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Petition to amend the written statement

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

Neha Sharma

…Petitioner/Defendant

Vs.

Arjun Kumar

…Respondent/Plaintiff

Petition filed on behalf of the Petitioner/Defendant under Order 6 Rule 17 CPC

For the reasons stated in the accompanying affidavit, the petitioner prays that this Hon’ble Court may be pleased to amend the written statement by adding para 4(a) as mentioned hereunder, and to pass such other orders as the Hon’ble Court deems fit and proper in the circumstances and in the interest of justice.

Amendment to be made:

To add para 4(a) — “The age of ink and the revenue labels affixed on the suit pronote are not of the year 2023.”

Place: New Delhi
Date: 6th June 2025

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

N.B: For filing the petition under Order 6 Rule 17 CPC, there is no need to file a separate application for consequential amendment under Rule 28 of the Civil Rules of Practice. It can be mentioned in the amendment application itself. After amendment, rejoinder shall be filed by the plaintiff.

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, Neha Sharma, W/o Ramesh Kumar, Hindu, aged about 35 years, Businesswoman, R/o 123, Green Park, New Delhi, do hereby solemnly affirm and state on oath as follows:

  1. I am the petitioner/defendant in the suit and well acquainted with the facts of the case.
  2. The plaintiff filed the suit against me for recovery of an amount alleged due on a rank forged pronote. I filed my written statement denying the allegations and stating that the suit pronote is a rank forgery and that I never borrowed any amount from the plaintiff. The suit pronote is fabricated due to misunderstandings between me and the plaintiff.
  3. The written statement may be read as part and parcel of this affidavit.
  4. Recently, after verifying the suit pronote with the permission of this Hon’ble Court, I came to know that the age of the ink and the revenue labels affixed on the pronote are not from the year 2023 — the date mentioned on the pronote.
  5. I was unable to mention these facts in my original written statement as this information came to light only after examination.
  6. Hence, I pray that this Hon’ble Court may be pleased to allow me to amend my written statement to add para 4(a) as follows:
    • “The age of ink and the revenue labels affixed on the suit pronote are not of the year 2023; the pronote was apparently prepared just before filing the suit.”
  7. Else, I will suffer irreparable loss.

Deponent
(Signature) Neha Sharma

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, she signed/thumb-marked below.

Place: New Delhi
Date: 6th June 2025

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