plaintiff is very well known personality to the Defendants
family andthe Plaintiff is very aware of the Defendants
because one
of the Defendant No.1 Dhananjay Shahi use to run his petty shop
of grocery in the nearby residential locality of SG pocket and his
shop is just located 200 meters away from the Plaintiff resident.
<br>

That ealicr Defendant No.1 shop is situated at the L pocket DD,


market, Dilshad Garden, Delhi- [Link] the Defendant tNo.1is
very well aware with the family menbcrs of the Plaintiff, as the
Plaintiff family members were habitual to buy grocery products frorm
defendant No.1 petty shop which is run by Mr. Dhananjay Shahi,
Mr. Adarsh Shahi and Mr. Jainendra Shahí. Hence all the
Defendants are very well aware of the Plaintiff since frorn his
childhood and the Plaintiff is very well aware with all the Defendants
since from his childhood.

5): That since from very long time the Defendant no.1 and 2 had the
social and native cordial relationship with the Plaintiff family. That
the Plaintiff is aware of all the Defendants since from hís chíldho0d,
to entering into and, to practising into his legal profession.
Meanwhile the Defendant No.1 has transformed his small shop of
groceryin the office of Shahi Road line, whích is his trucking
business.

6): That when one of the Defendant No.1 Dhananjay Shahi started his
new trucking business, the Defendant No.1 had faced the miserable
problems because of his business rivalry in the local market and
Defendant No.1 is unable to handle them alone without the legal
support.

7): That the Defendant No.1 had approached to the Plaintiff in the years
2022 for the legal assistance, legal opinion and for legal
conferences. That since from the 2022 to July, 2025 Defendant No.1
is in consistent touch with Plaintiff and Defendant No.1 taking
Plaintiff paid legal services for the different kind of matters at the
<br>

different point of time. That the legal and professional services


which the Plaintiff had provided to the Defendant No.1 are all
paid
professional legal services and nothing is for pro bono. That for
each
and every single legal service the Defendant No.1 was charged with
the fees and at the various intervals the varioUs fees bills were
raised upon the Defendant No.1.

8): That The Plaintiff has every time raised professional fees bill upon
the Defendant no.1 through the electronic platform of
What app
messages which is an accepted practise in between
both the parties;
but Defendant no.1 was consistently habitual of being
committing
the consistent default in making the payments of the fees at the
various intervals point of time since from year 2022 to March 2025.
That the Defendant No. 1 had never paid his fees on tíme,
that the
Defendant is very much habitual since from the beginning of the
time to first get his legal work done and then to pay off his legal
fees liabilities which the Defendant no.1 owes to
the Plaintiff
(Advocate).

9): That their prevails a common understanding in between the


Defendant No.1 and in between the Plaintiff that whatever legal
work the Plaintiff will perform into Defendant favour, for
each work
the Defendant No.1 will becharged with the different rate and fees
for different assignments and legal works. That each legal
work will
have itS own different cost and fees and for each legal work
and
assistance proper quotations were served upon Defendant No.1 for
his consent, the legal work was always started when the Defendants
No.1 had gave his expressed consent upon
the proposal and upon
the fees to the Plaintiff. That every time the legal services were
<br>

performed into the Defendant No.1 favour in advance and after then
it is Defendants No.1 had paid the bills, as Defendants No.1 had

always being a wilful and deliberate defaulter.

10): That the Plaintiff use to perform various legal activity and
professional due diligence for the protection of the Defendants legal
interest, for the protection of his family, for his trucking business
from the unlawful and unwanted social personality and have also
protected the Defendant No.1 from the various litigation process
and from the various criminal complaints which were filed against
the Defendant No.1 before the Seemapuri Police station and before
the Jyoti Nagar Police Station.

11):That for the above mention process and for above mention litigation
work and for other professional services the fees bill were raised
upon the Defendant No.1 and the Defendant No.1 had paid all the
previously fees bill till February, 2025. That the Plaintiff had put the
Defendant No.1 at liberty to pay off his entire pending bill by the
way of instalments, but Defendant No.1 had intentionaly never paid

the legal fees bill on time rather the Defendant No.1 always being

the fees defaulter. That after March, 2025 the various new and fresh
bills were raised upon the Defendant No.1 for the new legal

professional work which was performed into the Defendant No.1


favour.

12):That, the Defendant No.1 being satisfied with the legal services of
the Plaintiff, he has issued the authority letter upon his official letter
head vide dated: 23rd of January, 2023 bearing reference No.
9873770002 in the name of "SHAHI ROAD LINES" which contain his
<br>

signature, his GSTIN Number: 07DDPS4366D1ZP and contain his


official scal upon the authority letter. The Letter was issued by
the
Defendant No.1 the favVour of the Plaintiff with an intention and
in

determination that the Plaintiff will protect his all legal interest and
legal issues and represent the Defendant No.1 and his trucking
business before any lawful authority and before any Hon'ble Court
which is establish within the territorial jurisdiction of India. That
the
letter which the Defendant No.1 had issued into the faVour the
Plaintiff expressly contain all the conditions and expressly mention
his wilful consent upon the terms of specialised legal skills which
the
Plaintiff need to perform into his favour which varies from cases to
case and the Defendant No.1 expecting
the same skills from the
Plaintiff to be exercised into his favour. That the Plaintiff has
acted
into Defendant No.1 favVour by placing his reliance upon this true
authority letter which was executed into Plaintiff favour and, by
which the Defendant No.1 had delegated all the legal powers
into
the favour of the Plaintiff.
13): That even today when this Plaint is filed before the Hon'ble Court of
Law the Defendant No.1 has neither
terminated the legal services
authority which he has executed in the favour of Plaintiff through
the letter dated 23rd of January, 2023 nor does the Defendant No.1
has ever revoked any advocate and client relationship which was
established by the authority letter dated 23rd of January, 2023 and
there use to prevails a coordinative relationship in between both the
Parties upon the common understanding.

14): That the Defendant No.1 had further authorised the Plaintiff to
represent the Defendant before the Various Hon'ble Court
of law
<br>

and before the various legal authority, for which the Defendant No.1
had executed various documents of extreme relevance and
importance into the favour of the Plaintiff and authorising the
Plaintiff to use it whenever it is required urgently to represent the
Defendant No.1 legal interest. That from the long going on implied
and expressed practise and understanding in between the
Defendant No.1 and the Plaintiff it is very fairly clear that upon the
various occasion the Plaintiff had acted and used his professional
legal skills to protect Defendant No.1 and his trucking business legal
interest. That allthe legal acts were performed into the Defendant
No.1 favour only after his expressed message or by telephonic
expressed consent and, upon ever occasion the Plaintiff had made
the Defendant No.1 aware of the facts and circumstance of the case
and legal issues which may or might prevails against him at the
various point of time and in the various different matters. That the
Defendant No.1 has delegated all the legal power in the favour of
the Plaintiff, through which he was authorised the plaintiff to
represent the Defendant No.1and histrucking business before any
Concerned authority.

15): That the Plaintiff has upon the Defendant No.1 expressed, deemed
expressed and implied instructions have appeared for the Defendant
No.1 inthe various matter ie appeared several time before the
Seemapuri police station, appeared before the Hon'ble Court of Mrs
Niharika Kumar Sharma Senior Civil judge cum Rent Controller,
Shadhara District, Karkardooma Court: in the matter of Mohd Aslam
vs. Dhananjay Shahi, further has appeared many time before the

Hon'ble Court of Shri. Ankur Jain TI District Judge: in the matter of


<br>

Aarti Mishra vs.


Dhananjay Shahi, Shadhara, KarkarDooma District
Court, has appeared before the Hon'ble Court of Shri Rahul
Sainai,
Judicial Magistrate First Class, Shadhara, Karkardooma
District
Court :
in the matter of Raj Kumar vs. Dhananjay Shahi
in case
number CT: 48Z/2025, has appcared before the Hon'ble Court
of Shri Deepankar Mohan, District Judge, Shadhara, Karkardooma
District Court: in the matter of Raj Kumar vs.
Dhananjay Shahi in
case number CS: 242/2025.
16): That upon Defendant No.1 expressed instruction the Plaintiff
has
performned various legal duties at various point
of time on the
Defendant No.1 demand for the protection of the Defendant No.1
and his trucking business to the best of his ability, knowledge
and
legal skills.

17): That for the above mentioned bundle of work the Defendant No.1
had did the promised to the Plaintiff to pay the fees for different
Work at different point of time. That the Defendant had paid the
various fees for various Works to the Plaintiff which The Plaintiff had
risen upon the Defendant No.1 in the form of legal services bill at
the various point of time. That the Defendant No.1 is habitual of not
paying his professional legal fees bill on time and habitual of
committing the wilful and deliberate default by not paying his part
of professional legal services fees on time. That further the
Defendant No.1 usually pays off his fees in default after some time
other than the time for which it is fixed for or expected from him or
had never paid the fees upon the day when it is fixed for.
<br>

18): That whatever legal services which the Plaintiff has provided to the
Defendant No.1 at the various point of time he had made the
payment of fees for various legal services by the mode of online
transaction, that majority of the fees is paid by the mode of UPI
virtual ID transaction from Defendant No.1 bank account to Plaintiff
bank account. That the Plaintiff has consistently raised the various
professional legal services bill upon the Defendant No.1 since from
the year of 2022 to till March 2025, for which he had made the
payment of approximately (). 1,86,172/-. This clearly expressed
that their prevails the relationship of the Advocate and client in
between both the Parties and at the various point of time the
Defendant No.1 had made the breach of his promises, but when the
Plaintiff had issued the final ultimatum and warning to the
Defendant No.1 that he might face the strict legal action, it is only
then the cheater Defendant No.1 had cleared allthe due which
prevails in the form of charges upon the Defendant No. 1 which were
in the form of legal professional services bill. That the details of the

payment of the legal professional fees bill of which the Defendant


No.1 had made the payment in the favour of Plaintiff is mentioned

and reflected as below:

Table of fees paid from 24.05.2023 to February, 2025.


[Link]. DATE AMOUNT TXN APPLICATION
(INR) MODE

24/5/2023 7,500/ UPI GOOGLEPAY


1:
GOOGLEPAY
2: 29/5/2023 5,000/ UPI
7,500/ UPI GOOGLEPAY
3: 1/6/2023
GOOGLEPAY
4: 1/6/2023 5,000/- UPI
<br>

5: 8/6/2023 5,000/- UPI GOOGLEPAY


6: 20/6/2023 3,000/ UPI GOOGLEPAY
7: 1/7/2023 4,000/ UPI GOOGLEPAY
8: 31/7/2023 13,500/ UPI GOOGLEPAY
9: 21/8/2023 6,000/ UPI GOOGLEPAY
10: 1/9/2023 5,000/ UPI GOOGLEPAY
11: 2/9/2023 5,000/ UPI GOOGLEPAY

12: 13/9/2023 300/ UPI PAYTM


13: 26/9/2023 4,000/ UPI GOOGLEPAY
14: 2/11/2023 5,000/ UPI GOOGLEPAY
15: 4/11/2023 5,000/- UPI GOOGLEPAY
16: 17/11/2023 1,000/ UPI GOOGLEPAY
17: 23/11/2023 2,100/ UPI GOOGLEPAY

18: 1/12/2023 5,000/ UPI GOOGLEPAY


19: 3/12/2023 5,000/ UPI GOOGLEPAY
20: 14/12/2023 1,500/ UPI GOOGLEPAY
21: 5/1/2024 5,000/ UPI GOOGLEPAY
22: 6/1/2024 5,000/ UPI GOOGLEPAY
23: 6/2/2024 5,000/ UPI GOOGLEPAY
24: 7/2/2024 7,000/ UPI GOOGLEPAY
25: 7/03/2024 26,700/- UPI GOOGLEPAY
To February, and PAYTM
2025 42,612
Total amount till 1,86,712/
February, 2025
19. That it is evident from the above mention facts and from the UPI
payment transactions description which the Defendant No.1 had
made into the favour of the Plaintiff at various intervals and at
various point of time, that the Defendant No.1 had taken the
specific professional legal services from the Plaintiff in the past time
and for the same the Defendant No.1 had paid for legal expenses
<br>

bill for the profesional legal services which were rendered to him
by the Plaintiff.
Pending Professional legal fecs for worth (). 1,00,000/
raised against Defendant No.1, 2 and 3 for performing the
specific specialised legal skills of drafting, pleading
"Written Statement, Counter Claims and various
Applications" and appcaring before the Hon'ble Court of
Law in the matter of RAJ KUMAR Vs. DHANANIAY SHAHI
and ORS. IN CASE NUMBER CS: 242/2025 BEFORE THE
HON'BLE COURT OF SHRI DEEPANKAR MOHAN, DISTRICT
JUDGE, SHADHARA, KARKARDOOMADISTRICT COURT.

20. That the Defendant No.1 on one day called out the Plaintiff
telephonically and, the Defendant had narrated all the factual
position of his and of his family member in regard to one civil
original suit for recovery of money for worth (E). 13 Lakhs which
was instituted by one Mr. Raj Kumar Bhati against the Defendant
No.1, his family and against his trucking business. That the
Defendant No.1 had shared his litigation problem with the Plaintiff
through the way of what's app electronic message vide dated 21st
of April, 2025, in that message the Defendant No.1 had shared the
3 different kind of PDF files which contain the summon of Order 5
of CPC which was issued by the Hon'ble Court of Shri Deepankar
Mohan, District Judge, Shadhara, Karkardooma District Court: in the
matter of Raj Kumar vs. Dhananjay Shahi in case number CS:
242/2025against the Defendant No.1, his Son Mr. Adarsh Shahi
and, his wife Mrs. Munni Shahiwhercin all the defendants made the
defending and alleged party by Mr. Raj Kumar and by the Hon'ble
Court of Law. That the Defendants had asked the Plaintiff to provide
his legal opinion and, for the same the Plaintiff had provided his
legal opinion to the Defendant No.1 and Defendant No.2 through
<br>

telephonic conversation and through physical meeting at various


places only after appointment upon the civil recovery matter.
21. That upon Defendant No.1 instruction the Plaintiff has started to
work out upon various application under Order 1 rule 10 and rule
13 read with section 151 of CPC for the Defendant No.1 separately
containing all the relevant factual position and objection and,
another application under Order 1 rule 10 and rule 13 read with
section 151 of CPC for Defendant No.1 Son Mr. Adarsh Shahi and,
for his wife Munni Shahi, who were defendant No. 3 and 4 in the
respective Plaint which was filed by Mr Raj Kumar. That further
another combined application under Order 7 rule 11 read with
section 151 of CPC was prepared and made into the favour of
Defendant No.1, Defendant No.2 his son and Defendant No.3 his
wife. Further the complete written statement and the Counter Claim
under order 8 and Rule 6A (1) of CPC has been drawn, encrypted
and pleaded into Defendant No.1 favour, for his Son Mr. Adarsh
Shahi and, for his wife Mrs. Munni Shahi and for his trucking
a
business after doing lengthy legal discussion with the Defendant
No.1.
22. That further when the written statement and counter claims were
completed by the Plaintiff, it is
then the Plaintiff has consistently
demanded various documents in the form of annexures from
22.06.2025 to 25.06.2025 which the Defendant No.1 had send and
provided to the Plaintiff through the what's app message vide dated
25.06.2025 to do a scrutiny and to made those dOcuments a part
of written statement which was completely drafted into Defendant
No.1, 2 and 3 favour. That further on 12th of July the Plaintiff had
<br>

through the way of What's app message had send and shared
another annexure with Defendant No.1 son Mr. Adarsh Shahi and
had asked him to get the print out of the annexure which was a
Medical Report of Mrs. Munni Shahiwhich was handed over to the
Plaintiff by the Defendant No.1, which was an important part
for all the Defendants written statement and counter claims. That
Defendant No.1 son has got the job done and provided the same
annexure to the Plaintiff upon his instruction, that from the what's
app messages a fair conclusion can be drawn that the Defendants
had given an instruction to the Plaintiff to draft the written
statement into their favour as soon as possible before the next date
of hearing of the Civil matter which was on 23.07.2025. That it is
the Defendant No.1 who had instructed the Plaintiff to draft the
written statement in the favour of 3 Defendants against the Plaint
of Mr. Raj Bhati.
23. That further the Defendant no. 1 had approached to the Plaintiff on
10.07.2025 and had instructed the Plaintiff to take the print out of
the PDF file of written statement which the Plaintiff had provided
all

and transferred to the Defendant No.1 in full with all the relevant
documents through the What's app message vide on dated 8n of
July, 2025. That the complete PDF file containing various
applications, written statement and their counter claim were
provided to the Defendant No.1 for the reading and checking of the
drafting. That after being satisfied with the drafting and after
reading out all the relevant documents and extract of the PDF file
which was shared with the Defendant No.1, he had then through
the telephonic call gave an instruction to the Plaintiff to get the print
<br>

out of the whole file. That on 10th of July, 2025 the Plaintiff in the
presence of the Defendant No.1 had shared the file PDF
containing all the annexures, applications, written statement and
counter claims with the Photo copy shop owner Mr Ravi Gautam at
his what's app number 7532078591, that upon the Plaintiff
instructions he has taken out all the prints and had delivered and
handed over the same to the Defendant No.1, for which the
Defendant No.1 had made the physical payment of the printing of
copy bill for worth (E). 450 in the favour of printing
shop owner by
the way of online transfer payment mode UPI.
24. That the Defendant No.1 had on 10th of July, 2025 had also signed
all the Concern papers and all the affidavits and, Defendant No.1

had asked the Plaintiff to provide the details of all the documents
upon which his Son and his wife as Defendant No. 3
and 4 will have
to signed. That upon Defendant No.1 asking the Plaintiff had
provided all the details of the documents where the Defendant
No.1 son and his wife need to do the sign. The signs are required
on the very initial page of the applications, written statements
and
COunter claims; further the signed were required on
the Affidavit
and upon whole application, written statement and counter claim
and the same was communicated, explained and narrated to the
Defendant No.1 physically and through electronic message
as welI. That the details of the same were provide to the Defendant
No.1 through the what's app message which is in
the form of image
and contains the details of the complete description of pages
where
the signs are required to be done of the Defendant No.2 and 3 on
the same day vide dated 10h of July, 2025.
<br>

25. That the Plaintiff has also drafted the counter claim for forth ().
5,61,000/- (FIVE LAC SIXTY ONE THOUSAND ONLY) into the
favour of 3 Defendants and, against the claims of Mr. Raj Kummar
Bhati which he has established into his plaint. That the Plaintiff has
informed the Defendant No.1 about the completion of counter claim
through the what app message vide on dated 22nd of June, 2025
and upon the same the Defendant No.1 has given his consent and
the complete and final PDF file of Counter claim along with the
written statement has been provided to the Defendant No.1 and 2
at their respective what app number 9873770002 vide on dated 8th
of July, 2025 and the Defendant No.1 had come to signed counter
claim on 10th of July, 2025 after taking appointment from the
Plaintiff.
26. That on 12th of July, 2025 the Defendant No.1 and his son Mr.

Adarsh Shahi had contacted the Plaintiff telephonically various time


to get all the paper work done related to annexing, various
application, written statement and counter claim. That the Plaintiff
had handed over all the documents to the Defendant No.2 Mr.
Adarsh Shahi for the purpose of signing all the documents and the
same was shared at Defendant No.2 what's app No. 9873770003.
That when all the documentation singing formalities were
completed and initiated by the Defendant No.2 Mr. Adarsh Shahi,
then for the same the Plaintiff had then asked the Defendant No.2
Mr. Adarsh Shahi to go to the Karkardooma Court and get the
affidavit attestation work done, all the clerical work and
miscellaneous file maintaining work done of all the documentS and
for the same the Plaintiff had then transferred the number of his
<br>

former junior legal associate of Mr Nitin Sharma Advocate at


Karkardooma District Court on the same day. That the number of
Mr. Nitin Sharma was shared with defendant no.2 at his What's App

and the Defendant No.2 has followed the instruction of the Plaintiff
and approached to Mr. Nitin Sharma Advocate to get the affidavit
attestation work done of 13 different affidavits which were
connected with various documents, all the other clerical work and
miscellaneous file maintaining work done of all the documents. That
after getting the 13 affidavit attestation work done of various
documents the Defendant No.2 had then signed the register
maintained for affidavits record vide on 12th of July, 2025. That
further the Defendant No.2 had made the payment for worth ().
600/- to Plaintiff former junior asSociate Mr. Nitin Sharma Advocate
at Karkardooma District Court for getting the affidavits attested, for
other clerical and other miscellaneous work done and, for getting
the various documents signed done and, did the payment by the
mode of UPI transfer method.
27. That further the Plaintiff has reminded the Defendant No.2 Mr.
Adarsh Shahi to get the print out of one Annexure and the same
was shared at Defendant No.2 Mr. Adarsh Shahi what's app number
on 12th of July, 2025 and the Defendant No.2 had taken out the

the same and had made the payment of the samne to


print out of
the Photostat owner upon the instruction of the Plaintiff. That
further the Plaintiff has provided various bills to the Defendant No.2
for which he has to make the payment of various outstanding bills
of all the Defendants, which Defendant No.2 had deliberately
avoided and at the last the Plaintiff has paid the bill in cash and the
<br>

Defendant No.2 had promised the Plaintiff that he will pay back the
amount which he had never reimbursed.
28. That after getting the affidavit attested and signed and all the
clerical and miscelaneous work done, the Defendant No.2 has
brought back all the documents to the Plaintiff for getting them
checked of their correctness. When all the documents were checked
by the Plaintiff then at that movement the Defendant No.2 Mr.
Adarsh Shahi had asked the Plaintiff that to hand over the
possession of all the document to him so he could get the sign of
his mother who is Defendant No.3 upon all the documents. That
believing upon the statement of the Defendant No.2 Mr. Adarsh
Shahi at that movement the Plaintiff has handed over the
possession of all the relevant drafted documents along with the
annexures under the trust without knowing the fact that the
Defendants had not got the affidavits verified by the Plaintiff. That
the Defendant No.1 and 2 had asked the Plaintiff that they will

provide the signed documents of the Defendant No.3 by the evening


of 12th of July, 2025 or any among the Defendants will bring the
Defendant No.3 in the evening to get the document signed. But
both the Defendants No.1 and 2 has fraudulently, with dishonestly,
with conspiracy in pre-planned manner committed the wilful and
deliberate cheating and criminal breach of trust upon the Plaintiff
by not returning the drafted documents back to the Plaintiff for
filling till 18th of July, 2025.
29. That the Defendant No.1 had kept the Plaintiff in dark and had used
the Plaintiff for the sake of their legal interest and then told the
Plaintiff that all the defendants don't want to get the legal work
<br>

done by the Plaintiff. That the Plaintiff was completely surprised by


the deceptive move of the Defendant No.1 and 2 when they have
withdrawal their case back from the Plaintiff, after getting all
the
legal documentation and drafting work done and after receiving all
the completed original PDF file at their respective what's app into
their favVour, That further the Defendants had never paid
the single
penny of the professional legal fees for
getting the legal drafting
work done of all the documents which the Plaintiff has raised upon
the Defendants through the what's app message vide on dated 13n
of July, 2025, the professional legal fees bill for drafting
and getting
the various documentS executed into Defendants favour i.e 3
different applications, written statement, counter claims, annexing
various documents and getting all the miscellaneous work
done
stands unpaid for worth (?). 1,00,000 (One Lakh Rupees) in total.
30. That there prevails allthe text messages and exchanged
conversation in between the Defendants and the Plaintiff, it could
very rationally, reasonably and fairly be observed
that the Plaintiff
has acted upon Defendants instruction and has performed his legal
professional specific drafting skills into their favour and for the
protection of Defendants legal interest only upon the Defendant
no.1 promise that he will pay the fees of (). 1,00,000/- for drafting
charges.
Professional legal fees for worth (). 30,000/- raised
against Defendant No.1, 2 and 3 for performing the specific
specialised legal skills of drafting, pleading, giving legal
consultation, legal opinion, preparing inspection Report
and appearing before the Hon'ble Court of Law in the
matter of RAU KUMAR VS. DHANANJAY SHAHI and ORS. IN
CASE WUMBER CT:
487/2025 BEFORE THE HON'BLE COURT
<br>

OF Mr. RAHUL SHANI, JUDICIAL MAGISTRATE FIRST


CLASS, SHADHARA, KARKARDOOMA DISTRICT COURT.

31, That the Defendant No.1 had approached to the Plaintiff in an


urgent need for getting the legal protection and shield into his
favour, into the Defendant no.1 whole family members and into his
trucking business from the false criminal complaint which one Mr.
Raj Kumar Bhati has initiated against the Defendants before the
Police station Jyoti Nagar, then immediately Mr. Raj Kumar has
instituted the Criminal complaint against the Defendants and
against their trucking business before the Hon'ble Court of Mr. Rahul
Shani, Judicial Magistrate First Class, Karkardooma District Court.
That upon the Direction of the Hon'ble Court of Law I.0 of Jyoti
nagar has issued the Notice to the Defendant no.1 to join the
preliminary Enquiry vide on dated 8th of May, 2025 at 4:00 p.m
Room No. 217 P.S Jyoti Nagar, Delhi.
32. That the Defendant No.1 has shared the Notice to join the
preliminary examination and enquiry at the what's app number of
the Plaintiff vide dated on 6th of May 2025, that after reading out all
the facts which the Defendant no.1 had narrated to the Plaintiff.
The Plaintiff had then given his legal advice and legal opinion and
has asked the Defendant no.1 to join the preliminary examination
and Enquiry which is to be conducted by the I.0 of Jyoti Nagar
Police Station. That through the Telephonic conversation the
Plaintiff has asked the Defendant no.1 and told him in what manner
and in what way the Defendant No.1 need to give his answer under
section 180 of the BNNS and the Defendant no.1 had joined the
Enquiry and had provided all the annexures of his favour and also
<br>

2
produced the written criminal complaint which the Defendant no.1
had given with the Harsh Vihar police station against the Raj Kumar
which was drafted by the Plaintiff Mr. Akhileshwar
Jha (AdvoOcate)
vide on dated 19.10204 which was diary as 82/2024
dated
19.10.2024, that the same complaint is the part of I.O finding
and
investigation and, the same is relied upon by the 1.0 of Jyoti Nagar
by which he has filed its closure report with the Hon'ble
Court of
Mr. Rahul Shaini, Judicial Magistrate
First Class, Karkardooma
District Court.
33. That from the shared documents i.e Police Enquiry notice
and the
Defendant no.1 hand written answer under section 180
of BNSS
related to the criminal matter which the Defendant no.1 had
shared
at What's app number of the Plaintiff, it could
be fairly and
reasonably be Concluded that the Defendant No.1 was ain
Consistent touch with the Plaintiff and
the Defendant No.1 had
received the various legal instructions
and opinion through the
telephonic cellular calls from the Plaintiff
and after receiving the
various instruction from the Plaintiff
the Defendant no.1 has acted
into that specific manner before
the PS. Jyoti Nagar for the
protection of his legal interest and for his
trucking business. That
upon the criminal complaint
matter the Plaintiff has rendered the
Defendant no.1 his professional legal
services to the best of his legal
knowledge and ability and the Defendant
No.1 had revived the
same, however at
the very beginning the Plaintiff has made
the
Defendant no.1 clear that the whole
service related to the criminal
matter will cost him for worth Rs.
30,000/- upon which the
Defendant No.1 had shown his acceptance
and asked the Plaintiff
<br>

to act for him and to protect the Defendant no.1 and other
Defendants from whole the criminal legal proceedings.
34. That further the Defendant No.1 had approached to thePlaintiff on
gth of July and asked the Plaintiff to inspect the file of the criminal
COurt to get to know about the status of his criminal case for the
same the Defendant no.1 have signed the inspection application
vide on dated 8th of July, 2025 and upon the Defendant no.1 clear
instruction the same application for inspection was moved and
proceeded vide dated on 16.07.2025 before Hon ble Court of Mr.
Rahul Shaini, Judicial Magistrate First Class, Karkardooma District
Court and the same was allowed vide dated on 16.07.2025 with the
fresh vakalatnama which the Defendant No.1 had authorised the
Plaintiff to use into his favour. That the complete inspection report
along with the status report has been send to the
I.0 Closure
Defendant no.1 through the What's app message which was into
his favour and upon his instruction the Plaintiff has acted specifically
and immediately to protect him from any adverse order. That as the
Plaintiff had through the what's app message and through the
telephonic call had told and informed the Defendant no.1 that the
Hon'ble Court had wrongfully marked his appearance into the order
sheet which is as "accused present in person" the same was wrongly
reflected into the order sheet of vide dated 05.07.2025 which was
ordered by the Hon'ble Court of Mr. Rahul Shaini, Judicial Magistrate
First Class, Karkardooma District Court. That the same order was
communicated to the Defendant no.1 on what's app and the
Defendant no.1 has asked the Plaintiff to proceed before the
Hon'ble Court Immediately.
<br>

22
Pending Professional legal fecs for worth (). 65,000/
which is raised against Defendant No.1 for performing the
specific specialised legal skills of drafting lengthy legal
written submissions, lengthy arguments, pleading, giving
legal consultation, legal opinion, and appearing before the
Hon'ble Court of Law in the matter of MOHD. ASLAM VS.
DHANANJAY SHAHI. IN CASE NUMBER CS. No. Z59/2021
BEFORE THE HON'BLE COURT OF Ms.
NIHARIKA KUMAR
SHARMA SEVIOR CIVIL JUDGE CUM RENT CONTROLLER,
SHADHARA DISTRICT, KARKARDOOMA DISTRICT COURT.

35. That the Plaintiff has further appeared before the Hon'ble Court of
Niharika Kumar Sharma Senior Civil Judge cum rent controller,

Shadhara District, Karkardooma Court, in the matter of Mohd. Aslam


vs. Dhananjay Shahi, wherein the Plaintiff has drafted the lengthy

written submission for the Defendant no.1 and the same has been
transferred to the Defendant No.1 in the PDF form on vide dated
12th of May, 2025 and the same has also been filed before the
Hon'ble Court of law. That further the final arguments on the matter
held on 14.05.2025, for which the Plaintiff has appeared for the
Defendant no.1 and provided the detailed and lengthy legal
submission for the Defendant no.1 and the same is reflected into
the judgement of the Hon'ble Vide dated 10.07.2025. That for the
purpose of drafting the written submission, for appearance before
the Hon'ble Court of Law, for giving the lengthy arguments and for
case citation research work the fees charged upon the Defendant
no.1 was as (1). (). 1000 per page which made the fees as ().
1,000/- per page x 42 pages = (). 42,000/-, (2). (R). 30,000/- as
the lengthy legal arguments (3). Date appearance fees ). 1500/
(4). And legal research work (), 1500/- which make the total =
<br>

(E). 75,000/- out of which the appearance fees of (). 1500/- dated
14.05.2025 was only paid.
36. That the legal fees billwas first raised upon the Defendant no.1 vide
on dated 14th of May, 2025 through the what's app message for the
legal services which the Plaintiff has provide to him and the
Defendant no.1 had neither disputed nor declined norrefused
nor opposed to pay the professional legal services fees bill.

37. That out of (E). 75,000/-, the Defendant no.1once paid (?).1,500/
vide on dated 21st of May, 2025 and another part payment of (?).
10,000/- the Defendant no.1 had did on vide dated 1* of July, 2025
intothe favour of the Plaintiff which take the Defendant no.1 bill

chargeable liquidated liability down to worth (). 63,500/-.


38. That further the Plaintiff has appeared before the Hon'ble Court of
Niharika Kumar Sharma Senior Civil Judge cum rent controller,
Shadhara District, Karkardooma Court vide on dated 10.07.2025 for
which the legal fees for appearance remain outstanding for worth
(*). 1,500/-.
39. That after marking the fresh appearance for the Defendant no.1 into
the Aslam matter the previous outstanding unpaid chargeable
liability for professional services bill stands at (). 63,500/-+ the
fresh outstandingbilfor worth (). 1,500/- makes the fees total
outstanding amount bill at worth (). 65,000/- till the date of filing
of this plaint against the Defendants before this Hon'ble Court of
law.
Pending Professional legalfees for worth (). 9,000/- raised
against Defendant No.1, 2, 3 and the Defendant no.1
trucking business for performing the specific specialised
legal skills of drafting, pleading, giving legal consultation,
legal opinion, preparing criminal and civildefamation legal
<br>

2 4

notice for worth (E). 2,50,00,000/- against


RAJ KUMAR FOR
INSTITUTING THE FALSE CRIMINAL COMPLAINTAGAINST
DHANANJAY SHAHI, AGAINST HIS FAMILY MEMBERS AND
AGAINST HIS TRUCKING BUSINESS.

40. That the Defendant no.1 has instructed the Plaintiff to draft one
legal notice of criminal and civil defamation for worth (3).
2,50,00,000 (Two crore and fifty Lakhs Rupees Only) on the behalf
,
of the Defendant no.1 Mr. Dhanangay Shahi Mr. Adarsh Shahi,
Mrs. Munni Shahi and upon the name of the Defendant no.1

trucking business namely Shahi Road line against the Raj Kumar
Bhati.

41. That the same notice was prepared after the Defendant no.1
instruction on the behalf of the 4 personality and the same legal
notice was served upon what's app number 8802607920 of Mr. Raj
Kumar Bhati vide on dated 1st of July, 2025.
42. That the status of service was shared with the Defendant no. 1 at
his what's app number vide on dated 12th of July, 2025 and further
upon the instruction of the Plaintiff the Defendant No.1 has posted

the physical legal Notice to Mr. Raj Kumar through the registered
speed post which bears the postal receipt no. ED 613165645IN vide
dated 30.06.2025 and the Defendant No.1 had further scanned the
hard copy of the legal Notice and send it tothe what's app number
of the Plaintiff vide dated on 30th of June, 2025. That the Defendant
no.1 have intentionally shared the postal receipt and scanned legal
notice at the official mobile number of the Plaintiff shows the
Defendant no.1 clear intentions that he was intended to engage the
Plaintiff for the drafting of the legal notice and serving the same
<br>

upon the Defendant no.1 opponent namely Mr. Raj Kumar Bhati in

the civil and criminal matter.


43. That further the Plaintiff is having the original receipt of the speed
post which the Defendant no.1 has shared and handed over the
physically receipt with the Plaintiff.
44. That for drafting the legal notice the Plaintiff has charged the
Defendant No.1 with the professional and drafting fees of worth (*).
10,000/- but after the discount the amount was decreased to and
remained at (*). 9,000/-, that further for the same the billwas send
at the Defendant no.1 what's app number immediately vide on
dated 7th of June, 2025 defining the description of the whole bill.
date the professional legal services anddrafting bill
That further till

amount of (). 9,000/- remained outstanding and unpaid upon the


Defendant no.1 part. That the Defendant No.1 clearly seems to
have committed a unilateral, deliberate and wilful breach of his
promise to pay the whole amount within the reasonable time and
by his conduct it could be fairly be assumed that the Defendant
No.1 is avoiding to pay his due liquidated liabilities.

Pending Professional legal fees for worth (). 4,000/- raised


against Defendant No.1 for performing the specific
specialised legal skills of giving legal consultation, legal
opinion, giving of legal arguments and appearing before the
Hon'ble Court of Law in the matter of AARTI MISHRA VS.
JANANDAR SHAHI OTHERS, CS, No. 116/2023 BEFORE
&

THE HON'BLE COURT OF Mr. ANKUR AIN II DISTRICT


JUDGE SHADHARA DISTRICT, KARKARD0OMA DISTRICT
COURT.

