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 Petition to receive additional written statement

IN THE COURT OF THE CITY COURT, 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. 8 R. 9 and Sec. 151 of CPC

For the reasons stated in the accompanying affidavit, the petitioner prays that the Hon’ble Court may be pleased to grant permission to receive the additional written statement filed herewith, 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

IN THE COURT OF THE CITY COURT, 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 suit and petitioner herein, and I am well acquainted with the facts of the case.
  2. The plaintiff is a money lender engaged in money lending business without any valid license. She used to lend money and recover it through daily basis installments.
  3. I borrowed an amount of Rs. 1,50,000/- from the plaintiff and executed the suit promissory note merely as security. I have been regularly making daily payments, which were recorded in a small pocket notebook provided by the plaintiff.
  4. However, I inadvertently failed to include this plea in my original written statement — namely, the fact that the plaintiff has no money lending license and that the suit itself is not maintainable under law.
  5. These facts are vital for proper adjudication of the matter and in the interest of justice.

Hence, I therefore pray that the Hon’ble Court may be pleased to grant permission to file the additional written statement containing the above submissions.
Else, I will be put to irreparable loss and immense hardship.

Deponent

Solemnly affirmed and the contents of the affidavit read over to the deponent and explained in Telugu. The deponent admitted the contents as true and correct and signed/thumb-marked before me this the 6th day of June 2025.

Place: New Delhi
Date: 6th June 2025

Advocate