WEEK 14-APLLICATION UNDER ORDER 6 RULE 17

IN THE COURT OF MR. ____________,LEARNED CIVIL JUDGE, LAHORE.

IN RE:
___________ V E R S U S __________

A P P L I C A T I O N ON BEHALF OF THE PLAINTIFF/APPLICANT UNDER ORDER 6 RULE 17 C.P.C. FOR AMENDMENT IN PLAINT.

Respectfully Sheweth:
1. That titled civil suit is pending for adjudication before this Learned Court for today i.e. ____.
2. That through the instant application, the applicant humbly seeks indulgence of this Learned Court for seeking permission to amend Clause I of paragraph No. 4 of the plaint; proposed amendment is as following:
“It is pertinent to mention here that the defendant at various occasions demanded huge amount of money from the plaintiff. Because the plaintiff had always been earning much more than the defendant as she was working in a higher scale, therefore, she had always fulfilled his demands and gave him a huge amount of money when the marriage was intact and she is also entitled to file a separate suit for recovery of said amount.”
3. That inadvertently, aforesaid fact i.e. proposed amendment could not be added in the plaint, therefore, permission is sought from this Learned Court for amendment of plaint as stated above inter-alia on the following:
G R O U N D S
i. That the aforesaid proposed amendment is not inconsistent with the original version of the applicant taken in the plaint.
ii. That the omission to mention the sentence stated above as proposed amendment was neither intentional nor deliberate rather it was inadvertently not mentioned.
iii. That the proposed amendment goes to the root of the case and in order to determine the real question in controversy by this Learned Court, it is necessary that proposed amendment may be allowed.
v. That if the applicant is not allowed to amend her plaint as proposed above, irreparable loss will be suffered by her.
vi. That applicant humbly seeks permission of this Learned Court to raise additional grounds at the stage of arguments.
P R A Y E R
In aforementioned circumstances, it is humbly prayed that applicant in hand may kindly be accepted & the applicant may graciously be allowed to amend her plaint as stated above.

APPLICANT
THROUGH
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