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/defendant under Or.14 R.2 and 151 of CPC.
For the reasons stated in the accompanying affidavit, the petitioner respectfully prays that this Hon’ble Court may be pleased to try the issue, “Whether this court has territorial jurisdiction to try the suit”, as a preliminary issue, and to pass such other orders as this Hon’ble Court deems fit and proper in the circumstances and in the interest of justice.
Place: New Delhi
Date: 6th June 2025
Advocate for Petitioner
IN THE COURT OF THE CITY CIVIL JUDGE, NEW DELHI
I.A. No. 23/2025 in O.S. No. 1024/2024
Neha Sharma
…Plaintiff
Vs.
Arjun Kumar
…Defendant
Affidavit
I, Arjun Kumar, S/o Ramesh Kumar, Hindu, aged about 35 years, Businessman, residing at 123, Green Park, New Delhi, do hereby solemnly affirm and state on oath as follows:
- I am the defendant in the above suit and the petitioner herein, and I am well acquainted with the facts of the case.
- The plaintiff/respondent has filed the present suit for declaration that her termination from service is illegal and for a mandatory injunction. I have already filed my written statement, and the contents of the same may be read as part and parcel of this affidavit.
- I respectfully submit that this Hon’ble Court has no territorial jurisdiction to entertain or try this suit. The cause of action and relevant transactions, as explained in the written statement, occurred outside the jurisdiction of this court.
- If the court proceeds with the trial without first determining the jurisdictional objection, valuable judicial time will be wasted and I, as the defendant, will be put through unnecessary hardship.
- It is, therefore, just and necessary that the Hon’ble Court decide the following as a preliminary issue: “Whether this Court has territorial jurisdiction to try the suit.”
Hence, I respectfully pray that the Hon’ble Court may be pleased to take up and decide the above issue as a preliminary issue before proceeding with the trial of the case.
Failing which, I will be put to irreparable loss.
Deponent
(Arjun Kumar)
Solemnly affirmed and the contents of the affidavit were read over to the deponent and explained in Telugu, and he admitted them to be true and correct and signed before me on this the 6th day of June 2025.
Place: New Delhi
Date: 6th June 2025
Advocate