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Petition for amendment of plaint

IN THE COURT OF THE CITY CIVIL COURT, NEW DELHI
I.A. No. 23/2025 in O.S. No. 1024/2024

Arjun Kumar, S/o Ramesh Kumar, Hindu, aged 35 years,
Occ: Businessman, R/o 123, Green Park, New Delhi

…Petitioner / Plaintiff

Vs.

Neha Sharma,

…Respondent / Defendant

PETITION UNDER ORDER VI RULE 17 CPC READ WITH RULE 28 OF CIVIL RULES OF PRACTICE

The petitioner above-named respectfully submits as follows:

For the reasons stated in the accompanying affidavit, the petitioner prays that this Hon’ble Court may be pleased to permit the following amendments to the plaint in the interest of justice and to avoid multiplicity of proceedings:

Proposed Amendments:

  1. To insert paragraph 3(b):
    “The plaintiff is the absolute owner of the plaint schedule property and he is having rights, title, and interest over the same.”
  2. To insert paragraph 5(b):
    “The plaintiff seeks a declaration that he is the absolute owner of the plaint schedule property. The present market value of the property is Rs. 10,00,000/-, and 3/4th of the market value is Rs. 7,50,000/-, on which court fee of Rs. 3,750/- is paid under Section 24(d) of the Court Fees and Suits Valuation Act.”
  3. To insert paragraph 7(a)(2):
    “For a declaration that the plaintiff is the absolute owner of the schedule mentioned property.”

The petitioner therefore prays that this Hon’ble Court may be pleased to allow this petition and amend the plaint as above, and pass such other orders as deemed fit and proper in the interests of justice.

Place: New Delhi
Date: 6th June 2025

Advocate for Petitioner
(Sd/-) [Advocate’s Name]

IN THE COURT OF THE CITY CIVIL COURT, NEW DELHI
I.A. No. 23/2025 in O.S. No. 1024/2024

Arjun Kumar

…Plaintiff

Vs.

Neha Sharma

…Defendant

AFFIDAVIT

I, Arjun Kumar, S/o Ramesh Kumar, Hindu, aged about 35 years, Businessman, R/o 123, Green Park, New Delhi, do hereby solemnly affirm and state on oath as follows:

  1. I am the plaintiff in the suit and the petitioner herein. I am well acquainted with the facts of the case.
  2. I have filed the suit (O.S. No. 1024/2024) against the defendant for permanent injunction and other reliefs. This Hon’ble Court has granted interim injunction in my favour.
  3. The plaint forms an integral part of this affidavit. The defendant has filed a written statement making baseless and false allegations that I do not have any right over the plaint schedule property.
  4. In order to rebut these false claims and to establish my title over the property, I am constrained to seek amendment of the plaint to include a prayer for declaration of ownership. This is essential to avoid multiplicity of legal proceedings and to obtain full relief.
  5. Hence, I respectfully seek leave of this Hon’ble Court to amend the plaint as follows:
    • To insert para 3(b): “The plaintiff is the absolute owner of the plaint schedule property and he is having rights over the plaint schedule property.”
    • To insert para 5(b): “The plaintiff seeks a declaration that he is absolute owner of the plaint schedule property. The present market value is Rs. 10,00,000/- on which 3/4th Market Value is Rs. 7,50,000/- on which a Court Fee of Rs. 3,750/- is paid under Section 24(d) of the Court Fees and Suits Valuation Act.”
    • To insert para 7(a)(2): “For a declaration that the plaintiff is the absolute owner of the schedule property.”
  6. If the above amendment is not allowed, I will suffer irreparable loss and hardship.

Deponent
(Signature) Arjun Kumar

Solemnly affirmed and signed before me on this the 6th day of June, 2025. The contents of the affidavit were read over and explained to the deponent in Telugu and upon admitting the same to be true and correct, he signed/thumb-marked below.

Place: New Delhi
Date: 6th June 2025

Advocate for the Petitioner
(Sd/-) [Advocate’s Name]