Bangalore District Court
Smt.K.V.Lalitha vs The Deputy General Manager on 23 September, 2017
IN THE COURT OF IX ADDL.CITY CIVIL AND
SESSIONS JUDGE AT BANGALORE (C.C.H.5)
Dated: This the 23rd day of September 2017
Present: Smt. M.H.Shantha,
M.A., LL.B.,
IX Addl. C.C & S.J, Bangalore.
O.S. NO.2638/2011
Plaintiff: Smt.K.V.Lalitha,
W/o. Shankar Bhat,
Aged about 58 years,
Residing at No.3,
2nd Cross, Resildar Street,
Seshadripuram,
Bangalore 560 020.
[By Sri.D.R., advocate]
-Vs-
Defendant: The Deputy General Manager,
(Recovery II), Karnataka State
Financial Corporation,
Head Office No.1/1,
Thimmiah Road,
Bangalore 560 052.
Represented by its
authorized officer
[By Sri.KCM, advocate]
Date of institution of the suit 11.04.2011
Nature of the suit Injunction
Date of commencement of 17.3.2014
recording the evidence
2 O.S.No.2638/2011
Date on which the judgment 23.09.2017
was pronounced
Total duration : Day/s Month/s Year/s
12 05 06
JUDGMENT
This suit is filed by plaintiff against the defendant for judgment and decree for the relief of mandatory injunction directing the defendant to hand over/deliver the original title deed in respect of the suit 'B' schedule property to the plaintiff and other documents in respect of 'A' schedule property and for such other relief.
2. The case of the plaintiff in brief is that, the plaintiff is absolute owner is in possession and enjoyment of the suit 'A' schedule property. The suit 'A' schedule property was acquired by plaintiff for a valuable sale consideration from her vendor through registered sale deed dated 9.6.1993 from one Abdul Raheem Khan who has purchased from his previous 3 O.S.No.2638/2011 vendor through a registered sale deed dated 11.4.1972 and same is registered on 3.5.1972. The khata of the suit schedule property stands in the name of plaintiff after purchase from her vendor Abdul Raheem Khan through a registered sale deed dated 9.6.1993. Further, plaintiff has stated that the encumbrance certificate for the period from 1.4.2004 to 4.9.2010 showing that the suit 'A' schedule property is still standing in plaintiff's name and even today, it is in her name and she is in possession and enjoyment of the suit schedule property. After purchase of the suit schedule property, the plaintiff and her family members were residing in the suit 'A' schedule property. The plaintiff and her previous vendor Abdul Raheem Khan have entered into an agreement of sale on 14.3.1992 on such terms and conditions as agreed between the plaintiff and her previous vendor and later, the period of execution of sale deed was extended pursuant to the agreement of 4 O.S.No.2638/2011 sale by its corresponding endorsements. From the date of its purchase, the plaintiff is in possession and enjoyment of the suit 'A' schedule property by paying all the property taxes to the concerned authority. Further, plaintiff has stated that during the period of registration of the revenue records, original title deeds of previous vendor including schedule B title deeds and such other related documents were handed over to her and the possession of the suit schedule property is also handed over to the plaintiff on the same day, prior to it, she was residing in the Schedule 'A' property. The plaintiff is absolute owner in possession and enjoyment of the suit schedule property. Further, plaintiff has stated that in connection with the proceedings for undervaluation where the plaintiff was made to pay an additional sum of Rs.14,000/-, these papers i.e. schedule B title deeds have been taken and later, the plaintiff was told that the said papers were lost and after not 5 O.S.No.2638/2011 being able to trace them. Thereafter, the plaintiff has given complaint to the jurisdictional Seshadripuram police station on 23.8.95 and the plaintiff has also given press advertisement in this regard. Further, plaintiff has stated that some of the miscreants/fraud players have played fraud on the Schedule 'A' property by creating collateral security by pledging the schedule B title deeds in the K.S.F.C. by impersonating the plaintiff's vendor as the owner of the suit 'A' schedule property and managed to get a loan amount totaling to a sum of Rs.27 lakhs from the financial institution in the name of firm M/s.Goverdhan Veg. The K.S.F.C. having without properly verifying the documents in respect of suit Schedule 'A' property and also not making any enquiry in respect of owner of the said property has granted loan after receiving the original schedule B title deeds of the Schedule 'A' property. Since the loan amount has not been repaid, the KSFC had 6 O.S.No.2638/2011 lodged private complaint on 25.1.2002 in PCR No.14/02 against the said cheaters and also arrayed the plaintiff as accused No.7. Further the plaintiff has stated that Later, the plaintiff enlarged on anticipatory bail and discharged on the ground of no case is made out against accused No.7/plaintiff by the prosecution before the 8th ACMM at Bangalore in CC 16841/2004. Further, plaintiff has stated that she had issued a legal notice on 8.4.2010 through her advocate narrating that because of the negligence on the part of the defendant corporation, plaintiff has been victim of the fraud played by miscreants (accused NO.2 - 6) and called upon the defendant to deliver and hand over the said alleged documents styled as collateral security of registered sale deed dated 11.4.1972. The defendant has given reply to the said legal notice on 3.5.2010. Hence the plaintiff is constrained to file this suit for the relief of mandatory injunction.
