IN THE COURT OF……………………………
Suit No……………………………. of 200
In the Matter of: –
AB………………………………………………………….. Plaintiff
versus
CD………………………………………………………. Defendant
Most Respectfully Showeth: –
1. That the presnt suit has been filed by the applicant-plaintiff for redemption of the mortgaged property registered under mortgage deed dated…………………………… The certified copy of the aforesaid mortgage deed is annexed hereto and marked as Annexure…………………………….
2. That it is submitted that the factum of mortgage has been denied by the defendant.
3. That the original mortgage relates to matters concerning the present suit. It is therefore expedient in the ends of justice and for the purpose of disposal of the case that this Hon’ble Court may direct defendant to make discovery on oath of the documents that is original deed which is in his possession and power.
PRAYER
It is therefore most respectfully prayed that the defendant may be ordered by this Hon’ble Court to make disclosure on oath of the documents referred to in the application which is in his possession and power and which pertains to the matter in question in the suit.
It is prayed accordingly Applicant
Through Advocate
Place:……………………………
Dated:……………………………

AFFIDAVIT
IN THE COURT OF……………………………………………..
Suit No……………………………. /200
In the matter of
AB…………………………………………… Plaintiff/Petitioner
versu
CD…………………………………….. Defendant/Respondent
AFFIDAVIT
I………………………………………………………………. resident of …………………………………… do hereby solemnly affirm and declare as under: –
1. That I am the…………………………… in this case and hence competent to swear this affidavit.
2. That the contents of the accompanying application are true and correct.
DEPONENT
VERIFICATION
Verified at…………………………… on this…………………………… day of …………………………… that the contents of the above affidavit are true and correct to my knowledge.
DEPONENT