court letter sep

7/30/2019 Court Letter Sep

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IN THE COURT OF THE DISTRICT MUNSIF COURTCHENGALPET

O.S. No.282/2009

1. Thiru. Padmanabhan2. Thiru. Prakash3. Thiru. Suresh - Plaintiffs

- VS-

1. State of Tamil Nadu representedBy The Secretary to Government

Transport Department, Saint George Fort,Chennai 9. - Defendants

and two others

WRITTEN STATEMENT FILED BY THE 1ST DEFENDANT

1. The suit filed by the plaintiffs for declaration to declare the suit properly

and permanent injunction as against the dependents is not maintainable in

law and on facts of the case.

2. The allegations contained in the plaintiff are hereby specifically denied and

put the plaintiff to strict proof of the same.

3. This defendant devices, various allegations contain in the plaint and put to

the plaintiff to strict proof of the same.

4. The defendant submits that the Highways and Rural works and National

Highways are controlled by The secretary, Transport Department,Government of Tamil Nadu since 20 years back. Now Highways and

National Highways are controlled by The secretary, Highways and minor

ports, Government of Tamil Nadu St. George Fort Chennai 9.


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5. The defendant submits that the plaintiffs unnecessarily included the first

defendant as a party in this suit and the first defendant is no way

connected with this suit.

6. The defendant submits that the suit is without notice under section 80C.P.C which is not maintainable.

7. The defendant, submits that there is no cause of action for filing the suit as

frame the 1st dependent as mis jointer and for the reason of mis jointer the

suit is not correct.

8. The defendant submits that the Secretary, Highways and Minor ports,

Government of Tamil Nadu, St. George Fort, Chennai 9 may be included

as a first Dependent in this suit in lieu of me. Since he is the necessary

party in the suit and this control the High way, National Highways and

Minor Ports.

9. The defendant is not a necessary party to the suit and this suit is not

properly described in order and not included the necessary party. Hence

pray that the suit may be dismissed without cost.

Secretary TransportGovernment of Tamil Nadu

Chennai 9.

DECLARATION

I Thiru. Age The secretary Transport

Department Government of Tamil Nadu here by declare that the fact

stated above are true to the best of my knowledge information, behalf and

sign this at chengalpattu on .09.2012.

Secretary TransportGovernment of Tamil Nadu

Chennai 9.


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IN THE COUR8T OF THE DISTRICT MUNSIF COURTCHENGALPET

O.S. No.282/2009

1. Thiru. Padmanabhan2. Thiru. Prakash3. Thiru. Suresh - Plaintiffs

- VS-

1. State of Tamil Nadu represented.

By Secretary to GovernmentTransport Department, Saint George Fort,Chennai 9. - Defendants

and two others

AFFIDAVIT FILED BY THE 1ST DEFENDANT

I Thiru. Age The Secretary, Transport

Department The Government of TamilNadu, Chennai 9 do hereby solemnly

afford sincerely as follows.

1. I am petitioner here in and first defendant in the above suit.

2. I submit that the above suit was filed by the plaintiff and two others here

in against Transport Department of The Government of TamilNadu for

getting the relief of declaration. Due to non filling of written statement I

was set exparte this is neither willfull nor wanted on. Hence by with filing

the written statement, hereby I pray that to set aside this exparte order

passed against me on.


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3. I therefore pray that the Honorable court may be pleased to set aside the

exparte order passed against me on and to pass such other suitable

order.

The Secretary, Transport DepartmentGovernment of Tamil Nadu

Chennai 9.

Solemnly affirmed and signed before me at Chengalpattu and day

of September 2012

Advocate for defendant


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IN THE COURT OF THE DISTRICT MUNSIF COURTCHENGALPET

O.S. No.282/2009

1. State of Tamil Nadu representedBy the Secretary to GovernmentTransport Department, Saint George Fort, - Petitioner Chennai 9.

1st Defendant

- VS -

1. Thiru. Padmanabhan2. Thiru. Prakash3. Thiru. Suresh - Defendants

PETITION FILLED UNDER ORDER 9 RULE 7 AND SECTION 151 C.P.C

For the reason stated in the accompany affidavit it is prayed that the

Honorable court may be please of set aside the exparte order passed against

the petitioner / on and to pass such other suitable order.

Dated as Chengalpattu on

Advocate for defendant


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IN THE COURT OF THEHONORABLEDISTRICT MUNISIF COURTCHENGALPATTU

1. State of Tamil NadurepresentedBy the Secretary toGovernmentTransport Department, SaintGeorge Fort, -PetitionerChennai 9.

1st Defendant

- VS -

1. Thiru. Padmanabhan2. Thiru. Prakash

3. Thiru. Suresh

- Defendants

PETITION FILLED UNDER ORDER9 RULE 7 AND SECTION 151C.P.C.

COUNCIL PETITION DEFENDANT


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AFFIDAVIT FILLED BY THE 1ST

DEFENDANT SECRETAYTRANSPORT GOVERNMENT OFTAMIL NADU



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1. Thiru. Padmanabhan2. Thiru. Prakash3. Thiru. Suresh

- P laintiffs

- VS-

1. State of Tamil NadurepresentedBy The Secretary toGovernmentTransport Department, SaintGeorge Fort,Chennai 9.

-Defendants

and two others

WRITTEN STATEMENT FILED BYTHE 1ST DEFENDANT SECRETAYTRANSPORT GOVERNMENT OFTAMIL NADU



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1. Original Suit No. O.S. No.230/2001

2. Filed in Alanthur Munsif Court by the petitioner M.K. Ramamoorthy, S/o

Kandan, Hindu Age 60 . Door No.25, V. Lane Indira Nagar,Chennai 20.

3. Original Suit dismissed 29.06.2010 in Alanthur Munsif Court.

4. Applied petition No. A.S. No.15/2010

5. Petitioner Thiru. M.K. Ramamoorthy, Chennai 20

6. Defendant 1. Minister of Surface Transport No.1, Palimer Street, New

Delhi 1.

2. Chief Engineer H & R W, East course Road, Project

3. Divisional Engineer H & R W. Saidapet Sub division,

Chennai 16

4. Collector of Kancheepuram, Collector office Kancheepuram

5. Commissioner Chitalapakkam, Chennai

6. Radha Krishnan, Managing Director, Poonga Restaurant

Hotel (P) Ltd., and Poonga College, Chennai.

7. Defendant 7 to 11 son and daughters of

Thiru. Radha Krishnan.

Reason of the case pray to alow this appeal to the Honourable Sub court

Tambaram by setting aside the Judgment and degree.

court letter sep

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