WRITTEN SUBMISSIONS ON BEHALFF OF THE ACCUSED

CIVIL SUIT No. OF 20_____.

IN THE MATTER OF :-

XXXXXXX … PLAINTIFF

V E R S U S

XXXXXXX … DEFENDANT

N.D.O.H: ……………

APPLICATION ON AND BEHALF OF THE PLAINITFF UNDER SECTION 151 OF THE CODE OF CIVIL PROCEDURE SEEKING PERMISSION TO FILING ON RECORD THE AFFIDAVIT OF 65B OF EVIDENCE ACT AND ADDITIONAL AFFIDAVIT OF THE PLAINTIFF.

1.   That the Present Application under Section 151 of the Code of Civil Procedure is being filed on and behalf of the Plaintiff.
   

2.   That plaintiff has filed certain documents in support of the aforesaid suit.
   

3.   That on last date of hearing this Hon’ble Court was pleased to grant liberty to the plaintiff to file the present application for supporting the document which 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 proving the electronic documents.
   

5.   That the documents which are sought to be brought on record by virtue of aforesaid application are material / necessary for the purpose of arriving at just decision in the above captioned matter.
   

6.   That the procedure is handmaid of justice and therefore the procedural hurdle should not be allowed to stand in arriving at just decision of case.
   

7.   That if the present Application is not allowed to stand, then the  same would occasion failure of justice and will cause an irreparable loss and injury to the Plaintiff herein and hence the Plaintiff should be allowed the plaintiff file the additional affidavit and affidavit under Section 65B of Evidence Act and taken on record by this Hon’ble Court.
   

P R A Y E R

In this facts and circumstances of the case this Hon’ble Court may be pleased to:-

A. Allow the present Application of the Plaintiff and him to file on record the additional affidavit and affidavit under Section 65B of Evidence Act before this Hon’ble Court.

B. Pass such further order or orders as this Hon’ble Court may deem fit and proper and in the interest of justice.

PLAINTIFF

DELHI THROUGH

DATED

(XXXXXXXXXX)

ADVOCATES

Chamber No.XX, XX,

XXXX Courts, Delhi-110054.

CIVIL SUIT No. OF 20___.

IN THE MATTER OF :-

SURESH SONI … PLAINTIFF

V E R S U S

KUNAL JAIN … DEFENDANT

I, the above named deponent, do hereby solemnly affirm and declare as under:

1.   That I am the plaintiff in the above said case and well conversant with the facts of the case and competent to swear the present affidavit.
   

2.   That the contents of the accompanying application under section 151 of C.P.C. have been drafted by my counsel as per my instructions and the contents of the same have been duly read and understood by me and after fully understanding the contents of the same, I hereby state that the facts stated therein are all true and correct to my knowledge.
   

3.   The facts stated therein may kindly be read as part and parcel of the present Affidavit also as the contents of the same have not been reproduced herein for the sake of brevity.
   

DEPONENT

VERIFICATON :-

      Verified at Delhi on this ___, day of February, 2017 that the contents of the above Affidavit are true and correct to my knowledge, nothing material has been concealed there from.

DEPONENT