45. That further the Plaintiff has appeared upon the Defendant no.1
instruction before the Hon'ble Court of Mr. Ankur Jain II District
Judge, Shadhara District, Karkardooma Court vide on dated
<br>

26
17.07.2025 in the matter of Aarti Mishra Vs.
Janandar Shahi &

Others. CS. No. 116/2023 for which the legal fees for
appearance and giving of the legal submission before the Hon'ble
Court of Lawremain stands outstanding for worth ().
4,000/-.That
the Defendant no.1 had neither disputed nor declined nor
refused nor opposed nor resistedthe fees amOunt or bill vhích
he is expected to pay.
46. That the Defendant No.1 had asked the Plaintiff to appear into his
favour and the Defendant No.1 agreed to pay for appearance and
submission fees vide on dated 17.07.2025 for the same the Plaintiff
has raise the billagainst him through the way of What app message
and the Defendant No.1 through the message vide dated
18.07.2025 has promised to pay off his chargeable liquidated
liability in respect of unpaid fees and, the Defendant No.1 has never
disputed, declined, refused, resisted or opposed to pay an
amount of fees bill which the Plaintiff has raised against the
Defendant no.1 at the various point of time.
47. That the Defendant No.1 being the consistent defaulter in making

the payment of his fees, the Plaintiff has finally decide to stop
representing and appearing for the Defendant No.1 into anyof his
litigation matters and for the same the whole file of Aarti Mishra
case has being handed over to the Defendant No.1 in the form of
PDF file through the way of what's app message vide dated on

18.07.2025. As an unpaid outstanding fees amount remains unpaid


till the date of filing of this Plaint before the Honble Court of law.
48. That upon the Defendant no.1 instruction the Plaintiff has appeared
for the Defendant No.1 in the various matter i.e. (1) appeared
<br>

(27
vide on dated 10.07.2025 before the Hon'ble Court of Mrs
Niharika Kumar Sharma Senior Civil judge cum Rent Controller,
Shadhara District, Karkardooma Court: in the matter of Mohd Aslam
on
vs. Dhananjay Shahi, (2): further has appeared vide dated
17.07.2025 before the Hon'ble Court of Shri Ankur Jain 2 Distríct

Judge
:
in the matter of Aarti Mishra Vs. Dhananjay Shahi,
Shadhara, KarkarDooma District Court, (3): has appeared vide
on dated 16.07,2025 before the Hon'ble Court of Shri Rahul

Sainai, Judicial Magistrate First Class, Shadhara, Karkardooma


District Court:in the matter of Raj Kumar Vs. Dhananjay Shahi and
vide on
Ors.
in case number CT: 487/2025, (4) has appeared
dated15.07,2025 before the Hon'ble Court of Shri. Deepankar
:
in
Mohan, District Judge, Shadhara, Karkardooma District Court
case
the matter of Raj Kumnar vs. Dhananjay Shahi and Ors. in
number 242/2025.
CS:

Detailed inspection report, filing of inspection application
and filing of fresh vakalatnama upon the instructions of the
Defendant no.1 in the two different matters: 1): NUMBER
CT: 48Z/2025 2): IN CASE NUMBER CS: 242/2025 before
THE HON'BLE
the two different court of law 1): BEFORE MAGISTRATE
COURT OF SHRI RAHUL SAINAI, JUDICIAL
FIRST CLASS, SHADHARA, KARKARDOOMA DISTRICT
COURT 2): BEFORE THE HON'BLE COURT OF SHRI
DEEPANKAR MOHAN, DISTRICT JUDGE, SHADHARA,
KARKARDOOMA DISTRICT COURT.

no.1 knowledge on
49. That the Plaintiff has bring into the Defendant
16h of July that in the order sheet vide dated
05.07.2025 his
in
appearance is wrongfully marked as the accused appeared
upon
person in the number CT: 487/2025 by the Hon'ble, that
for him
the Defendant no. 1 instruction the Plaintiff had appeared
<br>

on 16.07.2025 and had moved the inspection application along wíth

various authorised documents which the Defendant No.1 has


authorised the Plaintiff to use before the Hon'ble Court of Law. That
the Plaintiff has obtained the Defendant no.1 instruction and
consent through a telephonic call and for the same had made the
Defendant No.1 aware of all the process and stage of críminal trial
which is pending against the Defendant No.1 and for the same the
Defendant no.1 has specifically asked the Plaintiff to proceed and
appear before the Hon'ble Court of Law. That upon the Defendant
no.1 instruction the Plaintiff has appeared before the Hon'ble Court
of Law and provided him every single detail into his favour by the
way of inspection report which the Plaintiff did from 02: 10 P.m to
2: 47 P.m. That the Plaintiff being the Defendant no.1 authorised
legal consultant has did all the due diligence to protect his legal
interest and further had provided the Defendant No.1 a lengthy

legal conferences and legal opinion through the telephonic call and
physical meeting.
50. That upon the Defendant no.1 instruction the Plaintiff has
appeared and moved the fresh application for file inspection on
15.07.2025 and moved the vakalatnama in case number CS:
242/2025 the Defendant No.1 has authorised the Plaintiff
which

to use before the Hon'ble Court of Law. That upon his instruction
the Plaintiff has appeared before the Hon'ble Court of Law and
provided the Defendant no.1 every single detail by the way of
inspection report which the Plaintiff did from 1:05 p.m to 01:32 p.m
around. That the Plaintiff being the Defendant no. 1 authorised legal
consultant and representative has did all the due diligence to
<br>

29
protect his legal interest and further had provided the Defendant
No.1 a lengthy legal conferences and legal opinion through the
upon the Defendant no.1 civil
telephonic call and physical meeting
recovery matter for worth Rs. 13 Lakhs. That the details of all the
on time has been
above mentioned aspects have been fairly and
disclosed to the Defendant no.1 before the next date of
proceedings.
upon
Details ofprofessional legal services fees bills raised
the Defendants vide in dated 18th of July, 20025
bill
51. That the Plaintiff got served the defendant no.1 with fees
dated 16th of July, 2025 which was sent the name all the
in

Defendants by the plaintiff through Regd./AD and speed post vide


on dated 18th of July, 2025 at the correct address of the defendants

demanding the amount of the above said professional legal services


fees; in question within 15 day from the receipt of the bills and the
same is refused to accept by the Defendants. That the Plaintiff has
received the returned and refused envelope at his official address
on 26.07.2025 which the Defendants had deliberately avoided to
accept. But the Plaintiff through the electronic What's app message
vide on dated 18.07.2025 at 10: 13 a.m. has been successfully
delivered and sends a PDF file of the to the Defendants No.1
bil

and at his registered what app number which are 9873770002


respectively and, the same was successfully delivered to him by
using the electronic platform of what app messaging. Despite
service of the Bill neither reply nor payment has been made by the
defendants till today, hence the present suit.
<br>

52. That on 18h of July, 2025 the Plaintiff has raised the
reasonable, legal and valid bill upon the Defendant No.1 as he is
consistently committing the brcach of his promises in making
the
payment of his legal and professional enforceable bill in
the form of
instalments which were designed and made into his
favour only
after the common understanding in between the Defendant No.1
and the Plaintiff. That the description of the bill are as follows:
"Subject: BILL: Payment of fees of (). 2,10,000/
(Two Lakhs and Ten Thousand).
(1). For Exchange and receiving of legal opinion- legal
consultation services, conference charges, considering and
reading out relevant lengthy documents charges.
(2). Darting of various 2 Different application under
Order 1
Rule 10(2) and (13) on behalf of the 3 personS,
(3). 1 Common Application under order 7 Rule 11 on
behalf of
the 3 persons,
(4). Common Written statement and separate Counter Claim
for No.1, Mrs. Munni Shahi, Mr. Adarsh Shahi.
(5). Appearance fees for appearing before 2 different Hon'ble
Court.
(6). For preparing Lengthy written submissions, for giving
lengthy legal arguments.
(7). Drafting of (). 2,00,000/- recovery and (). 2,50,00,000/
defamation Legal notice against Mr. Raj Kumar Bhati on
behalf of Mr. Dhananjay Shahi, Mrs. Munni Shahi, Mr.
Adarsh Shahiand their trucking business.
(8). For Exchange and receiving of legal opinion- legal
consultation services, conference charges, considering and
reading out relevant documents connected with Notice
Under 175(3) of BNSS and statement given under of Mr.
Dhananjay Shahigiven under section 180 of BNSS.
(9). Other Miscellaneous and clerical Charges (). 2,000/-."
Sir/Mam,
Iwantto inform that the 9 sort of expenditure are still pending on r part
which are Dartingof various 2 Different application under
Order 1
<br>

3 persons,
1 Common
Rule 10(2) and (13) on behalf of the
Application under order 7 Rule 11 on behalf of the 3 persons,
A

Common Written statement and separate Counter Claim for


No.1, Mrs. Munni Shahi, Mr. Adarsh Shahi Which is for worth (4).
1,00,000/-. Appearance fees for appearing before 2 different
Hon'ble Court vide dated on 10.07.2025 and 17.07.2025
(R).1500/-) + ((R). 2,000/+ (R). 2,000/-)=({). 5,500/-. For preparing
Lengthy written submissions, for giving lengthy legal arguments
(R)42000/- +() 30,000/- +() 1,500 + 1,500/-= ().75,000/-). Drafting
of ().2,00,000/- recovery and (). 2,50,00,000/- defamation
Legal notice against Mr. Raj Kumar Bhati on behalf of No. 1, Mrs.
Munnai Shahi, Mr. Adarsh Shahi and their trucking business
which is (*), 9,000/- For Exchange and receiving of legal opinion
legal consultation services, conference charges, considering and
reading out relevant documents connected with Notice Under
175(3) of BNSS and statement given under of Mr. Dhananjay
Shahigiven under section 180 of BNSS which is ().30,O00/- and the
COst of other miscellaneous and cderical Charges for worth (*), 2,000/-.
That pending legal conference charges, acceptance of brief physically and
through electronic mode, research work and reading of documents,
formulation of legal opinion, lengthy legal consultation charges
telephonically and through What App Message, drafting of legal written
of Law and lengthy
submissions, appearance before the Hon'ble Court
oral submissions and other miscellaneous and clerical charges in whole
legal exercise matter for worth (*). 2,10,000/-.
of pending fees upon legal work done
Table A: Details
are mentions are as follows:
In the Matter of Raj Kumar Vs. Dhananjay Shahai and
Ors, CS. 242/2025.
Drafting of various 2 Different application under Order 1
Rule 10(2) and (13) on behalf of the 3 persons, 1
Common Application under order 7 Rule 11 on behalf of
the 3 persons, A Common Written statement and
separate Counter Claim for the Mr. Dhananjay Shahi,
Mrs. Munnai Shahi, Mr. Adarsh Shahi. Which is for worth
(). 1,00,000/
BILL DESCRIPTION
<br>

[Link] Particular/ Description of fees Unpaid


Fees
in ().| fees in
).
1: Drafting of various 2Different
application under Order 1 Rule 10(2)| 20,000
and (13) on behalf of the 3 persons. + 40,000/
A. Adarsh
Shahi and Munni Shahi 20,000
B. Dhananjay Shahi
Acceptingof brief Plaint, Conference charges,
Reading and Research Work on Documents,
legal opinion and, drafting charges.
2: Drafting of a Common Application under 20,000
order 7 Rule 11 on behalf of the 3
persons. Mr. Dhananjay Shahi, Mrs.
Munni Shahi, Mr. Adarsh Shahi: Charges 20,000/
for Providing of legal Conference
telephonically and upon what app electronic
message, consultation and legal opinion
Charges, drafting of lengthy and legal
application charges and other Miscellaneous
Charges left unpaid.
3: Drafting of Common Written statement 20,000
for Mr. Dhananjay Shahi, Mrs. Munni
Shahi, Mr. Adarsh Shahi. 20,000/
Drafting of Common written statement
"against Raj kumar claim" Charges for
Providing of legal Conference on telephonic
call, consultation and legal opinion Charges,
drafting of common written statement
charges, arrangements of all the annexures
related to W.S and other Miscellaneous
Charges left unpaid.
4: Drafting of separate Counter Claim for 20,000
Mr. Dhananjay
Shahi, Mrs. Munni Shahi,
Mr. Adarsh Shahi: Charges for Providing of 20,000
legal Conference on telephonic call and upon
what app electronic message, consultation
and legal opinion Charges, drafting of Counter
Claims under Order 8 Rule 6A of CPC charges
and other Miscellaneous Charges left unpaid.
<br>

33
All
the applications and written statement and
counter claims draft under the Defendant
No.1 written instructions, same has been
provided through the What's app message in
the PDF form, for the same the print out has
been taken out and affidavits attestation work
done. That the whole file containing all the
documents along with all the annexures and
affidavits were provided to all the Defendants
by the Plaintiff. The whole file contain
approximately 304 pages
5. TOTAL UNPAID FEES 1,00,000/

Total Expenditure:of Clause 1+2+3+4= (). 1,000,00/


IN WORDS:(One Lakhs) rupees only.
Table Details of pending fees upon legal work done are
B:

mentions are as folloWs:


Drafting of legal notice vide dated 01.07.2025 ().
2,00,000/- recovery notice and (). 2,50,00,000/
defamation Legal notice against Mr. Raj Kumar Bhati on
behalf of Mr. Dhananjay Shahi, Mrs. Munni Shahi, Mr.
Adarsh Shahi and their trucking business which is (*).
9,000/

[Link] Particular/ Description of fees Fees Unpaid


in (). fees in
(E).
1: Drafting of legal notice vide dated 9,000/
01.07.2025 for (). 2,00,000/- recovery 9,000/
notice and (*). 2,50,00,000/- defamation
Legal notice against Mr. Raj Kumar Bhati on
behalf of Mr. Dhananjay Shahi, Mrs. Munni
<br>

Shahi, Mr. Adarsh Shahi and their trucking


business
The legal notice has been served upon Mr. Raj
Bhati through What app no. 9560714537
upon his official What's App Number and the
status of electronic delivery report has been
duly shared with Mr. Dhananjay Shahi at his
What app no. 9873770002.
2. TOTAL UNPAID FEES 9,000/
BILL DESCRIPTION

Total Expenditure: of Clause (). 9,000/


1=

IN WORDS:(Nine Thousand) rupees only.


Table C: Details of pending fees upon legal work done are
mentions are as follows:
In the Matter of Mohd. Aslam Vs. Dhananjay Shahai. CS.
No. 759/2021.
Charges of (). 1,500/- Appearance vide on dated
10.07.2025, before the Hon'ble Court of Niharika Kumar
Sharma.
For preparing Lengthy written submissions, for giving
lengthy legal arguments on dated 14.05.2025 (*).
42000/- + (). 30,000/- + (7). 1,500 + (). 1,500/- = ().
75,000/-) - (). 10,000/- paid total= (*).63,500/- + (R).
1,500/- = (). 65,000/-.
BILL DESCRIPTION
[Link] Particular/ Description of fees
Fees Unpaid
in ().fees in
(E).
1: A:Drafting and preparing Lengthy 42,000
written submissions for Mr. Dhananjay
Shahi and the same has been brought +
<br>

upon the record of Hon'ble Court of law 30,000


through its order dated 14.05.2025,
B:
for giving lengthy legal arguments on (10,00
vide dated: 14.05.2025 for Mr. 0) paid 63,500
Dhananjay Shahi. +
1,500
C: charges for citation research and
relevant case finding
For drafting and preparing the written
submissions which has been filed before the
Hon'ble Court of Law and the same has been
shared through What app message to Mr.
Dhananjay Shahi at his What app no.
9873770002 on 12th of May, 2025.
Charges for Appearance vide on dated 1,500/- 1,500/
2.
10.07.2025, before the Hon'ble Court of
Niharika Kumar Sharma.
TOTAL UNPAID FEES 65,000/

Total Expenditure: of Clause 1 and 2= (). 65,000/


IN WORDS: (Sixty Five Thousand) rupees ony.

Table D:Detailsof pending fees upon legal work done are


mention are as follows:
In the Matter of Aarti Mishra Vs.
Janandar Shahi &

Others. CS. No. 116/2023.


Charges of (). 4,000/- Appearance vide on dated
17.07.2025, before the Hon'ble Court of Ankur Jain- II,
ADJ, Shahdara, Karkardooma District Court District
Court.
BILL DESCRIPTION
[Link] Particularl Description of fees Fees Unpaid
in (). fees in
(E).
1: Charges for Appearance vide on dated 2,000/
17.07.2025, before the Hon'ble Court of
Ankur Jain- II, ADJ,Shahdara,
<br>

36
Karkardoona District Court District
Court.
2: Charges for giving the submissions and 2,000/
arguments vide on dated 17.07.2025,
before the Hon'ble Court of Ankur Jain
II, ADJ, Shahdara, Karkardooma
District Court District Court. 4,000/
That the Hon'ble Court of law has passed an
order dated vide dated 17.07.2025 and the
advocate appearance is on record.
3 TOTAL UNPAID FEES
4,000/
Total Expenditure: of Clause 1 = (),
4,000/
IN WORDS: (Four Thousand) rupees
only.
Table E: Details of pending fees upon legal work done are
mention are as follows:
In the Matter of: Sh Raj Kumar Vs. Dhananjay Ors, &
CT

Case Dy. 78/2025. U/s175.3 BNSS,


Karkardooma
District Court and PS. yoti Nagar Delhi.
For Exchange and receiving of legal opinion- legal
consultation services, conference charges, considering
and reading out relevant documents through What's App
Messages and giving opinion and suggestions through
long telephonic conversations, connected with Notice
Under 175(3) of BNSS vide dated 06.05.2025
statement given under section180 of BNSS, 2023 by and Mr.
Dhananjay Shahi vide on dated 1105.2025. Further
the
Inspection Application filled upon the instruction of Mr.
Dhnanjay Sahahivide on dated 16.07.2025 and the fresh
Vakalatnama filed upon the authority and under
instruction of the Mr. Dhnanjay Sahahi and to get it
allowed from the Court of law. Further inspection report
shared at what's app. Further the details of closure
report have been shared of I.0 at the What's App.
BILL DESCRIPTION
<br>

[Link] Particular/ Description of fees Fees Unpaid


in Rs. fees in
Rs.
1: For Exchange and receiving of legal 30,000
opinion and legal tactics- legal
consultation services, Conference
charges, considering and reading out
relevant documents through What's App
Messages and giving opinion and
suggestions through long telephonic
Conversations, connected with Notice
Under 175(3) of BNSS vide dated
06.05.2025 and statement given under
section 180 of BNSS by Mr. Dhanangay
Shahi vide on dated 11.05.2025. Further
the Inspection Application filled upon
the instruction of Mr. Dhnanjay Sahahi
vide on dated 16.07.2025 and the fresh
Vakalatnama filed upon the authority
and under instruction of the Mr.
Dhnanjay Sahahi and to get it allowed
from the Court of law. Further
inspection report shared at what's app.
Further the details of closure report 30,000/
have been shared of I.0 at the What's
App.
The legal tactics and defences was shared
with Mr. Dhananjay Shahi through the lengthy
Telephonic calls and upon the successful
defence before the Police station Jyoti Nagar
Mr. Dhananjay has shared his defence
statement with me through What app
message of Mr. Dhananjay Shahi What app
no. 9873770002.
2. Other miscellaneous and clerical charges 2,000/-2,000/
involved in all the above mentioned process
mentioned at table A+B-+C+D
TOTAL UNPAID FEES 32,000/-J

Total Exxpenditure:of Clause 1 and 2= (E). 32,000/


<br>

38
IN WORDS: (Thirty Two Thousand) rupees only.

Total Expenditure stand unpaid in the form of legal fees:


describedinto Table A+B+C+D+E= (t). 2,10,000/
IN WORDS: (TwNo Lakhs and Ten Thousand) rupees only.
The Plaintiff had inform that the above mention is the detail of
unpaid fees, which have stillnot paid till the present date and the
defendants are under the liability to pay the fees of (). 2,10,000/
for the above mention legal work, as the legal services are not for
free or pro bono services. Please kindly clear the fees within in 15
days from the serving of this bill, either through account transfer,
UPI transfer, or through any other mode.

Details of UPItransfer No. Bank AcCount Details:


9560714537 31556721112 SBI

53. That, there prevails a relevant and substantial and admitted


documentary evidences, from which it could fairly be concluded that
there prevails a relationship in between the Plaintiff and between
the Defendants as of the "advocate and his client". That the
Defendant No.1 since from the earlier 2023 to till February, 2025
has paid the various amount as fees in the part instalments for the
legal services which the Plaintiff has raised upon the Defendant
No.1 for his various litigation and legal issues. That it is an

established fact that for the various matters the Plaintiff has
appeared for the Defendants before the Hon'ble Courts of Law and
has acted for them legally to protect their legal interest. That further
on the various OCcasions the Plaintiff has also transferred the

various PDF files of the various drafting which is connected with


defendants various cases which were only drafted after their
instruction and consent to pay upon the same. That for all the legal
services which the Plaintiff has provided to the defendants from
<br>

February, 2025 to July, 2025


a
fresh profcssional legal services bills
has been raised upon the Defendants by the way of What's app
message. That the Defendants since from the very beginning had
enjoyed the legal professional services of the Plaintiff and, for the
same they have never decline, disputed, resisted, refused or
opposeda single bill but in fact rather the Defendant no.1 has paid
the bill and comply with the conditions of the Plaintiff till of June,
2025.
54. That the Defendant no.1 after the month of June, 2025 stop
the payment of all the instalments in the month of July to
September, 2025 and the Defendant No.1 have committed the
deliberately and wilful breach of his all promise. That the Defendant
No.1 had did the promises at the various point of time to pay of the
complete set of fees through orally and through in expressed
written electronic messages. That the Defendant No.1 had never
declined, disputed, resisted, refused or opposed to pay any
fees or had never raised any objection upon the bills raised
upon the Defendants No.1 by the Plaintiff. But at certain point of

time the Defendant no.1 have stopped the payments of the fees,
without any reason.
DETAILS OF DEFAULT COMMITTED IN PAYING THE
INSTALMENTS OF FEES BY THE DEFENDANT NO.1, 2 and 3.

55. that the Defendant no.1 has made the promise to the Plaintiff to
pay the legal fees, but now onward from July to September, 2025
the Defendant no.1 is deliberately and wilflly avoiding his
liquidated liabilities which he owes to the Plaintiff, which the Plaintiff
has raised upon the Defendant no.1 in the form of enforceable bills
the complete descriptions of defaulted instalments are as follows.
<br>

A: Defaulted instalments of fees in the month of July,


2025.

[Link] Details of liability Defaulted instalment


amount in ().
1
Sh. Rai Kumar Vs. (*).15,000/
Dhananjay &
Ors. CT
Case
Dy.
78/2025.
(R). 15,000/- 1t instalment
defaulted out of (). 30,000/
2 In the Matter of Aarti ().4,000/
Mishra Vs.
Janandar Shahi
& Others. CS. No.
116/2023. (*). 4,000/- full
in
at one time instalment
defaulted.
3 In the Matter of Mohd. (3).10,000/
Aslam Vs. Dhananjay
Shahai. CS. No. 759/2021.
(?). 10,000/- 2nd instalment
defaulted out of (E). 65,000/-.
Total (). 29,000/

B: Defaulted instalments of fees in the month of August,


2025.
[Link] Details of liability Defaulted instalment
amount in ().
1 Sh. Rai Kumar Vs. (*).15,000/
Dhananjay &
Ors, CT Case
Dy.
782025:
(?). 15,000/- 2nd instalment
defaulted out of (E). 30,000/
2 Draftingof legal notice vide ().9,000/
dated 01.07.2025 (*).
2,00,000/- recovery notice
and (). 2,50,00,000/
<br>

41)

defamation Legal notice


against Mr. Raj Kumar Blhati
on behalf of Defendants:
(8). 9,000/- in full at one time
instalment defaulted
3 In the Matter of Mohd. (*).10,000/
Aslam Vs. Dhananjay
Shahai. CS. No. 759/2021:
(*). 10,000/- 3rd instalment
defaulted out of (*). 65,000/-.
Total (?). 34,000/

C: Defaulted instalments of fees in the month of


September, 2025.
[Link] Details of liability Defaulted instalment
amount in (7).
1 Sh. Rai Kumar Vs. (*).10,000/
Dhananjay & Ors. CS.
242/2025.
(*). 10,000/- 1t instalment
defaulted out of (), 1,00,000/
2 In the Matter of Mohd. ().10,000/
Aslam Vs. Dhananjay
Shahai, CS. No. 759/2021:
(). 10,000/- 4th instalment
defaulted out of (*). 65,000/-.
Total (E). 20,000/

56. That the Defaulted instalment amount is mentioned in the


above table (A+B-+C) for the months of July, August and
September, 2025 the total defaulted fees amount stands at ().
83,000/-,
<br>

4
57. That the Defendant No.1 has consistently made the promises
to pay the litigation fees to the Plaintiff orally as well as through
the
written what app messages. That after the expiry of 3 months and
the 3 consecutive instalments defaults upon
the part of the
Defendant No.1 it seems that the assurance which
the Defendant
No.1 has given to the Plaintiff is nothing
but the false promise and
the Defendant No.1 is deliberately avoiding his liability to pay
fees.
That the Plaintiff politely requested/ demanded
the said amount
from the Defendant No.1 at the various intervals.
However the
Defendant No.1 did not paid the same and the Defendant No.1
SOught Some more time, even after the expiry of some more
time
the Defendant No.1 kept on seeking more time to pay the litigation
fees amount and by this way the Defendant No.1 is avoiding his
expressly admitted liability fees amount.
58. That it is now clear that since the beginning the Defendant
No.1 had dishonest intention and the plaintiff is
left with no other
option but to issue a legal notice.
59. That the Plaintiff got served the defendant with legal notice
dated 08.08.2025 which was sent to all the Defendants by
the
plaintiff through his counsel by Regd./AD and speed post
at the
correct address of the defendants demanding the amount
of the
above said professional legal services fees; in question within 15
day from the receipt of the notice and the same is refused to accept
by the Defendants. That the Plaintiff has received
the returned and
refused envelope at his official address on 13.08.2025 which the
Defendants had deliberately avoided to accept. But the Plaintiff
through his Counsel vide on dated 09.08.2025 at 7: 32 p.m has
<br>

sUccessfully delivered and sends a PDF file of the Notice to cach of


the Defendants i.e the Defendant No.1 and No.2 at their registered
what app number which are 9873770002 and 9873770003
respectively and, the same was successfully delivered to them by
using the electronic platform of what's app messaging. Despite
service of the notice neither reply nor payment has been made by
the defendants till today, hence the present suit.
60. That as the above-said professional legal fees amount of ().
2,10,000/- [Rupees Two Lakh and Ten Thousand Only] is due
against the defendants which is legally payable and admitted by the
Defendant No.1 to the plaintiff and the plaintiff has demanded the
above-said amount several times orally, through expressly written
messages, through bills and through notice from the defendant but
the Defendant No.1 with his malafied motive and intention and in

order to avoid the plaintiffs professional fees, the Defendants has


not yet paid the above-said amount of the plaintiff till filling the suit.

61. That the Defendant No.1 has been avoiding the above-said
amount of (). 2,10,000/- [Rupees Two Lakh and Ten Thousand
Only] without any reason which is legally payable by him to the

plaintiff since after expiry 3 months and after committing the 3


consecutive defaults, therefore, the defendants has further
rendered himself liable topay the interest at the rate of Rs.12% Per
annum on the above-said amount since from July, 2025 to final
adjudication of suit.
62. That the cause ofaction for filing the present suitfirstly
arouse on various dates as mentioned albove. The cause of action
for filing the captioned suit first arouse when the Plaintiff has
raised the Bill of (E). 75,000/-against the Defendant No.1 vide on
<br>

dated 14th of May, 2025 and the Defendant No.1 keep on paying
the various pending fees of (). 2,500/- vide on dated 20th of May,
2025, then paid fees of (R). 1,500/- on vide dated 21th of May,
2025, then paid fees of (?). 2,500/- on vide dated 26th of May,
2025, that the First instalment of (). 10,000/- has been paid on
vide dated 1 of July, 2025 out of the total amount of (E).
. 75,000/
That after all the settlements of all the previous bills the amount
of (). 75,000/- has been taken down to (). 63,500/- which was
then communicated to the Defendant No. 1 vide on dated 2d of July,
2025. That, Secondly the cause ofaction for filing the captioned
suit further arose when the Plaintiff has raise the bill upon
Defendant No.1 vide on dated 2nd of July, 2025 for drafting the
the legal
notice for recovery of money and for civil and criminal defamation
vide dated 30.06.2025 for all the Defendants against Mr. Raj Kumar
Bhati. That further Thirdly the cause
of action arose on 7h of
July, 2025 when the Plaintiff upon the demand of
the Defendant
No.1 has provided the details of legal professional
services bill for
drafting the legal notice through the Whats App message.
That
further fourthly the cause of action arose on 10th of July, 2025
when the Plaintiff has raised the fees of (). 1,500 in the Mohd.
Aslam civil recovery matter which has taken the total bill in
recovery matter to (*). 1,500 + the civil
(). 63,500/-= (). 65,000/-. The
further 5tn time the cause of actionaroused on 13th of July, 2025
when the bill of (). 1,00,000/- was communicated and raised upon
the Defendant No.1 through the What's App electronic message.
That on the same date further reminder was made upon the
Defendant No.1 to pay the pending fees of (). 9,000. The further
6th timne the cause of action aroused on 15th of July,
when another reminder was made upon the Defendant No.1 to pay
2025
the 2nd instalment in the Aslam matter. The further 7th time the
cause of action aroused on 16th of July, 2025 when another
reminder was made upon the Defendant No.1 to pay the 2nd
instalment in the Aslam matter and to clear the other pending dues.
That upon the same dated vide dated 16th of July, 2025 the
Defendant No.1 had made the promise to the Plaintiff that he will
pay the fees. That the Plaintiff has kept on
acting upon the false
assurance of the Defendant No.1 which
he use to give expressly at
the regular intervals through the expressly written what's app
electronic messages upon the valid and legal demand of the
Plaintiff. That further gh time the cause
of action aroused
when on 17h of July, 2025 another reminder was made upon
<br>

the Defendant No.1 to pay the fccs. That further gh time the
cause of action aroused wien on 18" of July, 2025 when
another reminder was made upon the Defendant No.1 to pay the
fees and the Defendant No.1 had through the cxpressly written
what's app electronic messages did the prOmise and admitted the
liability to pay the professional legal services bill. That further 10h
time tlhe cause of action aroused whenthe Defendant No.1
has never shown his intention to pay of his liability rather he has
just kept on making the false promises and given the false
assurances to the Plaintiff. That the Plaintiff being fed-up with the
false assurances which the Defendant No.1 has given against his
legally enforceable liability, the Plaintiff has raise the bil of pending
fees for worth (). 2,10,000/- vide on dated 18h of July, 2025
against allthe Defendants through electronic message and through
the registered post- speed post at their respective register mobile
numbersand at their residential and official address. That further
11th time the cause of action aroused when the Defendant
No.1 has deliberately avoided the fees bill which was raised against
him, then the Plaintiff has served upon the Defendant No.1 a legal
notice vide dated 08.08.2025 which was successfully delivered to
them through electronic message at their at their respective
register mobile numbers, but they have refused to accept the Notice
which was send to them through the registered post- speed post at
their residential and official address. The cause of action further
arose when Despite service of the notice neither reply nor payment
has been made by the Defendant's till today, and the cause of action
is still continuing in favour of the plaintiff and against the
Defendant's as the amount is due.

63. That, the value of the suit for the purpose of jurisdiction and
court-fee for the relief of recovery of professional legal services fees
bill for worth (). 2,10,000/- [Rupees Two Lakh and Ten Thousand

Only] and the appropriate court fees of (?)_ 4400/


has been annexed herewith and the plaintiff further undertakes to
file fees if the Hon'ble court direct him to do so.
<br>

64. That the plaintiff has got the defendants served with the legal
notice upon the defendantswithin period of imitation and is filling
the present suit within the prescribed period of limitation.
65. That the plaintiff has not filled any other suit in respect of the
professional legal services fees bill before any of the Courts and he
clarifies/declares that the Plaintiff has filed only this suit in respect
of professional legal services fees bill. That further no similar suit or
petition has been filed by the Plaintiff before this Hon'ble Court or
the Hon'ble Supreme Court of India or any other Court.
66. That this suit is being filed Under Order XXXVIIof the Code of
Civil Procedure Code, 1908.
67. That no relief which does not fall under the ambit of the order
XXXVII of the Civil Procedure Code, 1908, has been claimed in
the
plaint and to the belief of the plaintiff; the Defendants has no
defence, as the Defendant No.1 along with other defendants has
completely admitted their liabilities specifically by the expressed
modes and by making the part payments of their liabilities related
to the professional legal services fees bill and by acting upon the
valid and lawful terms and condition of the Plaintiff. Hence the
Defendant No.1 has no right to defend/contest this case.
68. That the Plaintiff and the Defendants are residing and carrying
their profession and business for the purpose of work and gain at
National Capital Territory of Delhi within the territorial jurisdiction
of this Hon'ble Court, hence this Hon'ble Court has the jurisdiction
to try and decide the present Suit. That all the Defendants have
received the detailed legal work and get the legal services
performed into their favour from the plaintiff advocate and
<br>

MASU
AAMUN
expressly execute the written what's app electrön@smessagesihtoa
olgovbA
the favour of Plaintiff by doing the promises arid'ogivingethe
[Link]
assurances timely, through the electronic messages the Defendaitsama
has admitted their liability to pay the professional legal services bill.

PRAYER
It is therefore, most respectfully prayed before the Hon'ble Court of
law may kindly be pleased to pass
a) Adecree for Rs. 2,10,000/- (Rupees Two Lakhs and Ten
Thousand) against the Defendants and in the favour of the
B:13.
Plaintiff be passed. fox the Payment oF fees
per annum from the date
b) Along with an interest thereon @12%
suit
of first default July, 2025 to till the final adjudication of the
to
or till recovery of the amount thereby direct the defendants
pay the same in the interest of justice.
To award the full cost of the Suit/litigation which is worth Rs.
c)
clerical charges in
25,000/- and other miscellaneous and other
favour of the Plaintiff and against the Defendants.
And
with relief which this Hon'ble
d) To pass any other order along
proper, keeping in view all the facts and
Court may deem fit and
against the
circumstance, in the favour of the Plaintiff and
of justice.
Defendant's herein may be granted in the interest
It is prayed accordingly.

PLAINTIFF
AKHILESHWAR JHA
Place: DELHI
8
DATED:29. 09.2025
<br>

SOLANK!
[Link]
KUMAR (BA,
INOIA
E
cOURNOIDAAPURAM
SAURABH THROUGH
[Link]@[Link]
SUPREME
Advocate 9456934987
NIT
Ch.
No.Z
adv.
E-malil : Mob.:
[Binay Kumarand Saurabh Kumar
Solanki & ASSOT.]
ADVOCATE FOR THE PLAINTIFF
E-506, KKD COURT, DELHI
Mobile No. 9560714537
E mail: akhilno.2@[Link],

VERIFICATION
Verified at Delhion this Ol3#_ day of September,
2025 that the
Contents of Para 1 to 60 are correct and true to the
knowledge, and the contents of the para no. best of my
61 to 6_are
believed to be true on information received and believed to be
true. Last para is prayer to this Hon'ble Court.

PLAINTIFF
IN THE COURT OF How’scz SENTO R “CIVIL
ic - , JUDGE, (DISTRICT SHAHDARA),
KARKARDOOMA DISTRICT COURT, DELHI
CS CASE No. /2025

IN THE MATTER OF:


Mr. AKHILESHWAR JHA ... PLAINTIFF
VERSUS
Mr. Dhananjay Shahi & O. RS. ...DEFENDANTS
AFFIDAVIT

I, Akhileshwar Jha S/o Shri Mukteshwar Jha age about _30


years R/o: 38-B, SG Pocket, Dilshad Garden, Delhi — 110095,
presently at New Delhi, do hereby solemnly affirms and state
on oath as following:
1. That, I am the Plaintiff in the above noted case and well
conversant with the facts and circumstance of the case
and I am therefore competent to swear to this affidavit. . ° :
2. That, the accompanying Plaint has been drafted by my
counsel under my instructions and the same has been
explained and read over to me in my vernacular language
and I have understood the same. The contents of the
same are true and correct to my knowledge and the same
may kindly be read as part and parcel of affidavit, which
are not repeated here in after for the sake of brevity.
3.I have understood the contents of Plaint from para 1 to
60. I have understood the contents are correct from para
No. 61 to 6% to the best of my knowledge which are also
<br>

(50
4. That, Annexure - P/01 to P/ 28 at pages SS to 2S|
annexed to this Plaint are either originals or certified
copies or true copies of their respective originals.

iBÈNTJFIED

DEPONENT
VERIFICATION
25 AUG 2025
Verified at Delhi on the day of August, 2025
the contents of this affidavit are true and Correct to that
my
knowledge and behalf and nothing has been
concealed
therefrom.

DEPONENT
NO/K. BANDANA
Dolhi
Rsgn. ty4. e718
24 ATTESTEB
NOTARY PUBLÍC DELHI
Govt. sAdia
zô.02.2030 MOb. 9054799498
Govt
of
i)
IN THE COURT OF Ho/v’BLé Senvor-CGIVIL
t. _ JUDGE, (DISTRICT SHAHDARA),
KARKARDOOMA COURT, DELHI
CS CASE No. /2025

IN THE MATTER OF:


Mr. AKHILESHWAR JHA ...PLAINTIFF
VERSUS
Mr. Dhananjay Shahi & O. RS. ...DEFENDANTS
LIST OF DOCUMENTS/RELIANCES

1. | ANNEXURE NO:P/1 - oS
ORIGINAL AUTHORITY LETTER DATED 23.01.23
2. | ANNEXURE NO: P/2 -
TRUE COPY OF ORDER SHEET VIDE DATED €6-SS
24.04.2025 AND CERTIFIED COPY OF ORDER AND
DECREE SHEET 10.07.2025 IN THE CS NO.
759/2021
3. |ANNEXURE NO: P/3 -
TRUE COPY OF ORDER SHEET VIDE DATED C4
17.07.2025 IN THE CS NO. 116/2023
4: | ANNEXURE NO: P/4-
CERTIFIED COPY OF INSPECTION APPLICATION bo- bb
DATED 16.07.2025, © VAKALATNAMA — DATED
08.07.2025 AND,
ORIGINAL DETAILED INSPECTION REPORT DATED
16.07.2025 IN THE CT NO. 487/2025.
5: | ANNEXURE NO: P/5 —
CERTIFIED COPY OF INSPECTION APPLICATION §+-71
DATED 16.07.2025, VAKALATNAMA DATED
08.07.2025.
6: | ANNEXURE NO: P/6 -
ORIGINAL OF LEGAL SERVICES FEES BILL VIDE F2- 44
DATE 16.07.2025 UPON ALL THE COMMON
DEFENDANTS.
7: | ANNEXURE NO: P/7 - Fe 299;
ORIGINAL OF RETURNED AND REFUSED ENVELOPE
AND POSTAL RECEIPT DATED 17.07.2025 ALONG
<br>

WITH TRACKING REPORT DATED


17.07.2025
8: ANNEXURE NO: P/ 8

TRUE COPY OF ELECTRONIC


SERVICE OF BILL
THROUGH WHAT'S APP MESSAGE
VIDE DATED
18TH OF JULY, 2025.
9: ANNEXURE NO: -
P/ 9

ORIGINAL OF NOTICE DATED


ALL THE
08.08.2025 UPON4-126
DEFENDANTS TO PAY THE LEGAL
SERVICES FEES BILL.
10: ANNEXURE NO: P/10 -
ORIGINAL OF RETURNED AND REFUSED
AND POSTAL RECEIPT DATED ENVELOPE124-1?|
WITH TRACKING REPORT DATED
08.08.2025 ALONG
08.08.2025.
11: ANNEXURE NO: P/11 -
TRUE ELECTRONIC RECORD SERVICE
OF NOTICE
WHAT'S APP 132-133
UPON THE DEFENDANTS THROUGH
MESSAGE VIDE DATED 9TH OF AUGUST,
THEIR WHAT'S APP NUMBERS, 2025 AT
12: ANNEXURE NO: P/12 -
TRUE ELECTRONIC RECORD OF PDF FILE
OF
WRITTEN STATEMENT/ COUNTER CLAIMS
VARIOUS APPLICATIONS SHARED WITH ANDI345
THE
PHOTOSTAT SHOP OWNER AT WHAT APP NUMBER
7532078591 ON DATED 10TH OF JULY, 2025.
13: ANNEXURE NO: P/13 –
TRUE ELECTRONIC RECORD OF PAYMENT BY
DEFENDANT MADE ON 10TH JULY,
2025 TO 136
PHOTOSTAT SHOP OWNER FOR PDF PRINT OUT
THROUGH UPI TRANSACTION.
14: ANNEXURE NO: P/ 14 -
TRUE ELECTRONIC RECORD OF PAY TM AND
PHONE PAY UPI TRANSACTION HISTORY OF|3t-144
DEFENDANT: DHANANJAY SHAHI AND SHAHI
ROAD LINES.
15: ANNEXURE NO: P/15 -
TRUE ELECTRONIC RECORD OF WHAT
APP4S-I8|
ACCOUNT IMAGE AND STATUS OF DEFENDANT
NO.1 AND THE COMPLETE RECORD HISTORY OF
ELECTRONIC MESSAGE.
16: ANNEXURE NO: P/16
<br>

TRUE ELECTRONIC RECORD OF WHAT APP


ACCOUNT IMAGE AND STATUS OF DEFENDANT 182-187
NO.2 AND THE COMPLETE RECORD HISTORY OF
ELECTRONIC MESSAGE.
17: ANNEXURE NO: P/17 -
TRUE ELECTRONIC RECORD OF TELEPHONIC
ACCOUNT IMAGE AND DETAILS OF DEFENDANT8%- II
NO.1 AND N0.2 AND THE COMPLETE CALL
RECORD HISTORY OF DEFENDANTS AND
PLAINTIFF
-
18: ANNEXURE NO: P/18
TRUE ELECTRONIC RECORD OF DETAILS
OF22
COMPLETE TEXT MESSAGE HAPPENED IN
BETWEEN DEFENDANT N0.1 AND PLAINTIFF.
19: ANNEXURE NO: P/19 -
TRUE COPY OF NOTICE OF ENQUIRY DATED 213-2)4
06.05.2025 ISSUED TO_DEFENDANT NO.1 BY
JYOTI NAGAR P.S. IN THE CT NO. 487/2025
20: ANNEXURE NO: P/20 -
TRUE COPY OF STATEMENT UNDER SECTION 180
OF BNSS, 2023 GIVEN BY DEFENDANT NO.1
ON
2S
11.05.2025 AND SHARED WITH THE PLAINTIFF.
21: ANNEXURE NO: P/21
TRUE COPY OF SUMMONS ISSUED AGAINST ALL
THE DEFENDANTSAND THE PLAINT IN THE CS NO. 2I6-223
242/2025 SHARED WITH THE PLAINTIFF ON
DATED 21ST OF APRIL, 2025.
-
22: ANNEXURE NO: P/22
TRUE COPY OF SHARED CRIMINAL COMPLAINT 224-227
ANNEXURE DATED 19.10.2024 DRAFTED BY THE
PLAINTIFF IN THE FAVOUR OF THE DEFENDANT,
-
23:ANNEXURE NO: P/23
TRUE COPY OF SHARED LEGAL NOTICE DATED
30.06.2025 OF GIVIL RECOVERY AND CRIMINAL
223-23
AND CIVIL"DEFAMATION AGAINST MR. RAJ
KUMAR.
-
ANNEXURE NO: P/24
24:
ORIGINAL POSTAL RECEIPT DATED: 30.06.2025 244
25: ANNEXURE NO: P/25 -
TRUE ELECTRONIC MESSAGE RECORD OF SERVICE24346
<br>

OF NOTICE UPON MR. RAJ KUMAR FOR


DEFENDANT NO.1 DATED 1,07.2025
26: ANNEXURE NO: P/26 -
TRUE COPY OF SHARED ANNEXURE ENVELOPE
OF|24+
SHAHI ROAD LINES BEARING THE SPEED POST
SLIP DATED:25.06.2025.
27: ANNEXURE NO: P/27 -
TRUE ELECTRONIC RECORD OF VARIOUs
TRANSACTIONS WHICH DEFENDANT NO.1 DID IN
248-49
THE FAVOUR OF MR. RAJ KUMAR.
ANNEXURE NO: -
28: P/28
TRUE COPY OF SHARED ANNEXURE OF
MEDICALSo-s|
RECORD OF DEFENDANT NO.3 MRS. MUNNI
SHAHI.

PLAINTIFF
AKHILESHNAR JHA
Place: DELHI
DATED: 29. 08.2025
THROUGH

[Binay Kumar and Saurabh Kumar


Solanki & ASSOT.]
ADVOCATE FOR THE PLAINTIFF
E-506, KKD COURT, DELHI
Mobile No. 9560714537
E mail: akhilno.2@[Link],
SAURABH KUMARSOLANKI
LLB, LLM)
AdvocaleSUPREME COURT OF (BA, INDIA
Ch. No. 202, H-196, Sec 62 1,NOIDA
INDRAPURAM
1057, NITIKHAND
E-mall: [Link]@[Link]
Mob.: 9456934987
<br>

ANNE XURE
GSTIN: 07DQDPS4366D1ZP

SHAHI ROAD LINES


SR R.O. : N-22/A6, Pocket-N, Dilshad Garden, Delhi-110095
M: 9911994410, 9873770002

Ref, ...
...
Dated
To,
Mr. AKHILESHWAR JHA (Advocate), D/2861/20|7
[Link] Lawyers Chamber Block.
Chamber No, 412
Bhagwan Das Road.
Supreme Court of lndia,
New Deilhi- 110001,
SUBJECT: APPOINTMENT LETTER AS LEGAL COUNSEJJCONSULTANT
Dear Sir,
want to bring into your knowledge that on the behalf of the "SHAHI ROAD
I

LINE", we have considered your candidature, competence and cxpcrience in the field of law
and. for the position of legal Counsel/Consultant in our
company for tlhe next 7 years we are
our Company namcly
pleascd to offer you the position of legal Counsel/Consultant in
SHAHI ROAD LINE.
As you are confirmed with the appointment, expected on your part to take the legal
it is

company with the following


decision with regard to the legal interest and affairs of the
-
responsibility as mention below:
you before thc Hon'ble Supreme Court of
To act, appear and plcad, in the cases assigned to
Ld. Tribunals, in which the
India, Hon'b!e High Courts, Ld. District and Session Courts, and cross
same may be tried and heard. To sign ile, verify and present pleadings, appeals
compromise or other
objections or petitions for executions review, revisions, withdrawal,nccessary or proper for the
as may be dccmcd
pctitions or affidavits or other documcnts
or take back iocuments, to admit or deny
prosecution of the said case in all its stages. To file
or compronie the said case or subnit to
the docunents of the opposite party. To withdraw
may arisc touching or in any manner relating to
arbitration any differences or disputes that
the said case. yeu will always be loyally and
You agrec io the best of your ability and experience that
the company/tire.
conscientiously perlorm all the duties and obligation requircd of and from
LINES With
Thanking you. regard
ROAD
SHAHI prop
For (Mr. DllANANJAY SHA)
Director of SIlAH ROAD LINE.
PLACE: DELIII

1
<br>

S6

14 Civ Suit 759/21


MOHAMMAD ASLAM Vs. DHANANJAY SHAHI

24.04.2025
Prescnt: Plaintiffin pcrson.
Sh. Mohd. Rafi, Ld. Counscl lor plaintiT.
Sh. Akhileshwar Jha, Ld. Counscl for thc dcfendant.
Defendant in person.

Matter is fixcd for DE.


At this stage, evidence affidavit of DW Dhahanjay Shahi is filed. It
is submitted by Ld. Counsel for the defcndant that copy of the same is already

supplicd in advance to the Ld. Counsel for the plaintiff.


DWI examination in chief, cross examincd and discharged. DE
stands closed by way of separate statement.
Put up for addressing final arguments on 14.05.2025.
Date is given as per the convenicnce of the counscl.

(Niharika Kumar Sharma)


Senior Civil Judge cum RC, (Shahdara)
Karkardooma Courts, Delhi/24.04.2025

Digital signatures of Ld. Presiding Officer have expired.


<br>

22Civ Suit759/21
MOHAMMAD ASLAM Vs. DHANANJAY SHAHI S038ion,

10.07.2025
with
Present: Ms. Shabnan Parvecn, Ld. Proxy Counscl for plaintif
plaintifl.
for
Sh. Akhileshwar Jha ond Ms. Shreya Jha, Ld. Counscl
defendant.

Mattcr is fixcd for addressig furthcr final arguments.


Arguments already lhcard.
cvcn datc, the suit of the
Vide separatc judgment of an
Lakh Thirtcen
plaintiff is decrecd for Rs.2, 13,000/- (Rupccs Two
annum from thc date of filing of
Thousand Only) wvith intercst @7% per
the suit till the date of decree and costs of thc suit of Rs. 10,000/- (Rupces

Ten Thousand Only) in favour of the plaintiff and against the defendant.
room
Decree Sheet be prepared accordingly. File be consigned to record
after due compliance.

(Niharika Kumar Sharma)


Senior Civil Judge cum RC, (Shahdara)
Karkardooma Courts, Delhi/10.07.2025

EYAiER
<br>

THE COURT OF MS. NIIHARIKA KUMAR SIIARMA,,


N

SNIOR CIVIL JUDGE


CUM- RENT CONTROLLER, SIIAHDARA DISTRICT, KARKARDOOMA
COURTS,
DELII,

DECRE! SIIEET
Civil Suit No, 759/21
Unique Casc IID No.DLSHO3-001407-2021
Mohamunad Aslam,
Slo Sh. lslam,
R/o L-113A, Dilshad Garden,
Ncar Mother Diary Jhilmil,
East Delhi-110091.
...Plaintiff
Vs.
Shri Dhananjay Shahi,
Slo [Link] Shahi,
R/o A-2/469, Gali no.21,
Subhash Kansla Marg, llarsh Vihar,
Delhi-110093.
...Defendant
SUIT FOR RECOVERY OF RS.2,13,000/- (RUPEES TWO LAKH THIRTEEN THOUSAND
ONLY).

Date of Institution: 07.09.2021


Present Ms. Shabnam Parveen, Ld. Proxy Counscl for plaintiff with plaintiff.
Sh. Akhileshwar Jha and Ms. Shreya Jha, Ld. Counscl for defendant.

It is ordered that the suit of the plaintiff is decrecd for Rs.2,13,000/-


(Rupees
Two Lakh Thirteen Thousand Only) with interest @7% per annum from
the date of filing of
the suit till the date of decrce and costs of the suit of Rs. 10,000/- (Rupees Ten Thousand
Only)
in favour of the plaintiff and against the defendant.
COSTS OF SUIT

Plaintiff Defendant
Stamp of Plaint Rs.10,000/- (Rupccs Ten NIL
|Stamp on Vakalatnama Thousand Only) NIL
Subsistence for Witness
NIL
Commissioner's fee NIL
|Service of process
NIL
Pleader's Fees NIL
Total Rs.10,000/ NIL

Given under my hand and the seal of the Court on this 10" day of July, 2025.

(NIHARIK KUMAR SHARMA)


SENIOR CIVIL JUDGE- CUM- RENT CONTROLLER,
SHAHDARA, KARKARDOOMA COURTS, DELHI.
"10.07.2025

omce ef he irit 9 Sa: om da


Karketdome Courts, D:
Certitie6ba Trun Gopy
Exeiner
Date. Coeying Agacy (Cit)
S

Autherisd nder
tndian Eugence Au.
<br>

ANNE X VRE O: PI3

17 CS 116/23
AARTI MISHRA Vs. JANANDAR PRATAP SHAHI

17.07.2025
Present: Plaintill in person.
Sh. Akhileshwar Jha, Ld. Counsel for the de fendant
no.2 alongwith dclendant no.2.

Steps not taken by plaintifT pursuant to last order


datcd 18.02.2025.
Plaintiff sought adjournment stating that hcr counscl
isunavailable today bcing unwcll.
It is submittcd by defendant no.2 that he wishes to
change his counscl and sccks time to engage a ncw counscl for
himsclf on NDOH.
Put up for payment of costs by plaintiff/ further
proccedings on 03.11.2025.

(Ankur Jain-M)
DJ-02, SHD District
KKDDelhi 17.07.2025

(ol

Dyitally.
ANKUJAIN
ANKUR
Date:
JAIN 2025.07.17
<br>

2 ANNEX VRL NO: PI4


NGT OF DELueAyRT FEE
DeToA1702459J
the Distl. &

IN THE COURT OF LD. C.J.M., SHAHDARA,


DISTRI
KARKARDOOMA COURTS, DELHI

[Link] NO. /2025


IN THE MATTER OF;

SH. RAJKUMAR
S/O LATE SH. NETRAPAL SINGH
RJO E-268, GALI
NO
ASHOK NAGAR, SHAHDARA,
DELHI-110093. 4
MOBILE NO. 88026020.
...COMPLAINANT
88o26o 792o
VERSUS

SH. DHANANJAY SHAHI


S/ONOT KNOWN
MOBILE NO. 9873770002
2. JAINENDER PRATAP SHAHI
BROTHER OF DHANANJAY SHAHI.
MOBILE NO. 9958002224
3. ADARSH SHAHI
S/O DHANANJAY SHAHI
MOBILE NO. 9873770003
4
SMT. MUNNISHAHI
W/O DHANANJAY SHAHI
MOBILENO. 9873770002
ALL PRESENTLY AT A-2/469,
GALI NO. 21, SUBHASH KANSAL MARG,
HARSH VIHAR, DELHI-110093.

HAVING OFFICE NAMELY


"SHAHI ROADLINE"
AT SHOP NO. G-15,
POCKET L,
DPANSMp
DELHL1lo0
GARDEN,

Examiner
<br>

the
Die

KDCourie
Cimin
AND PERMANENT RESIDENT OF
VILLAGE GAJHARA,
POSTOFFICE UJJARPAR,
POLICE STATION GAGAHA,
DISTRICT GORAKHPUR,U.P. ...ACCUSED PERSONS
P.S.: JYOTI NÁGAR

COMPLAINT UNDER SECTION 200 CR.P.C./223


BNSS FOR TAKING COGNIZANCE AGAINST THE
ACCUSED PERSONS PUNISHABLE U/S SI835)S5) B
N3

MOST RESPECTFULLYSHOWETH:

1. That the complainant is peace loving and law-abiding citizen


of India and has been residing permanently at the above
mentioned address with his family.
persons for a
2. That the complainant has known the accused
tenants of the
few years as accused persons were
years and gradually
complainant for approximately eight
developed familial relations with them.
a grocery shop at
3. The accused persons initially' operated
Dilshad Garden,
shop No. G-15, L-Pocket, DDA Market,
name
Delhi-110095, and later established an office under the
"Shahi Road Lines &Transport" in the same shop.
a property and
4. That in year 2022, when complainant sold
withdraw some cash from his account for his daughters
that
marriage, the accused prson came to know
of huge amount in his
complainant
i st!losession received when his
bank accounts out of coipensation he
11AUG
Examinet
<br>

RCopy

KKD

NCTOF DELHI
COURT
DLCT1503818G26020
FEE (63) Courte
ency fCrimne
15JUL-2025

NCT OF DEL GURT EEL

eT:487/ DLCKoeisrsáKa26

Raling.

AKHILESHWAR LLM)
JHA
LLB- J/665
(BASCBA NO: COURT
(ADVOCATE)
DI2861/2017 HIGH
DELHI BLOCK
INDIA/ CHAMBERDELHI-01
NO.
ENROL COURT OF
SETALVAD NEW
SUPREME INDIA,
CH. 4,
NO. COURT OF
SUPREME Mob. No.:
9560714537

2025 tA )
eMelve wt)
Cots
M
ahi Ex HsI
<br>

FEC
Of DELHI cOURT
oT
a26020
DLOT180300002DoZu
16-JUL-2025

N THE COURT or S dtel..SATILAaatelokugyAteHSTCs,SHA.


Suit/Appeal No.
c48.7.2e2s... JURISDICTION OF 201

in re:
.Plalntlf(s) or Petitioner(s)
CLCTISO8csGZ3020a

Appellant(s) Cornplainant(s)
1

VERSUS
Defendant (s)/ Hespondent(s) /AccUsed Know all to whom
thesg Presgnt shall cone that /y..As4.
The above
named..taAL ....do hereby appoint

AKHILESHWARLLB-JHA GAURABH KUMAR (BA, SOLANK


(ADVOCATE) LLM) (BA Advocato
my LB, Lhorize him?
ENROL NO. D2861/RQ:4n aRANA gcate/s) to be faP REta ooURTBO Hoctg cáse i
SUPREME COURT OFINDiA/DE h. No. 202, H-196, Sec 02 NOIDA
court in which the same
CH. NO. SETALVAD CHAMBER AL0ÇK
plead i:thei 10NTI SHANPcduPRAR/&Aef
SUPREME COURT OF INDIA NEN
Mob. Nd,95&57Y4537
ANAAnd
PEalso in the 2ueilatedouineyEbject payment to of fees separately
for each court by me/us.
petitions or for executions review,
To sign file, verify and present pleadings, appeals cross-objection
or as may be deemed necessary
withdrawal, compromise or other petitions affidavits other documents
, or
proper for the prosecution of the said case in all its stages subjects to payment of fees for each stage.
party.
To file and take back documents, to admit and/or deny the documents of opposite
or submit to arbitration any differences of disputes
Towithdraw or compromise the said case
that may arise touching or in any manner relating the said case.
to

To take execution proceedings on paying separate fee.


and to do all
Todeposit, draw and receive money, cheques, cash and grant receipts hereof course
may be necessary to be done for the progress and in the of the
other acts and things which
prosecution on the said case.
power and
To appoint and instruct any other Legal Practitioner authorizing him to exercise the
upon Advocate whenever he may think fit to do so and to sign the
authority hereby conferred the Ž090338

power of attorney on our behalf.


Advocate or
And I/we undersigned to hereby agree to ratify and confirm all acts done by the
matter as own acts, as if done by me/us to all intents and purpose.
his substitute in the my/our
appear court on all
l/we undertake that I/We or my/our duly authorized agent would
in
And
and will inform the Advocate for appearance when the case is called.
hearings
or his substitute responsible for the
And i/we undersigned do hereby agree not to hold the advocate
costs ordered by the court shall be of the Advocate which he
result of the said case. The adjournment whenever
shall recelve and retain for himself.
or part of the fee agreed by me/us
And I/we undersigned do hereby agree that in the event of the whole
to be paid to the advocate remaining unpaid he shall be entitled to withdraw from the prosecution of the said case
until the same is paid up. The fee settle is only for the above
case and above Court. I/We hereby agree that once
the fee is I
paid, /We will not be entitled for the refund of the same any case whatsoever and if the case
prolongs for more than 3 years the original fee shall be paid again by me/us.
IN WITNESS WHERE OF I/We do
been understood by me/us on this
......
hereunto set my/our hand to these presents the contents
.Day of.k.202nccepted
of which have
subject to the terms of
the fees.
omorofthe (eslutent)
KarkarC
ldentify the Slgnayure/ThunGertitassh
Di3 udg
delgw Menttehid Persth,
Client

AKHILESHWAR JHA EopyPresence. Client.


(ADVOCATE)
LLB- LLM)
Fignkdin y he
ENROL NO, DIZ861/2017 (BASCBA NO0:J/685
SUPREME COURT OF INDIA/ DELHI HIGH BAURAEHKUIA&oLANKA
Kdvocato
Eramine
CH. NO, ,SETALVAD
CHAMBER BLOCK
COURT Anany nal)
of ine
SUPREME COURT OF INDIA, NEW DELHI-01
Mob. No.:9560714537
SUPRMdiNa
Ch. No. 202, Hio, Se PLLM
1057, NIt
kR2
E-mall : [Link]. AND
NOIDA
1, INDRAPURAM
Mob.:.[Link] A
<br>

(ORIGINAL INSPECTTON )
T
REPo

oq
(npla y

AFRa
No No
yel
Log
,-
Ragheud:

Subictigiing

t
weD1cs2

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<br>

(alou|23

2) 3) tes acta dalau en

F Aee

-
te
(ohdtttgit
Naty ot, (onec cuee.
S

AT
oiccte

otlirt
Uls- 2
foat
Aidut
<br>

ANNeXuRE No:
at Distt. &
Ses.
D

Kartatdooma
Cuurts
INTHE COURT OF HON'BLE DISTRICT JUDGÉDvinn
SHAHDARA, KARKARDOOMA COURTS, DELHI.

CIVIL SUIT NO. /2025

OF:
IN THE MATTER

...PLAINTIFF
SH. RAJKUMAR
VERSUS
SH. DHANANJAY SHAHI & ORS. ...DEFENDANTS

MEMO OF PARTIES

SH. RAJKUMAR
S/OLATE SH. NETRAPAL SINGH
R/O E-268, GALI NO.7,
ASHOK NAGAR, SHAHDARA,
DELHI-110093.
MOBILE NO. 880260720. ...PLAINTIFF

VERSUS

1
SH. DHANANJAY SHAHI
S/O NOT KNOWN
MOBILE NO. 9873770002
2. JAINENDER PRATAP SHAHI
BROTHER OF DHANANJAY SHAHI.
MOBILE NO. 9958002224
3 ADARSH SHAHI
S/O DHANANJAY SHAH
MOBILE NO. 9873770003
4. SMT. MUNNI SHAHI
W/O DHANANJAY SHAHI
MOBILENO. 9873770002
ALL PRESENTLY AT A-2/469,
GALI NO. 21, SUBIHASH KANSAL MARG,
HARSH VIHAR, DELHI-110093.

ATTESTEO|
07 AUG 2025

E amner
<br>

e4l4
226

t)
<br>

Karardcorma
Cours

HAVING OFFICE NAMELY


"SHAHI ROADLINE"
AT SHOP NO. G-15, POCKET L,
DDA MARKET, DILSHAD GARDEN,
DELHI-110095.

AND PDERMANENT RESIDENT OF


VILLAGE GAJHARA,
POSTOFFICE UJJARPAR,
POLICE STATION GAGAHA,
DISTRICT GORAKHPUR,U.P. ..DEFENDANTS

Filed by

Delhi Mukesh Kumar Bhardwaj


Date: (2.04.2025 Advocate
[Link].G-712, Karkardooma Courts
Shahdara, Delhi-110032
[Link].93 12254443

JATTESTED
7AUB 2026

Examna
NOT OP
<br>

OCL gOUNT PEt


DLOT123607502n13
12-JUL-2025

7HE
JUDa,SHADHARA
C3|212T224

2
Dhannjoy Shahi d os 23/4|

APPLI CA TloN
iN A712 oFCS Wo.
242/2s

3)

he
TSHWNAR ENRDL NO. DI2861/2017
JHACeu
(BA LLB- LLM)
SCBA N0: J/665
SUPREME COURT OF
97 AUG 20S CH!
NO.,
INDIA/ DELHI HIGH
SETALVAD CHAMBER
SUREME COURT OF INDIA,
C
COURT
BLOCK
NEW DELHI-01(
Mob. No.: 9560714537

Exa (hder te) AWTL SsPlre- e.

uni 8i
<br>

Dislt

iCT O DRHHCOUNT rER

Suit/Appeal

In te:
No.....k2.. JURISDCTION Or
2015

Petitioner(s)
Appellant(s) Cornplainant(s)
VLRSUS

D'u. j..aefendant
these Prgsent hallconnéthat (-/ kepgndent(9)/ Accused Vnov
l/y.... all to whom
..2..[Link]
The above .[Link]...[Link]-1/cc9?
named....tl..Udlt..
.....do hereby apoint
AKHILESHWAR JHA SAURABH
(ADVOCATE) (herein KUMAR SOL
ENROL NO. D/2861/2017 943bAyate/4tE mPHSAdvoçate
SCBA NO: JI665 n
SUPREME COURT REME tlhe abovYHnpkrls:horize him:
OF INDIA ADacHI
NO 412 SELALVAn anoCoslgleaf Ch, Ng. COURT OF INDIA
in he aiqo-olk
CH HUADHR OOCK
SUPREME COURTG6INIAUNAYAIEJHI01 also in tht app 2iEGifPb any other court
ig courGbjde it6payment
in which the same
Mob, No.. 9560714537 Mob,: of fees separately
To slgn file, verlfy
and present pleadings, appeals
revision, withdrawal, compromise or cross-objection or petitions
or proper for other petitions or affidavits or other for executions review,
the prosecution of the said case in all documentsias may
its stages subjects to payment be deemed necessary
of fees for each stage.
To file and take back
documents, to admit and/or
deny the documents of
opposite party.
To withdraw or compromise
may the said casce or submit to arbitration any
that arise touching or in any manner differences of disputes
relating lo the said case.
To take execution proceedings orn
paying separate fee.
To deposit, draw
and receive money, cheques, cash
other acts and things which may and grant receipts hereof and to
be necessary to be done for the progress do all
prosecution on the said case, and in the course of the
To appoint and instruct any
other Legal Practitioner authorizing him
authority hereby conferred upon to exercisc the power
power of attorney on our the Advocate whenever he may and
behalf. think fit to do so and to sign the
1717231

And I/we undersigned to


his substitute in
hereby aeree to ratify and
the natter as my/our own acts, as if done by confirm all acts done by the Advocate or
me/us to all intents and purpose.
And l/we undertake
that /We or my/our duly authorized
hearings and will inform agent would appear in court on
the Advocate for appearance when all
the case is called.
And i/We undersigned
do hercby agree not to hold
result of the said case. The the advocate or his substitute
adjournment costs whenever responsible for the
shall receive and retain
for himsell,
ordered by the court shal be of
the Advocate which he
And l/we undersigned
do hereby agree that in
to be paid to the advocate the event
renaining unpaid he shall be entitled of the whole or part of the fee agreed by me/us
until the sarne is paid up. The to withdraw from the
fee settle is only for the prosecution of the said case
the fee is paid,IWe will not above case and above Court.
be entitled for i/We hereby agree that once
prolongs for more than 3 years the refund of the same in any case
the original fee shall be paid again whatsoever and if the case
by me/us.
IN WITNESS WIHERE OF I/VWe
been understood by ne/us on do hereunto set my/our hanst
this to these presents the contents
the fees. ....D..Hl....ay of...4.5f.....201BAccepted subject toof which have
the terms of
Advocate
Client
Client
PnT
ice oftheauellhunl
the Distir lmnessionof Below Mentioned Person,

hain My Presence. The Client.


Ci (BA, LLM

Date.
iamin.
Inan Evidec9Acl CS78
1i$72
of the
<br>

Akfileshwar Jha (ADVOCATE)(BALLB)(LLM) ANNEXRo-Ps


SUPREME COURT OF INDIA/DELHI HIGH COURT
ENRT No. DI2861/2017 SCBA No. J/665
[Link], Setalvad Chamber Block, Supromo Court of India, New Delhl-110001
Ch. No.-755, Lawyor's Chambor Block, Dwarka Sector-10
Off.-Cum.-Resi.:- 38-B, SG Pockot, Dilshad Gardon, Dolhl-110095
Mobile no - 9560714537, 9868394921 Emall: [Link]]hascl@[Link]

To, DATE: 16.07.2025


(1). Mr. Dhananjay Shahi S/o Vishanath Shahi
(2). Mrs. Munni Shahi W/o Dhananjay Shahi
(3). Mr. Adarsh Shahi S/o Mr. Dhananjay Shahi
R/o A-2/ 469, Gali No. 21, Subsh Kansal Marg,
Harsh Vihar, Delhi- 110093,
Subject: BLL: Payment of fees of Rs. 2,O,000/- (Two Lakhsand
TEN Thousand),
(1). For Exchange and receiving of legal opinion- legal
consultation services, conference charges, considering and
reading out relevant lengthy documents charges.
(2). Darting of various 2 Different application under Order 1
Rule 10(2) and (13) on behalf of the 3 persons,
(3). 1 Common Application under order 7 Rule 11 on behalf of
the 3 persons,
(4). Common Written statement and separate Counter Claim for
Mr. Dhananjay Shahi, Mrs. MunnaiShahi, Mr. Adarsh Shahi.
(5). Appearance fees for appearing before 2 different Hon'ble
Court.
(6). For- preparing Lengthy written submissions, for giving
lengthy legal arguments.
(7). Drafting of Rs. 2,00,000/- recovery and Rs. 2,50,00,000/
defamation Legal notice against Mr. Raj Kumar Bhati on
behalf of Mr. Dhananjay Shahi, Mrs. Munnai Shahi, Mr.
Adarsh Shahi and their trucking business.
(8). For Exchange and receiving of legal opinion- legal
consultation services, conference charges, considering and
reading out relevant documents connected with Notice
Under 175(3) of BNSS and statement given under of Mr.
Dhanangay Shahigiven under section 180 of BNSS.
(9). Other Miscellaneous and clerical Charges Rs. 2,000/-.
Sir/Mam,
I want to inform you that the 9 sort of expenditure are still pending on
your part which are Darting of various 2 Different application under
Order 1 Rule 10(2) and (13) on behalf of the 3 persons, 1
Common Application under order 7 Rule 11 on behalf of the 3
persons, A Common Written statement and separate Counter
AKHILESHNAR JHA LLM) (BA LLB-
(ADVOCATE)
ENROL NO, DI2861/2017 SCBA N0: J665
DELHI HIGH COURT
SUPREME COURT OF INDIA/
CH. NO. SETALVAD CHAMBER BLOCK
DELHI-01
SUPREME COURT OF INDIA, NEW
Mob. No.: 9560714537
<br>

Akhileshwar Jha (aDvoCATE)(BALLB)(LLM)

SUPREME COURT OF INDIADELHI HIGH COURT


ENRT No. DI2861/2017 SCBA No. J/665
Ch.N0. Setalvad Chambor Block, Suprome Court of India, New Delhi-110001
Ch. No.-755, Lawyer's Ghambor Block, Dwarka Sector-10
Off.-Cum.-Resi..- 38-B, SG Pocket, Dilshad Garden, Delhi-110095
Mobile no - 9560714537, 9868394921 Email:
[Link]@[Link]
Clain feE ME-Dhananjay_ Shabi, Mrs. Munnai shahi, Mr. Adarsh
Shahi. Which is for worth Rs. 1,00,000/-. Appearance fees for
appearing before 2 different Hon'ble Court vide dated On
10.07.2025 and 17.07.2025 (1500/- + 2,000/-= 3,500/-). For
preparing Lengthy written submissions,_for giving lengthy legal
arguments (42000/- + 30,000/- + 1,50075,000/-), Drafting of Rs.
2,00,000/- recovery and Rs. 2,50,00,000/- defamation Legal
notice against Mr. Raj Kumar Bhati on behalf of Mr. Dhananjay
Shahi, Mrs. Munnai Shahi, Mr. Adarsh Shahi and their trucking
business which is 9,000/-. For Exchange and receiving of legal
opinion- legal Consultation services, conference charges,
considering and reading out relevant documents connected with
Notice Under 175(3) of BNSS and statement given underof Mr.
Dhanangay Shahi given under section. 180 of BNSS which is
30,000/-. That pending [Link] charqes, acceptance of brief
physically and through electronic mode, research work and reading of
documents, formulation legal opinion, lengthy legal consultation
of

and through What App Message, other


charges telephonically
miscellaneous and clerical charqes in whole leqal exercise matter for

worth Rs. 2,)0,000/-.

Table A: Details of pending fees upon legal work done are mention
are as followS: Ors.
In the Matter of Raj Kumar Vs. Dhananjay Shahai and
CS. 242/2025.
Darting of various Different application under Order 11
2
persons,
Rule 10(2) and (13) on behalf of the 3 on
Common Application under order 7 Rule 11 behalf of
the 3 persons, A Common Written statement and separate
Mrs. Munnai
Counter Claim for Mr. Dhananjay Shahi,
Shahi, Mr. Adarsh Shahi. Which is for worth Rs. 1,00,000/
BILL DESCRIPTION
AKHILESHWAR JHA
(BA LLB- LLM)
(ADVOCATE) SCBA NO: J/665
ENROL NO. DI2861/2017 HIGH COURT
INDIA / DELHI
SUPREME COURT OF CHAMBER BLOCK
: CH, [Link]
INDIA, NEW DELH-01
SUPREME CÖURT OF
Mob. No.: 9560714537
<br>

Akileshwar Jha (ADVOCATE)(BA/LLB)(LLM)


SUPREME COURT OF INDIA/DELHIHIGH COURT
ENRT No. D/2861/2017 SCBA No. J/665
[Link].-, Setalvad Chamber Block, Supromo Court of India, New Dolhi-110001
Ch. No.-755, Lawyer's Chambor Block, Dwarka Soctor-10
off.-Cum.-Resl.:- 38-B, SG Pocket, Dilshad Gardon, Delhi-110095
-Mobilo no-9560714537, 9868394921 Emall:. [Link]@[Link]
[Link]. Particular/[Link] Wnpaid
in Rs. fees in
Rs.
1: Darting of various 2 Different application| 20,000
under Order 1 Rule 10(2) and (13) on
behalf of the 3 persons. 20,000 40,000/
A. Adarsh Shahiand Munnai Shahi
B. Dhananjay Shahi
Accepting of brief, Conference charges,
Reading and Research work on Documents,
legal opinion and,drafting charges.
2: Drafting of a Common Application under 20,000
order 7 Rule 11 on behalf of the 3
persons. Mr. Dhananjay Shahi, Mrs.
Munnai Shahi, Mr. Adarsh Shahi: Providing 20,000/
of legal Conference on telephonically Charges
and upon what app electronic message,
consultation and legal opinion Charges,
drafting of lengthy and legal application
charges and other Miscellaneous Charges left
unpaid.
3: Drafting of Common Written statement for 20,000
Mr. Dhananjay Shahi, Mrs. Munnai Shahi,
Mr. Adarsh Shahi. 20,000/
Drafting of Common written statement
"against Raj kumar claim" Providing of
legal Conference on telephonically Charges,
consultation and legal opinion Charges,
drafting of Common written statement
charges and other Miscellaneous Charges left
unpaid.
4: Drafting of separate Counter Clain for 20,000
Mr. Dhananjay Shahi, Mrs. Munnai Shahi,
Mr. Adarsh Shahi: Providing of legal 20,000
Conference on telephonically Charges and
upon what app electronic message,
Consultation and legal opinion Charges,
drafting of Counter Claims under Order 8 Rule
6A of CPC charges and other Miscellaneous
Charges left unpaid.
All the applications and written statement and
counter claims draft under your written
instructions, same has been prvided through
AKHILESHVWA
: J/665
(ADVOCATE) SCBA NO
DI2861/2017
DELHI HIGH COURT
ENROL NO. INDIA/ R BLOCK
COURT OF CHAMBER
DELH-01
SUPREME SETALVAD
NEW
INDIA,
CH. NO. COURT OF9560714537
SUPREME
Mob. No.:
ARfileshwar Jha
<br>

(ADVOCATE)(BA/LLB)(LLM).
SUPREME COURT OF INDIA/DELHI HIGH COURT
ENRT No. DI2861/2017 SCBA No. J/665
[Link]., SetalvadChambor Block, Supromo Court of india, Now Delhi-110001
Ch. No.-755, Lawyer's Chamber Block, Dwarka $octor-10
Off.-Cum.-Resi.:- 38-B, SG Pockot, Dilshad Gardon, Dolhi-110095
no -
Mobile 9560714537, 9868394921 Email: [Link]@[Link]

the What's app message in the PDF form, for


the same the print out has been taken out
and affidavits has been done. That
file containing all the documents the whole
along with all
the annexures and affidavits has
provided to you all the applicant or tobeen my
clients.
5. TOTAL UNPAID FEES
1,00,00
0/

Total Expenditure: of Clause


1+2+3+4= 1,000,00/
IN WORDS: (One Lakhs) rupees only.

