IN THE HON’BLE HIGH COURT OF DELHI AT DELHI
C.M.(M) NO…………………… OF 2018
IN
EXECUTION PETITION NO 164/2017
IN THE MATTER OF:
M/s S&S Technocrate (P) Ltd ……….Petitioner
Versus
Shri Rathi Steel Ltd …………Respondent
REJOINDER ON BEHALF OF PETITINER TO THE REPLY
FILED BY THE RESPONDENT NO.1.
MOST RESPECTFULLY SHOWETH:-
Preliminary submissions:
1. It is at the outset humbly submitted that Decree Holder has
filed a 7 page reply which does not contain any specific
reasoning for the payment. The DDA has to be impleaded, in
order to, avoid multiplicity of proceedings.
REPLY TO PRELIMINARY OBJECTIONS:-
2. That the contents of Para No.1 to 3 of preliminary objection
of the Reply are absolutely wrong and hence the same are
vehemently denied. It is specifically denied that no cause or
occasion for the Applicant to file the present application, the
present application is gross abuse misuse of the process of
law. hence the application of the applicant is liable to be
dismissed.
REJOINDER TO THE PARAWISE REPLY:
1. That the contents of para 1 to 7 of the para wise reply so
far as it does not admit of the contents of corresponding
para of the application are wrong and denied and the
contents of corresponding para of the application are re-
asserted and reiterated.
2. That the contents of Para No. 8 of the para wise reply is
absolutely wrong and hence the same are vehemently
denied. It is submitted that the calculation sheet
submitted by the respondent is wrong and hence merit no
response.
3. That the contents of para 9 of the para wise reply so far
as it does not admit of the contents of corresponding para
of the application are wrong and denied and the contents
of corresponding para of the application are re-asserted
and reiterated.
REJOINDER TO REPLY TO THE GROUNDS:
1. That the contents of para A of the grounds so far as it
does not admit of the contents of corresponding para of
the application are wrong and denied and the contents
of corresponding para of the application are re-asserted
and reiterated.
2. That the contents of para B of the grounds so far as it
does not admit of the contents of corresponding para of
the application are wrong and denied and the contents
of corresponding para of the application are re-asserted
and reiterated.
3. That the contents of para C of the grounds so far as it
does not admit of the contents of corresponding para of
the application are wrong and denied and the contents
of corresponding para of the application are re-asserted
and reiterated.
4. That the contents of para D of the grounds so far as it
does not admit of the contents of corresponding para of
the application are wrong and denied and the contents
of corresponding para of the application are re-asserted
and reiterated.
5. That the contents of para E to F of the grounds so far as
it does not admit of the contents of corresponding para
of the application are wrong and denied and the
contents of corresponding para of the application are
re-asserted and reiterated
6. That the contents of para G to I of the grounds so far as
it does not admit of the contents of corresponding para
of the application are wrong and denied and the
contents of corresponding para of the application are
re-asserted and reiterated.
7. That the contents of para J of the grounds so far as it
does not admit of the contents of corresponding para of
the application are wrong and denied and the contents
of corresponding para of the application are re-asserted
and reiterated.
8. That the contents of para 10 to 12 of the grounds so far
as it does not admit of the contents of corresponding
para of the application are wrong and denied and the
contents of corresponding para of the application are
re-asserted and reiterated.
9. That the contents of reply to Prayer clause are
absolutely wrong and hence the same are vehemently
denied. On the contrary it is respectfully submitted that
the prayer made in the corresponding prayer clause of
the complaint are reiterated as correct.
PRAYER
Last Para of the reply is a prayer to this Hon’ble
Court which merits no consideration. On the
contrary the complainant prays before this Hon’ble
Court that the relief prayed in the complaint may
kindly be granted in favour of the complainant and
against the opposite party.
New Delhi Petitiner through
Counsels
Filed on: