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Petition to answer the Interrogatories

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

Arjun Kumar

…Petitioner/Defendant

Vs.

Neha Sharma

…Respondent/Plaintiff

Petition filed on behalf of the petitioner/defendant under Or.11 R.1 and 151 of CPC.

For the reasons stated in the accompanying affidavit, the petitioner respectfully prays that the Hon’ble Court may be pleased to grant leave and direct the respondent/plaintiff to deliver the following interrogatories for examination, and to direct the respondent/plaintiff to answer them, and to pass such other orders as the Hon’ble Court deems fit and proper in the circumstances and in the interest of justice.

Place: New Delhi
Date: 6th June 2025

Advocate for Petitioner

To Answer the Following Interrogatories

  1. Whether the plaintiff obtained a promissory note from Mr. Rakesh Mehta for Rs. 1,50,000/- on 10th March 2022?
  2. Whether the plaintiff obtained a promissory note from Mr. Sunil Verma for Rs. 2,00,000/- on 15th May 2023?
  3. Whether the plaintiff filed a suit in O.S. No. 788/2023 on the file of District Court, New Delhi against Mr. Sunil Verma for recovery of pronote debt, and whether the defendant in that suit filed his written statement stating that the plaintiff is a money lender without having any valid and proper license to conduct money lending business?

Advocate for Petitioner/Defendant

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

Neha Sharma

…Plaintiff

Vs.

Arjun Kumar

…Defendant

Affidavit

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

  1. I am the defendant in the above suit and the petitioner herein. I am well acquainted with the facts of the case.
  2. I respectfully submit that the plaintiff has filed this suit with baseless and frivolous allegations to recover an amount under a pronote. I have already stated in my written statement that the plaintiff is involved in money lending business without any proper and valid license.
  3. It is further submitted that the plaintiff has, in the past, obtained several pronotes from other individuals and filed suits against them as well. One such suit is O.S. No. 788/2023 against Mr. Sunil Verma for recovery of a pronote debt of Rs. 2,00,000/-, where the defendant in that suit alleged that the plaintiff is operating without a valid license.
  4. To prove that the plaintiff is a habitual money lender lacking proper authorization, I request the Hon’ble Court to allow the following interrogatories to be answered by the respondent/plaintiff:
    • Whether the plaintiff obtained a promissory note from Mr. Rakesh Mehta for Rs. 1,50,000/- on 10th March 2022?
    • Whether the plaintiff obtained a promissory note from Mr. Sunil Verma for Rs. 2,00,000/- on 15th May 2023?
    • Whether the plaintiff filed a suit against Mr. Sunil Verma for recovery of pronote debt, and whether in that suit the defendant stated that the plaintiff is a money lender without a valid license?
  5. These interrogatories are necessary and relevant to the issue in the current suit and will assist in securing justice.

Hence, I pray that the Hon’ble Court may be pleased to direct the respondent/plaintiff to file an affidavit answering the above interrogatories.
Else, I will be put to irreparable loss.

Deponent
(Arjun Kumar)

Solemnly affirmed and the contents of the affidavit were read over to the deponent and explained in Telugu, and he admitted them to be true and correct and signed before me on this the 6th day of June 2025.

Place: New Delhi
Date: 6th June 2025

Advocate