IN THE COURT OF THE CITY CIVIL JUDGE, NEW DELHI
I.A. No. 23/2025 in O.S. No. 1024/2024
Arjun Kumar
…Petitioner/Defendant
Vs.
Neha Sharma
…Respondent/Plaintiff
Petition filed on behalf of the petitioner/plaintiff under Or. 38 R. 5 and 151 of CPC.
For the reasons stated in the accompanying affidavit, the petitioner prays that this Hon’ble Court may be pleased to:
- Direct the respondent/defendant to furnish adequate security for the suit amount and costs,
- In case of failure, order attachment before judgment of the petition schedule property (movable/immovable),
- And to pass such other and further orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and in the interest of justice.
Place: Hyderabad
Date: 12th June 2025
Advocate for the Petitioner
IN THE COURT OF THE CITY CIVIL JUDGE, NEW DELHI
I.A. No. 23/2025 in O.S. No. 1024/2024
Arjun Kumar
…Petitioner/Defendant
Vs.
Neha Sharma
…Respondent/Plaintiff
Affidavit
I, Rajesh Verma, S/o Krishna Verma, Religion: Hindu, aged about 42 years, Occupation: Trader, R/o Flat No. 14-B, Lake View Apartments, Hyderabad, do hereby solemnly affirm and state as follows:
- I am the plaintiff in the above suit and the petitioner herein. I am well acquainted with the facts of the case.
- I filed the present suit for recovery of Rs. 2,00,000/- along with interest @18% p.a. on the basis of a pronote executed by the defendant on 10th January 2023, towards a loan taken for family needs. The defendant agreed to repay the same on demand either to me or to my order. Despite repeated oral demands and issuance of a registered legal notice dated 15th February 2024, the defendant has not repaid the amount.
- The defendant has acknowledged the debt but continues to avoid payment. Recently, I came to know that the defendant is trying to alienate the petition schedule immovable property in favour of his relatives without consideration, with a view to defraud me and other creditors. This alienation is intended to frustrate any decree that may be passed in my favour and delay its execution.
- If notice is given, there is every possibility that the defendant will transfer or dispose of the property, thereby making it impossible for me to recover the decretal amount.
- Hence, I pray that this Hon’ble Court may be pleased to:
- Direct conditional attachment of the petition schedule property before judgment,
- And pass such other order(s) in the interest of justice.
Else, I will be put to irreparable loss and hardship.
Deponent: Rajesh Verma
Solemnly affirmed and the contents of this affidavit were read over and explained in Telugu to the deponent, who admitted them to be true and correct, and affixed his signature/thumb impression before me on this the 12th day of June 2025.
Place: Hyderabad
Date: 12th June 2025
Advocate