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Petition for framing additional issue

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

Arjun Kumar

… Petitioner / Plaintiff

Vs.

Neha Sharma

… Respondent / Defendant

Petition filed on behalf of the petitioner/plaintiff under Or.14 R.5 and 151 of CPC.

For the reasons stated in the accompanying affidavit, the petitioner prays that this Hon’ble Court may be pleased to frame the following additional issues and pass such other order or orders as this Hon’ble Court may deem fit and proper in the circumstances of the case and in the interest of justice.

Place: New Delhi
Date: 6th June 2025

Advocate for Petitioner

Additional Issues Proposed:

  1. Whether the defendant has willfully suppressed material facts from the court?
  2. Whether the plaintiff is entitled to any further reliefs not specifically claimed in the plaint?

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, Occupation: Businessman, residing at 123, Green Park, New Delhi, do hereby solemnly affirm and state on oath as follows:

  1. I am the plaintiff in the above suit and the petitioner herein. I am well acquainted with the facts and circumstances of the case.
  2. The Hon’ble Court has already framed certain issues after going through the pleadings of both sides, and the matter is now posted for trial.
  3. However, upon closer examination and legal advice, it is necessary that the following additional issues be framed to secure a just and complete adjudication of all matters in controversy between the parties.
  4. There is no prejudice or hardship that would be caused to the respondent/defendant by the framing of these additional issues.
  5. The following issues are required to be framed: i. Whether the defendant has willfully suppressed material facts from the court?
    ii. Whether the plaintiff is entitled to any further reliefs not specifically claimed in the plaint?
  6. In the interest of justice and fair trial, it is just and necessary that this Hon’ble Court may frame the above additional issues.

Hence, I humbly pray that this Hon’ble Court may be pleased to frame the additional issues mentioned above in the suit, and pass such other and further orders as may be deemed fit and proper in the circumstances of the case.

Deponent: Arjun Kumar

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

Place: New Delhi
Date: 6th June 2025

Advocate