SUIT FOR RECOVERY OF MONEY

CT. CASES NO. xx/xxxx

      IN THE MATTER OF:-

      Xxxxxxxx …COMPLAINANT

VERSUS

      Xxxxxxxx …ACCUSED

  

APPLICATION ON BEHALF OF THE APPLICANT /ACCUSED FOR FILING THE RELEVANT/ADDITIONAL DOCUMENTS ON RECORD

1.    That the aforesaid complaint case filed by the complainant against the accused and same is pending before this Hon’ble Court for today arguments.
   

2.    That on xx.xx.xxxx, during the cross examination of the complainant, it has been revealed that the complainant had filed a case against the xxxxxxxx and same is pending before the Tis Hazari Courts, Delhi, for recovery of sum of Rs.xxxxxx. On the request cross examination was deferred and this Hon’ble Court directed the complainant to bring the **ITRs and the proceedings of civil case** filed by the complainant along with its documents, but the complainant intentionally didn’t file the same till date. Applicant after waiting for so much time of the complainant to file the said documents, applicant himself applied the certified copy of the same in the year 2020.
   

3.    That the applicant while going through the said documents it has come to know that the complainant intentionally and deliberately duping the innocent persons by filing the false and frivolous case against them. Hence, the said documents are very essential, necessary and just decision of the case, which shows the conduct/background of the complainant. The said documents has come to the knowledge from the cross examination of the complainant.
   

4.    It is further submitted that the said documents could not be filed by the applicant due to the pandemic was going-on and the said documents is necessary for the adjudication of the present case.
   

5.    That the said relevant documents are necessary for the purpose of determining the real question of controversy between the parties and for effective adjudication of the present case as the matter is at the stage of arguments.
   

6.    That the present application is being filed before this Hon’ble Court with bonafide purpose without any prejudice to the other party and the same should be allowed in the interest of justice. That the said additional documents are pertinent as they provide a clear and complete picture of the dispute between the parties.
   

7.    That in the interest of justice and for bringing important fact and evidence before this Hon’ble Court for fair and proper adjudication of the present matter, accused seeks an opportunity to file the additional document on record.
   

8.    It is submitted that aforesaid additional documents are very essential and just decision of the case.
   

9.    That if the present application is not allowed then the applicant would suffer irreparable loss which cannot be compensated in terms of money.
   

10. That the present application is filed to place the additional documents on record and the same may be allowed in the interest of justice and the same will not cause any prejudice to the complainant.

11. That the present application is in the interest of justice, equity and good conscience.

It is therefore prayed to the Hon’ble Court kindly allow the present application and allow the applicant to file the additional/relevant documents on record mentioned in para 2 above, in the interest of justice.

Pass such other and further order(s) as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case.

      DELHI APPLICANT/ACCUSED

      THROUGH

      DATED

XXXXXXXXXXXXX

ADVOCATES

Address: XXXXXXXX

XXXXXXXXXXXXXXX

Mob.No.- XXXXXXXXXX

      Email: XXXXXXXX@XXXXX.XXX