7 O.S.No.2638/2011
3. In pursuance to the summons the defendant has appeared through his counsel and filed the written statement. In the written statement, the defendant has contended that the suit filed by plaintiff is not maintainable either in law or on facts. The suit is bad for non joinder of necessary parties. The plaintiff claims to have purchased the schedule property from Abdul Raheem Khan. The said Abdul Raheem Khan has deposited all the original title deeds of the suit schedule property with the Corporation. Further, the defendant has contended that Abdul Raheem Khan, the firm and its partners are necessary and proper party to the suit to decide the dispute between the parties to the suit. The suit is barred by law of limitation. The plaintiff claims to have purchased suit schedule property on 9.6.1993 and claims to have lodged complaint with the Seshadripuram police station on 23.8.1995 and has alleged that press advertisement was given and also 8 O.S.No.2638/2011 issued legal notice dated 15.4.1998 to the defendant demanding for the said sale deed. The present suit filed after 12 years from 15.4.1998 is hopelessly barred by law of limitation. Further, defendant has contended that the suit for bare injunction filed against a statutory institution without seeking the relief of declaration is not maintainable in law.
Further the defendant has contended that M/s.Govardhan Veg a partnership firm represented by its partners Sanjeev Kumar Palan, Smt.Saroja S.Palan, Prabhakara Poojari and Mudanna approached the Corporation for financial assistance for establishment of a posh restaurant at No.39/3 & 39/3C, Kanakapura Main Road, Banashankari, Bangalore. The Corporation accordingly sanctioned a term loan of Rs.20.50 lakhs and additional term loan of Rs.7.70 lakhs subject to the terms and conditions of the Corporations loan sanction letters dated 5.4.1993 and 9.12.1994 to the partnership firm. 9 O.S.No.2638/2011
Further, defendant has contended that as security for the repayment of the amounts sanctioned and released to the firm, Abdul Raheem Khan has executed surety agreements in favour of the Corporation and mortgaged the property bearing Old No.6, present No.3, situated at Rasildar Street, Sheshadripuram, Bangalore, measuring east to west 70 feet, north to south 23 feet 7 inches and bounded on East by Rasildar Street, west by house of Mohamad Sab, North by Mahamad Latif & others, and south by ashambi's house, by depositing the original title deeds of the property to the Corporation as security for the repayment of the aforesaid loans to the Corporation.
Further, defendant has contended that Abdul Rahim Khan has created equitable mortgage on the said property by deposit of original title deed and has participated in recording memorandum of entry. Under the aforesaid agreement, Abdul Rahim Khan 10 O.S.No.2638/2011 has given his surety for the repayment of the principal sum, interest etc., due from the partnership firm to the Corporation. Abdul Rahim Khan has also executed an affidavit that he is the absolute owner of the property and that the property is free from all encumberance, claims, demands of whatsoever nature etc., and also executed an undertaking in this regard.
Further the defendant has contended that Abdul Rahim Khan has deposited all the original title deeds of the property in favour of the Corporation i.e. registered sale deed dated 3.5.1972, khata extract dated 25.8.72, tax paid receipts and encumbrance certificate in respect of the property. That an amount of Rs.20.12 lakhs in respect of the term loan and Rs.6.92 lakhs in respect of the additional term loan was released to the partnership firm. Further, the defendant has contended that the partnership firm is chronic defaulter in the matter of repayment of the 11 O.S.No.2638/2011 loan dues to the Corporation. In spite of several deemed notice and reminders and show cause notice the partnership firm failed to repay the loan dues. Hence, the Corporation was constrained to recall the entire loan by notice dated 8.1.98 and called upon the partners of the firm and Abdul Rahim Khan to pay the loan dues.