Table B:
Details of pending fees upon lègal.
mentions are as follows: work done are
Drafting of legal notice vide dated 01.07.2025 Rs.
2,00,000/- recovery notice and. Rs.
defamation Legal notice against Mr. Raj 2,50,00,000/
behalf of
Kumar Bhati on
[Link], [Link],
[Link] and their trucking
9,000/-. business which is
BILL DESCRIPTION
[Link]. Particular/ Description of fees Fees Unpaid
in Rs. fees. in
Rs.
1: Drafting legal notice vide dated9,000/
of
01.07.2025 for Rs. 2,00,000/- recovery
notice and .Rs. 2,50,00,000/- defamation
Legal notice against Mr. Raj 9,000/
Kumar. Bhati on
behalf of [Link],
[Link], [Link] and
trucking business their
The legal notice has been
served upon
[Link] through, What app no.
9560714537 upon his official What's App
Number and the statUs of delivery
report
been duly shared with [Link] hasat

AKHILESHWAR
(ADVOCATE)
ENROL NO.
SUPREME DIZ861/2017 (BA LLB-
JHA
COURT SCBA LLM)
CH. NO. OF INDIA DELHI N0: J665
I
SUPREME SETALVAD CHAMBER HIGH COURT
COURT BLOCK
OFINDIA,
NEW DELHI-01
Mob. No.:9560714537
<br>

Akhileshwar Jha (aDvocAT)OALBJLLM)


SUPREME COURT OF INDIA/DELHI HIGH COURT
ENRT No. DI2861/2017 SCBA No. J/665
of Indih, Now Dlhl-110001
[Link].-, Sotalvad Chambor Block, Supromo Court
Ch. No.-755, Lawyor's Chambor Block, Dwarka Soctor-10
Dolhi-110095
Off.-Cum.-Rosl..- 38-B, SG Pockot, Dllshad Gardon,
Mobilo no - 9560714537, 9868394921 Emall:
[Link]@[Link]
his-AhatappMU98S7TO002
24 TOTAL UNPAID FEES 9,000/

Total Expenditure:_of Clause 1= Rs. 9,000/


IN WORDS:(Nine Thousand)rupees only.

Table C: Details of pending fees upon legal work done are


mention
are as followS:
In the [Link] [Link],CS. No.
of

759/2021.
Charges of Rs. 1,500/- Appearance vide on dated
10.07.2025, before the Hon'ble Court of Niharika Kumar
Sharnma.
For preparing Lengthy written submissions, for giving
lengthy legal arguments(Rs. 42000,/- + Rs. 30,000/- + Rs.
1,500= 73,500/-) - Rs. 10,000/- paid total= 63,500/- 41,soo
BILL DESCRIPTION

[Link]. Particular/ Description of fees Fees Unpaid


in Rs. fees in
Rs.
1: A:Drafting and preparing Lengthy written 42,000
submissions for [Link]änjayShahi and,
B: for giving lengthy legal arguments orn
vide dated: 14.05.2025 for 30,000
[Link].
(10,00
0) paid
C: chargesfor citation research and + 63,500
relevant case finding 1,500
The Drafted and prepared written submissions
has been filed before the Hon'ble Court of Law
and the same has been shared through What
app message to [Link] at his
What app no. 9873770002.
2. Charges for Appearance vid on dated 1,500/- 1,500/
10.07.2025, before the Hon'ble Court of
Niharika Kumar Sharma.
TOTAL UNPAID FEES 65,000/
AKHILESHWVAR JHA
(ADVOCATE)(BA LLB- LLM)
ENROL NO. DI2861/2017 SCBA NO: J/665
SUPREME COURT OF INDIA/ DELHI
CH. NO, , HIGH COURT
SETALVAD CHAMBER BLOCK
SUPREME COURT OF INDIA,
NEW DELHI-01
Mob. No.:9560714537
Akfileshwar Jha
<br>

(ADVOCATE)(BALLB)(LLM)
SUPREME COURT OF INDIA/DELHI HIGH COURT
ENRT No. DI2861/2017 SCBA No, JJ665
[Link]., Sotalvad Chamber Block, Supremo Court of Indla, New Delhi-110001
Ch. No.-755, Lawyor's Chambor Block, Dwarka Sector-1O
Off.-Cum.-Resi.;- 38-B, SG Pocket, Dilshad Garden, Delhi-110095
Mobile no - 9560714537, 9868394921 Email: [Link]@[Link]
Total Expenditure: of Clause 1
and 2= Rs. 65,000/
IN WORDS: (Sixty FiveThousand)rupces only.

Table D: Details of pending fees upon


are as follows:
legal work done are mention

In the
Matter of Aarti Mishra [Link]&
Others, CS. No. 116/2023.
Charges of Rs. 000/- Appearance
17.07.2025, before the Hon'ble Court of vide
Ankur
on dated
Jain- II,
ADJ, Shahdara, KarkardoomaDistrict Court
District Court.
BILL DESCRIPTION

[Link]. Particular/ Description of fees Fees Unpaid


in Rs. fees in
Rs.
1: Charges for Appearance vide on dated 2,000/
17.07.2025, before the Hon'ble Court of
Ankur Jain- II, ADJ, Shahdara,
Karkardooma District Court District Court
2. APPSRANCS and Avgument, Sobmision 2yoco/
chegs on ui de
dae. |+|o4|o2S
TOTAL UNPAID FEES Z000/
11,000/
Total Expenditure: of
Clause 1 = Rs.
IN WORDS:( -Jrupees -CFoue T HOUs AN
D) hus any

Table E: Details of pending fees upon


are as follows:
legal work done are mention
In the Matter of: Sh Raj Kumar Vs. Dhananjay& Ans. CT
Case Dy.
78/2025. U/s 175.3 BNSS, Karkardooma
District Court and PS. Jyoti Nagar Delhi.
For Exchange and receiving of legal opinion- legal
consultation services, conference charges, considering

AKHILESHWAR JHA
(ADVOCATE)
(BA LLB- LLM)
ENROL NO. DIZ881/2017 SCBA NO:J665
FIN
SUPREME COURT OF INDIAI DELHI HIGH COURT
CH NO SETALVAD CHAMBER BLOCK
SUPREME COURT OF INDIA, NEW DELH-01
Mob. No.: 9560714537
<br>

(aDvOCATE)@ALLB)(LM)
Akhileshwar Jha
SUPREME COURT OF INDIA/DELHI HIGH COURT
ENRT No. D/2861/2017 SCBA No. J/665
Dolh-110001
[Link].-, Sotalvad Chambor Blok, Supremo' Court of India, Now
Ch. No,-755, Lawyor's Chambor Block, Dwarka Soctor-10
oncumarÜng 3BL, 9GIArKAt RsttfarYeg tBhat's App
Mobile Mdegseugos63A19G0gIAALEiyhak4lghgata SHSShrough
Hang-telephonie-tUITvErstions, Conneted with Notice
Under 175(3) of BNSS vide dated 06.05.2025 and
statenent given under section 180 of BNSS by
[Link] Shahi vide on dated 1105.2025. In the CT
case No. 487/2025
BILL DESCRIPTION
[Link]. Particular/ Description of fees Fees Unpaid
in Rs. fees in
Rs.
l: For Exchange and receiving of legal 30,000
opinion and legal tactics- legal
consultation services, Conference
charges, considering
and reading out
relevant documents through What's Ápp
Messages and giving opinion and
Suggestions through. long telephonic
conversations, Connected with Notice 30,000/
Under 175(3) of BNSS vide dated
06.05.2025. and statement under given
section 180 of BNSS by [Link]
Shahi vide on dated 1105.2025. In the CT
case No. 487/2025.
The legal tactics and defences was shared
with [Link] Shahi through the lengthy
Telephonic calls and upon the successful
defence before the Police station Jyoti Nägar
[Link] Shahi has shared his defence
statement with me through What app
message of [Link] Shahi What app no.
9873770002.
2. Other miscellaneous and clerical charges 2,000/-|2,000/
involved in all the above [Link]
mentioned at table A+B+C+D
TOTAL UNPAID FEES 32,000/

Total Expenditure: of Clause 1 and 2= Rs. 31,000/


IN WORDS: (Thirty Thousand) rupees only.

AKHILESHWVAR JHA
LLB- LLM) (BA
(ADVOCATE) SCBA NO: J/665
DI2861/2017 HIGH COURT
ENROL NO. DELHI
COURT OF INDIA/
CHAMBER BLOCK
SUPREME , SETALVAD DELH-01
.NO. NEW
OF INDIA,
SUPREME COURT No.:9560714537
Mob.
<br>

Akfiileshwar Jha (apvocATEXBALLDJLLM)

SUPREME COURT OF INDIA/DELHI HIGH COURT


ENRT No. DI2861/2017 3CBA No. J/665
[Link].-, Setalvnd Chamber Block, Supromo Court of Indla, Now Dolhi-110001
Ch. No.-755, Lawyor's Chambor Block, Dwarka Soctor-10
Off.-Cum.-Rosi.:- 38-B, SG Pockot, Dllshad Gardon, Dolhl-110095
Mobilo no - 9560714537, 9868394921 Emall: [Link]@[Link]

Total Expenditure stand unpaid in the form legal fees: described


of

into Table A+B+C+D-+E = 2, |0,000/


IN WORDS: (Two Lakhs and,
I want to inform you
Cl Thousand) rupces only.
that the above mention s the detail of unpaid fees,
which you have still not paid till the present date and you are
under the
liability to pay the fees of Rs. 2,10,000/- for the above mention
legal work,
as the legal services are not for free or pro bono
services. Please kindly
clear the fees within in 36 days from the serving of this bill,
either
through account transfer, UPI transfer, or through any other mode.
Details of UPI transfer No. Bank Account Details:
9560714537 31556721112 SBI
With regard you faithfully
AKHILESHWAR JHA
(ADVOCATE)
ENROL NO. DI2861I2017
(BA LLB- LLM)
SCBA NO:J/665
SUPREME COURT OF INDIA/ DELHI HIGH COURT
CH. NO. SETALVAD CHAMBER BLOCK
SUPREME COURT OF INDIA, NEW DELHI-01
Mob. No..9560714537

(AKHILESHWAR JHA AND Assot.)


PLACE: DELHI ADVOCATE
SUPREME COURT OF INDIA
<br>

ANNE XVRL NO!


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Dtnton PncodoTrlArctDN ocntonDsy


Distt Court KKD SO 17/07/2025 1300 45 110095 29 50 Inland Speed Post Nand Nagn C SsO
26/07/2025 1757 22
Event Details For: ED748057944IN
Durent Status: hem Delivered(Sender)
Tnt0ce
26/07/2025 1757 22 Jhilmil HO Item Delivered(Sender)
26/07/2025 049:12 Jhtrnll HO Out for Devery
26/07/2025 08 34 01 Jhilmil HO Itern Recerved
240I2025 104432 Rohln! Sector7 So tern Redrected to Jhtrnil HO lnsutficent Addrss
24/07/2025 09 26 06 Rohnl Sector7 SO Ilern Received
24-07-2025 06:43:12 MA RMS Bhawan tem Dispatched
24-07-2025 0333 36 Dlh RMS Bhawan NSH-1| Itern Dspatched
24-07-225 01A626 Delhi RS Bhawan NSHHI Hem Bagged
22/07/2025 1036 56 Nand Nagn C SO Ilem Dispatched
22/07/2025 103615 Nand Nogrn C 60 tern Bagged
21/07/2025 1847:01 Nand Nagr C SO Item Returned Refused
21/07/2025 1138:17 Nand Nagd c so Out for Dellvery
21/07/2D25 10 24 02 Nand Nag C So Item Recerved
21/07/20O5 02350O MA RMS Bhawan
tem Dlspatched
20/07/2025 23 59 00 New Delhi NSH
ltern Bagged
19/07/2025 19.5500 MA RMS Bhawan
tern Dispatched
19/07/2025 03 05 00 New Delhi NSH Itern Bagged
18/07/2025 1923:32 Nand Negn c 80 Itern Dispatched
18/07/2025 19 22 08 Nand Nagr C S0 Itenn Bagged
1B/07/2025 163336 Nand Nogi C s0 Hen Returned Refued
18/07/2025 09 34 30 Nand Nagn C S0 Out for Delivery
1a/07/2025 086744 Nand Nagn c so tern Recetved
17/07/2025 23 45 0o0
New Delhu NSH Ilenn Bagyed
17/07/2025 214500 MA RAS Bhawan ttem Dlspatched
17/07/2025 16 20 22 Distt Court KKD SO
Item Dsspatched
17/07/2025
15:5726Diatt Court KKD BO
hem Bagged
17/07/2025 13 00 45 Distt Court KKD SO
Iterm Booked
<br>

2:17 .lO61y

Up Wale Bhiya Market..


-Shahi
10:08 am
18 July 2025

Sir app ko pura time diya


gaya hai sari
fees puri dene ka, lakin aaj
aur abhi tak
app ne mujhe bachi hui koi fees nahidi
hai. 10:09 am v
Ihave appeared for you in the various
matters and even then you are
deliberately avoiding my fees
So for the reason Iam putting you under
liability to make the payment of fees biil
and expenditure within the reasonable
time.
Herein after I serves upon the whole fees
structure for which youhave engaged
me. To do your litigation work in form
of appearance, submission, arguments,
drafting, formulation of legal opinion,
conversation and conference charges and
other works. 10:13 am

Forwarded
Akhileshwarha uovoCATINaALLNO
SUPIEI COUT OF OADELNHON coUNT
ENKT Ne. D2012017
C
LUe

DATEI 1407.2021
l

[Link]
8 pages 793 kB• PDF

10:13 am

You
Abhi tak Aslam walifees nahi ayee hai. ?
1,500/- ki
Ye abhi bhipending hai 10:14 am

Message
<br>

ANNEXU2E No!P)9

SAURABH SOLANKI& ASSOCIATES


Advocates & Solicitors [Link]
(SUPREME COURT OF INDIA)
CH. NO.: 202, H-196, SEC-63, NOIDA
ADV. AKHILESHWAR JHA 1057, NITI KHAND, 1 INDIRAPURAM
(SUPREME COURT OF INDIA)
E-506, KKD COURT NEW DELHI
ADV. JITENDRA TYAGI T-31, TEES HAZARICOURT DELHI
E-92, KKD COURT NEW DELHI
(DELHI HIGH COURT)
ADVOCA
Mob.: 9456934987
ADV. NITIN SHARMA
(DELHI HIGH COURT) E-MAIL: [Link]@[Link]

Dated: 08.08.2025
SPEED POST

To,
1: Mr. Dhananjay Shahi,
S/o Late Shri Vishvanath Shahi,
2: Mrs. Munni Shahi,
W/o Mr. Dhananjay Shahi
3: Mr. Adarsh Shahi,
S/o Mr. Dhananjay Shahi

Having a common resident at:


R/o: A-2/ 469, Gali No. 21,
Subhash Kansal Marg,
Harsh Vihar, Delhi - 110093
Mobile Number: 9873770002, 9810940743, 9873770003

LEGAL NOTICE

Subject: LEGAL NOTICE/DEMAND NOTICE FOR THE RECOVERY


OF AMOUNT FOR WORTH Rs. 2,10,000/- ALONG WITH
THE INTREST RATE OF 129/% PER ANNUM, FOR THE
PROFESSIONAL LEGAL SERVICES WHICH WERE
RENDERED TO ALL 3 OF YOU NOTICEE/ DEFAULTERS
FOR THE DIFFERENT MATTERS AT VARIOUS POINT OF
TIME.
AKHILESHNAR JHA AAURABH KUMAR SH
(ADVOCATE) (BA LLB- LLM) COURTOF INDIA
ENROL NO. DI2861/2017 SCBA N0: J/665 SUPREMc
7ND,
Ch. No.
2
NODA
NORAPURAM
SUPREME COURT OF INDIA/ DELHI HIGH
CH. NO. SETALVAD CHAMBER
COURT E-mall :
[Link]
SUPREME COURT OF INDIA NEWDEIHLOA :9458934987
Mob. No.: 95607145
14537
<br>

Under the instruction and on bchalf of my legal associate Mr.


Akhileshwar Jha "Advocale" S/o Mr. Mukteshwar Jha R/o 38-B, SG
Pocket, Dilshad Garden, Dolhi 110095. I hercby serve upon yOu the
following legal notice:

1. That you Mr. Dhananjay Shahi, Mrs. Munni Shahi, Mr.


Adarsh Shahi, (Hereinafter referred as the "defaulter/noticee")
that you all are very well aware of my legal associate since from
his childhood and my lcgal associate is very wcll awarc with all of
you the Noticee sincO fromn his childhood. That you Mr.

Dhananjay Shahii use lo run your petty shop of grocery in the


nearby residential locality of SG pocket and your shop is just
located 200 meters away from our legal associate resident. That
earlier your shop is silualed at the L
pocket DDA market, Dilshad
Garden, Delhi- 110095. That you the Noticees is very well aware
with the family members of our legal associate, as our legal
associate family members were habitual to buy grocery products
from your petty shop which is run by Mr. Dhananjay Shahi, Mr.
Adarsh Shahiand Mr. Jainendra Shahi.
2. That since from very iong time you the Noticees have the social
and native cordial relationship with our legal associate family. That
my Legal Associate knows you all the Noticees since from his

childhood to practising his legal profession. Meanwhile you Mr.


Dhananjay Shahi have transformed your small shop of grocery
in the officeof Shahi Road line, which is your trucking business.
3. That when one of you the Noticee Mr. Dhananjay Shahi started
ADVJAEHWARHAAC,
trucking busincsS you have faced the miserable position
LLM)
A (BA LLB-
D/2861/2017/$CBA NO:
TDELHLHIGH
COURT
SOLA
COURTOFANDJA
ENROENO
CHAMBERBLOCK SAURABHKUMAR FINDIA M
SETALVAD NOIDAPURAM
SUPREME
COURT
CH
SUPREMÊ OFI
NO. GOURT
REME Loom
M6, 9466934987
Ad
.doM Ch. [Link]
Mob.:
adv.
E-mall:
<br>

88

because of your busincss rivalry in the local market and yOu are
unable to handle them alone without the legal support.
4. That you the Noticee Mr. Dhananjay Shahi had approached to
my legal associate in the ycars 2022 for the legal assistance, legal

opinion and for legal conferences. That since from the 2022 to
July, 2025 you are in consistent touch with our legal associate and
taking his paid legal scrvices for the different kind of matters at
the various point of tim. That the legal and professional servíces
which my legal Associate had provided to you the Noticee Mr.
Dhananjay Shahi are all paid services and nothing is for pro
bono. That for each and every single legal service you the noticee
Mr. Dhananjay Shahi were charged with the fees.

5. That My legal associate has every time raised the fees bill upon
you the Noticee but you are habitual of committing
the consistent
default in makingthe payments of the fees at the various intervals
point of time since frorm 2022 to march 2025. That you the Noticee
had never paid your fCes on time, that you the Noticee is very
much habitual since from the beginning of the time to first get
your legal work done then to pay off the legal
fees which you the
Noticee Mr. Dhananjay Shahiowes to my legal associate.
6. That their prevails a common understanding in between you the
Noticee Mr. Dhananjay Shahi and in between my legal associate
that whatever legal work my legal associate will perform into your
favour, for each work you be charged with the different rate
will

and fees. That each Work will have its own different cost and fees
and for each legal work and assistance a proper quotation was
served upon you for your consent, the legal work had always
LANKI

aTAAMUN ttRAB4KUMARFINOIA NA
AIaMI cOURNNoiRAAPURA
MARUAO SUPREME
SUOSBMAoiov
[Link] Advoce [Link] LCom
9456934987
No.
reG-Ee900:.doM Ch. [Link]
[Link]
bnsod E-mall : Mob.:
[Link]:
len
<br>

started when you the Noticoes Mr. Dhananjay Shahi have given
the consent upon the proposal and upon the feos to my legal
associate. That cvery time the legal services were performcd into
your favour in advance and after then you have paid the bills, as
you had being always a dfaulter.
7. That the my legal associate use to perform various legal activity
and professional duc diligence for the prolection of you the
Noticees lcgal interest, for the protection of your farnily, for your

trucking busincss frorm the unlawful and unwantd social

personality and havc also protcctcd you the Noticcc


Mr.

Dhananjay Shahi from the various litigation proces5 and from


the various criminal complaints which had been filed against you
the Noticee Mr.
Dhananjay Shahi before the Seemapuri Police

station and before the Jyoti Nagar Police Station.


8. That for the above nention process and for above mention
were
litigation work and for other professional services the fees bill
raised upon you the Noticce and you the Noticee Mr. Dhananjay
Shahi have paid al! the previouslytill February, 2025. That my
bill

legal assOciate have put you the Noticee Mr. Dhananjay Shahiat
liberty to pay off all thc pending bill by the way of instalments, but
you have intentionally ncver paid the fees on time rather you the

Noticee Mr. Dhananjay Shahi always being the fees defaulter.


were raised
That after March, 2025 the various new and fresh bills
upon you the noticcec for the new legal professional work.
Dhananjay Shahi being satisfied with
9. That, you the noticee Mr.
you have issued the
the legal services of ny legal associate,
authority letter upon yOur lctter hcad vide datcd: 234 of
DMAJOe SOLANK
(MJJ EIJ A)
AAMU?AHEA GAURABH KUMAR (BAINOA
Advoce uPREME
OF
SUP H-198. COUNOIDA
INDRAPURAM
KHAND 1,
MARUASIQNL, OMADK,Keo Ch. No. 202,
[Link]
1057
[Link]
TOCACc8o vbe: lis-3 E-mall: 948i34987
Mob.:
:.doM e
<br>

JanuarY, 2023 bcaring reference No, 9873770002 in the name of


"SHAHI ROAD LINES" which contain you signature, your G5IN
Number: 07DQDPS4366D1ZP and contain your seal upon the
authority letter. Thc Lettcr was issued by you the noticee Mr.
Dhananjay Shahi in the favour of my Legal Associate with an
intent and determination that my client will protect your all the
legal intcrest and legal issucs and represent you the Noticee Mr.

Dhananjay Shahi and your trucking business before any lawful


authority and before any Hon'ble Court which is establish within
the territorial jurisdiction of India. That the letter which you the
Noticee Mr. Dhananjay Shahi have issued into the favour my
legal associate expressly contain all the conditions and expressly
mention your wilful consent upon the terms of specialised legal
skills which my legal associate need to perform into your favour
which varies from cases to case and you the Noticee Mr.
Dhananjay Shahi expecting the same skills from my Legal

associate to be exercised into your favour. That my legal associate


has acted into your favour by placing his reliance upon this true
authorityletter which was executed into his favour and, by which
you the Noticee has delegated all the legal powers into the favour

of my legal associate.
10. That you the Noticee Mr. Dhananjay Shahi have further
authorised my Legal Associate to represent you the Noticee before
the Various Hon'ble Court of law and before the various legal
authority, for which you the Noticee Mr. Dhananjay Shahi have
executed one vakalatnama into the favour of my Legal Associate
and authorising him to use it whenever it is required urgently to
iita9R AAMUA
HSARJAe SAURABH KUMAR SOLANKI
Advocate
(BA, LLB, LLM)
sUPREME COURT OF IND
Ch. No. 202, H-196,
kRAND,INDRAPURAM
fnoo tlerrngo :1037,
[Link]@[Link]
TaC+eeaC8vbs : stn Esml
Mob.: 9458934987
[Link] ol
<br>

represent your legal interest. That from the long going on implied
and expressed practise and understanding in between, you the
Noticee Mr. Dhananjay Shahi and my legal associate it is very
fairly clear that upon the various oCcasion my legal associate have
acted and used his profcssional legal skills to protect you and your
trucking business legal interest. That all the legal acts are
performed into your favour only after your expressed message or
,my legal
by telephonic expressed consent and upon ever occasion

associate had made you the Noticee Mr. Dhananjay Shahi,aware


of the facts and circumstance of the case and legal issues which
may or might prevails against you at the various point of time and
in the variouS different matters. That you the Noticee Mr.
power in the
Dhananjay Shahi have delegated all the legal
favour of my legal associate through which he is authorised to:
represent you the Noticec Mr. Dhananjay Shahi and you're trucking
business before any concerned authority.
11. That my legal associate has upon you expressed, deemed
you the
expressed and implied instructions have appeared for
Noticee Dhananjay Shahi in the various matter i.e appeared
several time before the Seemapuri police station, appeared before
Civil judge
the Hon'ble Court of Mrs Niharika Kumar Sharma Senior
cum Rent Controller, Shadhara District, Karkardooma Court: in the
matter of Mohd Aslam vs. Dhananjay Shahi, further has appeared
many time before the Hon'ble Court of Shri Ankur Jain 2 Additional
District Judge in the matter of Aarti Mishra
: vs. Dhananjay Shahi,

Shadhara, KarkarDooma District Court, has appeared before the


Hon'ble Court of Shri Rahul Sainai, Judicial Maqistrate FirstClass,
URABH KÜMAR
RAANK
LLB, LLM)
INDIA
SUPREME COURT OF
NODA.
Sec 62 1, INDRAPURAM
H.196,KHAND
Ch. No. 202,
[Link]
1057,
E-mall : Mb.:g456934987
<br>

Shadhara, Karkardooma District Court


: in the matter of Raj Kumar
Vs. Dhananjay Shahi in case number CT: 487/2025 has
appcarcd before the lon'ble Court of Shri Deepankar Mohan,
in the
District Judge, Shadhara, Karkardooma District Court:
matter of Raj Kumar vs. Dhananjay Shahi in case number CS:

242/2025.
my legal assocíate has
12. That upon your cxpressed instructíon
performed various legal duties at various point of time at your
demand into the protccLion of you the Noticee Mr. Dhananjay
Shahi and your trucking business to the best of his ability,
knowledge and legal skils.
you the
13. That for the above mentioned bundle of work
Noticee Mr. Dhananjay Shahi had did the promised to my Legal
Associate to pay the fees for different work at different point of
time. That you the Noticee had pay the various fees of various
work to my legal associate which he has raised upon you in the
form of legal services bill at the various point of time. That you the
Noticec M. Dhananjay Shahi habitual for not paying of your fees
on time and habitual of committing the wilful and deliberate

default by not paying your part of professional legal services fees


on time. That further you the Noticee Mr. Dhananjay Shahi usually
pays your fees in default after some time other than the time it is
fixed for or had never paid upon the day when it is fixed for.
14. That whatever legal services which my legal associate has
provided to you the Noticee Mr. Dhananjay Shahi at the various
point of time you had did the payment of fees for various legal
services by the mode of onine transition, that majority of the fees
AAMAUNHAARUAR
RA92 SAURABH KUMAR SOA
AGKIO TAUC uovbA Advocate PREME COURT OF
NDIA
N

[Link],teor S196, Seo 62NHbRAPURAM


No.52NITn kHAND 1,
[Link] vbs
TeCXSBAO
:
Rsrm-9 Ch. [Link]
.[Link]@gmail.c
:.doM E-mall: [Link].:9456934987
<br>

is paid by the mode of UPI virtual TD transaction fron one bank


accOunt to another bank account. That my legal associate has
consistently raised the various professional legal services bill upon
you the Noticee Mr. Dhananjay Shahi since from the year of 2022
to till March 2025, for which you have made the payment of
approximately Rs. 1,86,172/-. This clearly expressed that their
prevails the relationship of the Advocate and client in between
both of you and at the various point of time you the Noticee Mr.
Dhananjay Shahi had made the breach of your promises, but when
my legal associate has issued the final ultimatum and warning to
you the Noticee Mr. Dhananjay Shahi that you might face the strict
legal action, it is oniy then you the cheater Noticee have cleared all
the due which prevaiis the form of charges upon you the
in

Noticee Mr. Dhananjay Shahi which were in the form of legal


professional services bill. That the details of the payment of the
legal professional fees bill which you the Noticee Mr. Dhananjay
Shahi had made the paynent to my legal associate is described as
below:
Table of fees paid from 24.05.2023 to Ferburary, 2025
[Link]. DATE AMOUNT TAN APPLICATION
(INR) MODE

1: 24/5/2023 7,500/ UPI GOOGLEPAY

2: 29/5/2023 5,000/ UPI GOOGLEPAY

3: 1/6/2023 7,500/ UPI GOOGLEPAY

4: 1/6/2023 5,000/ UPI GOOGLEPAY

5: 8/6/2023 5,000/ UPI GOOGLEPAY


AJOAAMUA HGARUAS
R0
AICMÍ TAUO9 BMIqUB SAURABH
Advocate
KUMAR OLANKI
(BA, LLB, LLM)
MASRUTAOM SUPREME COURT OF INDIA
Ch. No. 202, H-196, Sec 62 NOIDA
1057, NITI KHAN 1, INDRAPURAM
uOM E-mail : [Link]í.[Link]
Mob.: 0456ss4987
ILAB
<br>

6: 20/6/2023 3,000/ UPI GOOGLEPAY

7: 1/7/2023 4,000/ UPI GOOGLEPAY

8: 31/7/2023 13,500/ UPI GOOGLEPAY

9: 21/8/2023 6,000/ UPI GOOGLEPAY

10: 1/9/2023 5,000/ UPI GOOGLEPAY

11: 2/9/2023 5,000/ UPI GOOGLEPAY

12: 13/9/2023 300/ UPI PAYTM

13: 26/9/2023 4,000/ UPI GOOGLEPAY

14: 2/11/2023 5,000/ UPI GOOGLEPAY

15: 4/11/2023 5,000/ UPI GOOGLEPAY

16: 17/11/2023 1,000/ UPI GOOGLEPAY

17: 23/11/2023 2,100/ UPI GOOGLEPAY

18: 1/12/2023 5,000/ UPI GOOGLEPAY

19: 3/12/2023 5,000/ UPI GOOGLEPAY

14/12/2023 1,500/- UPI GOOGLEPAY


20:

21: 5/1/2024 5,000/ UPI GOOGLEPAY

6/1/2024 5,000/ UPI GOOGLEPAY


22:

6/2/2024 5,000/- UPI GOOGLEPAY


23:

24: 7/2/2024 7,000/ UPI GOOGLEPAY

GOOGLEPAY
25: 7/03/2024 26,700/ UPI

To February,
SAURABH SOLANKI
LLB, LLM)
DMAJO8 AAMUA HEAAUA& BA,
tsoovtA AovocateSUPREME COURT OF INDIA
AIMI 4OTAUOD SMSAAue 202, H-196,
Ch. No. 1037, Sec 62 NOIDA
NITI KHAND 1, INDRAPURAM
AgIOMSaps2.0kHAosA
MASAUAAGI, GHAHe
[Link] : liam E-mall: [Link]
Mqb.:9456934987
F8eAEOBedoM
<br>

(43)

2025 and PAYTM

42,612

Total amount till 1,86,71 2/


February, 2025

15. That it is evidernt from the above mention facts and from the

payment transactions description which you the Noticee Mr.


UPI

Dhananjay Shahi had madc into the favOur of my legal associate at


various intervals and at various point of time, that yOu had taken
the specific professional legal services from my legal associate in
the past time and for the same you the Noticee Mr. Dhananjay
Shahi hac paid for lcgal cxpenses bill for the professional legal
services which were rendered to you by my legal associate.
16. That you the Noticee Mr. Dhananjay Shahi has on one day
called out my legal associate telephonically and, you the Noticee
had narrated all the factual position of yours and of yours family
member in regard to one civil original suit for recovery of money
for worth Rs. 13 Lakhs which was instituted by one Mr. Raj Kumar
Bhati against you, your family and against your trucking business.
That you the Noticee have shared your litigation problem with my
legal assOciate through tre way of what's app message vide dated
21* of April, 2025, in the message you the Noticee Mr. Dhananjay
Shahi have shared thc 3 different kind of PDF files which contain
the summon of Order5 of CPC which was issued by the Hon'ble
Court of Shri Deepankar Mohan, District Judge, Shadhara,
Karkardooma District Court: in the matter of Raj Kumar vs.
BMANR AAMUA HAAAUAR SAURABH KUMAR SOLANKI
(BA LL8, LLM)
SUPREME COURT82OF INDA
Advocate
Ch. No. SH-190,3
NRHANO 1,NQIRRAPURAM
INDRA
moolngV : [Link]
T8CECtdO:.doMvbs:arn Emall 9458934987
Sde hob.:
<br>

Dhananjay Shahi in case number cS: 242/2025 against you


the Noticce, against your Son Adarsh Shahi and, against your
Mr.

wife Munni Shahi. That you the Noticec had asked my legal
associate to provide his lcgal opinion and, for the same my legal
associate had provided the legal opinion to you the Noticee
through telephonic conversation and through physical meeting
only after appointment.
17. That upon your instruction my legal asSocíate had started a
work out upon various application under Order 1
rule 10 and rule
13 read with section 151 of CPC for you the Notícee separately
containing all the relevant factual position and objection and
another application under Order 1 rule 10 and rule 13 read with
section 151 of CPC for your Son Mr. Adarsh Shahí and, for your
wife Munni Shahi, who were defendant
No.3 and 4 in the
respective Plaint. That further another combined application
under
Order 7 rule 11 read with section 151 of CPC was
made into your
favour, into your son and wife favour. Further
the complete written
statement and the Counter Claim under order 8
and Rule 6A (1)
of CPC has been drawn, encrypted and
pleaded into your favour,
for your Son Mr. Adarsh Shahi and, for your
wife Munni Shahi and
for your trucking busincss after doing a
lengthy legal discussion
with you the Noticee Mr. Dhananjay Shahi.
18. That further when the written statement
and counter claims
were completed by my
legal associate he has consistently
demanded various doCuMentS in
the form of annexures from
22.06.2025 to 25.06.2025 which you
the Noticee had send and
provided to my legal associate
through the what's app message
DMAJO3 AAMUA
AOMI
HORAUAG
O TAUQ
SAURABH KUMAR SOLANKI
MASIUTH
fnoo. farnA607
Advocato
LLM)
UPREME COURr
SU o MA,
Ch, No. 202, H-190,Sc 2NRAAPURAM
.doM 1057,NiTI KHAND 1, INDR
: [Link]
Emal
a Mob.: 945G934987
<br>

95

vide datcd 25.06.2025 to do a scrutiny and to made those


documents a part of wrillen statement which has bcen corrnpletely
drafted into you favOUr and into the favour of your son and vwife.
That further on 12" of July my lcgal associate has through the way
of What's app messagc had send and shared another annexure
with your son Mr. Adarsh Shahi and had asked him to get the prínt
out of the annexure which was an important part of your all 3
noticce written statemenl and counter claims. That your son has
got the job done and provided the same annexure to my legal

associate upon his instruction, that after reading out all the what's
app messages I have corne to the conclusion that you the noticee
have given the instruction to my legal associate to draft the
written statement into your favour as soon as possible before the
next date of hearing of tne matter which is 23.07.2025. That it is
you the Noticee who had instructed my legal associate to draft the

written statement in the favour of 3 noticees against the Plaint of


Mr. Raj Bhati. That further you the noticee had approached to my
client or: 10.07.2025 and had instructed to my legal associate to
take the print out of all the PDF file of written statement which my
legal associate has provided and transferred to you the noticee in
fuii with ail the rctevant documents through the What's app
message vide on dated 8" of July, 2025. That the complete PDF
file containing various application, written statement and your
COunter claim has been prOvided to you the Noticee for the reading
and checking of the drafting. That after being satisfied with the
drafting and after rcading out all the relevant documents and
extract of the PDF fiic wh ch was shared with you the Noticce, you
MAJOe AAMUA HaAAUAB SOLANKI
oieoovt
ACMÍ RO TAUO M3AU SAURABH KUMAR (BA,
NDIA
LLB, L

AdvocateSUPREME COURT OF
H-196,Sec 62 NOIBAPURAM
Ch. No. 202, NT!
KHANO 1.
[Link]í.[Link]
1067,
oM E-pal: 9456934987
Mob.:
<br>

have through the telephonic call had given the instruction to my


legal associate to get the print out of the whole file. That on 10h of
July, 2025 my legal associate has shared the file PDF containing all
the annexures, applications, written statement and counter cdaims
with the Photo copy shop owner Mr Ravi Gautam at his what's app
number 7532078591, that he has taken out all the prints and had
delivered the same to you the Noticee, for which you the Noticee
had made the payment of the printing of copy bill for worth Rs.
450 in the favour of printing shop owner by the way of online
transfer payment mode UPI.
19. That you the Noticee had on 10th of July, 2025 had also
signed all the concern papers and all the affidavits and, you have
asked .my legal associate to provide the details of al the
documents upon which your,.son and your wife as Defendant No. 3.
and 4 will have to signed. That upon your, asking my legal
associate had provided you al the details of the documents where
your,son and your wife need to do the sign. The signs are requiredyr:
on the very initial page of the applications, written statements andT,
counter caims; further the signed were required on the Affidavit
and upon whole application, written statement and counter claim.
That the details of the same was provide to you the Noticee
through the what's app message which is in the form of image and
contains the details of the complete description of pages where
the signs are required to be done of the Noticee No.2 and 3 on the
same day vide dated 10" of July, 2025.
20. That my legal associate has also drafted the counter claim
for forth Rs. 5,61,000/- (FIVE LAC SIXTY ONE THOUSAND...
SAURABH KUMAR SOLANI
(BA, LLB, LLI
Advocate
SUPREME COURT OF INDIA
Ch, No. 202, H-196, Sec 621, NOIDA
INDRAPURA'
1057, NITI KHÁND
/E-mail [Link]@[Link]
:

Mob.: 9456934987
J.
<br>

.ONLY) into the favour of you 3 Noticees and, against the claims
of Raj Kummar Bhati which, he, has established in the plaint.
Mr.

