Application for Amendment of Plaint

IN THE COURT OF THE LEARNED court_designation, district

Civil Suit No. suit_number of year

plaintiff_name, son/daughter of plaintiff_father, resident of plaintiff_address, holding CNIC No. plaintiff_cnic ... Plaintiff

VERSUS

defendant_name, son/daughter of defendant_father, resident of defendant_address, holding CNIC No. defendant_cnic ... Defendant

APPLICATION FOR AMENDMENT OF PLAINT UNDER ORDER VI RULE 17 OF THE CODE OF CIVIL PROCEDURE 1908

Respectfully sheweth:

1. That in the course of the present suit, bearing Civil Suit No. suit_number of year, it has become necessary and expedient to amend the plaint in order to determine the real questions in controversy between the parties.

2. That the following amendments are sought to be made to the plaint: amendment_details.

3. That the amendments sought are nature_of_amendments, and do not introduce any new cause of action. The amendments only clarify and refine the issues already raised in the original plaint.

4. That the reason for seeking the amendment is reason_for_amendment. The Plaintiff has come to know these facts time_when_facts_discovered.

5. That the Defendant will not be prejudiced by the grant of this application, as lack_of_prejudice_explanation. The Defendant has already filed his Written Statement and has had full opportunity to meet the Plaintiff's case.

6. That delay, if any, in filing the present application is explained by explanation_for_delay, and does not prejudice the Defendant.

7. That the amendment is necessary to prevent multiplicity of suits and for the proper administration of justice.

8. That the Plaintiff prays leave to amend the plaint and has prepared an amended plaint incorporating the proposed changes. A copy of the amended plaint is annexed as Annexure 'A'.

PRAYER

It is, therefore, most respectfully prayed that this Honourable Court may be pleased to:

(a) Allow this application for amendment of the plaint;

(b) Grant leave to the Plaintiff to amend the plaint as shown in Annexure 'A';

(c) Grant such time to the Defendant as may be necessary to file a fresh Written Statement, if so required;

(d) Proceed with the suit on the basis of the amended plaint; and

(e) Grant any other relief deemed just and proper in the circumstances.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of the above application are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ plaintiff_name Plaintiff Through: _____________________________ counsel_name Advocate