Further, defendant has contended that the said Abdul Rahim Khan has not given any reply to the notice dated 8.1.98, the plaintiff has got issued a legal notice dated 15.4.98 making all false claims in respect of the property. The defendant has given reply to the legal notice dated 15.4.98. In the reply dated 22.8.98 the plaintiff was called upon to meet the Corporation officials along with the information as to what happened regarding the alleged complaint stated to have been lodged by the plaintiff to the jurisdictional police for alleged missed documents 12 O.S.No.2638/2011 along with original sale deed stated to have been executed on 9.6.93.
Further, defendant has contended that the plaintiff has neither approached the Corporation officials nor furnished the information sought for by the Corporation in the matter. Thereafter, the Corporation has lodged a criminal complaint against the partnership firm its partners, Abdul Rahim Khan and the plaintiff, and the said criminal case is pending consideration before the Magistrate Court. The plaintiff who is well aware of the entire loan transaction and also about mortgage of the property and pendency of the criminal case has got issued legal notice dated 8.4.2010 and as now filed this false suit in collusion with Abdul Rahim Khan making all false allegations against the Corporation with malafide intention. Further, defendant has contended that as on 10.6.2011 an amount of Rs.6,42,48,575/- is due to the Corporation from the 13 O.S.No.2638/2011 firm. The Corporation is entitled to proceed against the property owned by Abdul Rahim Khan for recovery of the loan dues. Since the firm failed to repay the loan dues the action initiated against the property is in accordance with law. Instead of paying the loan dues the surety Abdul Rahim Khan has now set up the plaintiff and has got filed the above collusive suit by suppressing the above true facts.
Further, defendant has contended that the property is mortgaged to the defendant Corporation for the above said loan by Abdul Rahim Khan. The remedy if any the plaintiff is to seek for declaration of her title and ownership over the property against Abdul Rahim Khan. The alleged khata certificate or uttara patra dated 5.3.94 is created document for the purpose of the case. Further, defendant has contended that the plaintiff or her family members were not residing in the schedule property at any time. The alleged agreement of sale dated 14.3.92 is 14 O.S.No.2638/2011 created and concocted document created for the purpose of the suit. All the original title deeds and revenue records of the property are deposited with the Corporation as collateral security for the loan availed by Abdul Rahim Khan. The plaintiff has been taking inconsistent pleas on different occasions as to how the sale deed was lost. Further, defendant has contended that owner of the property Abdul Rahim Khan has himself come to the Corporation and has deposited the original title deeds of the property with the Corporation as security for the loan availed by the partnership firm. The property has been taken as security for the loan after due verification of the title deeds and after following due process of law. The lodging of the private complaint by the Corporation and subsequent proceedings is matter of record. The plaintiff has filed the above suit in collusion with Abdul Rahim Khan has been claiming to have taken the original documents on the basis of 15 O.S.No.2638/2011 created and concocted sale deed and claims to have lost the title deeds on one occasion at her house and at another occasion that it is lost in undervaluation proceedings. Hence the defendant prays for dismissal of the suit.
4. On the above pleading of the partiers, my predecessor in office has framed the following Issues:
(1) Whether the plaintiff proves that she is entitled for the relief of mandatory injunction directing the defendant to deliver the original title deed mentioned in Schedule-B along with related revenue original or certified documents in respect of Schedule 'A' property?
(2) Does she entitle for the relief sought for?
(3) Whether the defendant proves that suit is not maintainable as contended?
(4) Does she prove suit is barred by law of limitation?
(5) Whether plaintiff is entitled for the relief sought for?
(6) What order and decree?16 O.S.No.2638/2011
5. In support of the case of plaintiff, he has got examined himself as P.W.1 and also produced 21 documents at Exs.P-1 to P-21. On the other hand, Senior Manager of the defendant corporation by name Ravindranath Reddy has been examined as D.W.1 and got marked 15 documents at Ex.D-1 to
15.
6. Heard the arguments of learned counsels for both the parties. After hearing arguments and considering the oral and documentary evidence on record, my findings on the above issues are here under:
Issue No.1 : In the Negative
Issue No.2 : In the Negative
Issue No.3 : In the Negative
Issue No.4 : In the Negative
Issue No.5 : In the Negative
Point No.6 : As per final order,
for the following:
17 O.S.No.2638/2011
REASONS
7. Issue No.1: In support of the case of the plaintiff, she has got herself examined as P.W.1. P.W.1 in her evidence has deposed that she is the absolute owner in possession and enjoyment of the suit 'A' schedule property. Further, P.W.1 has deposed that she has purchased the suit schedule property from one Abdul Raheem Khan under registered sale deed dated 9.6.1993. Further, P.W.1 has deposed that prior to purchase of the suit schedule property her vendor Abdul Raheem Khan has executed an agreement of sale in respect of the suit schedule property on 14.3.1992 and handed over the possession of the suit schedule property in favour of her. Further, P.W.1 has deposed that her vendor Abdul Raheem Khan had purchased suit 'A' schedule property under registered sale deed dated 11.4.1972 and registered on 3.5.1972. Further, P.W.1 has deposed that khata of the suit schedule 18 O.S.No.2638/2011 property is standing in her name. Further, P.W.1 has deposed that she is in possession and enjoyment of the suit schedule property as absolute owner. Further, P.W.1 has deposed that she is paying tax to the concerned authority. Further, P.W.1 has deposed that at the time of execution of the sale deed by her vendor in respect of the suit schedule property, her vendor Abdul Raheem Khan has handed over the original title deeds of his previous vendors including the suit 'B' schedule title deeds to her. Further, P.W.1 has deposed that she has given 'B' schedule original title deeds to the Deputy Commissioner for detection of undervaluation of Stamps in respect of under valuation proceedings. Further, P.W.1 has deposed that the said suit 'B' schedule original title deed was not returned to her by Deputy Commissioner for detection of undervaluation of Stamps. Further, P.W.1 has deposed that the said suit 'B' schedule original title deed was lost and she 19 O.S.No.2638/2011 has given complaint to the jurisdictional Sheshadripuram police station in this regard on 23.8.1995 and also given paper publication on 21.2.1996. Further, P.W.1 has deposed that the Deputy Commissioner for detection of undervaluation of Stamps have issued notice on 28.7.1993 to her in respect of under valuation. Further, P.W.1 has deposed that the defendant Corporation had filed a private complaint in PCR14/2002 before VIII ACMM, Bangalore and the same was registered as CC No.16841/2004 against the partners of M/s.Goverdhan Veg and also against her. Further, P.W.1 has deposed that the accused 2 to 5 in said CC No.16841/2004 have obtained loan for Rs.27 lakhs from the defendant Corporation by depositing the suit 'B' schedule title deeds in the defendant Corporation as collateral security by impersonating her vendor Abdul Raheem Khan as owner of the suit 'A' schedule property. Further, 20 O.S.No.2638/2011 P.W.1 has deposed that she was discharged for the offence alleged against her in CC16481/2004 before VIII ACMM, Bangalore. Further, P.W.1 has deposed that the defendant Corporation without verifying the documents in respect of the suit schedule property had sanctioned the said loan amount to the said persons by receiving the suit 'B' schedule original title deed. Further, P.W.1 has deposed that on 8.4.2010, she has issued legal notice to the defendant Corporation calling upon it to deliver and hand over registered sale deed dated 11.4.1972 i.e. suit 'B' schedule original title deed, but the defendant has given untenable reply to the said notice issued by her. The plaintiff has produced certified copy of sale deed dated 11.4.1972, certified copy of sale deed dated 9.6.1993, encumbrance certificates, order sheet in PCR/CC 16841/2004, notice copies, original registered sale deed, agreement of sale, endorsement, NCR, paper 21 O.S.No.2638/2011 publication, receipt, encumbrance certificates, tax receipt, letter, tax paid receipts, death certificate, notarized copy of identity card, adhar card and the same are marked at Ex.P-1 