To,
The LawyerClubIndia Ld Friends
GRIEVANCE APP.
‘ART 350. THE CONSTITUTION OF INDIA 1949’
AGAINST ADV. RAJENDAR CHAUHAN JUNIORS
PANKAJ RANA ADV. AND ARVIND KUMAR ADV.
FIND IN SAHARANPUR DISTRICT COURT.
My Dear Ld Friends,
PARA ONE:- That I Mr K.K Agarwal Advocate (Full name Kumar Krishan Agarwal) a practicing lawyer since 2009 before the District Court of Muzaffarnagar, Saharanpur and Delhi Region. That since 2009 in my personal property cases of family I occasionally come to Saharanpur in each calendar month 4- 5 times for various cases of various Court of laws and appellate Courts. That I am the member of the District Bar Association Muzaffarnagar + Saharanpur Adhivakta Association + Registered through the Entrance Card Pass in the Supreme Court of India. That I know mostly the good local Advocates of Saharanpur bar and also the many Court deputed Staffs how efficient and negligent they work and what type of traits and nature they are. That I always keep a safer distance from the fighting, assaulter and weak lawyers whose main purpose are to creating Judicial interference in the Court legal proceedings and make unlawful malafide applications for lingering on the matter up to many years and their dirty dilatory tactics. That till today I have some problems face off in District Saharanpur but none heavier as yesterday on dated 24-January-2017 I faced off before the Civil Judge [Senior Division], Saharanpur.
PARA TWO:- That the One Advocate Rajendar Chauhan whose two juniors Named “Pankaj Rana and Arvind Kumar” worked for Rajendar Chauhan. That an Original Suit No. 468/16 titled as “Anurag Singhal vs Pardeep Kumar & Ors” was pending since 04-July-2016 on which on the first filing day the Interim Injunction in false impression thru advocate was granted by the P.O to the Anurag Singhal and his Advocate is Rajendar Chauhan. That on the 13-July-2016 I filed by reply of 6C for vacate it then the matter was deferred for 18-July-2016 then the Judge on Leave thru HJS Exam but could not get a chance to get heard. That on Dec 2016 the Learned P.O on my request press for 6C hearing to Rajendar Chauhan but he refused then again date given in December then in January 2017 then yesterday first time dated 24-01-2017 I hope that I got full working day for press the arguments on pending 6C. That in Tuesday morning 11.30 AM I requested so many times for my turn but every time the two Juniors create obstruction of justice and interference and pretense that Senior will come, directed to Reader give one to two months as out of the laws papers filed then again I press for 6C then after lunch and so on so many dilatory tactics but would get a chance to conduct the hearing of 6C completed. That on this a verbal aggressive fight took place on the provocation of Pankaj Rana where he challenged me so set me right then I said Do you have power to kill me and then Anurag Singhal Plaintiff also took part in confrontation to me and my mosiji before Learned P.O where somehow other advocates in open court and P.O take control the war situation. Then I request to Ld P.O to refer the matter to Ld D.J about this but then P.O drop it and take control in perplexed situation.
PARA THREE:- Now the main concern is that the two Juniors named Pankaj Rana and Arvind Kumar are not authorized on Vaklatnama (Under Advocate Act 1961 and S.119 of CPC) of Rajendar Chauhan in this Suit but they created judicial interference, obstruction of justice and mockery about me by saying that I came from Muzaffarnagar, not live in Saharanpur, they set me right in couple of seconds, said I am no manners, today no hearing would takes place, they have right to interrupt me if I conduct hearing on 6C etc etc every time then I made request before open court of law to listen the suit on 6C that your order is Void order how and there is many legal precedents that injunction is only granted for 15 days and then after fresh order may again pass, the Plaintiff plaint is defective, no injunction can be granted against Criminal Trespassers and Rank trespassers and the injunction cannot be granted for stopping Criminal Proceedings of this Plaintiff before CJM Saharanpur under sec 41 of Specific Relief Act and Order 39 Rule 2 amendment by Uttar Pardesh and injunction is barred under all the legal precedents passed by the Hon’ble Allahabad H.C JTRI Circulars and the Apex Court Ruling attached in the Suit file already and ignorance of all these things make a Civil Contempt. That I requested to the Learned P.O to kindly understand this file into which I submit all the relevant matter of the legal precedents so that in future this type of fraud and collusion never occurred by any advocate in the name of injunction and then same thing the opposite party like me may bear as I bore in several months.
PARA FOUR:- That any person of Indian who enrolled in any State Bar Council Of India may practice up to any State District Court, any High Court or the one and only Apex Court of India and there is no restriction on the place of residence where he lives or not. That Similarly Ld P.O or Judges also may be deputed in any Court of India except his/her home town in India. That the two advocates Pankaj Rana and Arvind Kumar are spreading anarchy and State legal Practice discrimination in between advocates of the Bar Council of India. That today if the hooliganism demeanor advocates not controlled then the one day sure come that these type of fighter advocates destroy the system of justice and the reputation of the Bar Council in just couple of minutes.
PARA FIVE:- That the everyone advocate in the Saharanpur Bar or other Bars not humble and gentle, not good knowledge about all laws and legal precedents except some limited advocates in Bar, but come daily for creating calculated judicial interference in the name of legal practice and get hired before the other advocates so that work of hooliganism and fighting and terror may show off to the opposite parties that you in danger zone keep a safer distance from them and the daily familiar Court P.O work according to their mood and Style and direction and the Staff also and whatever the abuse of law applications and out of law application they moved somehow pressurize to opposite party to take and then build pressure on Court of laws to pass an abuse of discretion on it in any cost or give a date of One to two months on Malafide applications.
+ PRAYER +
That now what I request to this Bar Council of Uttar Pardesh that kindly pass and explicit orders or precept that only those advocates who have deemed authorized on Saharanpur Bar Recognized Vakalatnama by litigants may contest the cases or suits in only decorum and decency without fighting. That kindly may observe through secret observer the Conduct of these two advocates thru secret enquiry that in mostly suits of Rajendar Chauhan how Pankaj Rana and Arvind Kumar are behaving to others parties and other legal fraternity advocates daily and in open court and in open premises of District Court. That if I get this problem through these two “Pankaj Rana and Arvind Kumar” then what these two person may do to others in other suit files and parties. Any other relief also may be pass for dignity of law to save and save the life of the other advocates in this Profession.
Complainant/Petitioner:-
Dated:- 25-Jan-2017
Mr. KK Agarwal Advocate,
Mb:- 09319365499, 09675730306,
09910362303, 09457837917.
Address:- 210 South Civil Lines, Muzaffarnagar, U.P
