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Improvements

(Querist) 17 March 2013 This query is : Resolved 
Improvements are sought in the following draft application to be filed in a civil court for amendment of plaint where notice to defendent has not yet been issued:




In the court of……………………………………..
Suit no. ……………….

……………….. Plantiff
Versus
………………………….Defendant


APPLICATION FOR AMENDMENT OF PLAINT

The Applicant respectfully submits as under:

1. That the applicant is the plaintiff in the above noted suit which is fixed for……..

2. that the applicant prays to make following amendments in the plaint as these are imperative for proper and effective adjudication of the case:

a) The following may be added at the end of para ……… of the Plaint:

……………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………..


b) Para……… of the Plaint be replaced by the following new Para………
………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………

3.That the above prayed amendments will not change the nature of the suit.

4. That it is humbly prayed that in the interest of justice the application as per submissions made above may be allowed otherwise irreparable loss will be causes to the applicant/Plaintiff.

Place:
Date:

Applicant

Verification

Verified at Delhi on this day of ………2013 that the contents of paras 1 to 3 of the Application are true to my knowledge and para 4 is prayer to this Hon’ble Court.

Applicant










Nadeem Qureshi (Expert) 17 March 2013
The application can be drafts depend on the facts and circumstances of the case. but as a format it is nice
prabhakar singh (Expert) 17 March 2013
The form is okay.
R.K Nanda (Expert) 17 March 2013
take help of lawyer.
Raj Kumar Makkad (Expert) 17 March 2013
It shall be better if you add one more paragraph to the effect that the proposed amendment shall not prejudice the respondent/defendant.
abhimanyu (Querist) 18 March 2013
Thanks Experts.

It may be advised whether there is any need to give a comparative statement of amendments proposed and earlier submissions separately or copies of amended plaint alongwith application for amendments, like the one proposed above, and affidavit would suffice.
prabhakar singh (Expert) 18 March 2013
amended plaint copy is furnished after amendment is allowed and carried out in the plaint.
abhimanyu (Querist) 18 March 2013
Whether there is any need to give a comparative statement of amendments proposed and earlier submissions separately in the application for amendment.
prabhakar singh (Expert) 18 March 2013
No!You seems to be adventurous!You are advocate or party in person?
Raj Kumar Makkad (Expert) 18 March 2013
It is better to submit comparative statement of amendment.
Devajyoti Barman (Expert) 18 March 2013
Take help of an advocate. if you are an advocate and consult your seniors.
abhimanyu (Querist) 18 March 2013
Advice has been sought to avoid delay in the case.
ajay sethi (Expert) 18 March 2013
advisable to get it drafted by a lawyer . mention in detail amendments sought
Adv k . mahesh (Expert) 18 March 2013
well drafted


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