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: