IN THE COURT OF SH. Judge's name, LD. CIVIL JUDGE, Court complex name COURTS, DELHI
CIVIL SUIT No. Civil suit number OF 20Last digit of suit year
IN THE MATTER OF:
Plaintiff's name… PLAINTIFF
V E R S U S
Defendant's name… DEFENDANT
N.D.O.H.: Next date of hearing
APPLICATION ON BEHALF OF THE PLAINTIFF UNDER SECTION 151 OF THE CODE OF CIVIL PROCEDURE SEEKING PERMISSION TO PLACE ON RECORD THE AFFIDAVIT UNDER SECTION 65B OF THE INDIAN EVIDENCE ACT AND THE ADDITIONAL AFFIDAVIT OF THE PLAINTIFF
MOST RESPECTFULLY SHOWETH:-
1.That the present application under Section 151 of the Code of Civil Procedure is being filed on behalf of the Plaintiff.
2.That the Plaintiff has filed certain documents in support of the aforesaid suit.
3.That on the last date of hearing, this Hon'ble Court was pleased to grant liberty to the Plaintiff to file the present application for supporting the documents already filed along with the plaint.
4.That the present application under Section 151 of the Code of Civil Procedure is being filed by the Plaintiff for the purpose of proving the electronic documents.
5.That the documents sought to be brought on record by virtue of the present application are material and necessary for the purpose of arriving at a just decision in the above-captioned matter.
6.That procedure is the handmaid of justice, and therefore a procedural hurdle ought not to be permitted to stand in the way of arriving at a just decision in the case.
7.That if the present application is not allowed, the same would occasion a failure of justice and would cause irreparable loss and injury to the Plaintiff. It is therefore necessary that the Plaintiff be permitted to file the additional affidavit and the affidavit under Section 65B of the Indian Evidence Act, and that the same be taken on record by this Hon'ble Court.
P R A Y E R
In the facts and circumstances of the case, it is, therefore, most respectfully prayed that this Hon'ble Court may graciously be pleased to:-
A.Allow the present application of the Plaintiff and permit him to place on record the additional affidavit and the affidavit under Section 65B of the Indian Evidence Act before this Hon'ble Court.
B.Pass such further order or orders as this Hon'ble Court may deem fit and proper in the facts and circumstances of the case and in the interest of justice.
PLAINTIFF
THROUGH
Date of application
PLACE: DELHI
ADVOCATES FOR THE PLAINTIFF
Chamber No. Chamber number, Chamber address line,
Court complex name Courts, Delhi.
IN THE COURT OF SH. Judge's name, LD. CIVIL JUDGE, Court complex name COURTS, DELHI
CIVIL SUIT No. Civil suit number OF 20Last digit of suit year
IN THE MATTER OF:
Plaintiff's name… PLAINTIFF
V E R S U S
Defendant's name… DEFENDANT
AFFIDAVIT
AFFIDAVIT OF SH. Deponent's name, S/O SH. Deponent's father's name, PARTNER OF M/S. Firm name, R/O Deponent's address
I, the above-named Deponent, do hereby solemnly affirm and declare as under:-
1.That I am the Plaintiff in the above-said case, am fully conversant with the facts of the case, and am competent to swear the present affidavit.
2.That the contents of the accompanying application under Section 151 of the Code of Civil Procedure have been drafted by my counsel as per my instructions; the contents thereof have been duly read over and understood by me, and after fully understanding the same, I state that the facts stated therein are true and correct to my knowledge.
3.That the facts stated in the accompanying application may kindly be read as part and parcel of the present affidavit, as the contents thereof have not been reproduced herein for the sake of brevity.
DEPONENT
VERIFICATION:-
Verified at Delhi on this Date of verification that the contents of the above affidavit are true and correct to my knowledge, and nothing material has been concealed therefrom.
DEPONENT