IN THE HONBLE HIGH COURT AT CHENNAI O.S. No.

OF 2010

MR.RAMU, C/O. V.O. OFFICE, 2ND KAVIDI STREET, THANDUMARIAMMAN KOVIL OPPS, CHENNAI 602 101 PLAINTIFF Vs. MR. SOMU DOOR NO.4, MARIAMMAN KOVIL STREET, MANGADU, CHENNAI 602 101 DEFENDANT

WRITTEN STATEMENT FILED UNDER ORDER VIII RULE I OF CPC:

S. Deepak ram,B.A., B.L., (Hons)

COUNSEL FOR DEFENDANT.

IN THE HONBLE HIGH COURT AT CHENNAI O.S. No. OF 2010

MR.RAMU, C/O. V.O. OFFICE, 2ND KAVIDI STREET, THANDUMARIAMMAN KOVIL OPPS, CHENNAI 602 101 Vs. MR. SOMU DOOR NO.4, MARIAMMAN KOVIL STREET, MANGADU, CHENNAI 602 101

PLAINTIFF

DEFENDANT

WRITTEN STATEMENT FILED UNDER ORDER VIII RULE I OF CPC:

1. The address for service of all notices and processes on the Defendant is that of his counsels M/s. S. Deepak Ram, at No. 449 New Addl. Law Chambers High Court Buildings Chennai 600 104. 2. The Defendant is Mr. Somu ,residing at Door No.4, Mariamman Kovil Street, Mangadu, Chennai 602 101 3. The Plaintiff is Mr. Ramu, son of Siva , aged about 67 years, residing at C/O. V.O. Office, Door No.3, Mariamman Kovil Street, Mangadu, Chennai 602 101 4. The Defendant submits that he is the absolute and present owner of the schedule mentioned land . 5. The Defendant submits that he has purchased the said land which is adjacent to Plaintiffs property and he also states that he has got approval to construct building over the land and he also attaches the copy of approval document herewith. 6. It is humbly submitted that, plaintiff has falsely pleaded in plaint para 6 and defendant denies it by stating that defendant doesnt make any unauthorised construction and also he denies the fact that he doesnt use any filthy, unparlimentary and abusive language towards the Plaintiff and further informed that he didnot make the construction in detriment to the Plaintiffs compound wall and building . 7. The defendant denies para 7 of plaint by stating that the Defendant didnt interfere in the said compound wall according to his own whims and fancy.

8. The defendant denies para 10 of plaint by stating that the building proposed by the Defendant doesnt cause damage to the Plaintiffs compound wall and thus charge made by them are false. 9. Therefore the defendant prays and humbly submits that this Honble Court may be pleased to record my observations and therefore prays for a Judgment and Decree:1. For the cost for creating mental agony due to false accusation and also for causing hindrance to defendant in construction of building in his land. 2. For the cost of the suit. 3. Pass any such order or orders as it may deem fit and proper in the circumstances of the case and thus render justice. Dated at Chennai on this 26th day of January, 2014. VERIFICATION I, Somu, the defendant herein do hereby declare that whatever stated above in paragraphs 1 to 13 are true and correct to the best of my knowledge. Verified at Chennai on this 10th day of September 2013 DEFENDANT COMMON SCHEDULE OF THE PROPERTY All that piece and parcel of land situated within the Registration District of North Chennai and Sub-Registration District of Purasawalkam, Namazhvarpettai, Subburayan 5th Street ; Within which land comprising of 19 feet East-West wards and 112 feet North-South wards totaling 2,128 sq.ft. of land having Old Survey No.650 to 653 and 688/A and New Survey No.2914/9 Part as per Patta. Verified at Chennai on this 26th day of January, 2014. DEFENDANT

DOCUMENTS FILED UNDER ORDER VII RULE 14(1) CPC

S.NO 1. 2. 3. 4. 5. 6.

DATE 09.08.1980 21.09.1981 21.09.1981 12.09.2010 10-11-2013 11-11-2013

DESCRIPTION OF THE DOCUMENT Sale Deed in favour of the Defendant Patta issued by Thasildhar, Purasawalkam, infavour of the Defendant Patta issued by Thasildhar, Purasawalkam, infavour of the defendant and 2 others for common pathway area. Document of approval to built building over the said land Complaint lodged by the defendant Acknowledgement from Police station

NATURE Copy Copy Copy Copy Copy Copy

STATEMENT OF ADDRESS UNDER ORDER VI RULE 14(A) CPC

Name & address of the plaintiff

Mr.Ramu, C/O. V.O. Office, 2nd Kavidi street, Thandumariamman Kovil opps, Chennai 602 101 Mr. Somu Door No.4, Mariamman Kovil Street, Mangadu, Chennai 602 101

Name & address of the defendant

Dated at Chennai on this 26th day of January, 2014.

DEFENDANT VERIFICATION

I, Somu , the defendant herein do hereby declare that whatever stated above in documents and statement columns are true and correct to the best of my knowledge and belief. Verified at Chennai on this 26th day of January, 2014. DEFENDANT