to 21. In the cross- examination, P.W.1 has pleaded her ignorance regarding the fact that one Goverdhan Veg company has obtained loan for Rs.20,50,000/- from the defendant corporation on 5.4.1993. Further, P.W.1 has deposed that she did not know that the said Goverdhan Veg company has borrowed additional loan of Rs.7.7 lakhs from the defendant Corporation on 9.12.1994. Further, plaintiff has pleaded her ignorance regarding the fact that at the time of obtaining the loan from the said Goverdhan Veg company, her vendor Abdul Raheem Khan has deposited suit 'B' schedule title deeds as security for the said loan amount in the defendant Corporation. Further, P.W.1 has deposed that she did know that the defendant Corporation has issued notice to 22 O.S.No.2638/2011 Goverdhan Veg company and its partners and her vendor Abdul Raheem Khan calling upon them to repay the loan amount borrowed by them. Further, P.W.1 in her cross-examination has deposed that her vendor died about 19 years ago. Further denied that her vendor has not executed any sale deed in favour of her. P.W.1 deposed in her cross-examination that zÁR¯ÉUÀ¼ÀÄ ¥ÀæwªÁ¢ ¸ÀA¸ÉܬÄAzÀ ¥ÀqÉAiÀĨÉÃPÁzÀgÉ UÉÆêÀzÀðs £ï ¸ÀA¸ÉÜ ªÀÄvÀÄÛ C§Äݯï gÀ»ÃA SÁ£ï zÁªÁ¸ÀévÀÛ£ÀÄß ¸ÉPÀÄåjnAiÀiÁV ¤ÃrzÀÝjAzÀ CzÀgÀ ªÉÄð£À ¸Á® wÃj¹zÀgÉ ªÀiÁvÀæ ¥ÀqÉAiÀħºÀÄzÀÄ JA§ ¥Àæ±ÉßUÉ ¸ÁQëAiÀÄÄ £ÁªÀÅ ¸Á® ¥Àq¢ É ®è ªÀÄvÀÄÛ £ÀªÀÄUÉ UÉÆwÛ®è JAzÀÄ £ÀÄrAiÀÄÄvÁÛgÉ. From the above evidence of P.W.1 and also from the documents produced by plaintiff, it is clear that the plaintiff has purchased the suit schedule property from one Abdul Raheem Khan under registered sale deed dated 9.6.1993. Further, it is clear that her vendor Abdul Raheem Khan has purchased the suit 'A' schedule property under registered sale deed dated 11.4.1972 and the same was registered on 3.5.1972. Further from the 23 O.S.No.2638/2011 evidence of P.W.1 and also documents produced by plaintiff, it is clear that plaintiff has not produced any documents to show that at the time of registration of the sale deed by her vendor in respect of suit 'A' schedule property on 9.6.1993 he has handed over the original sale deed dated 11.4.1972 to her. Further it is the case and contention of the plaintiff that the original suit 'B' schedule title deed was given by her to the Deputy Commissioner for detection of undervaluation of Stamps and the same was not returned to her by the said Deputy Commissioner for detection of undervaluation of Stamps. Further it is the case of the plaintiff that the said original 'B' suit schedule title deed was lost in possession of the Deputy Commissioner for detection of undervaluation of Stamps at the time of undervaluation proceedings. But the plaintiff has not produced any documentary evidence in this regard to show that original suit 'B' schedule title 24 O.S.No.2638/2011 deed was given to the concerned Deputy Commissioner for detection of undervaluation of Stamps by the plaintiff. Further there is also no documentary evidence to show that the plaintiff has tried to take back the original suit 'B' schedule title deed from the Deputy Commissioner for detection of undervaluation of Stamps. The plaintiff has not produced any documents to show that the said suit 'B' schedule original title deed was lost in possession of the Deputy Commissioner for detection of undervaluation of Stamps. There is no evidence on record from the plaintiff to show that she has tried to take back the original suit schedule title deed from Deputy Commissioner for detection of undervaluation of Stamps, if at all she had given the same to the Deputy Commissioner for detection of undervaluation of Stamps. Even the plaintiff from the year 1993 till 2010 she had not tried to take back the original suit 'B' schedule title deed from Deputy 25 O.S.No.2638/2011 Commissioner for detection of undervaluation of Stamps if it was given to it. Therefore without any supporting evidence mere pleadings and oral evidence of P.W.1 cannot be taken into consideration that she has given suit 'B' schedule original title deed to the Deputy Commissioner for detection of undervaluation of Stamps and the Deputy Commissioner for detection of undervaluation of Stamps has not returned the said title deed to the plaintiff and the said title deed was lost in the possession of the Deputy Commissioner for detection of undervaluation of Stamps.