That my legal associate has informed you about the completion of


the same through the what app message vide on dated 22nd of
June, 2025 and upon the same you have given your consent and
the complete and final PDF file of Counter claim along with the
written statement has been provided to you the Notice at your
what app number 9873770002 vide on dated 8" of July, 2025 and
you the Noticee had come to signed counter claim on 10h of July,

2025 after taking appointment from my legal associate.


21. That on 12th of July, 2025 you the Noticee and your Son Mr.
Adarsh Shahi had contacted my legal associate telephonically
various time to get all the paper work done related to anhexing,
various application, written statement and counter claim. That my
legal associate had harnded over all the documents to the Noticee
[Link] Shahi, for signing all the documents purpose and the
same was shared .at Noticee No.3 what's app No. 9873770003.
That when all the documentation singing formalities were
completed and initiated by the Noticee No.3 Mr. Adarsh Shahi,
then for the same my legal associatè had then asked the Noticee
No.3 Mr. Adarsh Shahi to go to the Karkardooa Court and get the
affidavit attestation work done, all the clerical work and
miscellaneous file maintaining work done of all the documents and
for the same my legal associate has transferred the number of his
junior legal associate of Mr Nitin Sharma Advocate at Karkardooma
District Court. That the number of Mr. Nitin Sharma was shared at
the Noticee No.3 What's App and the Noticee No.3 has followed
AOS 4AMU EAJAE SAURABH KUMAR
Advocate SOANKI
(BA,
SUPREME LLB, LLM)
SeOs
Ch. No. 202, H-196,COURT
1057, NITI KHAND NOIDA
INDIA
E-mail : [Link]@[Link]
1, (NDRAPURAM
T8ePcea tOM
Mob.:9456934987
(14)
<br>

(43

the instruction of my legal associate, and approached to Mr Nitin

Sharma Advocate to get the affidavit attestation work done of 13


different affidavits which were connected with various documents,
all the other clerical work and miscellaneous file maintaining work
done of all the documents. That after getting the 13 affidavit
attestation work done of various documents. you the Noticee No.3
had then signed the register maintained for affidavits record vide
on 12h of July, 2025. That further you the Noticee No.3,had made

the payment for worth Rs. 600/- for getting the affidavits attested,
for other derical and other miscellaneous work done and signed
the documents upon an instruction of my legal associate to his
junior legal associate of Mr Nitin Sharma Advocate at Karkardooma
District. Court and, made the payment by the mode of UPI transfer
method. That further my legal associate has reminded ,you the
Noticee No.3 Mr. Adarsh Shahi to get the print out of one
Annexure and the same was shared at Noticee No.3 Mr. Adarsh
Shahi what's app number on 12th of July, 2025 and you the Noticee
No.3 had taken out the print out of the same and had made the
payment of the same to the Photostat owner upon the instruction
of my legal associate. That further my legal associate has provided
to you the Noticee No.3 to make the payment of various
outstanding bills of yours, which you, have deliberately avoided and
at the last my legal associate has paid the bll cash and you the
in

Noticee No.3 had promised my associate that you will pay back the
amount which you had never reimbursed.
22. That after getting the affidavit attested and signed and all
the clerical and miscellaneous work done, you the Noticee. No.3.
SAURABH KUMAR SOLAI
AGVOcate (BA, LLB,1
sUPREME COURT OF ÎNDIA
Ch. No. 202, H-196. Sec 62 NOIDA
1037, NITI KHAND INDRAPUR/
1,

E-mall : [Link]
Mob.:9456934987
<br>

has brought back ll documerts to my logal asciate for


te
qetting them checked of thr corcctness. When all the
docunents were chccked by my legal associate then at that
movemcnt you the NotcOe No.3 Mr. Adarsh Shahi had ashed rny
lcgal associate that tohand over the possessiorn of all the
documcnt tohim so hc could get the sign of his rmother vho is
Noticce No.3 upon all the docurnents, That belicving upon the
statement of you the Noticce No.3 Mr. Adarsh Shahí at that
movement my legal associate has handed over the possession of
all the rclcvant draftcd docurnents under the trust vithout
knowing the fact that you the Noticccs had not get the affidavits
verified by my legal associate and further you the notices had not
allow my lcgal asSOCiate to sign the rcgister of affidavit verification
record. That you thc Noticee No.1 and 2 had asked my legal
associale that you will provide the signed documents of the
Noticee No.3 by thc evening of 12" of July, 2025 or you will bring
the Noticcc No.3 in the cvening to get the document signed. But
you both the Noticecs has fraudulently, with dishonestly, with

Conspiracy in prc planncd manner cornmitted the wilful and


delibcratc chcating und crininal brcach of trust upon my legal
associate by not returrirng the drafted documents back to my legal
associate for filing tthat till 18" of July, 2025 you the Noticee M.
Dhananjay Shahí had kecp my legal associate in dark and had
uscd the sake of your legal interest and then asked my
hirrn for

lcgal associate that you all the noticee don't want to get the legal
work done by tum. That my legal associate was completely
surprised by the deceptive nove of you the Noticee Mr. Dhananjay
MAHOeAAMUA HAAAUAR
SAURABH KUMAR SOLANK!
Ndvocats (BA, ULA, LM)
BUPREME COURT OF INDUA
Ch. No. 202, H.190, Sec 62 NOIOA
1057, rti KHAND 1, INÖRAPURAM
[Link] ipcgmáil com
TOOEY:.doM Enal
Mgb.:9456934987
<br>

Shahi when you have wilhdrawal your casc back from my legal
associatc, after getting all the legal documentation and drafting
work done and after recciving all the completed original PDF file at
you what's app inlo your favour. That further you the Noticees had
never paid the single penny of the professional legal fces for
drafting all the documcnts which my legal associate has raised
upon you the Noticees through the what's app message víde on
dated 13"h of July, 2025, the professional legal fees bill for drafting
the various documents i.c 3 different applications, written
statement, counter claims, annexing and getting all the
miscellaneous work done stands unpaid for worth Rs. 1,00,000
(One Lakh) in total.
23. That after geting reading all the text messages and
exchanged conversation in between youthe Noticees and my legal
associate, it could very rationally, reasonably and fairly be
observed that my legal associate has acted upon your instruction
and has performed his lcgal professional specific drafting skills into
you favour and for the protection of your legal interest only upon
your pronise that you will pay the fees of Rs. 1,00,000/- for

drafting charges.
24. That you the Noticee No.1 Mr. Dhananjay Shahi had

approached to my legai associate in an urgent need to protect and

shield you the noticec and your whole family members and your
trucking business from the false criminal complaint which one Mr.

Raj Kumar Bhati has initiated against you before the Police station
Jyoti Nagar, then immedialely Mr. Raj Kumar Has instituted the
Criminai complaint against you the Noticees and against your
SAURABH KUMAR SOLANKI
(BA, LLB, LLM)
1AMAJO2 AAMUNHGARUA8 Advocate OF INDIA
(MJ 8ID AS) efaoovbA SUPREME COUKLOIDA
AICMI TAU0 BMDS9U2
O

ch. No. 202, H1SARBNDRAPURAM


1057,NIT! KHAN
: [Link]
E-mall
:a-& dv.solank4967
Mob.:
14)
<br>

trucking business bcforc the Hon'blc Court of Mr. Rahul Shani,


Judicial Magistratc Frst Class, Karkardooma District Court. That
upon the Direction of the Honble Court of Law I.0 of Jyoti nagar
has issucd the Notice to you the Noyicee to join the preliminary
inquiry vide on dated 8" of May, 2025 at 4:00 p.m Room No. 217
PS Jyoti Nagar, Dclhi.

25. That you the Noticcc No.1 has shared the Notice to join the
preliminary examination and enquiry at the what's app of my legal
associatc vide datcd on 6" of May 2025, that after reading out al
the facts and the facts which you the Notice No.1 Mr.
Dhananjay
Shahi have narrated to my legal associate, he has given you the
legal advice and legal opinion and has asked you to join the
preliminary examination and enquiry which is to be conducted by
the I.0 of Jyoti Nagar Police Station. That through the Telephonic
conversation my legal associate has asked you the Noticee and
told you in what manner and in what way you the Noticee No.1

need tO give your answer under section 180 of the BNNS and you
the Noticee had joincd the Inquiry and had provided all the
annexures of your favOur and also produced the written criminal
complaint which you the Noticee has given with the Harsh Vihar
police station against thc Raj Kumar which was drafted by the Mr.

Akhileshwar Jha (Advocale) vide on dated 19.10204 which was


diary as 82/2024 dated 19.10.2024, that the same complaint is the
part of I.0 finding and investigation and, the same is relied upon
the same the L.0 of Jyou Nagar has filed its closure report with the
Hon'ble Court of Mr. Rahul Shaini, Judicial Magistrate First Class,
Karkardooma District Court.
SAURABH KUMAR SOLANKI
(EA, LLB, LLM)
AdvocateSUPREME COURT INDIA
(MJJ, NOIDA,
AU) ch, No. 202, H-190,SRNDRAPURAM
1087, NIT!
E-mail [Link]
:

AARUAS
<br>

26. That from the sharcd documents i.e Police Inquiry notice and
your answer under section 180 of BNSS related to the criminal
matter which you the Notice No.1 had shared at What's app
number of my legal associate, it could be fairly and reasonably be
concluded that you the Noticee Mr. Dhananjay Shahi was in a
consistent touch with my legal associate and you were receiving
the various legal instructions and opinion through the telephonic.
cellular calls from my legal associate and after receiving the
various instruction from my legal associate you the you the Noticee
Mr. Dhananjay Shahih has acted into that specific manner before
the PS. Jyoti Nagar for the protection of your legal interest and
your trucking business. That upon the criminal complaint matter
my legal associate has rendered you his professional
legal services
to the best of his legal knowledge and ability and you
the Noticee
Mr. Dhananjay Shahi had revived
the same, however at the very
beginning my legal associate has made you clear that the whole
service related to the criminal matter will cost you for worth Rs.
30,000/- upon which you the Noticee Mr. Dhananjay Shahi had
shown your acceptance and asked my legal asSOciate to act for
you and to protect you from whole the criminal legal
proceedings.
27. That further you the Notic:e Mr. Dhananjay Shahi had
approached to my clicnt on 8h of july and asked my client to
inspect the file of the criminal court to get to know
about the
status of his criminal case for the same you have signed
the
inspection application vide on dated 8h of July, 2025 and upon
your clear instruction the same application
for inspection was
moved and proceedcd vide dated on 16.07.2025 before Hon'ble
MAJOgAAMU HGAAUAB
MARUu ISAURABH KUMAR SOLANKI
(BA, LLB, LIM)
\vocateSUPREME COURT OF INDIA
ireloà vos : sm Ch. No. 202,
H-196, Sec 62 NOtDA.
INDRAPURAM
A :.doM 1057, NITI KHAND 1, com
2-mall [Link] ibcT gmali
:
<br>

Court of Mr. Rahul Shaini, Judicial Magistrate First Class,


Karkardooma District Court and thc same was allowcd vide dated
on 16.07.2025 with the frosh vakalatnama which you the Noticee

Dhananjay Shah had duthorised my legal associate to use into


Mr.

your favour. That the complete inspection report along with the I.0
Closure status report has bcen send to you through the What's
app message which was into you favVour and upon your instruction
my legal associate has acted specifically and immediately to

protect you from any adverse order. That as my legal associate


had through the what's app message and through the telephonic
call has told and inforrmed you that the Hon'ble Court had
wrongfully marked your appearance into the order sheet which is
as "accused present in person" the same was wrongly reflected
into the order sheet of vide dated 05.07.2025 which was ordered
by the Hon'ble Court of Mr. Rahul Shaini, Judicial Magistrate First
Class, Karkardooma Disirict Court. That the same order was
Communicated to you on what's app and you have asked my legal
associate to proceed bcfore the Hon'ble Court Immediately.
28. That my legal associate has further appeared before the
Hon'ble Court of Niharika Kumar Sharma Senior Civil Judge cum
rent controller, Shadhara District, Karkardooma Court, in the
matter of Mohd. Aslam vs. Dhananjay Shahi, wherein my legal
associatc has drafted thc written submission for you and the same
has been transferred to you the Noticee Mr.
Dhananjay Shahi in
the PDF form on vide daled 12" of May, 2025 and the same has
also becn filed bcfore the Hon'ble Court of law. That further the
final arguments on the matter held on 14.05.2025, for which my
SOLANKS!
214A.
AAMU HaAFUAB SAURABH KUMAR (BA, LLB,
AdvocateSUPREME COURT OF NDIA
sisovtb .Sec 62 NOIDA
Ch. No. 202, HyoOLNDRAPURAM
[Link]@[Link]
1057,
[Link] insipa
T8GEOBdAe:.doMvbs : Bam 20 E-mall:
Mob.:
9456934987
<br>

legal asSociate, has appeared for you and provided


the detailed and
lengthy legal submission for you and the same is reflected into
the
judgement of the Hon'ble Vide dated 10.07.2025. That for the
purpose of drafting the written submission
the fees charged was
as (1). Rs. 1000 per page which made
the fees as Rs. 1,000/- per
page x 42 pages = Rs. 42,000/-, (2). 30,000/- as
the lengthy legal
arguments (3). Date appearance fees Rs. 1500/- (4). And legal
research work Rs. 1500/- which make the total = Rs. 75,000/- out
of which the appearance fees of dated 14.05.2025 was only paid.
29. That the legal fees bill was first raised upon you the Noticee
vide on dated 14th of May, 2025 through
the what's app message
for the legal services which my legal associate
has provide to you
and you the Noticee had never disputed nor declined to pay
the
professional legal services fees bill.
30. That ut of Rs. 75,000/-, you the Notice once paid
Rs.1,500/-vide on dated 21* of May, 2025 and another part
payment of Rs. 10,000/- you the noticee had did on vide dated 1*
of July, 2025 into the favour of my legal associate which take your
bill chargeable liability down to worth Rs. 63,500/-.

31. That further .my legal associate has appeared before the
Hon'ble Court of Niharika Kumar Sharma Senior Civil
Judge cum
rent controller, Shadhara District, Karkardooma Court vide on
dated 10.07.2025 for which the legal fees for appearance
remain
stand outstanding for worth Rs. 1,500/-.
32. That after marking the fresh appearance for you
the Noticee,
into the Aslam matter the previous outstanding
unpaid chargeable
liability for professional services bill stands at Rs.
63,500/-+ the
SOLANKI
SAURABH KUMAR (BA,
INDIA
LLB, LLM)
AdvocateSUPREME COURT OF
.Sec 62 NOIDA,
H%AND LINDRAPURAM
Ch. No. 202,
1057, NITI
[Link]@[Link]
E-mall : 9456934987
Mob.:
<br>

fresh bill
outstanding, for worth Rs. 1,500/- makes the total
outstanding amount at wWorth Rs. 65,000/- till he date of services
of this legal notice upon you.
33. That you the Noticee no.1 Mr Dhananjay Shahi has
instructed my legal associate to draft one legal notice of criminal
and civil defamation for worth Rs. 2,50,00,000 (Two crore
and fifty
Lakhs Rupees Only) on the behalf of Mr.
Dhananjay Shahi, Mr.
Adarsh Shahi, Mrs. Munni Shahi and upon the name of yours
trucking business namcly Shahi Roadline ine against the Raj
Kumar Bhati.
34. That the same notice was prepared after your instruction on
the behalf of the 4 personality and the same legal notice was
served upon what's app number 8802607920 of Mr. RajKumar
Bhati vide on dated 1
of July, 2025.
35. That the status of service was shared with you the Noticee
at your what's app number vide on dated 12h of July, 2025 and
further upon the instruction of my legal associate you theNoticee
Dhananjay Shahi has posted the physical legal Notice to-Mr.
Mr.

Raj Kumar through the registered speed post which bears the
postal receipt no. ED 613165645IN vide dated 30.06.2025 and you
the Noticee had further scanned the hard copy of the legal Notice
and send it to the what's app number of my legal associate vide
dated on 30 of June, 2025. That you have intentionally shared
the postal receipt and scanned legal notice at the official mobile
number of my legal associate,showS your clear intentions that you
were-intended to engage my legal associat for the drafting of the
SAURABH KUMAR SOLANKI
(BA, LLB, LLM)
Advocate
SUPREME cOURT OFINDIA A

Ch. No. 202, H-196, SebNDRAPURAM


NITI KHAND 1,
:
1057,
adv.š[Link]@[Link]
E-mail
Mob.:9456934987
f.3.
<br>

(1o6)

legal notice and serving the same upon your opponent Mr. Raj

Kumar Bhati.
36. That for drafting the legal notice my legal associate has
charged you the Noticee Mr. Dhananjay Shahi with the professional
and drafting fees of worth Rs. 10,000/- but after the discount the
,
amount remained was Rs. 9,000/- that further for the same the
bill was send at your what's app number immediately vide on

dated 7 of June, 2025 defining the description of the whole bill.


That further till date the professional legal services and drafting bill

amount of Rs. 9,000/- remained outstanding and unpaid at your


part. That you the Noticee Mr. Dhananjay Shahi clearly seems to
have committed a unilateral deliberate and wilful breach of your
promise to pay the whoie amount with the reasonable time and by
your conduct it cOuld be fairly be assumed that you the Noticee Mr.
Dhananjay Shahi is having no intention to pay for your liabilities.
37. That further my legal associate has appeared upon you're
instruction you the Noticee Mr. Dhananjay Shahi before the
Hon'ble Court of Ankur Jain II District Judge, Shadhara District,
Karkardooma Court vide on dated 17.07.2025 in the matter of
Aarti Mishra Vs. Janandar Shahi & Others. CS. No.
116/2023 for which thc legal fees for appearance and giving of
the legal submission before the Hon'ble Court of Law remain stand
outstanding for vworth Rs. 4,000/-. That the fees amount or bill
was never declined to pay nor was ever disputes.
38. That you the Noticee Mr. Dhananjay Shahi had asked my
legal associate to appear into you favour and you the Noticee
2NHO3 AAMUA HaAAUAE
AE)
ANOMI R0 TAUCAgKeed,
tp-pay for appecarance and submission fees vide on dated
TBCACepeng SAURABH KUMAR (BA,
SOLANK
:toM Advocate
SUPREME COURT OF NDIA
Ch. No. 202, H-196, Seo 62 NOIDA
NITI KHÄND 1, INDRAPURAM
1057,
E-mail : [Link]@[Link]
9456934987
(22
<br>

17.07.2025 for the same my legal asSociate


has raise the bill
against you thrOugh the way of What app message and you
the
Noticee through the message vide dated 18.07.2025
has promised
to pay of your chargeable liability in respect of unpaid
fees and
You the Noticee had never disputed
the any bill which my
fees
legal associate has raised against you at the various time.
,
39. That you the Noticee being the consistent defaulter in
making the payment of,your, fees, my legal associate has finally
decide to stop representing and appearing for you the noticee into
any of your litigation matters and for the same the whole file of
Aarti Mishra case has being handed over to you,the Noticee Mr.
Dhananjay Shahi in the form of PDF file through the way of what's
app message vide dated on 18.07.2025. As an unpaid outstanding
fees amount remains unpaid till the date of service of this legal
notice.
40. That upon your instruction my legal assoiate has appeared
for you the Noticee Mr. Dhananjay Shahi in the various matter ie.
(1) appeared vide [Link] i0.07.2025 before the Hon'ble
Court of Mrs Niharika Kumar Sharma Senior judge cum Rent
Civil

Controller, Shadhara District, Karkardooma Court: in the matter of


Mohd Aslam vs. Dhananjay Shahi, (2): further has appeared
on
vide dated 17.07,2025 before the Hon'ble Court of Shri
Ankur Jain 2 Additional District Judge : in the matter of Aarti
Mishra vs. Dhananjay Shahi, Shadhara, KarkarDooma District
Court, (3): has appeared vide on dated 16.07.2025 before
the Hon'ble Court of Shri Rahul Sainai, Judicial Magistrate First
Class, Shadhara, Karkardooma District Court : in the matter of Raj

SAURABH KUMAR SOLA


Advocate LLE (BA, L.
SUPREME COURT OF INDIA
Ch. No. 202, -198 NOIDA
105. NTRC82KHAND 1, INDRAF
E-mail:[Link]@[Link] A

Mob.:,9456934987
<br>

Kumar vs. Dhananjay Shahi in case number CT: 487/2025, (4)


has appeared vide on dated 15.07. 2025 beforc the Honble
Court of
Shri Deepankar Moharn, District Judge, Shadhara,
the matter of Raj Kurnar vs.
:
Karkardooma District Court in

Dhananjay Shahi in case number CS: 242/2025.


41, That my legal associate has bring into your knowledge on
16h of July that in the order sheet vide dated 05.07.2025 your
appearance as the accused appeared in
is wrongfully marked
person in the number CT: 487/2025 by the Hon'ble, that upon
your instruction my legal associate has appeared for you and had
moved the inspection application along with the Vakalatnama
which you the Noticee Mr. Dhananjay Shahi has authorised my
legal associate to use before the Hon'ble Court of Law. That my
legal associate has obtaincd your instruction and consent through
a telephonic call and for the same had made you the Noticee Mr.

Dhananjay Shahi aware of all the process and stage of criminal


trial which is pending against you the Noticee and for the same
you have specifically asked my legal associate to proceed and
appear before the Court. That upon your instruction my legal
associate has appeared before the court and provided you an
every single detail by the way of inspection report which he did
from 02: 10 [Link] to 2: 47 P.m. That my legal associate being your
authorised legal consultant has did all the due diligence to protect
your legal interest and further had provided you the Noticee a

lengthy legal conferences and legal opinion through the telephonic


.. call and physical meeting.
SAURABH KUMAR SOLANKI
(BA, LL8, LUM)
AdvocateSUPREME COURT OF INDIA
Ch. No. 202, H-196, Seg 62 NOIDA
1057, NITI KHAND INÔRAPURAM
1,

E-mal: [Link]
AB)
AlOKi O T5OAM3AU8 .eM Mob.: 9456934987
t
ACIOM S809t-H SoS
AGGAI,OAys:
[Link].
T8CDECDdNe :.doM
nm-3 Z5
<br>

42. That upon your instruction my legal associate has appeared


and moved the fresh application for file inspection on 15.07.2025
and moved the vakalatnama in case number CS: 242/2025
which you the Noticec Dhananjay Shahj has authorised, my
Mr.

legal associate to use before the Hon'ble Court of Law. That upon
your instruction my legal associate has appeared before the court
and provided you an cvery single detail by the way of inspection
report which he did from 1:05 P.m around. That my legal associate
being your authorised legal consultant has did all the due diligence
to protect your legal interest and further had provided you the
Noticee a lengthy legai conferences and legal opinion through the
telephonic call and physical meeting upon your civil recovery
matter for worth Rs. 13 Lakhs. That the details of all the above
on time has been:
mentioned aspects have been fairly and
disclosed toyou before the next date of proceedings.
43. That my legal associate had did the pro bono matter into the
favour of your daughter when someone among from
your relatives
had made the obscene message of your daughter, for the same
you the Noticee. Mr. Dhananjay Shahi. and your son had
my legal
approached to my legal associate for the legal help. That
associate in the wake of social and moral responsibility had
rescued your daughter and your family from the miserable and
my legal associate
from the embarrassing state of position. That
has helped you pre[aring the written complaint and had
in

personally pursued the matter with the Harsh Vihar Police Station
SHO. That in the end you the Noticee had got the matter settled
my legal associate about the
with the. çulprít and had informed
SOLAN
SAURABH HKUMAR (BA, LLB, LI
INDIA
COURT OF
Advocate 02ME Sec 62 NOIDA INDRAPUR
.H-196,
KHAND 1,
[Link]@[Link]
NITI
Ch, No.
Exmall :
9456934987
Mob.
<br>

same. That such kind of understanding and coordination in


between you the Noticee Mr. Dhananjay Shahi and my legal
associate which clearly establish that you are strongly depended
upon my legal associate for all the professional legal services and
he has provided all the legal services to you in the past time for
the protection of your legal interest.
44. That on 18h of July, 2025 my legal associate has raised the
reasonable, legal and valid bill upon you the Noticee. Mr.
Dhananjay Shahi, as you are consistently committing the breach of
your promises in making the payment of your legal and
professional bill in the form of instalments which were designed
and made into your favour only after the common understanding
in between you the Noticee and my legal associate. That the
description of the bill are as follows:
"Subject: BILL: Payment of fees of Rs. 2,10,000/- (Two
Lakhs and Ten Thousand).

(1). ForExchange and receiving of legal opinion- legal


consultation services, conference charges, considering
and reading out relevant lengthy documents charges.
(2). Darting of various 2 Different application under Order 1
Rule 10(2) and (13) on behalf of the 3 persons,
(3). 1 Common Application under order 7 Rule 11 on behalf of

the 3 persons,
(4). Common Written statement and separate Counter Claim
for Mr. Dhananjay Shahi, Mrs. Munni Shahi, Mr. Adarsh
Shahi.
ŠAURABH KUMAR SOLANKI
(BA, LLB, LLM)
Advocato INDIA
SUPREME COURT OF NOIDA
H-196, 1. INDRAPURAM
Ch. No, 202,
O34 NITI KHAND
adv.š[Link]@[Link]
E-mall:
b.:9456934987

24
<br>

(5). Appearance fees for appearing before 2 different Hon'ble


Court.
(6). For preparing Lengthy written submissions, for giving
lengthy legal arguments.
(7). Drafting of Rs. 2,00,000/- recovery and Rs. 2,50,00,000/
defamation Legal notice against Mr. Raj Kumar Bhati on
behalf of Mr. Dhananjay Shahi, Mrs. Munni Shahi, Mr.
Adarsh Shahiand their trucking business.
(8). For Exchange and receiving of legal opinion- legal
consultation services, conference charges, considering
and reading out relevant documents connected with
Notice Under 175(3) of BNSS and statement given under
of Mr. Dhanangay Shahi given under section 180 of BNSs.
(9). Other Miscellaneous andclerical Charges Rs. 2,000/-."

Sir/Mam,
Iwant to inform you that the 9 sort of expenditure are still pending on
your part which are Darting of various 2 Different application
under Order 1 Rule 10(2) and (13) on behalf of the 3 persons, 1
Common Application under order7 Rule 11 on behalf of the 3
persons, A Common Written statement and separate Counter
Claim for Mr. Dhananjay Shahi, Mrs. Munni Shahi, Mr. Adarsh
Shahi Which is for worth Rs. 1,00,000/-. Appearance
fees for
appearing before 2 different Hon'ble Court vide dated on
10.07.2025 and 17.07.2025 (1500/-) + (Rs. 2,000/+ Rs. 2,000/-) =
5,500/-. For preparing Lengthy written submissions, for giving
lengthy legal arguments (42000/- + 30,000/- + 1,500 + 1,500/-=
75,000/-). Drafting of Rs. 2,00,000/- recovery and Rs.
>MA 1O2 AAMUN HaAAUAE
otepovtA
SAURABH KUMAR SOLANKI
(BA, LLB, LLM)
Advocate
(MJS,8.A0) oTAUO3 BMBAIUa SUPREMSec COURT OF INDIA
62 NODAA
Ch. [Link] 1, INDRAPURAM
: [Link]
:

[Link] [Link] ::iem-D E-mall


9456934987
T8C-CODahg :.doM
<br>

2,50,00,000/- defamation Legal notice against Mr. Raj Kumar


Bhati on behalf of Mr. Dhananjay Shahi, Mrs. Munnai Shahi, Mr.
Adarsh Shahi and their trucking business which is 9,000/-. For
Exchange and receiving of legal opinion- legal consultation
services, conference charges, considering and reading out
relevant documents connected with Notice Under 175(3) of
BNSS and statement given under of Mr. Dhanangay Shahi given
under section 180 of BNSS which is 30,000/- and the cost of other
miscellaneOus and clerical Charges for worth Rs. 2,000/-. That pending

legal conference charges, acceptance of brief physically and through


electronic mode, research work and reading of documents, formulation
of legal opinion, lengthy legal consultation charges telephonically and

App Message, other miscellaneous and clerical charges


in
through What

whole legal exercise matter for worth Rs. 2,10,000/-.

of pending fees upon legal work done


Table A: Details
are mention are as follows:
In the Matter of Raj Kumnar Vs. Dhananjay Shahai and

Ors. CS. 242/2025.


Drafting of various 2 Different application under Order
1 Rule 10(2) and (13) on behalf of the 3
persons, 1
on behalf of
Common Application under order 7 Rule 11
the 3 persons, A Common Written
statement and
separate Counter Claim for Mr. Dhananjay Shahi, Mrs.
Rs.
Munnai Shahi, Mr. Adarsh Shahi. Which is for worth
1,00,000/
BILL DESCRIPTION

[Link] Particular/ Description of fees Fees Unpaid


in Rs. fees in
Rs.

1AMAJhe AAUA H8ARUAE SAURABH KUMAR SOLANK.


(BA, LLB. LLM)
(AJJ,8 AS) eteovbA Advocate
SUPREME COURT OF INDIA
Ch. No. 202, H-196, Sec 62 NOIDA
1057, NITIKHAND 1, INDRAPURAM
[Link]: iem-3 E-mall : [Link]@[Link]
T8RceaCe:.doM 24 Mob.: 9456934987
<br>

(3

1: Drafting of various 2 Different 20,000


application under Order 1 Rule 10(2)
and (13) on behalf of the 3 persons.
40,000/
A. 20,000
Adarsh Shahi and MunnaiShahi
B. Dhananjay Shahi
Accepting of brief Plaint, Conference
charges, Reading and Research work on
Documents, legal opinion and, drafting
charges.

2: Drafting ofCommon Application 20,000


under order 7 Rule 11 on behalf of the
3 persons. Mr. Dhananjay Shahi, Mrs.
Munnai Shahi, Mr. Adarsh Shahi: 20,000/
Providing of legal
Conference on
telephonically Charges and upon what app
electronic message, consultation and legal
opiniorn Charges, drafting of lengthy and

legal application charges and other


Miscellaneous Charges left unpaid.

3: Drafting of Common Written statement 20,000


for Mr. Dhananjay Shahi, Mrs. Munnai
Shahi, Mr. Adarsh Shahi. 20,000/

Drafting of Common written statement


"against Raj kumar claim" Providing of
legal Conference on lelephonically Charges,
consultation and legal opinion Charges,
R
AAMdraiu)uAE
ANnO of ComION written statement SOLANS
TSUOb
MARUA GlesovbA SAURABH KUMAROF INDIA
Advocate SUPREME NOIDA.
CU
H-190,SA8
INDRAPURAM
Ch. No. [Link]@[Link]
NII KHAN
S456934987
E-mall : ..
<br>

charges, arrangcments of all the annexures


relatcd to W.S and other Miscellaneous
Charges left unpaid.

4: Drafting of separate Counter Claim for 20,000


Mr. Dhananjay Shahi, Mrs. Munnai
Shahi, Mr. Adarsh Shahi: Providing of 20,000
legal Conference on tclephonically Charges
and upon what app electronic message,
consultation and legal opinion Charges,
drafting of Counter Claims under Order 8
Rule 6A of CPC charges and other
Miscellaneous Charges left unpaid.

the applications and written statement


All

and counter claims draft under your written


instructions, has been
Same provided
through the What's app message in the PDF
form, for the same the print out has been
taken out and affidavits has been done. That
the whole file containing all the documents
along with all the annexures and affidavits
has been provided to you all the applicant or
to my clients. The whole file contain
approximately 304 pages
5
TOTAL UNPAID FEES 1,00,00
0/
SOLANK!
LLD, LLM)
KUMAR
SAURABH URT OF
AdvocateSUPREME 62 NOIŽAPURAM
C

ACMI kHAND 1, IND


[Link]
AaioRuOSt Ch. No.20, 9456934987
E-mall : [Link].:
T80ECaCe :.doM
[Link] : Bem-3
<br>

Total Expenditure: of Clause 1+2+3+4= 1,000,00/


IN WORDS: (One Lakhs)rupces only.

Table B: Details of pending fees upon legal work done are


nentions areas follows:
Drafting of legal notice vide dated 01.07.2025 Rs.
2,00,000/- recovery notice and Rs. 2,50,00,000/
defamation Legal notice against Mr. Raj Kumar Bhati on
behalf of Mr. Dhananjay Shahi, Mrs. Munnai Shahi, Mr.
Adarsh Shahi and their trucking business which is
9,000/-.
BILL DESCRIPTIN
[Link] Particular/ Description of fees Fees Unpaid
in Rs. fees in
Rs.
1: Drafting of lega! notice vide dated 9,000/
01.07.2025 for Rs. 2,00,000/- recovery
notice and Rs. 2,50,00,000/- defamation 9,000/
Legal notice against Mr. Raj Kumar Bhati on
behalf of Mr. Dhananjay Shahi, Mrs. Munnai
Shahi, Mr. Adarsh Shahi and their trucking
business

The legal notice has been served upon [Link]


Bhati through What app no. 9560714537
upon his official What's App Number and the
status of delivery report has been duly
shared with Mr. Dhananjay Shahi at his What
app no. 9873770002.

2. TOTAL. UNPAID FEES 9,000/

A
JogAMUA HBAAUAE
tvbA
SOLANKI
SAURABH KUMAR (BA, LLO, LLM)
AB)Ta00 M

AdvocateSUPREME OF INDIA
COURoDA
Ch. No. 202, H1 SNDRAPURAM
[Link]
1057,
:
OCcoBe :.doM E-mall Mob.: 9456934987
<br>

Total Expenditure: of Clause 1= Rs. 9,000/


IN WORDS: (Nine Thousand) rupees only.
Table C: Details of pending fees upon legal work
done are
mentions are as follows:
In the Matter of Mohd. Aslam
No.
s.
Dhananjay Shahai. CS.
759/2021.
Charges of Rs. 1,500/- Appearance vide on dated
10.07.2025, before the Hon'ble Court of Niharika Kumar
Sharma.
For preparing Lengthy written submissions, for giving
lengthy legal arguments on dated 14.05.2025 (Rs.
42000/- + Rs. 30,000/- + Rs. 1,500 + 1,500/- = 75,000/-) –
Rs. 10,000/- paid total= 63,500/- + 1,500/- = Rs.
65,000/-.
BILL DESCRIPTION

[Link] Particular/ Description of fees Fees Unpaid


in Rs. fees in
Rs.
1: A:Drafting and preparing Lengthy 42,000
written submissions for Mr. Dhananjay
Shahi and the same has been brought
upon the record of Hon'ble Court of law
through its order dated 14.05.2025,
B: for giving lengthy legal arguments 30,000
on vide dated: 14.05.2025 for Mr.
Dhananjay Shahi.
(10,00
0) paid
-+
63,500
C: charges for citation research and 1,500
relevant case finding
For drafting and preparing the written
submissions which has bcen filed before the
Hon'ble Court of Law and the same has been
shared through What app message to Mr.
SAURABH KUMAR
(MISMAJo2
IAS) AAM Advocato SOLANK!
$UPREME(BA, LLB, LLM)
No. 202, H-1t00,COURT
Ch,
Sec
OF INDIA
KHAND 02 INDRAPURAM
NOIDA
E-malt : [Link]
1,
[Link]: Enm-9
TSGoe:.doM Mob.: 9456934987
<br>

Dhananjay Shalhi at his What app no.


