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Petition to add petitioners as plaintiffs in the suit

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

Arjun Kumar (Deceased)

…First Plaintiff

1. Rajiv Kumar, S/o Arjun Kumar, aged 32 years, Hindu, Businessman,
R/o 123, Green Park, New Delhi
2. Rohit Kumar, S/o Arjun Kumar, aged 28 years, Hindu, Private Employee,
R/o 123, Green Park, New Delhi

…Petitioners/Proposed Plaintiffs 2 and 3

Vs.

Neha Sharma

…Respondent / Defendant

Petition filed on behalf of the Petitioner /Plaintiff under Or.22 R. 10 and 151 of CPC

The petitioners respectfully submit that for the reasons stated in the accompanying affidavit, this Hon’ble Court may be pleased to:

  1. Add the petitioners as Plaintiffs 2 and 3 in the above suit;
  2. Consequentially amend the plaint as prayed below; and
  3. Pass such other order or orders as this Hon’ble Court deems fit and proper in the circumstances of the case and in the interest of justice.

Consequential Amendments to the Plaint:

  1. To add the petitioners as Plaintiffs 2 and 3 in the short and long cause title.
  2. To amend the word “plaintiff” as “deceased first plaintiff” wherever it occurs in the plaint.
  3. To amend the prayer portion: the word “plaintiff” may be replaced by “plaintiffs 2 and 3.”

Place: New Delhi
Date: 6th June 2025

Advocate for the Petitioner

Note: A similar application may be filed to implead defendants as LRs of a deceased person where a will is executed.

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

Arjun Kumar (Deceased)

– Plaintiff

Vs.

Neha Sharma

…Defendant

Affidavit

I, Rajiv Kumar, S/o Late Arjun Kumar, Hindu, aged about 32 years, Occupation Businessman,
R/o 123, Green Park, New Delhi, do hereby solemnly affirm and state as follows:

  1. I am the first petitioner herein and am well acquainted with the facts of the case.
  2. My father, Late Arjun Kumar, filed the above suit for specific performance of contract and other reliefs against the defendant.
  3. During the pendency of the suit, my father passed away on 12th February 2025.
  4. In his lifetime, he executed a registered will dated 3rd January 2024, bequeathing the suit schedule property jointly to myself and my brother Rohit Kumar.
  5. Based on this will, we are the rightful claimants and necessary parties to the pending proceedings.

Therefore, I respectfully pray that this Hon’ble Court may be pleased to:

  • Add us as Plaintiffs 2 and 3 in the suit, and
  • Allow consequential amendments to the plaint as stated in the petition.

Otherwise, I shall be put to irreparable loss and injury.

Deponent: Rajiv Kumar

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

Place: New Delhi
Date: 6th June 2025

Advocate