IN THE HIGH COURT OF………………..
LA. No………………… of 19………………..
Civil Suit No…………………………. of 19………………..
C. F…………………………………………………………. Plaintiff
versus
C. D……………………………………………………… Defendant
Date of hearing………………
Respectfully Showeth:
I. That after order of notice to the defendants by this Hon’ble Court, defendants No. 3 and 4 who are bent upon usurping the plaintiffs’ land, involved in the present suit, instead of filing the written statement and reply to stay application, raised unnecessary controversy with the aim of prolonging the decision of the real issue by this Hon’ble Court and made application that for the relief of declaration against………… and………….. which are also the parties in the suit, service of notices is a mandatory requirement and so on the plaintiff has thought it best to give up the relief of declaration in the circumstances and to amend the plaint accordingly with a light amendment in the averment relating to cause of action to the following effect which may kindly be permitted as the same does not in any way change the context and nature of the suit to the detriment of the defendants, the suit being in its earlier stage:
1. The title of the suit may kindly be read as 4Suit for Permanent Injunction’.
2. In para No………… of the plaint, in place of words 4from time to time’ the words ‘First week of………….. onward’, may kindly be read.
3. In para No……. of the plaint in the first line after the word ‘plaintiff the following words ‘in the first week of………. when defendants No. 3 and 4 started threatening the plaintiff and then’, may kindly be read as added between the word ‘plaintiff and the word ‘on’.
4. In the prayer clause sub-clause (1) may kindly be treated as deleted and in the end of sub-clause No. (2) the following words may kindly be treated as added ‘measuring…….. sq. yds. out of khasra No………. ‘
It is prayed that the above amendment may kindly be permitted in the plaint an amended copy of which is enclosed herewith for orders as to its being placed on record, annexures with original plaint may kindly be treated as un-disturbed.
Prayed accordingly.
Place:
Plaintiff
Date: Through Advocate