9873770002 on 12"h of May, 2025.
2. Charges for Appearance vide on dated 1,500/-| 1,500/
10.07.2025, beforc the Hon'ble Court of
Niharika Kunar Sharma.
TOTAL UNPAIDFEES
65,000/

Total Expenditure: of CIause 1 and 2= Rs. 65,000/


IN WORDS: (Sixty Five Thousand) rupees only.

Table D: Details of pending fees upon legal work done are


mention are as follOws:

In the Matter of Aarti Mishra Vs. Janandar Shahi &


Others. CS. No. 116/2023.
Charges of Rs. 4,000/- Appearance vide on dated
17.07.2025, before the Hon'ble Court of Ankur Jain- II,
ADJ, Shahdara, Karkardooma District Court District
Court.

BILL DESCRIPTION

[Link] Particular/ Description of fees Fees Unpaid


in Rs. fees in
Rs.
Charges for Appearance vide on dated 2,000/
17.07.2025, before the Hon'ble Court of
Ankur Jain- IL, ADJ, Shahdara,
Karkardooma District Court District
Court.
2: Charges for giving the submissions and 2,000/
arguments vide on dated 17.07.2025,
SOLANK
AYAZ AbBreheHon'ble Court of Ankur lain KUMAR
SAURABH COURTbFNORAAPURAM
ACIHOMca on3,D0-4,cO .o. 2
: Advocate BUPREM, BeeIND
[Link]
[Link] idnatgavbs is-9 9456934987
NITI
Sh. No. GV.6olank
E-mall :
<br>

II, ÁDJ, Shahdara, Karkardooma


District Court District Court.
That the Hon'ble Court of lawhas passed an 4,000/
order dated vide dated 17.07.2025 and the
advocate appearance is on record.

3 TOTAL UNPAID FEES 4,000/

Total Expenditure: of Clause 1= Rs. 4,000/


IN WORDS: (Four Thousand) rupees only.
Table of pending fees upon legal work done are
E: Details

mention are as follows:


In the Matter of: Sh Raj Kumar Vs. Dhananjay Ans. CT &

Case Dy. 78/2025. U/s 175.3 BNSS, Karkardooma


District Court and PS. Jyoti Nagar Delhi.
For Exchange and receiving of legal opinion- legal
consultation services, conference charges, considering
and reading out relevant documents through What's
App Messages and giving opinion and suggestions
through long telephonic conversations, connected with
Notice Under 175(3) of BNSS vide dated 06.05.2025
and statement given under section 180 of BNSS by Mr.
Dhanangay Shahi vide on dated 1105.2025. Further the
Inspection Application filled upon the instruction of Mr.
Dhnanjay Sahahi vide on dated 16.07.2025 and the
fresh Vakalatnamafiled upon the authority and under
instruction of the Mr. Dhnanjay Sahahi and to get it
allowed from the Court of law. Further_inspection
ŠAURABH
Advocate KUMAR SOLANKI
(BA, LLB, LLM)
SUPREME COURT OF INDIA
Ch. No. 202, H-196,
NITI Sec 62 NOIDA
1057, KHAND 1,
E-mail : [Link]
Mob.: 9456934987
<br>

report shared at what's app, Further


the details of
closurc report have bcen shared of I.0 at the What's
App.

BILL DESCRIPTION
[Link] Particular/ Description of fees Fees Unpaid
in Rs. fees in
Rs.
1: For Exchange and receiving of legal 30,000
opinion and legal tactics- legal
-
consultation services, conference
charges, considering and reading out
relevant documents through What's
App Messages and giving opinion and
suggestions through long telephonic
conversations, connected with Notice
Under 175(3) of BNSS vide dated
06.05.2025 and statement given under
section 180 of BNSS by Mr. Dhanangay
Shahivide on dated 1105.2025. Further
the Inspection Application filled upon
the instruction of Mr. Dhnanjay Sahahi
vide on dated '16.07.2025 and the fresh
Vakalatnama filed upon the authority
and under instruction of the Mr.
Dhnanjay Sahahi and to get it allowed
from the Court of law. Further
inspection report shared at what's app.
IMAJda AAMUN
HOAAUAB
stsovbA GAURABH KUMAR SLAN
Advocate
8UPREME COURT OF INDIA
1V TM,teoT
tok vba:
ism-3
Ch, No. 202, H:190,
1057, NTK
SARNORAPURAM
E-mait [Link]
:

.doM Mob.: 046954D,


<br>

Further the details of closure report


have bcen shared of I.0 at the What's
App.
30,000/
The legal tactics and defences was shared
with Mr. Dhananjay Shahi through the
lengthy Telephonic calls and upon the
successful defence before the Police station
Jyoti Nagar Mr. Dhananjay has shared his
defence statement with me through What
app message of Mi: Dhananjay Shahi What
app no. 9873770002.
2 Other miscellaneous and clerical charges 2,000/- 2,000/
involved in all the above mentioned process
mentioned at table A+B-+C+D
TOTAL UNPAID FEES 32,000/

Total Expenditure: of Clause 1 and 2= Rs. 32, 000/


IN WORDS: (Thirty Two Thousand) rupees only.

Total Expenditure stand unpaid in the form of


legal fees:
described into Table A+B+C+D+tE = 2,10,000/
IN WORDS: (Two Lakhs andTen Thousand) rupees only.
Iwant to inform you that the above mention is the detail of unpaid
fees, which you have still not paid till the present date and you are
under the liability to pay the fees of Rs. 200000/- for the above
mention legal work, as the legal services are not for free or pro
bono services. Please kindly clear the fees within in days from
the serving of this bill, cither through account transfer, UPI

transfer, or through any other mode.

Details of UPI transfer No. Bank AcCount Details: SOLAN


MA
AAMUA H8ARUAE SAURABH KUMAROF(BA,
INDIA
AdvocateSUPREME COURT
c 62 NOIDA,
INDRAPURAM
MARUANGMI Ch. No.
02H-106,3D 1,
[Link]@[Link]
o
[Link]: Eern-3 E-mall : 9456934987
TEEeaAG :.doM
<br>

9560714537 31556721112 SBI

45. That, after rcading out all the relevant and substantial
documentary evidences, it could fairly be concluded that there
prevails a relationship in between my legal associate and between
you the Noticees as of the "advocate and his
client" That you the
Noticee since from the carlier 2023 to till February, 2025 you have
paid the various amount as fees in the part instalments for the
legal services which my legal associate has provide you the
Noticee for your various litigation and legal issues. That it is an
established fact that for the various matters my legal asSociate has
appeared for you the Noticee before the Hon'ble Courts of Law
and has acted for you icgally to protect your legal interest. That
further on the various occasions my legal associate has also
transferred the various PDF files of the various drafting which is
connected with your various cases which were only drafted after
your instruction and consent to pay upon the same. That for all
the legal services which my legal associate has provided to you
from February to July, 2025 a fresh professional legal services bills
has been raised upon you the noticees by the way of What's app.
That you the Noticees since had enjoyed the legal professional
Services of my lcgal associate, for the same you have never
decline a single bill but in fact rather you have paid the bill and
comply with the conditions til June, 2025.
46. That you the Nicecs after the month of June, 2025 stop the
payment of all the instalments in the month of July and august,
2025 and you the Noticee have committed the deliberately and
121MAJOg AAMUN
AOHOTMwilful,brcach o:your all promise. That you the Noticee had did the,
MASRUASOE SAURABHKUMAR SOLANKI (BA LLB, LIM)
AdvocateSUPREME COURT OF INDIA
Sec 62 NOIDA
GEo9 :.doM Ch. No. 202,
1057,
NNDRAPURAM
[Link]
E-mall :
Mob.: 9456934987
<br>

((
22)

promises at the various point of time to pay of the complete set of


fees through orally and through in expressed written messages.
That you the Noticce had never declined to pay any fees or had
ever raiscd any objccion upon the bills raised upon you the
Noticees by my legal associate. But in the certain point of time you
have the Noticee had stop the payments of the fees, without any
reason.
47. the above statcd by my legal associate are validated with
All

a dossier of evidence provided herein for his claims:

EVIDENCE (provided by my legal associate)


1. Authority Letter confirming appointment upon my legal
associate for the period of 7 years as legal consultant of
yours through your letter of appointment vide dated: 23rd
of January, 2023 upon the letter head of Shahi Roadline
which contain the GSTIN No. 07DQDPS4366D1ZP, contain
your sign and officiai seal.
2. A Blank Vakalatnarna Containing your sign and thumb
impression of your, through the blank vakalatnama you
the Noticee have authorised my legal associate to use it
before any authority to protect your legal interest.
3. Marked appearance, given arguments and provided the
drafted Written Submission on the behalf of you the
Noticee Mr. Dhananjay Shahi, upon an Order sheet vide
dated 14.05.2025 before the Hon'ble Court of Niharika
Kumar Sharma
4. Marked appearance upon an Order sheet vide dated
10.07.2025 before the Hon'ble Court of Niharika Kumar
Sharma.
5. Marked appearance upon an Order sheet vide dated
17.07.2025 before the Hon'ble Court of Ankur Jain II
SOLANK!
SAURABH KUMAR (BA,
INDA
LLEB, LLM)

AdvocatoSUPREME COURT OF
(2MAO Ch. No. 203, H:190, SAgNORAPURAM
1O57. NITI RHAN
[Link]
AIOMN
ARUA4nM9nqU
00r-H,[Link].
E-malt :
Mob.: 9456934987
Lbnslosvbs :
nOnonabe :.doM ian-3
<br>

application and vakalatnama moved on


6. Copy of Inspection
16.07.2025 before the Hon'ble Court of Shri Rahul Saina,
Judicial Magistrate First Class, Shadhara, Karkardooma
District Court : in the matter of Raj Kumar vs. Dhananjay
Shahi in case number CT: 487/2025.
7. Copyof Inspection application and vakalatnama moved on
15.07.2025 before the Hon'ble Court of Shri Deepankar
Mohan, District Juige, Shadhara, Karkardoorma District
Court : in the matter of Raj Kumar vs. Dhananjay Shahi in
case nimber CS: 242/2025.
8. Bili for professional iegai services vide dated 16.07.2025
has been raised upon you the noticee and the same has
been delivered to you at yours what app number on 18» of
Juiy, 2025.
9. That the bi!! was further send to you through the
registered speed post on 18.07.2025 the receipt of sarme is
availablie; further the tracking report showing that you the
Noticee refused to accept the Bill.
10. Record of ali the What's app conversation through
which at the various point of time the bill for professionai
legal services were raised after performing the lega! duty
and thG same was never challenged or contested or
disputed or deciirned by you the Noticees. That the
promises to pay the legal fees, record of part payment of
fegal fees into the favour of my legal associate.

SOLANK!
KUMAR NOLA
SAURABH COURODA
PMAEAMUA
(M HOAAUAE EME
INDRAPURAM
RAND 1,
SUPE10
[Link]
OMI O
TSUO BMDR4U8oleDovA Ch. No.
202, 9466934987
MARUASpo.D01 E-mall :
no imgpoqt ánekosvbs Mob.:
f8eNEGB2:.doM
<br>

11. Detail telephonic record which were held in between


my legal associate with you the Noticee and with your son
Noticee No.3 Mr. Adarsh Shahi.
12. Legal notice served upon Mr. Raj Bhati
13. Original Postal Receipt of the speed post.
14. Copy of Raj Kumar Bhati Plaint along with the
summons which you the Noticee had shared upon the
What's app Nunmber of my legal associate.
15. Copy of the Defarnatory Notice for Rs. 2,50,00,000/
drafted for you the Noiicee.
16. Service report upon Raj Kumar through the Whats
app.
17. Speed post receipt
dated 30.06.2025
18. Record of inspection report shared with you the
Noticee in the Criminal matter on 16.07.2025 only after
your instruction and consent.
19. Details of Appointment taken and legal conferences
done.
The above evidence respectively establishes that:

1: That, all of you the Noticees are under the direct contact with my
legal associates and have appointed him to render the legal
consultation services upon wide and mutiple legal purposes and
aspects.
2: That, all of you the Noticees are sharing and assigning your legal
assignments to my legal associate on the agreement that my legal
associate will be charge for the services and not work otherwise for
pro bono.

3: That, all of you the Noticees are meeting and attending the
(oO AAÇonferences only after taking the appointment and it is evident from
AIaM
MA RUgAAQIO H8ARUAB
slsdovbA
SAURABH KUMAR SHN INDIA
Advoca OF
sUPREME COUNoIDA.
Ch. No. 202,H:190, SAANDRAPURAM
[Link]@aA987 [Link]
E-mal : [Link].i
Mob.:
<br>

I2
that, thc physical mccting took placc becausc only then all of you
could sharc your sccret dccds wilh my legal associate.
However, you the Nolicces have not responded the conducivein
manner. Scveral opportunilics have
been provided to all of you to
fulfil obligation in spile of so many opportunities you have
miserably ,failcd' tbAntorm your promise and committed
the
WoARUASso8anUovbÁ
deliberate and ntentíonal brcach of your promise, further you have
Nnaloa
vba : iam-3
deliberately caused" the wrongful loss to my legal associate by
committing the chcating and criminal brcach of trust in the pre
planned way which clcarly amount to conspiracy. In this regard, I
hereby dircct you to makc the payment of bills/memorandum of fees
which is worth amount Rs. 2.10,000/- along with an interest of 12%
per annum, on the failure of which our legal asSociate namely Mr.
Akhileshwar Jha Advocates will be constrained to take suitable action
against you the Noticees under Law, at your cost consequences.
and
It is clarified that all action can be taken against all of yOu the
Noticees like lodging of FIR under BNS, 2023 for your bad deeds.
Further publishing in newspaper about your conduct and also take
any other recourse which is available the Noticees ate Undt
in law. Vou
Jiobtity Puy
do the outtknding Biu witiatsdays tom tu detehceriny
A copy of the notice is being retined at my office for future tuis noticl.
reference and use and, an amount of Rs 51,000/- (Fifty one
thousand Rupees) is chargeable upon you as cost of the notice.
So, please note and act accordirngly,
You are under legal Notice.
Place: DELHI ADVOCATE
AURABH KUMAR
SUPREME COURT OF INDIA
Ch. No. 202, H-190, Sep 62NOIDA
AKHILESHWAR JHAnal
ENROLATE) 1057, NITI KHAND 1, INDRAPURAM
:[Link]@gmá[Link]
(BA LLB- LLM
DI2861/2017 SCBA Mob.: 9458034987
SUPREME COURT OF INDIA/ DELHI NO:J/665
CH. HO.
HI
HIGH COURT
HIGH C
SETALVADCHAMBER
SUPREME COURT OF INDIA, BLOCK
NEW DELHI-01
Mob. No.: 9560714537
SAURABH KUMAR SOLANKI
<br>

((26

SUPREME COURT OF INDIA.


NOTE: A Copy this Legal Noticc is being retained for
future purpose and
use.

Thanking you.
L
SOLANKI
KUMAR (BA, LLB, LLM)
SAURABH COURT OF INDIA
iDA
SUPREME SeeBRAPURAM
H-196, ND 1,
AKHILESHVWAR JHA
LLB- LLM)
Ch, No. 202, NITI KHÁND
[Link]
1057,
(ADVOCATE) (BA E-mall : 9456934987
ENROL NO.
DI2861/2017 SCBA N0: J/665 Mob.:
DELHI HIGH COURT
OF INDIA/CHAMBER
SUPREME COURT
, SETALVAD BLOCK
CH..NO. INDIA, NEW DELHI-01
SUPREME COURT OF
Mob. No.: 9560714537

1MAIog AAMUN HSAAUAE


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GOVERNMENT OF INDIA

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Posts
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Home TrackN Trace

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Consignment No: ED893348146IN

Megh
Booked Dispatched In Transit Out for Delivery Delivered
Chatb
<br>

ED893348146IN Article Type: SP_INLAND Shipment Information

Booked at Destination
Delivered
Supreme Court SO Nand Nagri C S0

Routing Steps

0S/0S/2025 Item Bagged


13:46:09 Supreme Court SO

0S/0S/2025 Item Dispatched


19:02:54 Supreme Court SO

09/0S/2025 Item Bagged


00:12:19 New DelhiNSH

09/08/2025 Item Dispatched


05:18:36 New Delhi NSH

09/08/2025 Item Received


09:45:04 Nand Nagri C SO

09/08/2025 Direct Deposit - On Addressee instructions


17:25:16 Nand Nagri C SO

11/08/2025 Item Invoiced


08:04:40 Nand Nagri C SO

11/08/2025 Returned to sender


17:19:16 Nand Nagri C SO

12/08/2025 Item Bagged


15:14:46 Nand Nagri C SO

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15:22:36 Nand Nagri C SO

12/08/2025 Item Dispatched Megh


19:36:09 MARMS Bhawan Chatb
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12/08/2025 Item Received


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04:23:06 Delhi RMS Bhawan NSH-|

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13/08/2025 Item Received


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13/08/2025 Item Delivered


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<br>

19:47 LGeOO• ANNEXURE Nopn

A +9198737 70003
ADV. ITENDRA TYACI

ADV NITIN SIAaA


)
Demand Notlce to dhananjay
[Link]
43 pages59 MB PDE

1932 VZ
Forwarded
Ton the behalf of my legal Assocate
Mr. Akhileahwar Jha Advocate,
serves upon you the legal notice
for the recovery ofprotessional
legal fees for 2,10, 000/-. That
you have committedDelebrate
and willfuldegault in paying ofthe
fees inthe form of instalments.
You have consistently committed
2installments paying detault
with dishonesty and malafde
intentions Hence all the installments
arrangements stands terminated
as youhave unilaterallycommitted
the breach of yourpromise, you are Riced
asked and [Link] to pay the
full amount of fees 2,10, 000/-at
once for the professlonal servIces
which you have enjyed and y
Jegal assoclate performed into
your favOur Thanking you, act
accordingly
Advocate SAURABHIKUMAR
SOLANKI, SUPREME COURT 0..
Read mnore 19:32
<br>

19:47 U9EOO Vo
((33
+91 98737 70002
Av. JiTENDRA TYAGt
Mohi614419T
ADY N1tN nANM4 rHAIL d
alankiprpnellée

Demand Notlce to dhananjay


[Link]
43 pages 59 MB PDF

19:32 V/
Forwarded
my
lon the behalf of legal Associate
Mr. Akhileahwar Jha Advocate,
seves upon you the legal. notice
for the recovery protessional of

legal fees for 2,10,000/- That


you have committed Delebrate
and willfuldegaultin payingof the
fees in the forn of instalments.
You have consistently committed
2installments payingdefault
with dishonesty and mala fide
intentions. Hence all the installments
arrangements stands ternminated,
as you
have unilaterally committed
the breach of your prornise,you are
asked and,now expected to pay the
full amount offees2,10,000/-at
once forthe professional services
which yoUhave enjoyed and my
legal assoclate performed into
your favoUr,Thanking yoU, act
accordingly
Advocate SAURABHKUMAR
sOLANK, SUPREME cOURT OF
INDIA 19:32 W/
(134
<br>

2:19 ANNEXURL NO; P}I2

R
Photo State
Ravi Gautam
karkardooma Court E Block
+91 75320 78591

Audio Video Pay Search

Media, links, and docs 9>


hi 131 eNey

PhonePe
RLEARNING STUDY PONT
Shahi
marthvn Dhn
m

y12- 2@okicici on G

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eR RaviGautam Photo St..

10 July 2025

coURT of sH. DEPANKER MOHAN


DISTRCT AUDG, (DISTRICT AND sESsION UDGE,
SHANDARA), KÀRKARDOOMA cOURT, DLHI
CS CASE No 242 /2025

INIHE MATIRR Q:
SM. RAJ KUMAR AINTIFF

Dhananjay Shahi 13 lac recovery


matter 07 R11, 01 10(2) AND 13..
81 pages • 452 kB • PDF

11:57 am v

IN THE coURT Or SH. DUPANKLR MOHAN


DISTRICT UDGE, (DISTRICT AND SESSTON OGE,
SHANDARA), KRKARDOOMA COURT, DELI
cs CASE No. 242 /2025
INHUMATTER OE

SH. RA KUMAR -PLAINTIFF

written statement and counter


claim Raj kumar Bhati vs. Dhana...
162 pages 679 kB PDF

12:07 pm v
Forwarded
Masks, Stay Sat
<Dial 1692666868) <kzar

E0237851J44 1N 1VR:5968257EF1

3:3..5 Db/2923.15:.

A258pma

15rs 3:16 pm

Ok 3:41 pm v.

Message
<br>

B:23U
ANNE XuRE Mai 3
Transactlon Detalls

(OMrID

450 Payim

.ilo)

T2507101231351451475554 COPY

287961027797

TransactionNote
Sent using Paytm UPI

Customer Details
DHANANJAY SHAHI

Store Details
R-learningStudy Point | Q509720879
ID MS1811221132575615044194

Paytnent Solution Used


QR

raftlitett Instrunnent(s)
UPIAccount
450

AXNPN19261785723 SETTLE)
<br>

2:27

SL

ShahiRoad Lines
shahidhananjay12-1 @okicici

R> Pay

Mark as Favourite x Mute

Bank Verified Name


Shahi Road Lines

Shared Media

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<br>

2:27
I3a)
SL Shahi Road Lines
shahidhananjay12-1@okici..

28 Dec 2024

5,000
Received in Bank
11:45 PM

18 Feb 2025

2,000
Received in Bank
11:03 PM

03 Mar 2025

10,000
Received in Bank
9:38 PM

11 Jul 2025

500
Received in Bank
10:16 AM

+ Enter amount or add note


<br>

2:22 a

DS

Dhananjay Shahi
shatidhananjay12-2aricici

32 Pay

Mark as FavOuríte

Bank Verified Narne


Dhananjay Shahi

Shared Media

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<br>

DS
shahidhananjay12-2@okici... (40

01 Dec 2024

5,000
Received in Bank
9:31 PM

9:54 PM V

08 Jan 2025

3,000
Received in Bank
11:24 PM

17 Jan 2025

1,500
Received in Bank
10:48 PM

30 .J25
<br>

DS shahidhananjay12-2@okici... (4
5,112
Received in Bank
9:49 PM

20 May 2025

2,500
Received in Bank
11:45 PM

21 May 2025

1,500
Received in Bank
10:37 PM

26 May 2025

2,500
Received in Bank
11:01 PM
<br>

Dhananjay Shani
DS shahidhananjay12-2@okici.. ((42

30 Jan 2025

:4,000
Received in Bank
10:52 PM

23 Apr 2025

5,112
Received in Bank
9:49 PM

20 May 2025

2,500
Received in Bank
11:45 PM

21 May 2025

1,500
Received in Bank
10:37 PM
<br>

2:26 lO4:
(43)
History

O My Staternents FFilters

Received from
SHAHIROAD LINES 1,500
17 Oct 2024 Credited to

Received from
SHAHI ROAD LINES F5,000
02 Oct 2024 Credited to

Received from
SHAHI ROAD LINES 1,500
20 Sep 2024 Credited to

Received frorn
SHAHIROAD LINES 2,000
Credited to
26 Aug 2024

Received from
SHAHI ROAD LINES F4,250
Credited to
09 Jul 2024
<br>

2:26

History

My Statements FFilters

Received from
DHANANJAY SHAHI 2,000
17 Jul 2024 Credited to )

Received from
DHANANJAY SHAHI 2,000
06 Jul 2024 Credited to
<br>

ANVEXURS
Po:s
<br>

T
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ShahiUp Wale Bhiya Market


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SHAHI ROAD LINES I

23 May 2019

+91 98737-70002
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11:47

Shahi Up Wale Bhiya Market..


21 April 2025

r Forwarded

SUMMONS 4 DHANANJAYA
[Link]
33 pages 16 MB PDF

7:22 pm

22 April 2025

Sir, aaj fees kar wa do 5112/- 7:55 pm

7:55 pm

Sir kar wa do sir aaj to0 11:32 pm

11:32 pm

23 April 2025

Fees nahi ayee hai abhi


tak????????????????????????????2?
7:54 am

Message
<br>

41
11:48 4
.l,
Shahi Up Wale Bhiya Market...

24 April 2025

Defendant/Respondent Evidernce

14 MOHAMMAD KUNWAR
Suit/7592021 ASLAM MOHD, R.

versus
24-04-2025 DHANANJAY
SHAHI

Misc. ArgumentS

NIHARIKA KUMAR SHARMA


12:06 am

307 12:06 am

New building 12:06 am


/
Forwarded

MOUAMADAAM V
HtANANIAY SAD

A240, Call n2L, Subh Kal MurL Inh Yha, IeR91 eety
N Deal.

DocScanner 24 Apr 2025


1-25 [Link]
2 pages 1.2 MB PDF

1:34 pm

Adobe Scan [Link]


4 pages 1.3 MB PDF

Message
<br>

11:48

Shahi Up Wale Bhiya Market.

7:54 am /

Rat der se aaya tha Aaj ho jayegi 8:00 am

Raat ko kar ni thi to


Abhi kar ke khatam karO B:47 am
/

Ho jayegi Aaj Jarur 8:49 am

To AKHILESHWAR JHA

5,112
Pay ogoin

O Completed

23 Apr 2025, 9:49 pm

ICICIBank 7257

UPItransactíon ID

511305890209

To: AKHILESHWAR JHA


Paytm 9560714531@ptsbi

From: DHANANJAY SHAHI (CICI Bank 50pM

u
Thank
10:28 nm /

Message
<br>

11:49 IA.l41
Up
Shahi Wale Bhiya Market...

6 May 2025

156(3) ki complaint aur notice to attend


the enquiry 4:26 pm V
Wo mang lo 10 se ta to ye ASIhoga ya to
SI hoga. 4:27 pm V
Fonwarded

6:43 pm

Forwarded

7312.

6:43 pm)

7 May 2025

Message
<br>

11:49 4.l O41%

Shahi Up Wale Bhiya Market...

7 May 2025

ShahiUp Wale Bhiya Market Road L..


J Photo
App bolo to iskicriminal division dal ke
stay kar va du kya 12:51 pm /

Lakin wo jaldi dalni hog 12:52 pm


/
11 May 2025

lska print out nikal wa lo 1:29 pm /

3:00 pm

Sir 5000/- fees to kar Wa


do g:39 pm

12 May 2025

Message
<br>

11:49 A.l041:
Shahi Up Wale Bhiya Market...

12 May 2025

Forwarded

SKM_C45825051209270.pdf
44 pages PDF

15 MB

1:39 pm v
13 May 2025

A
To AKHILESHWAR JHA

200
Pay again

Completed

13 May 2025, 4:22 pm

HDFC Bank 5331

UPI transaction ID

549933197800

To: AKHILESHWAR JHA

Paytm 9560714537@ptsbi

14 May 2025

Message o
<br>

11:50

Shahi Up Wale Bhiya Market...

14 May 2025 11:29 am

Fees for the final submission and final


written submission.
1: fees for drafting, typing and legal
position setting.
Rs. 1000/- per page x 42 42000.
=

2: fees for final arguments Rs. 30,000/


3: fees for the 1,500/-.
4: Case law finding 1500/-.

Total = Rs. 75,000/-. 5:03 pm v!


Aaj ke kam ki puri fees 5:03 pm
!
3: fees for the day 1500/- likha hai.
5:06 pm

15 May 2025

You deleted this message


O

3:07 am

0
You deleted this message 3:07 am

MOHAMAMAD AS
AM V
DHANANJAY

140$ 2025
Pocnt Sh Mohd Rafi, Ld ('ounel fx plaintull wah plantf!
Sh AShilehwar Jha Id Cunel f delerdnt

Matler is fi
fr kiessung lnal wguments
Argumenis heard
Pu up for clwifkatn jdgment on 10.0 2025.

Wrllen mhmisn on hehalf of he delendant filed ('o suplied


Mauntoll s
duete file hs wrilicn argumcns h
uptcd
Citalans wthun twO Werk s lme wih aJance coy
D

the orpnite sde


|Dale s gn as per Ue cunscneKe of Ue cuusel

INihaika huma ShaImal


('d Judge cum KC.(5hahdara)
Senuw
Aakdnuma ('ts. Ikllw40S 2029

Message
<br>

11:51

Shahi Up Wale Bhiya Market..


You d
15 May 2025
essage 3:07 am

AtIDAS AM V
HANANIAY IA

ttter find n aklesg ial aguet


ea
Arpments
Mn fk elnment n 007 202,
La

Wten Mmn n half e dkfelant filed Con suged


o

Rarofln rnt le his wnten agunei wih suywte

Ihte n gn en as y ihe cvnveniene of he cuunel

(Nihaka kua Shar ma


Senn ( Jalge um k,(shahlara)
A arkardeNma ('rs Iklh|4 05 2124

Ye order aa gaya haiorder 4:30 pm


/
Abhi mare pass time nahi hai raat ko baat
karunga 5:12 pm /
Kuch urgent hai too message kar do
5:12 pm

Ok
5:12 pm

16 May 2025

5000/- abhi pendi hal g:46 pm /


Aur 1500/- 14 kidate ke g:46 pm v
Message
11:52
<br>

(S6
ShahiUp Wale Bhiya Market...
9:46 pm
16 May 2025
???? g:46 Dm
!
Fees kar do 9:46 pm

17 May 2025

75,000/
Ek may 25,000/
mai
June mai 25,000/
Aur july mai 25000/
De ke khatam karo 3:45 pm v
Fees ko, jayda time maat lo
3:45 pm v
O
Youdeleted this message
3:45 pm

Aur bachi hui fees hai


5000/-ki aur 1500/- ki aaj kal mai kar wa
do 3:46 pmn /

18 May 2025

Sir aaj to kar wa do


5000/- Iliaur
1500/
Total 6500/- ki fees 1:41 pm

Itna time kyoo le rahe hoo?????????


pmn
1:41

1:41 pm

Message
<br>

11:53

-) ShahiUp Wale Bhiya Market...

20 May 2025

Sir aaj to kar wa do


5000/- li aur
1500/
Total 6500/- ki fees 8:58 pm

Aaj ke liye bola tha app ne g:59 pm


/
Youdeleted this message 8:59 pm

Kar wa doo g:59 pm


!
Fees to kar wa do 11:42 pm

12 baj gay hai 11:42 pm

Bhej raha hu 11:43 pm

To AKHILESHWAR JHA

*2,500
Pay again

Completed

20 May 2025, 11:45 pm

ICICI Bank 7257

UPI transaction ID

550669246109

To: AKHILESHWAR JHA


Paytm 9560714537@ptsbi

From: DHANANJAY SHAHI(ICICI Bank)Pm

Message
<br>

11:54
38
Shahi Up Wale Bhiya Market...

From: DHANANJAY SHAH 20 May 2025 pm

Kal or karunga 11:47 pm

Sir puri kar dete 11:54 pm


v
4000/- ki boli thi aaj apne 11:54 pm v

11:54 pm !
21 May 2025

Bhaiya 1500/- to kar do aaj g:51 pm


/
To AKHILESHWAR JHA

1,500
Pay again:

Completed

21 May 2025, 10:37 pm

ICICI Bank 7257

UPI transaction ID
550791293567

To: AKHILESHWAR JHA


Paytm 9560714537@ptsbi

From: DHANANJAY SHAHI (ICICI Bank)O8 pm

Message
<br>

11:54

-( Shahi Up Wale Bhiya Market..


22 May 2025

Sir 2500/- rahe gaye hai 1:15 pm


V!
Wo bhi saturday tak kar do 1:16 pm

1:16pm !
25 May 2025

Sir kal kar wa dena 25007- 9:59 pm

Aur time maat lo 9:59 pm

Piz
9:59 pm

26 May 2025

Aaj kar wa do 2500/- ki bachi hui fees


2:49 pm !

Khatam karo aa) 2:49 pm v


Karke isko 2:49 pm
v

To AKHILESHWAR JHA

2,500
Pay egain

O Completed <<

26 May 2025, 11:01 pm

Message
<br>

11:55
|G0
Shahi Up Wale Bhiya Market..
22 June 2025

Sir iss mahine ke 73500 mai se 10,000/


ane hai 8:23 pm

Aabhi 10,000/- ayee nahi hal g:23 pm


/
Kar wa digiye 8:23 pm

8:23 pm /

Abhitak notice ka date send nahi kiya hai


8:55 pm

Vo send kar do 8:56 pm


v!
Written statement tayar haiapp ki
8:56 pm /

25 June 2025

Notice ki date too send karwa do


12:14 am /

?????????? 12:14 am

Forwarded

Message
<br>

77:55 4 ll 40%
(162)
ShahiUp Wale Bhiya Market..

25 June 2025

Notice ki date too send karwa do


12:14 am v
?????????? 12:14 am v
Forwarded

013 an OTO:13 am
OADLINs

+3
R10:13an
Forwarded

Message
<br>

(162
ShahiUp Wale Bhiya Market...

Forwarded

LAh t

nt enda
the "oeter/w d he s the
hd Rm Me Re nd at havybeng h

nay te amty k

d
trom
e
that thr ARe brokr that àxe d the
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aart
he ga then had
t hea nn Us the peiod of

he
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of le due to cGed and
J ualetr, the alkge ned he nt

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hom e we fogh Prgs famy aveg the goste tht hme and aheng fsth
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ktrratnn topyle
Tranler NE n the mde nt papt the arMa ,V o
teont
unb 112705500S 34 10 n au o e
namwly Ra ur Ahnpr the

A03 pm:
Forwarded

h
p
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o r
pyment
t
eat ne trurs tr
Mnton
4

tetesthe the ma hde lnt rt


th

netter ndn to the onglainart


penona nd tegraly but daet
epng hs ony oue d Genesd (Mtee
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the der
e
e dy
.a*t andthrealed
dedaese e d t

ddatr owe etest to ch is

Tht she vdae ndeaonaly


d

delbere
befely kan/torred
s
the detsr
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A

he sbove Male by the canglainant


are vaddated th dunie edene
t
y

prondee heen ciau

Urevgh DIUc dated de 06 023


1a/ Dnd otke "end
of detivery d
4g not/ Nottke
Demand "usking tepurt eerlving ide

mnd Nous "und through ndian Po th consignmwa unber


EDZInS1444Nnde daled 1s.04.2023.
am wa4 Jeivered/received but detbetately
6 Lagal notca Demand Nudca
poided- heaon Bhub Whals app number

Copyof Lgal note ded 14.042023.

Message
<br>

11:56

Shahi Up Wale Bhiya Market.

26 June 2025

Sir abhitak app ke 10,000/- nahi aye hai


iss mahene ke 8:17 pm v/

Mahena khatam ho raha hai g:17 pm

28 June 2025

Sir abhitak app ke 2:18 pm

10,000/- nahi ayee hal 2:18 pm


/
30 June 2025

ATt:l/./e, 1a12.,[Link]:[Link]

1123 am
Forwarded <

Message
<br>

Shahi Up Wale Bhiya Market...

30 June 2025
am
Forwarded

30062025 Rajkumar [Link]


16 pages 7.0 MB PDF

6:07 pm

Sir abhi tak 10,000/- nahi ayee


hai
10:10 pm /
?????????!!!!??!!!?????
10:10 pm

1 July 2025

Sir fees nahi ayee hai abhi


tak 12:00 am
?????2?????22?
12:00 am /

A
To AKHILESHWAR JHA

10,000
Pay agaln

O Completed

1Jul 2025, 11:34 pm

HOEC Rank
321

Message
<br>

1:57

ShahiUp Wale Bhiya Market..

A1July 2025
To AKHILESHIVAR JHA

10,000
ANy ogaln

O Completed

1l 2025, 1134 pn

HDFC Bank 5331

UPI transaction lD

55480S133758

To: AKHILESHWAR JHA


Paytm 9560714537@ptsbi

2 July 2025

ShahiUp Wale Bhiya Market Road L.

D Photo
From 73,500 to Balance 63,500/
8:09 pn /

Aur sir legal notice ke 9000/- pending hai


8:09 pm

7
July 2025

Cost of legal notice 10,000/


After discount= Rs. 9,000/
Details of charges

Message
<br>

11:58

Shahi Up Wale Bhiya Market...


