IN THE COURT OF SH. xn00000%, SENIOR CIVIL JUDGE, KARKARDOOMA COURTS: DELHI CASE NO- 000% INTHE MATTER OF - SH. Roomex PLAINTIFFS versus SH. 000001 DEFENDANT ‘APPLICATION ON BEALE OF THE PLAINTIFF UNDER ORDER VI RULE 17 READ WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 11908 FOR AMENDMENT OF PLAINT, MOST RESPECTEULLY SHOWETH . 1. The present suit has been fled by the Plants against the Defendant for @ decree of permanent, mandatory injunction and recovery of rent with interest @ 16% per annum with pendentelte& future interest as the defendant being tenant neithe vacating the Sut property not ‘paying rent tothe pantilfs. The present suit fs pending adjudication before this Hon'ble Court. The contents of the plant ae reiterated ‘ond reaffirmed and the same ae not repeated forthe soke of brevity. 2-The preset Aplin sing prefered bythe iti afer thecbserton of his Hon cout by way of an order dated ace passed onan apptaton ws 181 CP or drone ted to depos he et incur areas of ent andor cages led by ps Bodo the lors he Hable Cut obaved that nthe st nether alt hes cimed recovery ares ofr fe the meno a oe nore chimed ene prot or ur charges rth occupation out propery ale expan et agree5 That now he itis prefered the preset Appliaion ecking eae of hs Howe Court to accotdingl amend the Paint 4 The Piss accordingly Seking leave to amend Prayer proof the present Plant which pertains to present ute erat of ren 5. ew fhe above he Pint wishes amend the lowing paragraph or the purpose of areas of ent and hereore seks lave of this Home Court 1A. the paramo 13 which a olows “That the defendants tbl to pay the amount of Resa along wih pendent it and future nee able to py the cst and expenses of the preset suit and hepsi ar entitle to recive the said amount and the pints are further ented or any oer or farther "eet which the Hobie court may deem and proper. May be repaced with “That the defendants able to pay the amount of Rene with rer of et pendent lite ad future interest able to pay along the cst an expenses of he present suit and the plaintis are enfited to reeve the toll rer of ren after the expiration of Ret agreement fom 2 ‘ulate mace or 8 months as wells ure enti the vacation ost property long with 1% ineest from the due date tits reatizoton. As laste pins are frthe ented for any eter farther rat which the Hone court may deem it and proper” 8. The paragraph noe which sa flows: . Tht the volition ofthe suthas been asesed to xxx on which requ court fe of Rs, wnd-has been aie, May be replaced with ‘That the plait ated Rs xd cout fee with the plait and undertakes to fle deciet cout fees as and when requied with the retin and permission ofthis Hobe curt © Thelas Paragraph being the payer paragraph, which ia flows “is thereore most especialy prayed thot Honbe Court may Kindy passee ee ———$_—__*] HE therefore most respecthlly prayed thal Hon'ble Court may knly pas A Aeee We F the ants nd agint the defendant fr 8 Sum of RS. along wth 10% inte from the due date ti ization, 2 Pass. an order to direct the defendant to vacate the suit property of any person Ort ot arte eis may abo be ranted in tar of he pls nd api the eet hich hs Hoe Cut may dee and proper: ‘May be replaced with “Its therefore most respectful prayed that Hon'ble Court may kindly pass sox along with 18% interest from the due date tit its realization, 2Pass an order to decide the rate of rent after the expiry of rent agreement and pass a decree of money for total arrears of tent ater the expiration of Rent agreement trom motto aie for x months a well as utr rent Bl the vacation of Sut property alongwith TeX ert from the due date til its realization, 3 Pass an order to direct the defendant to vacate the suit property and aso direct to pay mesne profit & other charges for occupation ofthe suit Property 4A decree of permanent and mandatory inunction restraining the defendant, his agents, representatives, assignees or anybody climing though ‘oF under them from seling, alienating, transferring in any form & creating any thd pay interest in the suit property in favor of any person - SAny other or further reliefs may also be granted in favor of te plaintifs and against the defendant which this Hon ble Court may deem fit and proper.V0 EE EE iis 6.The aforesaid amendment is necessary in order to avoid the multiplicity of Migaions. 7. The Plaintif reserves its right to seek further amendments of the Plant, if necessary. The Paint further reserves it right to file the amended Plaint in due course, subject to the orders dicections of this Hon be Court ‘8. Its submitted thatthe present Application is bons fide and in the interest of justice. The same maybe kindly considered in ight ofthe above and this Hon'ble Court may be pleased to allow the same. the Plant shall accordingly take appropriate steps infor fling the ‘Amended Paint, as per the directions ofthis Hon'ble Cour. 9, {tis submitted that ne hardship or prejudice would be caused tothe Defendant if the present application is allowed as the suits stil inthe preliminary stage. The cause of action remains the same and nature of the suit would not change by way ofthe present amendment. The Plaintiff onty seeks to amend the elie for the arears of rent. 10. Inview ofthe facts and circumstances mentioned above, the Paint most respectfully prays that this Hon'ble Curt may be please to: ‘2. Allow the present application and permit the Plantif to amend the present paint and accordingly file the amended plant b. ass any such order(s) as this Hon'ble Court may deem fit and proper n the facts and circumstances ofthe present case, PLAINTIFF Date: THROUGH New Delhi ADVOCATE ‘Address: 90000000 ‘acseinininnricigainiaelalEmail: 00000, IN THE COURT OF SH. 1900 300000000%, TIS HAZARI COURTS, DELHI CASE NO X00 | IN THE MATTER OF: ‘SH. xn00008 _PLAINTIFES / VERSUS | ‘SH, na00000008 DEFENDANT. || ArnoaviT | saaonaa: W/o Sh Xec0000¢ R/O 209% 900,300, do solemnly state and affirm as under: ‘Mob.No.- XX00000000 1. That the deponent is Plaintiff no.1 in the present case. | am fully aware of the facts and circumstances of the present case and I am fully competent to swear and depose the present affidavit. 2. The accompanying Application has been drafted under my instructions and 1 have read and understood the contents of the same. | state that the contents therein are true to the best of my knowledge. VERIFICATION: DEPONENT MUM i |‘That the deponent is Plaintifno.1 in the present case. 1am fully aware ofthe facts and circumstances of the present case and {am fully competent to swear and depose the present affidavit. The accompanying Application has been drafted under my instructions and 1 have tead and understood the contents of the same. I state thatthe contents therein are true to the best of my knowledge. DEPONENT VERIFICATION: Verified at New Delhi on this _ day of 104 100, thatthe contents ofthe above affidavit are true to the best of my knowledge and belief No part of tis false and nothing material has Been concealed thereftom. DEPONENT