Application for Amendment of Pleadings (Order 6 Rule 17) Affidavit.
In the court of………..
1. That there is a mistake in calculating the amount due on the bond in suit and that it appears on a proper calculation as given in the schedule annexed to this petition that your petitioner is entitled to Rs. 580 and Rs. 380 as stated in the plaint, from the defendant.
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2. The petitioner will be put to considerable loss if the said mistake is not corrected.
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3. The petitioner therefore, prays that the plaint may be amended by inserting in it the correct amount due as given in the schedule hereunder in place of the schedule given in the plaint and that this petition may be made a part of the plaint. The petitioner undertakes to pay the deficit court fees which will be required on the amendment being allowed.
SCHEDULE Statement of the correct amount due.
Verification CAVEAT U/S 148-A C.P.C.
1. The petitioner lodges the caveat against the respondent and prays for prior notice before granting order in favour of the respondent.
2. I am the owner and possessor of the petition schedule property I hold title deeds as well as Adangal to prove my title and possession.
3. XY, who is my adjoining farmer wants to grab my property and has been making all sorts of attempts to grab the same. I came to know that XY is likely to file a case before the Honourable Court and ask for an ex parte interim order. The petitioner humbly submits that the petitioner would suffer irreparable loss should the court grant any order in favour of XY without hearing the petitioner.
4. The petitioner therefore prays that if the Court proposes to pass any order in favour of the respondent, prior notice may be issued to the petitioner and the petitioner may be accorded an opportunity of being heard.
5. Hence the caveat.