8. The Senior Manager by name M.N.Ravnindranath Reddy of the defendant Corporation has been examined as D.W.1. D.W.1 in his evidence has deposed that Goverdhan Veg company represented by its partners by name Sanjeev Kumar Palany, Smt.Saroja S.Palan, 26 O.S.No.2638/2011 Prabhakara Poojary and Mudanna have borrowed loan of Rs.20.50 lakhs from its Corporation on 5.4.1993. Further they have borrowed additional loan of Rs.7.70 lakhs from its Corporation on 9.12.1994. Further, D.W.1 has deposed that at the time of borrowing of loan amount Abdul Rahim Khan has executed the mortgage deed as security for the said loan amount borrowed by Goverdhan Veg company by depositing the original title deeds of the suit schedule property in the defendant Corporation as security for the repayment of the loan. The defendant has produced original sale deed dated 11.4.1972, endorsement issued by BBMP, tax paid receipts, encumbrance certificate, certified copy of sale deed, reply notice and postal acknowledgement, loan agreement, undertaking letter, confirmation letter and memorandum of entry drawn and the same are marked at Ex.D-1 to 15. D.W.1 has deposed that he has not produced loan documents 27 O.S.No.2638/2011 for the year 1993. In the cross-examination, nothing has been elicited by her in order to disbelieve his evidence. From the evidence of P.W.1 and D.W.1 and also from the documents produced by plaintiff, it is clear that the contention taken by plaintiff that the original suit B schedule title deed was lost and the same was given by her to the Deputy Commissioner for detection of undervaluation of Stamps cannot be accepted. As stated above, the plaintiff has not produced any documents to show that she has tried to take back the suit B schedule title deed from the said Deputy Commissioner for detection of undervaluation of Stamps from 1993 to 2010. Therefore, plaintiff has failed to prove that she is entitled for the relief of mandatory injunction directing the defendant to deliver the original suit B schedule title deeds along with other documents. Therefore, the plaintiff has failed to prove issue No.1. Accordingly, issue No.1 is answered in the negative. 28 O.S.No.2638/2011
9. Issue No.3 and 4: The defendants have contended that the suit is not maintainable and the suit is barred by law of limitation but in support of this contention, the defendant has not chosen to adduce any evidence on his behalf. Therefore, the defendant has failed to prove issue No.3 and 4. Accordingly, issue No.3 and 4 are answered in the negative.
10. Issue NO.2 and 5 : As discussed above, the plaintiff has failed to prove that she is entitled for the relief of mandatory injunction directing the defendants to deliver original suit B schedule title deeds along with other documents in respect of suit A schedule property, the plaintiff is not entitled for any relief as sought for in this suit. Consequently, this suit filed by plaintiff deserves to be dismissed. Hence, plaintiff has failed to prove issues 2 and 5. 29 O.S.No.2638/2011 Accordingly, I answer issue No.2 and 5 in the negative.
11. Issue No.6: In view of my findings on issues 1 to 5 and for the reasons stated therein, this suit filed by plaintiff deserves to be dismissed. In the result, I proceed to pass the following:
O R D E R The suit filed by plaintiff is hereby dismissed.
No order as to cost.
(Dictated to the Judgment Writer, transcribed by her, corrected and then pronounced by me in the open court, on this the 23rd day of September 2017).
(M.H.Shantha) IX Addl. City Civil & Sessions Judge, Bangalore.
A N N E X U R E List of witnesses examined for plaintiff:
P.W.1 K.V.Lalitha 30 O.S.No.2638/2011 List of witnesses examined for defendant:
D.W.1 M.N.Ravindranathreddy List of documents exhibited for plaintiff:
Ex.P-1 & 2 Certified copies of sale deeds Ex.P-3 Encumbrance certificate Ex.P-4 Order sheet in PCR 14/2002 Ex.P-5 Copy of legal notice Ex.P-6 Reply notice Ex.P-7 Sale deed Ex.P-8 Agreement of sale Ex.P-9 Endorsement Ex.P-10 Police acknowledgement Ex.P-11 Paper publication & its receipts Ex.P-12 & 13 Encumbrance certificates Ex.P-14 Encumbrance certificate Form-16 Ex.P-15 Tax receipt Ex.P-16 Uttara patra Ex.P-17 & 18 Tax receipts Ex.P-19 Death Certificate Ex.P-20 ID card Ex.P-21 Adhar card List of documents exhibited for defendant:
Ex.D-1 Original sale deed
31 O.S.No.2638/2011
Ex.D-2 Certified copy of BBMP
endorsement
Ex.D-3 & 4 Tax receipts
Ex.D-5 to 7 Encumbrance certificates Ex.D-8 Certified copy of sale deed Ex.D-9 Legal notice Ex.D-10 Reply notice Ex.D-11 Postal acknowledgement Ex.D-12 Loan agreement Ex.D-13 Undertaking letter Ex.D-14 Confirmation letter Ex.D-15 Memorandum of entry IX Addl. City Civil & Sessions Judge, Bangalore.