IN THE COURT OF THE DISTRICT MUNSIF COURT CHENGALPET O.S. No.282/2009 1. Thiru. Padmanabhan 2. Thiru. Prakash 3. Thiru.

Suresh - VS1. State of Tamil Nadu represented By The Secretary to Government Transport Department, Saint George Fort, Chennai 9. 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.

- Plaintiffs

- Defendants

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 80 C.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 Transport Government 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 Transport Government of Tamil Nadu Chennai 9.

IN THE COUR8T OF THE DISTRICT MUNSIF COURT CHENGALPET O.S. No.282/2009 1. Thiru. Padmanabhan 2. Thiru. Prakash 3. Thiru. Suresh

- Plaintiffs

- VS1. State of Tamil Nadu represented. By Secretary to Government Transport Department, Saint George Fort, Chennai 9. and two others AFFIDAVIT FILED BY THE 1ST DEFENDANT

- Defendants

I Thiru. afford sincerely as follows.

Age

The

Secretary,

Transport

Department The Government of TamilNadu, Chennai 9 do hereby solemnly

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.

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 Department Government of Tamil Nadu Chennai 9. Solemnly affirmed and signed before me at Chengalpattu and day of September 2012

Advocate for defendant

IN THE COURT OF THE DISTRICT MUNSIF COURT CHENGALPET O.S. No.282/2009

1. State of Tamil Nadu represented By the Secretary to Government Transport Department, Saint George Fort, Chennai 9.

- Petitioner 1st Defendant

- VS -

1. Thiru. Padmanabhan 2. Thiru. Prakash 3. 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

IN THE COURT OF THE HONORABLE DISTRICT MUNISIF COURT CHENGALPATTU

1. State of Tamil Nadu represented By the Secretary to Government Transport Department, Saint George Fort, Petitioner Chennai 9.

1st Defendant - VS -

1. Thiru. Padmanabhan 2. Thiru. Prakash 3. Thiru. Suresh - Defendants

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

COUNCIL PETITION DEFENDANT

IN THE COURT OF THE HONORABLE DISTRICT MUNISIF COURT CHENGALPATTU

AFFIDAVIT FILLED BY THE 1ST DEFENDANT SECRETAY TRANSPORT GOVERNMENT OF TAMIL NADU

COUNCIL PETITION DEFENDANT

IN THE COURT OF THE HONORABLE DISTRICT MUNISIF COURT CHENGALPATTU

1. Thiru. Padmanabhan 2. Thiru. Prakash 3. Thiru. Suresh - P laintiffs - VS1. State of Tamil Nadu represented By The Secretary to Government Transport Department, Saint George Fort, Chennai 9. Defendants and two others

WRITTEN STATEMENT FILED BY THE 1ST DEFENDANT SECRETAY TRANSPORT GOVERNMENT OF TAMIL NADU

COUNCIL PETITION DEFENDANT

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 . Chennai 20. Door No.25, V. Lane Indira Nagar,

3. 4.

Original Suit dismissed 29.06.2010 in Alanthur Munsif Court. 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.