Caveat Model Draft

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MODEL DRAFT

IN THE HONOURABLE COURT OF DISTRICT ---------, AT --------


Caveat No.---- /2018

Between:

A.Arun Kumar,
S/o Mohan Kumar,
Aged 35years,
Occ. Business,
R/o China Waltair,
Visakhapatnam. …. Caveator

Versus

1.Bhaskar Raju,
S/o Krishna Rao,
Aged 30 years,
Occ.RTC Driver,
R/o Chinawaltair,
Visakhapatnam.

2.Smt. Kamalamma,
W/o Bhaskar Raju,
Aged 25 years,
Occ. House-hold,
R/o Chinawaltair,
Visakhapatnam. ….Opponents

CAVEAT FILED UNDER SECTION 148 A OF C P C


The Caveator above named respectfully submits on oath as follows:
1. That The caveator is the owner of the house-sie bearing no.14-2-36
situated at china waltair, surrounded by East Gram Panchayat road, North
Gram Panchayat Lane. South House of the opponent, West house of Prakash.
He purchased this site from Sri Murali Krishna, s/o Radha Krishna, r/o Ashok
Nagar, and got it registered in his name vide Registered Sale Deed
Document No. 456/92 of the sub-Registrar, Stamps and Registration, the
opponent No.1 was one of the attesters to the said document.

2. That the Caveator obtained permission from the Gram Panchayat and
started the construction of house.
3. That the opponent Nos. 1 and 2 asked the caveator to sell the space of his
south face (Which shall become north to the opponents) to an extent of 80
square yards. So that their house will, get spacious vacant space on the
north according to the vasthu. The caveator did not agree. The opponent
claimed that the seller of the said house-site (from whom the caveator
purchased) promised to sell that piece to them orally in 2011. The quarreled
with the caveator and challenged how will he complete the construction.
4. That the caveator suspects that the opponents may approach the court
seeking for interim injunction order ex parte for stopping the work of the
caveator and to harass him
5. That the caveator sent the copies of this caveat application to the
opponents by registered post and enclose herewith the postal receipts along
with this caveat petition.

The caveator prays the honourable court to give a notice to the caveator of
to his advocate, if the opponent party files any proceeding/ application for an
interim order. The caveator also prays the honourable court not to give any
ex parte interim order to the opponent party without hearing the caveator.
Place: Prayed.
Date: Sd/- xxxx
(Arun Kumar)
Caveator.
Name and Address of the Advocate of the caveator:

L. Rajasekhar,
S/o Krishan Rao,
R/o Gurudwar,
Visakhapatnam.

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