7 July 2025

Cost of legal notice 10,000/


After discount= Rs. 9,000/
Details of charges
1: Notice for Dhanangay Shahi=2,500/
2: For Adarsh Shahi =2, 500/
3: For Muni Shahi= 2,500/
4: For recovery of 2,00,000/- amount
notice
Rs. 1,500/
Total for legal notice 9,000/ 10:53 pm /
8 July 2025

IN THE coURT O SH. DEEPANIZR NOMAN


DIST AND SSION UDG
SHANDMRAL AAT OURT,
CS CASE No. 242 /2025

SH RA KUHAR

Dhananjay Shahi 13 lac recovery


matter O7 R11, 0 1 10(2)AND 13..
81 pages 452 kB PDF

9:08 am /

IU THE COURT OF SM. DLPANKER MOHAN


DISTRUCT UDGE, (DISTRICT AND Sess1ON UoG,
SHAHDARA), ÀRKARDOOMA COURT,
cs
CASE No. 242 /2025
DEI

SM RA. UMAR PLAKIFF

written statement and counter


claim Raj kumar Bhativs. Dhana...
162 pages 679 kB PDF

9:08 am
Ye tayar ho gai hal g:08 am
!
Message
<br>

11:58
((6
Shahi Up Wale Bhiya Market..

9 July 2025

Urgent baaat kar ni hai 10:01 pm


Call karna 10:01 pm

10 July 2025

cetan;

4q-2

A:20 pmn

60,000/- dogy appeal ke


Purey process ke
Jismai pure appeal ki Drafting hai, Sare
paper tayar karna hoga, final stage tak
argument tak hogi.
Pura case 60,000/- mai. 7:24 pm
<br>

11:59 A..l:O39%

Shahi Up Wale Bhiya Market... t


Pura case 6
10 July 2025 7:24 pm v
Sir aaj ki fees 1500/
Aur Certified copy apply karne hai uske
500/ 7:33 pm

11 July 2025

2N Surts921
AOLAMMAD ASLAM V's DMANANNAY SHLAIU

Preent
slantil
Jefeinlrt

display_pdf (1).pdf
1 page • 84 kB PDF

10:10am v

[Link]
YLDOOMINIOONOOURKARACOOA
CO.0AOAA

Udqe C D NaDUKE0S-001407-2021

display_pdf.pdf
7 pages 410 kB PDF

10:10 am
<br>

12:00 6
lO39:
ShahiUp Wale Bhiya Market...
10:10 am /
11 July 2025
A

To AKHILESHWAR JHA

500
Pay again

O Completed

11
Jul 2025, 10:16 am

ICICI Bank 0538

UPI transaction ID

519230252772

To: AKHILESHWAR JHA


Paytm 9560714537@ptsbi

Paper work 10:16 am

12 July 2025

Appeal mai.
App mujhe 50,000/- dede na
30,000/- phale
10,000/- bad mai aur
2000/-x 5 months= 10,000/
Total 50,000/

Agar mood ho karwaane ka too. 8:04 pm


<br>

Up
Shahi Wale Bhiya Market...

Agar mood 12 July 2025


.ka too. 8:04 pm v
Forwarded
Raj Kumar Bhati
LPalU +
fjkunàt Bhati tegat.
otice.

30082023 RaAuma Bhàti pd!

M. Raj kumat Bhat


put you Under the legsl hotice, aher the

aB0000024
2tor
causing intentional damage bnd
LtOAL NoTICE lo Mr Ral
Kumat Bhati pd

han to the reputation and oodwl ol


my client namely Mr Dhananjy Shahi
ond to his rest of the 2 othet famy
members Mr. Adarsh Shahi and Mnan Forsaroe
Suh urther you have deberetey
spoiled, ruined and caused the damage
to the Goodwll and reputation of my
cent trucing businessY
ForNhch my chent dalms Rs SUMMONS4 DHANANJAYA
SHAHI pd!
Indentions
cSnoncs nd malat
am serving upon you wh this legal
nobce, actsccording you are under legal
noice 2Juh 2025
orw
9 Ths message wsdeleled

etsage Messane

8:44 pm

Sunday) 13 Juys
225
Sir 1500/- ki fees too kar wa do 11:04 am

O
You deleted this message 12:46 pm

Appeal mai. App ek kam karlo



App mujhe 50,000/- dede na
1. 20,000/- phale dedo jise mai drafting
kakam shru karu.
2. 10,000/- ki 2 instalment bad mai aur

3. 2000/- in instalment x 5 months=


10,000/
=Total 50,000/
Dadna

Message
<br>

12:01

Shahi Up Wale Bhiya Market..

Sunday |3 July, Zo2s 12:58 pm /


App ko bhati wale mamle mai
•Written statement ban wa ne ke fees
deni hai
1,00,000/
•730,000/- iss saal 2025
And
•?70, 000/- 2026 mai January se july tak
•10,000/-ki instalment x 7 months
Total= 1,00,000/ 10:06 pm v/
App ne ye written statement ban wali hai
aur app ke pass hai.
App ko aur app ke beta ko written
Statement dedi hai maine
App ke affidavit bhi pure ho chuke hai
10:08 pm /

You
Cost of legal notice 10,000/
After discount= Rs. 9,000/
Details of charges ...
Ye abhi 9,000/- pending hai
71,500/- aslam wale mam le mai
pending hai 10:10 pm /

Tuesday| i Juy 202$


You
Ye abhi 9,000/- pending hai
?1,500/- aslam wale mamn le mai pending hai
Abhítak aslam wali appearance ka fees
nahi ayee hai
Kya dikat hai

Message
<br>

12:01
112
ShahiUp Wale Bhiya Market..

Tuesday 1

Sh Julg, 2025

You
Ye abhi R9,000/- pending hai
1,500/- aslamwale mam le mai pending hai

Abhi tak aslam wali appearance ka fees


nahi ayee hai
Kya dikat hai
Aaj Tuesday ho gay hai.
1,500/- (10.07.2025) tarik ki abhi tak
pending hai????????????

10:29 pm

Abhitakkk 1500/- ki fees nahi ayee hai


11:30 pm /
???????? ????? 11:30 pm

,
Wednesday i6 July 2025
Fees nahiayee hai 12:26 am

12:26 am

12:26 am

You
Abhi takkk 1500/- ki fees nahi ayee hai

AaJayegi
8:43 am

Thic mesSane NAs rleleted

Message
<br>

12:01 4.l039s

ShahiUp Wale Bhiya Market..


(y INS ITiESsHye i
Wednesday 8:44 am
I6"TDly202 r

9:35 am /

Shahi Up Wale Bhiya Market Road Lines


Aa Jayegi

9:36 am v/

29CT Case487.2O25
RAJKUMAR Ve DHANANJAY SHAHI
(yot Nar)

05.07.202s

Luwyen re sbetaining roa court wot.


Present LA APP fa the Sue
Acc n ern
LJ Conei kr the complaunart hrough V

Some clanfatos are requre fron he I0, therefoe


Ssue ntNT lo the IO o ppear un pTn on NDOH
a up lo arpuranr of the K rpuments on aran
ws 12%3) 8NSS n
2s 07 2025

(RAJILL SALNI)
JMEC4s Shahara Dsn
SADCours DefhaS07 2025

Message
<br>

12:01

Shahi Up Wale Bhiya Market...

Wecdnesday / 16 Juop

2:55 pm !

) ) is

Message
<br>

12:01

Shahi Up Wale Bhiya Market...

Wednesday
Wlu2.55 pm 2

File has been inspected after your


instructions, all the relevant documents
moved for file inspection 2:56 pm

App name issorder sheet maigaalat


tarike se charaya gya hai. 2:56 pm

I0 ne app ke favour mai Apni Inquiry


report di hai, ki koi offence nahi banta hai.
2:57 pm v
File inspection done from 2:10 to 2: 47
pm 2:58 pm

29CT Cuew4872023
RAJKUMAR Vs. DHANANJAY SIRAI
(Oyoti Nar)

05.07.2025

Luym re abstaining from court work.


L
APP
fo the Sue
Astusd in perun
L4 C'ounl fu th cumplasnunt thrugh V.

Sme clancatrs ae reyurad ftom the l), therefoc


nsuc mKE u the I(O w aprear in persn un NOH

Pu up li appurane of the I kagumcnts on arplicaton


us175BNSS on 28 07
8

(RAIULSAIN)
JMHC-08 Shahlra Disttl
KKDCNrns Ielh s 07 2025

Te galat likha hua hai.


2:59 pm

Message
<br>

12:02
(76)
Shahí Up Wale Bhíya Market..

Court ko bata napare g 9


9n /

Ye aaj court ne allo kiya tha


301 prn /
Abhi 301 prn /

Shahí Up Wale Bhiya tMarket Road Lines


Aa Jayegi

Abhi fees nahí ayee hai 1025 pr /

?????? 1025 prn /

16
LASIATI
17-07 2025 VEr

Message
<br>

12:03 A.l,O38.
(H)
Shahi Up Wale Bhiya Market...

Wednesday
6July) 262s
?????? 10:25 pm
v!
An:uents

16 SS55.2017 SMT.
AJWANTI
17-07-2025 versus
SOM NATH

17 CSl6023 AARTI VIDYA


MISHRA SAGAR
17-07-2025 versuS
JANANDAR
PRATAP
SHAHI

Shahi Up Wale Bhiya Market Road Lines


Aa Jayegi

Abhi tak 1,500/- ki fees nahi ayee hai.


11:47 pm
Aai ka din bhi khatam 11:47 pm

Kal kar dunga 11:50 prm

Shahi Up Wale Bhiya Market Road Lines


Kal kar dunga

Pata nahiye kaal kab ayee ga, ayee ga bhi


ki nahi 11:54 pm /

11:55 pm /
Thursday

Message
<br>

12:04

Shahi Up Wale Bhiya Market..

Thursday
1a Juy 2o2S
Pending hai 11:26 am
/

aarti mishra plaint complet [Link]


69 pages 22 MB PDF

9:27 pm

CASE INFORMATION FORMAT

AARTI MISHRA_compressed
(1).pdf
16 MB PDF

9:27 pn

1H THE COURT OF S
Atyg JAIH -1i ADOM
DISTRICT JU0at, (ossetrt AMO S$n DPLHI
SHAHDARA), VARKAMUOoKAACUAI,

Aarti [Link]
1.9 MB PDF

prm
9:27 /
Complete file of aarti Mishra has been
provided to you, in the PDF form. One
copy of each is retained by you as the
copy of client. 9:28 pm /

Message
<br>

12:06 M

Shahi Up Wale Bhiya Market..


copy of client Thursday 9:28 pm
|13uly0
Aaj ki fees appearance ki
2,000/
Aur legal submission and arguments ki
I 2,000/
Total 4,000/- pendind in aartiishra case.
For today
9:30 pmn

ShahiUp Wale Bhiya Market Road Lines


Aa Jayegi

Abhi tak Aslam walifees nahi ayee hai.


1,500/- ki
9:31 pm

You
Aaj kifees appearance ki
2,000/
Aur legal submission and arguments ki ..
Fees nahi mile hai abhi tak
11:02 pm

You
Abhi tak Aslam wali fees nahiayee hai.
1,500/- ki

Ye bhiabhi tak pending kyo hai


11:02 pm

11:02 pm /
Yesterday||2 Uulyzo2
Ye dono aajayegi
7:38 am <<
<br>

12:07 M

Å.lO38
ShahiUp Wale Bhiya Market...
Ye dono aajayegi Yesterday 18 0uly,202s

AARn MRAWAM RADAP ERANT

display pdf (2).pdf


l page 81 kB PDF

10:08 am

Sir app ko pura time diya gaya hai sari


fees puri dene ka, lakin aaj aur abhi tak
app ne mujhe bachi hui koi fees nahi di
hai. 10:09 am v
T
have appeared for you in the various
matters and even then you are
deliberately avoiding my fees
So for the reason am puttingyou under
I

liability to make the payment of fees biil


and expenditure within the reasonable
time.
Herein after Iserves upon the whole fees
structure for which you have engaged
me. To do your litigation work in form
of appearance, submission, arguments,
drafting, formulation of legal opinion,
conversation and conference charges and
other works. 10:13 anm

Forwarded
Akkileshuar Jha uovocATESAsLBLAM
sUPAEM coUMT oP nDLA DELH HeH coURT

DATEI6@r 202s

Message
<br>

2:18 .061x
+6 ShahiUp Wale Bhiya Market...
10:13 arn

You
Abhitak Aslam wali fees nahiayee hai.
1,500/- ki

Ye abhi blhi pending hai 10:14 am /

You
Aaj kifees appearance ki
I 2,000/ .
2 Aur legal submission and arguments ki
Aur ye bhi abhi tak pending hai 10:14am

20 July 2025

You
Aaj ki fees appearance ki
7 2,000/
Aur legal submission and arguments ki
..

Ye pending hai 8:47 pm v


You
Abhi tak Aslamwali fees nahi ayee hai.
1,500/- ki
Ye pending hai 8:47 pm

4000/
1500/
10,000/
JO o(O Total 15,500/- pending hài g:48 pm
/
Ye danihai fees app me janab ya
Time pass kar rahe hoo 8:48 pm !

Isko jaldse jald clear karo 8:49 pm v!


M

Message
<br>

ahsiS/o Dhananjay Sh...

82

TROe Setwocont
<br>

Adarsh ShahiS/o Dhananjay


Shahi
~Amrita Transport

Call
Pay Share

[AMRITA TRANSPORT]- Your


trusted
partner for road freight solutions.
We offer reliable truck transportation
services, connecting businesses
across[Delhi - Mumbai - Delhi).

Our expert team ensures:


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at your address.
Experience efficient and hassle-free
transportation with us." O

A sister concern of ShahíRoad Lnes

Travel and Iransport


<br>

Adarsh Shahi S/o... 18:


Lncryplion

Disappeaing essages

Chat lock
|ock nd hide ths chat onthis
devvce

Advanced Chat Privacy


Off

About and phone number

Available
15 Aprl 2021

+91 98737 70003


Mobile

No groups in common

Create group with Adarsh

Block business

Report business
<br>

3:37 atl 15%


(185)
Adarsh Shahi S/o Dhananjay..

30 June 2025

Hiadarsh willyou please check the


tracking report of India pist consignments
6:19 pm

Mare mobile mai nahi aa rha hai, we need


tocheck as it is delhi to delhi parcel
6:20 pm

You
Hiadarsh will you
please check the tracking
report of India pist consignments
Ok sir 6:20 pm

Might it may have been delivered to bhati


6:20 pm v
Give me 5mins 6:20 pm

Consignment details not found 6:26 pm

I guess we need to check this tomorrow in


speed post office 6:26 pm

if its not get updated by morning 6:26 pm

12 July 2025

Message
<br>

3:37

Adarsh Shahi S/o Dhananjay.

12 July 2025

Iveetiyettens t

Hece
L

kidney report .pdf


2 pages 792 kB PDF

12:16 pm /

CAM Nu 202 /20/

I A

Dhananjay Shahi 13 lac recovery


matter 07 R11,O1 10(2) AND 13.
81 pages 452 kB PDE

1157 am /

OP EN. DE 0PANKEn NOMAN


DrcoU
AHDARA ),
(S
KARKANDOONA COURT
CASE No 24)
DN
(025

written statement and counter


claim Raj kumar Bhativs. Dhana..
162 pages 679 kB •
PDF

1207 prm
v
Forwarded

15rs ?16 nm

Advocate Nitin Nitin


Sharma Karaval Nag
12:19 pm

Message

Message
<br>

3:37
(17)
Adarsh Shahi S/o Dhananjay. :

claim Raj kumar Bhoti vs. Dhana


162 1aP$ A70 DDF

1207 pm /
Iorwarded

15rs

Advocate Nitin Nitin


Sharma Karaval Nag
12:19 pm /
Message
You deletedthis message
3:18 pm
Ye hai kar dena isko 3:18 pm v
Screenshot share kardena 3:19 pm /
Pay kar diye hai
5:54 pm v
App mat karna 5:54 pm

Main aapko krdeta hoo


5:54 pm

Ok 5:55 pm
V!

You
App mat karna

Okji
5.55 pm

Message
<br>

3:23,
ANNEXU RE wo: P}P

Dhananjay Shahi
Truck Services

Call Message Video Directions

Contact info

+9198109 40743
Mobile

Delhi, India
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3:22
(a

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Dhananjay Shahi

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<br>

3:24

Dhananjay Shahi Truck Servic..


Cos
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<br>

3:24. B..|631

Dhananjay Shahi Truck ServiC...



Mobile +9198109 40743

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<br>

3:24 A.1l 63%

Dhananjay ShahiTruck Servic..


Mobile • +91
98109 40743

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<br>

3:24, E.l O63,


Dhananjay Shahi Truck Servic..
Mobile +91 98109 40743
3 4h
July202s
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KR.lO631
Dhananjay Shahi Truck Servic...

Mobile +91 98109 40743
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A atl 62%
9:17 209
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<br>

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<br>

3:30 >
ANNEXVKL NO:
Dhananjay Shahi Tru... PIS
T

Can't talk now. Call me lat

Thursday, 15 May 4:58 pm

Tam so sorrycan't answer the phone


right now. How canlhelp you?

6 RCS chat with Dhananjay

Wednesday 3:28 pm

Kar ta hu abhi phone, court mai hu

Texting with Dhananjay (SMS/MMS)

Can't talk now. Call me later?

6 RCS chat with Dhananjay

Koijaruri [Link] to what aap pe


1ikh do.

lam so sorry, I
can![Link] phone
right now How can help you?
4:26 pm O

RCS message
<br>

. :
Di:

PS
06 -os Plg

NO:
OFFICE OF THESTATION I0USE OFEFICER, PS JYOTI NAGAR, DELH
ANNEXURE

CTCase Dy No, 7S/2025,U/s 175.3 BNSS, PS JYOTI NAGAR DELII!


Vs Dlhanunjuy &
Ans
In tlhe muller of Sh Rajkunar
NOTICE/REQUEST TO JOIN TIIE ENQUIRY
To.
Sh Dhananjay Shahi
Marg
R/o A-2/469, Gali No.21, Subhash kansal
Harsh \Vihar Delhi
Mob.9873770002
Sir. filed a
Sh Rajkumar S/o Sh Netra Pal Singh
It is submitted that Delhi
you before Ld KKD Court Shahdara
against
complaint U/s 175.3 BNSS at PS Jyoti Nagar. You
are
same has been under enquiry
regarding cheating and the the allegation made by the
the enquiry and reply
directed requested to join at. 4.00 PM Room No. 217,
PS
matter on 08/05/25
Rajkumar against you in above

Jyoti Nagar Delhi.


SI Sanjv Kumar
No. 3618/D
PS: Jyoti Nagar
8750803311
(219)
<br>

1312.

OFPTCE OF THE sTATION ILOUSE OFFICER, PS JYOTI NAGAR, DELHI

CT Case Dy No, 78/2025, U/s 175.3 BNSS PS JYOTI NAGAR DELHI


Inthe mater of Sh Rajkunur Vs Dhananjay &
Ans

NOTICEREQUEST TO JOIN THHE ENQUIRY


To,
Sh jainendra Pratap Shahi
Rio A-2/469, GaliNo.21, Subhash kansal Marg
Harsh Vihar Delhi
Mob.9958002224
Sir.
It is submitted that Sh Rajkumar Slo Sh Netra Pal Singh filed a
Delhi
complaint U/s 175.3 BNSS against you before Ld KKD Court Shahdara
are
regarding cheating and the same has been under enquiry at PS Jyoti Nagar. You
directed/requested to join the enquiry and reply the allegation made by the
on 08/05/25 at. 4.00 PM Room No. 217, PS
Rajkumar against you in above matter
Jyoti Nagar Delhi.

SI Sanjeev Kumar
No. 3618/D
PS: Jyoti Nagar
8750803311
<br>

Vahvan
ansc

2o12

Jainenlo

2 6- 6r21

Conglarad
Hahi

CPh
fonenora
chele
<br>

ANNEXURsejA
PDLSHO10019962025_1_1
DLSHO1-001996-2025

No. 2
District and Sessions Judgc, Shaldara, KkD
IN THE COURT OF Sh. Dccpanker Moian
,
District Judge, SIIAHDARA.

SUMMONS FOR SETTLEMENT OF CS/242/2025


ISSUES RAJKUMAR Vs DHANANJAY SHAHI AND
ORS.
(0. 5, R. 1, 5.) NEXT DATE:23-07-2025
To,
DHANANJAY SHAHI AND ORS.
A-2/469 GALI NO 21 SUBASH KANSAL MARG HARSH VIHAR DELHIALSO AT
SHAHI ROADLINE,AT SHOP N0.G-15, POCKET L, DDA MARKET, DILSHAD
GARDEN, DELHI 95ALSO AT VILLAGE GAJHARA, [Link], [Link],
[Link], U.P.

Whereas RAJKUMAR has instituted a suit against you for you are hereby summcned to
file written statement within 30 days of the service of the present summons and to appear in this
a
Court in person, or by a pleader duly instructed, and able to answer all material questions relating
to suit, or who shall be accompanied by some person able to answer all such questions, on the 23
07-2025 at 10:00 O'clock in the forenoon, to answer the claim; and further you are hereby
directed to produce on the said day all documents in your possessions or power upon which you
base your defence or claim for set-off or counter-claim, and where you rely on any other document
whether in your possession or power or not, as evidence in support or your defence or claim for set
off, or counter-claim you shall enter such documents in a list to be annexed to the written statement.

Take notice that, in default of your appearance on the day before mentioned, the suit will be
heard and determined in your absence.
my hand and the seal of the Court, this 17-04-2025
Biveur

Disrict Judge
ati:
Notice Syou apprehend your witnesses will not attend of theikacs9d,
haveayrgiom this Court to compel the attendance of any witness, arddhe nOduction o
any you have a right to callon the witness to produce, on applyln to the Court and
dcnhHát
on depositing the necessary expenses.
2. If you admit the clainm, you should pay the money into Court together with the costs of the suit,
to avoid execution of the decree, which may be against your person or property, or both.

or
Visit [Link] for updates Qr
download mobile app "eCourts Services" from Android iOs
user as such
The process is system generated and transmitted in secured manner by authorised
physical signature not applied.
<br>

CASE INFORMATION FORMAT 24 Civi


DISTRICT ........ Shahdasa. Criminal

DECREE HOLDER ETC.


.c. NIPFTPETITIONER/ COMPLAINANT IAPPELAINANTI
& () FIELDS ARE MANDATORY)
PLEASE FILLUP ALL THE RELEVANT FIELDg

Name Ofthe Plaintiff /


Complainant /Etc. SH. Rakwni
Slo WNIo D/o

3 Address

Aadhar Card No. Pin Code: J| oo93


4 800! 03 ?7 INDIAN
Female Nationality
Gender Male Other
Other
6 Date of Birth /19 20 Age
7 Mobile No. e-mail:
8 Act /Section
Cort Fee Ascertained: 5o32
9 Valuation of Suit. Court Feo pakd / Deposited: | o32|

10 Police Station In Criminal Matters ony

11 FI.R. No. & Year In Criminal Matters onty

DEFENDANT lACCOUSED / RESPONDENT JDGEMENT DEBATER ETC.


S. FIELDS & (°) FIELDS ARE MANDATORY
PLEASE FILL UP ALL THE RELEVANT
No.
Name Of The
DEFENDANT /ACCUSED SH. Dhenojay Shah xors
Etc.
2 Slo Wle Dlo Vishvanoth
o
Subhush koniol Mar
3 Address A-2 /469,4oli .21
Harsh vÌhay, Dpl h- loo 93
4 Aadhar Card No. Not kmon Pin Code
INDIAN
5 Gender Male Famale Other |Nationality
Other:
6
6 Date of Birth Not Age
7 Mobile
No.8 434ooo 2 e-mail: -NG+ km
S
No.

Name Of The Advocate


Enrl. No.
:UKEt hiMAK H KR.
eNARO

2 Office / Chamber No. ADVCCATE


En. No.0 410.01
H.9312254443
3 9990387900
Mobile No. e-mail:

SUBMITTED BY;

PLAINTIFF / PETITIONERI DEFENDANTACCUSED //OTHER/ADVOCATE


I

C
<br>

(218
Unsupported Personality PCi

0000753825
GOVERNMENT OF NCT OF DELHI
c-Court Fee

DATE 8 TIME 03-APR-2025 12:30:24


NAMEs OF THE ACC REGISTERED UBER SHCIL
:

LOCATION KARKARDOOMA COURT


NAME OF LITIGANT RAJ KUMAR VIS DHANANJAY SHAHI& OTHERs
e-CoURI RECEIPT NO DLCTO344D2526NM798
e-COURT FEE AMOUNT 15032

(Rupees Fifteen Thousand Thirty-Two Ünly)

DLC TO0344D7'25479&

lStautov Alprt Tho uthontlcity of this Cour fuo recOipt ahould h


voefio at www shciletomp con Any xtiscropacy in the
detals on this tOoept and a9 AVaHabln on tho wobaito rondorS il invali In cas4 of any dìscrpadoy pluno irdorm tho Comooton
Authornty This recaipt is valld ony alter veritcalion & iocking hy the Cont otfcl

dhyu
<br>

INTUE COURT OF PRINCIPAL DISTRICTJUDGE.


SLAHDARA, KARKARDOOMA COURTS, DELHI.

CIVIL SUIT NO. /2025


IN TIIE MATTER OF:

SH. RAJKUMAR ...PLANTIFF


VERSUS
SH. DHANANJAY SUAUI& ORS. DEFENDANTS

INDEX

[Link]. PARTICULARS PAGES CFEE

1. Memo of parties A- B
2. Suit for rccovery of Rs. 1 3,00,000/ 1
-| 15032/
with supporting Affidavit
3 List of docunents with documents 12 -24
4. Vakalatnama
2
5 Duplicate sct of the suit

Filed by

Delhi Mukesh KAnar Bhardwaj


Date: (12.04.2025 Advocate
[Link].G-712, Karkardooma Courts
Shaldaru, Delhi-I10032
[Link].9312254443
<br>
,

(220

IN TH COURT OF PRINCIPAL DISTRICTJUDC:E.


SHAHDARA, KARKARD00MA COURTS, DELIHL

CIVIL SUIT NO. /2025

IN THE MATTER OF:

SU. RAJKUMAR ...PLAINTIFF


VERSUS
SH. DHANANJAY SHHAHI & ORS.
...DEFENDANTS

MEMO OF PARTIES

SH. RAJKUMAR
S/O LATE SHH. NETRAPAL SINGH
R/O E-268, GALI NO.7,
ASHOK NAGAR, SHAHDARA,
DELHI-110093.
MOBILE NO. 880260720.
...PLAINTIFF
VERSUS

1. SH. DHANANJAY SHAHI


S/O NOT KNOWN
MOBILE NO. 9873770002
2 JAINENDER PRATAP SHAHI
BROTHER OF DHANANJAY
SHAHI.
MOBILIE NO. 9958002224
3 ADARSH SHAHI
S/ODHANANJAY SHAHI
MOBILE NO. 9873770003
4 SMT. MUNNI SHAHI
W/O DIANANJAY SIAHI
MOBILE NO 9873770002
ALL PRESENTLY AT A-2/469,
GALI N0. 21, SUBHASH
KANSAL
HARSII VIlHAR, DELHLHO093. MARG,
<br>

I|AVING OFFICE NAMLY


"SLAHl ROADLINE:
AT SUOP NO, G- 15, POCKETL.
DDA MARKET, DILSUAD GARDEN,
DEUI-1|0093.

AND PERMANCNT RESIDENT OF


VILLAGE GAJI1ARA,
POSTOFFICE IJJARPAR,
POLICE STATION GAGiAlIA, ...DEFENDANTS
DISTRCT GORAKIPUR,U.P.

Filed by

Mukesh Kumar iyhardwaj


Delhi Advocate
Date: (2.04.2025
[Link].G-712, Karkardooma Courts
Shahdara, Delhi-110032
[Link].93 12254443
<br>

IN THE COURT OF
PRINCIlAL DISTRCTIUD, E,
SUAUDARA, KARKARDOOMA COURTS, DELIL

CIVIL SUTT NO. i2025

IN THE MATTER
OF:
SH. RAJKUMAR
SOLATE SH. NETRAPAL SINGH
R/OE-268, GALI NO.7,
ASHOK NAGAR, SIIAHDARA,
DELHI-110093.
MOBIENO. 880260720. ...PLAINTIFF

VERSUS

1. SH. DHANANJAY SHAH!


S/O NOT KNOWN
MOBILE NO. 9873770002
2 JAINENDER PRATAP SHAHI
BROTHER OF DHANANJAY SHAHI.
MOBILE NO. 9958002224
3 ADARSH SHAHI
S/O DHANANJAY SHAHI
MOBILLE NO. 9873770003
4. SMT. MUNNISHAHI
W/O DHANANJAY SHAHI
MOBILENO. 9873770002
ALL PRESENTLY AT A-2/469,
GALI NO. 21, SUBHASH KANSAL MARG,
HARSH VIHAR, DELHI-110093.

HAVING OFFICE NAMELY


"SHAHIROADLINE"
L,
AT SHOP NO, G- I5, POCKET
GARDEN,
DDAMARKET, DILSHAD
DELHI-| |0095.
RESIDENT OF
AND PERMANENT
VILLAGE GAJIIARA,
<br>

223
POSTO|CE LUARPAR.
POLICE STAION GAGAUA,
DISTRICT GORAKPUR,UP.
...DEFENDANTS
[Link] NA oAR

SUIT FOR RECOVERY OF RS.13,00,000/- (RUPEES


THIRTEEN LAC ONL) ALONGWITI INTEREST @

24% PER ANNUM

MOST RESPECTFULLY SHOWETH:

1.
That the plaintiff is peace loving and law-abiding citizen of

India and has becn residing permanently at the above


mentioned address with his family.
2. That the plaintiff has known the defendants for a few years
as defendants were tenants of the plaintiff for approximately

eight years and gradually developcd familial relations with


them.
3. The defendants initially operated a grocery shop at shop No.
G-15, L-Pocket, DDA Market, Dilshad Garden, Delhi

110095, and later established an office under the name

"ShahiRoad Lines &Transport" inthe same shop.


4 That in ycar 2022, when plaintiff sold a property and
withdraw sone cash from his account for his daughters

marriage, the defendants canie to know that plaintiff is still

in possession of huge amount in his bank accounts out of

compensation he received when his ancestral land was


acquired by Govt.,thercalter the defendant no. I
and 2 and 3
<br>

ANVXUREMe
(224
Dated 19 10 202A

(RININA (OMPAUNI AGAINSI MR. RA) KUMAR BMAI AND HI, WIEE FO#
(ONMMIING AN O N
AING AN) DISHONEST D15HON SI
O

PRIVINING DUBI BUNG AVAILABT FOR CRIDUOR, CRIMINAI BREACH OF SRUSI


and HAVING THI COMMON CRIMINAL INILNIONS BY NOT PAYING BACK HE
AMOUNI OF INR. 2,00,000/- (TWO LAKIS ONLY) ALONG WITH INTRESI OF 24%,
PER ANNUM FROM THE DATE OF DEFAULT AND THE COST OF LEGAL NOTICE RS.
21.000/-.

Dhananjay Shahi S/o Late Shr Vishvanath Shahi oge about 52 yoars k/o
M
Sus. Gai
h/
ann
\l Subhash Nansal Marg, Harsh Vifhar, Delhi 110093 and havirng office arddrr5 at
$hahi Road Ine at the above same mention office.

1 That Mr. (Hereinafter referred as the "defaulter/allege") and he is the


Raj Kumar Bhati,
government servant at Delhi Jal board. That, Mr. Raj Kumar Bhati and his wife is being
vEry well aware and known personality to my family. That Mr. Raj Kumar Bhati is having
the vey decp toot of rclation with me since from the very carlicr past and we both are
involved in past transactions as wellwe arc having concerns for cach other in the earlier
past history.
[Link]. allege is the government servant it is expected from him to show the good morais
and conducts in the society and due to being of his government servant people are
havng the faith and reliance upon Allege, that the Allege had broken that reliance of the
complarnant and had committed the cheating and commit the criminal breach of trust
wih his wite apainst the complaiLant.
3: That the defuulter in the month of May, 2021 had approached to the complainant for
the grant of loan for Rs. 1,00,000/- (Rupecs One lacs only) as thc defaulter was then had
the dire need for his wife health, treatment and hospitality purposes during the period of
Covio-19, the allege had then provided the generous reason to the complainant that if
tne amount is not urgently raised frorm complainant then the allege might face the
serious bereavernent in his family by an uncxpecled death of his wife due to covid and
iose sorrie other relative else well who is near and dear lo allege, the allege neither want
to lose any of hs relatives and nor this wife during the period of Covid.
4: That Conplainuht after considering the relation in between allege nd hinm un the earlier
past, atd onideing the other factors like allege benp the Hovenlent serVant, coming
from the vaell fioursh fnancal lanuly, baving the goodwill at that [Link] showng taith
upon allge, the oiplmait has developed the syuptiy and detemmaion to provIde
allege upurnhtthsumol R, 1,00,000/ ouly al tatnoveIent
5: That, the [Link] on vide dated I9,0% 202| h,
sted usmy he | (fund
nurnber 112/055005 3% to al acoul of alle bmely Raj kunn whhs S per the
<br>

,
6
hat alleg defulte i osfh of 2021 a
thathet) the

complainant had rovded toallepe with notte on mot


7 That the alec had asked to he [Link] to poe
n
oe other arntutt s
10000) ch 2an the allege had shown an uot oeed if roti, thote i; the

horrow: amout to other tedtors due to (ovd 19 fte ffert, nurt lleg
e

aiNeG 'rom th aUOUs other dfferent (editors lht lloged had ho the yer.
r
pressure to ropay b)ark the in hirt
n00dt me ht he is facing tho markot
t3ised from the market.
8: Tna:. the complainant again relying upon defaulter false statements and the iarratives,
the complainant had shown his determination and commitment to provide allege with
3nother loan on the implied guarantee and understanding that defaulter
is the

gOVernment employee and will not commit the breach of his promises. That vide dated
25 05.2021 the complainant had provided defaultcr on his ask the amount of
Rs

1.00.000/- (Rupees One Lacs) through NEFT with reference ID: 557991729 from the
current account of Shahi Road Lines to an Account of Raj Kumar.
9: Tha:, complainant on two different various occasions had accepted the facts that the
defaulter is in relay dire need of the funds, that defaulter was being unablc to get to have
2n, loan irom anywhere or had failed to manage any debt to fulfil the financial needs and
had reled upon defaulter goodwill and complainant after relying upon the establsh fact
tnat ceiaul:er is the government servant he will not cheat or commit the breach of his
pomise anc, repay back the money he owes to Complainant. That, defaulter by not
deiberately fulhling his promise has cheated andcommit the breach of trust upon the
omplainant
10:Tna:, soon after tthe time passes away, the defaulter have had been in the consistent
:oucr ith cornplainant and use to visit the office complainarnt with the promise that he
#llpay the debts vwhich allege as the delaulter owes lo complainant. That the total sum
of Ps. 2,00,000/ (Rupees Two lacs) was raised by the defaulter from complainant. the
¿oun! of Rs. 2,00,000/- were the hard earn money of complainant and the amount was
faised frorn cornplainant at the time when the period of Covid- 19 was on peak of its term
and coriplanart by hirnself vas in the need of money
u
11:1hat, the complnant has tacd the fonul ouch nd set bach due lo tlse anCe
eiven b
the defs ultt t) epay back the GSed borowed mout on the due e
nd
.
the curnplatotit ta: ufleed ens los m, commeoaluvities by not tulhllng
af
erpectatiui Gf hus cunteoal reditur, due to [Link] nglecung attitude
12:That, the delaulte unitently iakng the lalse proUuSes and givng enpty avsutance
through persnal teeting and through teephonn alls lo epay bach the boTOwed
<br>

