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Petition to add LR’s of the plaintiff

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

Late. Ramesh Chandra

…Plaintiff (Deceased)

1. Rajesh Ramesh, S/o Late Ramesh Chandra, aged 40 years, Hindu, Businessman, R/o 10-1-15, Begumpet, Hyderabad
2. Rekha Sharma, W/o Late Ramesh Chandra, aged 62 years, Hindu, Housewife, R/o 10-1-15, Begumpet, Hyderabad
3. Nikhil Ramesh, S/o Late Ramesh Chandra, aged 35 years, Hindu, Engineer, R/o 10-1-15, Begumpet, Hyderabad

… Petitioners (Proposed Plaintiffs 2 to 4 – Legal Representatives of Deceased Plaintiff)

Vs.

Arun Verma

…Respondent/Defendant

Petition filed on behalf of the petitioner/ Plaintiff under Or.22 R.3 and R. 28 of Civil Rules of Practice.

The Petitioners respectfully submit as follows:

That the Hon’ble Court may be pleased to implead the petitioners 2 to 4 as Plaintiffs 2 to 4, being the legal representatives of the deceased original plaintiff Late Ramesh Chandra, and further be pleased to consequentially amend the plaint, and to pass such other orders as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case and in the interest of justice.

Place: Hyderabad
Date: 11th June 2025

Advocate for the Petitioners

Consequential Amendments in the Plaint (as required)

  1. Add Petitioners 2 to 4 in both short and long cause title as legal representatives of the deceased first plaintiff.
  2. In Paragraphs 3 and 4, amend the word “plaintiff” to “first plaintiff”.
  3. In Paragraph 7 (Prayer clause), amend “plaintiff” as “Plaintiffs 2 to 4”.

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

Petitioners

Vs.

Defendant

Affidavit

I, Rajesh Ramesh, S/o Late Ramesh Chandra, Hindu, aged about 40 years, Occupation: Businessman, R/o 10-1-15, Begumpet, Hyderabad, do hereby solemnly affirm and state as follows:

  1. I am the 1st petitioner herein and the son of the deceased plaintiff. I am well acquainted with the facts of the case.
  2. The suit was filed by my father Late Ramesh Chandra for recovery of an amount due from the defendant.
  3. During the pendency of the suit, my father passed away intestate on 05.04.2025, leaving behind the following as his only legal heirs:
    • Myself: Rajesh Ramesh (S/o)
    • Rekha Sharma (W/o)
    • Nikhil Ramesh (S/o)
  4. There are no other legal heirs apart from us.
  5. It is necessary that we, as the legal representatives of the deceased plaintiff, be brought on record as Plaintiffs 2 to 4, and the plaint be suitably amended as per the accompanying petition.

Hence, I respectfully pray that the Hon’ble Court may be pleased to allow the petition, add us as plaintiffs, and permit the consequential amendments to the plaint, failing which we will be put to irreparable loss and hardship.

Deponent

Solemnly affirmed and signed before me, after the contents of this affidavit were read over and explained in Telugu, and understood by the deponent to be true and correct.

Place: Hyderabad
Date: 11th June 2025

Advocate