A suit is about to be dismissed for default. Court has framed issues. Some of the issues I want are not framed. Also, I omitted to plea certain defenses and want to file an application to amend. Should I do so by filing an application to amend my WS so that my defenses are not deemed to be waived? Or will the dismissal for default have no impact on the basis that I did not plea that defense?
Suit is pending in Pune, Maharashtra.