226
Is not attending
years has been passed awy and now the defaulter to meet
hat, since the two
complainant nor the delaulter has shown ay wlingness highhy
Is
the phone calls of the the conduct of delaulter
complalnant since from last 3 months, hence payment of the complainant who is
the dellberatcly avolding the
doubtful and the defaulter
lablllty and obligation to pay of his debts as on time
the Creditor and allege s under
years
the
from the date of rst payment for each of
the
three slnce
before the laps of
favour.
snction loan/borrowed amount in delaulter you to pay the amount of RS. 2,00,000/- at the last
complainant has asked
4: That, the
is delberate avoidance the lawtul
demand of the
meeting slnce then the defaulter deliberately
fide intentions because he is
complainant, That defaulter is havlng the malavery
payment of loan since from long. That allege adverse conducts
vodin8 the on years the complainant is requesting
establishes the fact that, even after passing
of Loan amount .e Rs. 2,00,000/- by
defaulter at regular ntervals for the repayment to the complainant nor
personally and telephonlcally but defaulter nelther responding
repaying his money.
That, thecomplainant also visited to the defaulter
House and Government Office on
is bound to make the
various occasion and several time for reminding allege that he
repayment of the loan, however one day thc complainanl
was remaincd in shock when
the defaulter directly refused to repay the loan amount to the complainant
and threated
on one pretext to other is
the complainant for dire consequences and the defaulter
avoiding to make the payment of the said loan amount i.e Rs 2,00,000/-.
That the defaulter intentionally and delberately not repaying the loan/borrowed
amount to the complainant and harassing me and also cheating me. it is the defaulter
lability to make/repay the above said payment to the complainant immediately.
All the above stated by the complalnant are validated with a dossier of evidence
rovlded herein for my claims:
EVIDENCE (provided by complainant)
1. Transaction for Rs. 1,00,000/- vide dated 15.05.2021
2. Transaction for Rs. 1,00,000/- vide dated 26.06.2021
3. Legal notice/ Dermand Notice "send through DTDC"- vide dated 13.06.2023.
4. Legal notice/ Demand Notice "tracking report of delivery and receiving - vide
dated 14.06.2023.
S. Legal notice/ Demand Notice "send through Indlan Post with consignment Number
ED287851344IN"- vide dated 15.06.2023.
6. Legal notice/ Demand Notice "item was delivered/received
but delberatey
avolded- with reason of insufficient address -ide dated 21.06.2023.
7. Advocate send Legal notice/ Demand Notice to Raj Kumar Bhati
Whats app number
8802607920- vide dated- 14.06.2023.
8. Copy of Legal notice dated 14.06.2023.
The above evidence respectively
establishes that:
1: That, the defaulter have the direct contact and relations
allege had on the various occasions with the complainant and
have accessed to the complainant for
money of Rs. 2,00,000/- as debt. borrowing the
2: That the above two transaction
which taken place on vide
26.06.2021 establishes dated 15.05.2021 and
that defaulter/allege have received amount
as debt in his favour at
his bank account as
the of Rs. 2,00,000/
repay it back to the borrowed money on the promise
the complainant as s0on as possible. to

3
<br>

227
by courler
nottce has bwn eervel uon the allege defulter vide
3; id tegl
viue dated
nouce/demand
13.06.2023 & 15.06. 2023 and
brougt cloctron se corior vide:
dateo
dated
was nove epllcd tt)or the
r.
0.2UZ3
the legal nottci
was delilestelv lvelded is slow tho thf ala hot inteiiti, ri the

part of the allcgo delauler. nanne Srvrnl oppotlJnities


bas not rosponded is the condutlvr
noweveT, the delauller
tefaultou o fulll he oblpation in sitc ol so ririy OPpomn
and comrriitted thr delherae
have been providod to
(ailed to vctorm hls ptouisc
gvento Allege, he has miscrably comnilled lhe chrating hy
showing the
of his pronlsr aud wrongful loss to
dno tnentonal brcach paymcnt, by causing 1hc intentional
timely
disnonesty by not making the Rs. 2,00,000/-
as the wrongful gain. That the
enjoying the amounl of an
tne coplainant and amount of Rs. 2,00,000/ in total along with
to the return authority t0 take the strict
detaulter is under liablity conccrn police
annum, It is requested to the as they both have committed
nterest of 24% per against his wife
Mr. Raj Kumar Bhati and raquest to lodge a FR
immediately
Iegal acthon against trust. it is further
criminal breach of government department Delhi Jal
the cheating and the
requested lo inimate so
cheating conducts, the
against them. It is further his misconduct and
employee about
Board' where the allege the
is
could also take the departmental action against him. GPF gmount to minimum, so
department
void the repayment of loan could bring his gccount for the recovery of
The defauiter to account and his salary
to kindly attach his GPF
t is reguested
the loan.
With Regard

Place: DELHI
AKHILESHWAR JHA
Drafted By: ADVOCATE
SUPREME COURT OF INDIA (DHANANJAY SHAHI)
Under the instructions of Complainant
<br>

SUPREME COURT OF INDIA/DELHI HIGH COURTi


ENRT N. DI2861/2047 8CBA No. J/666
[Link]. p4AniePnremeFloak Gourt of india, New Delhl-110001
Ch. No.-768, Lawyerts Chamber Blook, Dwarka Sector10
Of,-Cum,-Resl. 38-B, 8G Pooket, DIlehad Garden, Delhi110098
Moblle no- 860714637, D868394921 Emall: [Link]@[Link]

Daled: 30.06.2025
SPEED POST

Ra) Ku:nàr Bhati,


S/o Latc Sh. Netrapal Srngh
R/o:E-268, GALI NO. 7,
ASHOK NAGAR SHAHDAR,
-
Delhi 110093,
Mobile Number: 880250)/20

LEGAL NOTICE

Subiect: A): LEGAL OTICE/DEMAND NOTICE FOR THE


RECOVERY OF HOUNT FOR WORTH Rs.
2,00,000/
ALONG WITH TE INTREST RATE OF
24o PERANNUM,
WHICH WAS GIN!N BY Mr. DHANANJAY SHAHI TO YOU
ON: ONE IN TH. YEAR 5.05.2021 which was Rs.
1,00,000/- AND, SECOND CONSECUTIVELY AND
SIMULTANEOUSLY IN THE ,YEAR 26.06.2021
WHICH WAS Rs. 1,00,000/;
B): LEGAL NOTICE FOR DEFAMING Mr. DHANANJAY
SHAHI AND HIS FAMILY MEMBERS NAMELY: ADARSH
SHAH, MUNNISHAHI, FURTHER WITH THE MALA
FIDE INTENTIONS T0 CAUSE LOSS AND HARM TO
THE GOODWILL, FOR DEFAMING, FOR CAUSING
DAMAGES, FOR SPOILING AND RUINING THE
TRUCKING BUSINESS NAME AND PRESENCE
WITHIN THE TERNITORY OF INDIA NATION, BY
WRITING THESNSE, MALICIOUS, SCANDALOUS,
VEXATIONS nN) FRIVOLOUS AVERMENTS AND
ALLEGATION NrO THE FALSE CIVIL AND
CRIMINAL COMI AINT,
<br>

C): LEGAL NOTICE FOR [Link] WORTH


Rs. 2,50,00,000/-.(TWO CRORE AND FFTY LACS)
FOR DEFAMING AND CAUSING HARM TO NAME AND
REPUTATION OF MR. DHANANJAY SHAHI AND TO
HIS TWO FAMILY MEMBERS AND TO HIS TRUCKING
BUSINESS GOODWILL AND REPUTATION BY FILLING
THE FALSE AND FRIVOLOUS CIVIL AND CRIMINAL
PROCEEDINGS BEFORE THE POLICE STATION JYOTI
NAGAR AND THEN BEFORE THE HON'BLE COURT OF
LAW, KARKARDOOMA DISTRICT AND SESSION
COURT.
Under the instruction and on behalf of my client Mr. Dhananjay Shahi
S/o Late Shri Vishvanath Shahi R/o A-2/ 469, Gali No. 21, Subhash
Kansal Marg, Harsh Vihar, Dclhi - 110093. I hereby serve upon you the
following legal notice:

1, That you Raj Kumar Bhati, (Hereinafter referred as the

"defaulter/noticee") is the government servant at Delhi Jal board.


That, you are being very well aware and known personality to the
family of Mr. Dhananjay Shahi (Hereinafter referred as the
"Client"). That you the defaulter is having the very deep root of
relation with Mr. Dhananjay Shahai since from the very earlier past
and you both are involvcd in past transactions as well in the earlier
past history.
2. That, youbcing the govcrnment servant it is expected from you to
show the good morals and conducts in the Society and due to
being the government servant people are having the faith and
reliance upon you, that Noticee will not cheat them or commit the
criminal breach of trust.
3. That you the defaulter in the month of May, 2021 had approached
to my client for the granl of loan for Rs. 1,00,000/- (Rupees One
<br>

lacs only) as you thc dcfaultcr have thc dire need for your wife
you
health and hospitaliy purposes during the period of Covid-19,
my client that if
the Noticee had provided the generous reason to
the amount is not urgontly ralsed as in the form of personal or
friendly loan from my clicnt then you the Defaulter/Noticee might
face the serious bereavcment into your family by death of wife due
to covid and lose some other relative else well who is near
and
dear to Noticee, which you the Noticee don't want to lose them at
that time.
4. That my client after considering the relation in
between Noticee
and him in the earlier past, and considering
the other factors like
you being the government servant,
coming from the well flourish
financial family, having the goodwill at
that time and showing faith
upon you, My above said client has developed the
sympathy and
determination to providc you
the defaulter on your ask the sum
of
Rs. 1,00,000/- only at that movement.

5. That, my client on vide dated 15.05.2021


has transferred using the
FT (Fund Transfer), NEFT as
the mode of payment the amount of
(Rs. 1,00,000/-) from account number
112705500538 to an
account of Noticec namncly Raj Kumar which is as per
the need of
defaulter was transferrcd by my client. That
the defaulter has
given the assurance tha the borrowed amount will
be repaid as
sOon as possible within the reasonable
time period along with the
market interest.
6. That, you the defauller again in the month of June, 2021 had
approached to my client with the new request of borrowing some
amount of money at his office which was earlier situated at DDA
<br>

k31

market, L Pockcl. Thal, ny clicnt has asked you to repay the


earlier borrowcd armournt first, thcn hc will consider whcther to
give you a fresh further loan, that you the defaulter/Noticee had
made a request to my client many times and asked for some time
to repay back an earlier loan which amounts to Rs. 1,00,000/
within some few months. That, by considering the false and empty

promise of defaulter, my clicnt has provided Noticee with another


loan amount.
7. That, you the defauller had again asked to my client to provide
you one another amounl of Rs. 1,00,000/- as debt, again you the

defaulter had shown an urgent need of money as there is the


market slow down and you' are facing the financial incapability to
repay back your borrowed amount due to Covid- 19 after effects
which noticee have raiscd from the variOus other different sources.
That you the Noticee have shown the generous need to my client

that you are facing the market pressure to: repay back the loan
which yOu had raiscd frorn lhe market.

8. That, my client again rclying upon your false statements and the
narratives had shown his determination and commitment to
provide you with another loan upon the implied guarantee and
understanding that you are the government employee will not
commit the breach of your promises. That vide dated 26.06.2021
my client had provided you on your
ask the amount of Rs.
1,00,000/- (Rupees Onc Lacs) through NEFT With reference ID:
557991729 from the currCnt account of Shahi Road Lines to yours
Banking Account of Ra; Kumar.
<br>

232
different various occasions had accer
Ihat, my client on two
3. relay dire need of the fundS
dcfaultet is in
the facts that you the any loan frorm
being unable to get to have
that you the Noticee is
fulfil your financiat
or have failcd to manage any debt to
anywhere
upon the
relying upon your goodwill and relying
heeds and after
gOvernment servant you will not
establish fact that Nolicco is the
your promise, my client had
Cheat or commit the brcach of
sum of Rs. 2,00,000/- as the
provided to you the total
fulfilling
personal/friendly loan amount. That, by not deliberately
your promise Noticee had cheated and commit the breach of
Mala Fide
promise upon my client with the dishonest and
intentions to case the wrongful loss to my client.
10. That, soon after the time passes away, you the defaulter
have had being in the consistent touch with my client and use to
visit the office of my clicent with the promise that you will pay the
debts which Noticee as the defaulter owes to my client. That the
total sum of Rs. 2,00,000/- (Rupees Two lacs) was raised by the
defaulter from my client, the amount of Rs. 2,00,000/- were the
hard earn money on my client and the amount Wwas raised from my
client at the time when the period of Covid-19 was on peak of its
term and my client by himself was in the need of money.
11, That, my client has faced the financial crunch due to false
assurances of Noticee torepay back the raised borrowed amount
on time and my client has suffered an immense loss in his
commercial activities by not fulfilling an expectation of his
commercial creditors.
funds, Ccepte
<br>

232

12. That, you aslthe lefaulter consistently making the false


promises and giving ennpty assurance through personal mceting
and through telephonic calls to repay back the borrowed amount
which you owe to my client. That the mneeting and negations have
resul into nothing clsc then the false promises.
13. That, since the two years has been passed away and now
you are not attending the phone calls of my client nor you have
shown your willingncss to meet my client since from last 6
months, hence the conduct of your is highly doubtful and you as
the defaulter deliberatcly avoiding the payment of my client who is
you Creditor and you arc under the liability and obligation to pay

of your debts as on time before the laps of three years since from
the date of first payment for each of the sanction loan/borrowed
amount in your favour.
14. That, my client has asked you to pay the amount of Rs.
2,00,000/- at the last rmeeting since then you are deliberate
avoidance the lawful demand of my client. That you are having the
mala fide intentions bocause you are deliberately avoiding the
paymert since frorn very long. That Noticee adverse conducts
establishes the fact that, even after passing on years my client is
requesting you at regular intervals for the repayment of Loan
amount i.e Rs. 2,00,000/- by personally and telephonically but you
the Noticee ncither reqponding to my client nor repaying his
money.

15. That, My Client also visited to your House and Government


Office on various occasion and several time for reminding noticee

the that he is bound lo make the repayment of the loan, however


<br>

one
day my Clicnt was
rcmaincd in shock when
you
directly rcfuscd to repay noticee
the loan amount to ny
clicnt and
threatcd him for diro
consCqucncos and you
pretext toolher arC the noticee on one
avoiding lo make
amount i.c Rs 2,00,000/-. he payment of the said loan
16. That you the nolicee
Intentionally and
repaying the loan/borrowcd deliberately not
amount to my
him and also clicnt and harassing
cheating him.
It is yourlability
above said payment to make/repay
to my client immediately. the
17, That rather than
of paying back your
Noticee had owes debts which yoU
to rmy client, you the
coming up have find the imbecilic way
with the false, by
Scandalous, vexatious,
fraud averments frivolous and
and allegations
civil proceedings
through your false
criminal and
against my client.
18. That you the Noticee
had used such grievous
written remarks imputation and
into your Civil pleadings
CPC and into your under the provision
criminal complaint of
which you had
section 175 (3) of BNSS filled under
against my client
of Law Karkardooma before the Hon'ble
Court
Court, Delhi.
That by filling the
criminal complaint false civil and
and drawing your
pleadings in such a manner
and, with such mala
fide intentions to cause
monetary loss my
client, to his family
members
to
and too his trucking
your imputations business. That
against my client has
my client caused the great harm to
reputation in the social
and business Society as your
written liable attacks upon
my client are
very well intentional and with
defined knowledge the
that if you spoil, defame
and ruin the
<br>

notiree

(235
credibility, of my chent
nd of his trucking business then his vhole
fanily will gct distunb
and sufler monclarily.
19. That you the Noticce with
the dishonest and with Mala
Fide
intentions has illegaly,
inationally, unrensonably
and illogically
harnmed the reputation of nny
clicnt and of his trucking
Business.
20. That you the Noticee acted in such a way
with an only
intention to cause a dircct loss
and, adversely affect
the trucking
business of my client. That your
conduct is highly irresponsible
and
the words and expressions which were
used by yOu in your civil
Pleadings and Criminal Complaint
is highly derogatory
remarks,
false allcgations and averments
which establish that you a
have
blameworthy mind, and you the
Noticee have shown such an
abrupt attitude toward my client with an
only intention to lead him
down into the society and to
destroy his trucking business.
21. That "My client, a distinguished
business man running
business of trucking throughout
the territory of India, has
established a reputablc name by doing
the hard work over the
uncounted days and nights in
the business community". That my
client is engaged into all
the lawful and reasonable business
transaction and, has the trucking business by
putting his
business technical how's which a
is secret deeds and, a
technical
Superiority of any successful
business. As a respected
man and a social business
activis, my client enjoys a high reputation
in civil
society, the corporate world,
and among his clients who are
present throughout
the territory of India. That my
client is having
the very fair experienceof running
the trucking business and have
<br>

"claim

236
founded a
successful chain of numbers of trucks for doing

lawful business with lawful means.

22. That you the Noticee have launched a malicious smear


campaign against my client by distorting, tinting and manipulating
the facts in such a manner that by somehow my client has
wrongfully raise the sum of Rs. 50 lacs from the 5 unknown
persons and has also cause the loss to
them and to the other
innocent people with the dishonest intention,
these hypothetical
unknown persons arc no one but
the part of your imagination.
That yOu the noticee with your written
versions in the legal
pleadings have persistently spread false
accusations against my
client that he has made his
wealth by the fraudulent ways,
your conducts are that
nothing but a deliberate attempt
to tarnish my
client social and business reputation. My
clients consider your
actions as defamation and demand
that you immediately cease
and desist from further harrming my
client's image. Your motives
appear to be self-serving,
seeking to gain unlawful and illegal
monetary gains by dishonesty and
hence you have furnished a
libel statements and narrative into your
false Plaint.
23. That further you the Noticee have used
the libellous terms of
phrase, averments and false contentions
against my client, his
family and against his, well reputed
and established business into
your plaint which run from para 7, 8, 9, 11, 12, 13, 14, 15
and 18
of the Paint.
"avoided payment by giving false assurance"
"thereafter start threatening the defendant to not come to
(them for repayment of his loan."
ng
<br>

the

"claiming to have links in higher ups in police and


administration start seriding goons and anti- social
-
clements to silent the Plaintiff and his family members"
"receiving dircct thrcats from the defendants, warning of
dire conscquences"
"Plaintiff was frightened and stunned to sec three well
built persons"
"carrying pistol like tire arm" "told other 2 persons in front
of Plaintiff that "ISKO BOL0 KI SAHI SAHAB KO

PARESHAN NA KARE OR APNE 13 LAC BHOOL JAYE, NAHI


TO APNIJAAN SE HATH DHO BAITHEGA"
"Plaintiff was frightened and could not dare or gathered
courage to approach the police to complaint"
"Defendant defrauded multiple/ many individuals in a
similar manner usingy same modus operandi and some of
the victims whorm tie defendants cheated in similar
manner are known t thhe Plaintiff"
Details of the 5 persurns provided which are as follows"
"namely "Shri. Vijay Kumar, Shri. Rajender Kumar,
Shri. Priyansh Raj Singh, Shri. Shubham Tyagi, Shri.
Akash Verma" and had illegally raised 50 Lacs from this
5 persons.
"modus operandi, dishohest intentions, to never repay the
same lured and subsequently refused payment, while
using threats and ínimidations"
<br>

means and
"amassed wealth through fraudulent
previously struggling
purchased many trucks despite
financially"
"defendants are habitual offender/cheaters of proportion
who continue to exploit innocent people with impunity"
"fraudulent activitics caused immense financial and
mental distress to numerous victims"
"that they are prevented from further defrauding more
individual"
"against conducts and acts of defendants,
plaintiff lodged
a written complaint
with SHO Jyoti Nagar P.S"
"defendants have withheld the plaintiff's
amount of Rs. 13
Lacs without any justification"
"hence liable to pay the amount along
with interest 24@
per annum"
"Despite several request made by
the Plaintiff, defendants
not refund his amount Rs. 13 Lacs"
"act, action and conduct of the
defendant are illegal and
unlawful"
"defendants cannot be permitted to
take the advantage of
their own wrong".
That the above mentioncd statements
and averments into your
plaint are extremely libelous as it is
hard to believe when their
prevails any relationship of "promisor and promisee" or
of "creditor
and debtor". When have you
the Noticee have provided any loan
of Rs. 13 Lacs to my client, when
does any agreement has been
executed into your favour, when does my
client has raised the sum
<br>

nd
have
(229

of Rs. 50 Lacs from 5 diferent persons,


when my client has
cheated any person and how hy client has
made the massive
wealth from the trucking busincss by commiting
and playing fraud
upon thc innocent pcoplc.

24. That you the Nolicee has made the false and scandalous
averments and allegations in the form of Libellous manner vwhich is
easily accessible to cach and every individual of the society and
COurt stalf, the wrillcn substance is in the form
of English
languagc which can be read by everyone. That you the Noticee
have initiated the falsc civil and criminal proceedings against my

Client with the only solc purpose and objective to damage and
harm his expending and progressive trucking business.
25. All the above staled by my Client are validated with a dossier
:
of evidence provided hercin for their claims
3
EVIDENCE (provided by my client)
1. Transaction for Rs. 1,00,000/- vide dated 15.05.2021
2. Transaction for Rs. 1,00,000/- vide dated 26.06.2021

3. Legal notice send cri 13.06.2023.


4. Screen shoot of legai notice send to you on your what app
no. 8802607920.
5. False and scandalous civil plaint and
criminal complaints
before the various [Link].
6. Criminal complaint vide dated 19.10.2024.

That it is fairly establishcd by the above


stated dossier that the you
the noticee to avoided lhe Repayment
of the Personal/friendly Loan
to my client you havc conc up
with the false litigation with the only
purpose to bring the financial
burden and stresS upon the client. That
<br>

you the Noticee is very wcll awarc of the facts that you had raised

the personal loan for worth Rs. 2,00,000/- from my client and the
same transition is very well Supporled by the bank account to bank
account transaction through and by
the way of NEFT which my client
did in the yours favour and
hence you thc Noticee is under
the
liability to pay off the loan you
which had raiscd from my client one in
the Year 2020 which is for worth RS.
1,00,000/- and another in
year 2021 which is the
for worth Rs. 1,00,000/-,
apart from this two
transactions my client
has never did any other
transaction in yours
favour. That my
client further mentions
that you the Noticce just to
avoid your liability which you owes
to my client, you
the Noticee have
Come up with
the counter blast false criminal
and civil suit through
which you the Noticee
has tried to come up with all
fraud claims which could not the false and
be explained or does not
sanctity in the eye of law. That, you have any
the Noticee is very well aware of
the fact that you are having the previous
pending liabilities of Rs.
2,00,000/- against my client since
from the year 2021 to
2025, that
the my client further submits that you
the Noticee just to avoid his
liability which you owes to
the my client has Come up with
the
cOunter blast false criminal
and civil suit through which you
the
Noticee has tried to come up with
all the false and fraud claims
which
could not be explained or
does not have any sanctity in
the eye of
law. That you
the Noticee has hidden and
suppressed the
materialistic fact from the Hon'ble
Court of law that you were aware
of your liability which you owes
toward the my client which is of Rs.
2,00,000/- which had brought
into your knowledge
through 2
my tyou
<br>

client
had
and raised

hank the Slierent Notices which was


served upon you the
Noticee at 2
différeht point of timc.

26. That, you the Nolicee


have the direct contact
with my Client and relations
and Noticce had on
the various oCcasions
accesscd to my clicnt have
for borrowing the money
as debt and mny of Rs. 2,00,000/
client has provide
the personal loan into your
favour through
the NEFT which my client
using the various had made through by
modc of direct fund
account to Bank Accoun. transitions from bank

27. Then the above (wo


transaction which took
dated 15.05.2021 place on vide
and 26.06.2021 establishes
Noticec had received that you the
thc amount of Rs. 1,00,000/-
amount for worth Rs. and another
1,00,000/ as debt in your
bank acCOunt, as favour at your
the borrowed money or personal
friendly loan on
the promise tO repay it back to my
client as sOon as possible
the reasonable time. within
28. That since you the Noticee
has made the derogatory,
unreasonable, illogical
and misleading statement
against my client
with the only purpose
and with mala fide intentions
to ruined,
spoiled and defame my
client name and goodwill
commercial markel in the
and society, that you are
knowledge that how to use being very well
the technological gadgets
media platform; the high and social
responsible attitude is
part in which you expected on your
being as the responsible
completely failed, you citizen has been
the Noticee have completely
maintain the dignily failed to
and privacy of my client,
hence now you are
under the legal obligaton
and burden to make
good to my client
<br>

Cc

by compcnsating him in lhe monctary terms for worth Re


2,50,00,000/- (Two rorc and Ffty Lacs. ) for loss and darnages
which you have causcd to his name and his goodwill,
It is
expected from you he Noticee that you will compensate Imy
client
within the reasonable time failing upon
which my client will have
no other option thcn to initiale the criminal
defamation
proceedings against you before the court
of law.
29. However, you thC, Noticce
have not responded in the
conducive manner. Several
opportunitics have been provided
to
Noticee to fulfil the obligation
in spite of so many
opportunities
you have miserably
failcd to perform your promise
and committed
the deliberate and intentional
breach of your promise
committed the cheating by and
showing the dishonesty
by not making
the timely payment, by causing
the intentional wrongful loss to my
client and enjoying
the amount of Rs. 2,00,000/- as
the wrongful
gain. In this regard, I hereby
direct you through this legal
notice to
make the duly payment
of your debts within 15
days from
receiving of this legal notice
which you owe tO your
creditor Mr.
Dhananjay Shahi which is worth
amount Rs. 2,00,000/- in
total
along with an interest of @
24% per annum, on the failure
of
which my client namely Mr. Dhananjay
will be constrained to
take
suitable action under Law by filing
the case with the appropriate
COurt of law, at your cost,
risk and consequences. It is
clarified
that all action can be taken against you
the Noticee like lodging of
FIR and etc. for your
bad deeds and also take any other recourse
which is available in law.
<br>

(243
A
CODy of thc noticc is bcing rclaincd at Our office for future

refcrencc and use and arn ürriount of Rs 21,00,000/- (Twenty One


Lacs. Rupccs) is chargcable upon you as the cost of this legal notice.

So, please note and act sccordingly,

Youarc undcr lcgal Nolico


AKHILESHWAF JUS
COURT
NO: With Regard
SC8AHIGH
ERBLOCK
SCa
INOIAIDELHI
Dr112017
Placc: DELHI vÖCATE)
(ADVOCNO. OF e5114537
T
COU
SU SUPREVE Mcb.

Advocate: AKHILESHWAR JHA.

NOTE: A copy of this Legal Nolice is being retained for


future purpose
and use.

Ihanking you.
<br>

TN 7HLCoupT S. NHARTASHARMA, (244 244 ANNEXURC


LD. SLNIOR
CUIL JUoaL, SHAHD APA PISTRICT, No:P|21

(oRICI NAL SPEsP PosT RCiIRT)

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ANNEXURS NO.;

P27
SUCCESS
The transaction with Reference ID 536005740 is
processed successfully.

From Mocde Of Paynent

112705500538 FT(Fund Transfer),


NEFT

To Account Amouni
RAJKUMAR INR 1,00,000

Iransaction Dut: Transaction time


15-05-2021 2:20 PM

Download Receipt

The smoner and aster way


to Pay bills now becomes GEI
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7200
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SEND RECEIPT TO ADD TO FAVOURITE


BENEFICIARY
<br>

Payment Summary

Payment of INR 1,00,000.00 to RAJKUMAR

Reference ID: 557991729

To Account: RAJKUMAR

From AccOunt: SHAHIROAD LINES

Amount: INR 1,00,000.00

Payment Date(dd/MMlyyyy): 26/06/2021

Network: NEFT

Manual Release Required: No

Transaction Status: Success


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BXZ
ie NCT orp DELHI COURT FE!
DLCT1235579G2513P
= 42-JUL-2025

TT
IN THE COURT OF | HOW'BLE
SENTOR CIVIL
a - , . JUDGE, (DISTRICT SHAHDARA),
KARKARDOOMA DISTRICT COURT, DELHI
CS CASE No. /2025
IN THE MATTER OF:
Mr. AKHILESHWAR JHA ...PLAINTIFF
VERSUS
Mr. DHANANJAY SHAHI & O RS. ...DEFENDENT
APPLICATION UNDER SECTION 151 OF THE CODE OF
CIVIL PROCEDURE, 1908 ON BEHALF OF THE PLAINTIFEF/
APPLICANT SEEKING EXEMPTION FROM FILING THE
ORIGINAL/ TRUE TYPE COPY OR TRUE TYPE COPY OF
THE ANNEXURES ALONG WITH AFFIDAVIT.
MOST RESPECTFULLY SHOWETH:

1: That the present suit filed on the behalf of the plaintiff is


not maintainable either in facts or in law. All contents and
averments in the written statement and counter claims
filed on behalf of the answering defendant may be read as
a part hereof. That the Plaintiff has filed the accompanying
Plaint filed on behalf of the Plaint against the Defendants
along with certain documents annexed thereof. The
accompanying Plaint filed on behalf of the Plaintiff are
i FAMUIKEY Fe Succeed as per the grounds stated therein. The
’ Plaintiff°crave liberty of this Hon'ble Court to refer to and
Tes ceSSchtY pen sthe contents of the accompanying Plaint filed on
behalf of the Plaintiff with documents filed therein as the
same are not reiterated herein for the sake of brevity.
IN That on account of urgency in the mat.-, the
Plaintiff/Applicant been unable to get the copies of the
annexures typed and filed in respect of illegible and/or
<br>

2s3
dim documents filed as annexures to the accompanying
Plaint filed on his behalf. However, the Plaintiff undertakes
to file them as and when directed by this Hon'ble Court.
3: That the Plaintiff, therefore, pray for being exempted from
filing original as well as typed copy/ies of the annexures
and be allowed to file true copy/ies and/or print/s of the
same and the same may be taken on record as Such.
4: That the present application is made bona fide and in the
interest of justice.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble
Court may most graciously be pleased to:
a. Exempt the Plaintiff / Applicant herein from filing original,
true typed copies of the annexures filed along with the
Plaint against the Defendants, and/or
b. Pass any other order(s)/direction(s) which may be
deemed appropriate may also be granted in favour of the
Plaintiff and in the interest of justice.

IT IS PRAYED ACCORDINGLY.

PLAINTIFF
AKHILESHWAR JHA
Place: DELHI
DATED 29.8.2025 SOLANK
KUMAR (BA, 1
SAURÁBH OF INDIA
SUPREME COURT
Sec 82 NORRAPURAM
THROUGH Ch. No. 202 RRHAND 1,IN
1

[Link]
1057,1
E-mall :
9456934987
Mob.:

[Binay Kumar and Saurabh Kumar


Solanki & ASSOT.]
ADVOCATE FOR THE PLAINTIFF
E-506, KKD COURT, DELHI
Mobile No. 9560714537
E mail: akhilno.2@[Link],
Cs)
IN THE COURT OF HowBL¢ SENDTOR? CEVIL
a _. . JUDGE, (DISTRICT SHAHDARA),
KARKARDOOMA DISTRICT COURT, DELHI
CS CASE No. /2025

IN THE MATTER OF:


Mr. AKHILESHWAR JHA ...PLAINTIFF
VERSUS
Mr. DHANANJAY SHAHI & O RS. ...DEFENDENTS
AFFIDAVIT
I, Akhileshwar Jha S/o Shri Mukteshwar Jha age about _30
years R/o: 38-B, SG Pocket, Dilshad Garden, Delhi - 110095,
presently at New Delhi, do hereby solemnly affirms and state
on oath as following:
1. That, I am the Plaintiff in the above noted case and well
conversant with the facts and circumstance of the case
and I am therefore competent to swear to this affidavit.
[Link] the Contents of accompanying application under
section 151 of the Code Of Civil Procedure, 1908 on behalf
of the Plaintiff Application seeking exemption from filing
the original/ true type copy or true type copy the
annexures has been drafted by my counsel under my
instructions and the same are true and correct.

&
°
VERIFICATION 25 AUG 2025
il
DEPONENT

4 eeEPONENT
ATTEST
NOTARY PUBLIC DELHI
Govt. dia
MAR. HRAHTRERER
IN THE COURT OF //aw’3cge SENTOR GIVIL
_ . 7: JUDGE, (DISTRICT SHAHDARA),
KARKARDOOMA DISTRICT COURT, DELHI
CS CASE No. /2025
IN THE MATTER OF:
Mr. AKHILESHWAR JHA
_ PLAINTE FF
VERSUS
Mr. DHANANJAY SHAHI & ORS. ...DEFENDENTS
CERTIFICATE UNDER SECTION 63 (4) OF THE BHARATIYA
SAKSHYA ADHINIYAM, 2023 ON BEHALF OF THE
PLAINTIFF

I, Akhileshwar Jha S/o Shri Mukteshwar Jha age about _30


years R/o: 38-B, SG Pocket, Dilshad Garden, Delhi — 110095,
presently at New Delhi, do hereby solemnly affirms and state
on oath as following:
1: That I am the Plaintiff in the present case. As such, I am
competent to swear the present certificate.
2: That the accompanying Plaint has been drafted by my
counsel under my instructions and the contents of the
same are true and correct as per my personal knowledge
and based on documents available with me which include
What’s App messages, emails and other electronic records
derived and printed from the source without altering or
manipulating the same in any manner.
3: That copy of the afore-said documents along with all other
<br>

(2s6
me from my laptop/computer/mobile phone/electronic
device which have been and are working efficiently before,
at the time of or subsequent to retrieving the documents
electronically or taking the print outs of the same for the
purpose of filing my present Plaint against the
Defendants. Such electronic device has been in my
exclusive power, possession, control and usage and there
is no tampering of either such device or the information

retrieved for the purpose of making documents to be filed


as documents to Plaint against the Defendants.
4: That the print outs/ print reproduction of all such
documents has been taken/done by me, the contents
whereof are the ex-act reproduction of the original
same
information stored on source, as afore-said. The
in any
have not been tampered with or manipulated
manner whatsoever.
my Plaint against the
5: Those documents form a part of
Defendants and be taken on record as such.
6ARA
K. BANPANA
Rogn. Dalf.
Dat6
DEPONENT
260eICATION
of inVerified at Delhi on thé5 AU6 Zay of August, 2025 that
are true and correct to my
contents of this affidavit
th
knowledge and behalf and nothing has been concealed
therefrom.
IDENTTFLED
DEPONENT
ATTETBDELHI
NOTARY PUIC
Govt. ghdia
gT1 Sut 257
NCT OF DELHI COURT FEE.
err bucTasosec9szs02a = |
FIRE NOS iasccreacecdsnitiesecess CoN
UL-2025
ssccsseces :
ao wy 1

—th vu apart neaist peed


UA 1AM Wn Sie ee

/ . =

IN THE COURT OF Hov'OLs SC HE OR CI VIt iA Lh tp) rte [Del


Suit / Appeal No. C8 we: LZOLSe JURISDICTION OF 202
In re: -
17. ALHEL ES Bb Hf -— THe Cheleorat ) Plaintiff(s)_o, Petitioner(s)
Appelfant(s) | Complainant(s)
VERSUS
fh hic] doy Kh oat ca OVS. Defendant(s) / Respondent(s) / Accused

KNOW ALL to‘whom vhs Present shall a that! / We VILLA hare - Pes Lo -W8 B Gt: Lait,

Lilbludl (rwedlea, Mi ble~ e0t


The above named VLE GLES Gitlh pe = Ld, Ce ha ty do: hareby angotit
Binay Komanr ( B/2 0161 rel) “ae
SUNIL KUMAR
0-654/2018
TOMAR i a of
Enrol. No. ADVOCATE .
SUPREME COURT OF INDIA VIRENDRA MOHAN ein
patterecalledmtaladvdcate/s) to bi CURE
Office : F-1?reresina ROG Se BIN ths Above -nfe}
Ph.: 011 ~AS0BSFE caer the abovenetsheadsia, HiRcBis Ondmany OMe court in hig sa
Email
also’ in the appella' nat lading High cone Pneat Bae: 4603 Separately for each purely a
To sign file, verify and present pleading: pe alg EVO 583 BBjections. or ‘petitions tor executions review,
revision, withdrawal, compromise or other petitions or affidavits or other documents as may be deemed necessary or
proper for the prosecution of the said case in all its stages subjects to payment of fees for each stage.
To file and take back documents, to admit and/or deny the documents of opposite party.

To withdraw or compromise the said case or submit to arbitration any differences or disputes
that may arise touching or in any manner relating to the said case.
To take execution proceedings on paying separate fee.
To deposit, draw and receive money, cheques, cash and grant receipts hereof and to do all other acts and things
which may be necessary to be done for the progress and in the course of the prosecution on the said case. ;
To appoint and instruct any other Legal Practitioner authorising him to exercise the power and authority ia )
hereby conferred upon the Advocate whenever he may think fit to do so and to sign the power of attorney on our behalf. Ke Mires
And I/We the undersigned do hereby agree to ratify and confirm all acts -done by the Advocate or his Soe dhuite
in the matter as my/our own acts, as if done by me/us to all intents and purpose.
And I/We undertake that I/We or my/our duly authorised agent would appear in court on all hearings and will in for
m the Advocate for appearance when the case is called. :
And I/We undersigned do hereby agree not to hold the advocate or his substitute responsible for the result of the said case.
The adjournment costs whenever ordered by the court shal! be of the Advocate which he shall receive and retain for himself.
And We undersigned do hereby agree that in the event of the whole or part of the fee agreed by me/us te be paid to the
advocate remaining unpaid he shall be entitled to withdraw from the prosecution of the said case until the same is paid up.
The fee settle is om, for the above case and above Court. / We hereby agree that once the fee is paid, | / We will not be entitled
for the refund of the same in any case whatsoever and if the case prolongs for more than 3 years the original fee shall be paid again by me/ us.
IN WITNESS WHERE OF I/ We do hereunto set my/our hand to these presents the contents of which have been understood
by me/us on this .. Jeol day of Pen
Nectaraccsstbeond aarti! 202 Accepted subject to the terms of the fees.

err”, I Identify The Signature/


pe
Thumb Impression Of Below Mentioned Person,
ES
Whe Has Been Signed In My Presence. The Client.

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