Application for Framing Additional Issue

In the court of _____
In the matter of:
_____   VERSUS   _____
SUIT FOR SPECIFIC PERFORMANCE
 Application U/O _____  Rule _____  of CPC for Framing Additional Issue.
Sir,
 The applicant humbly submits as under: –
1- That the above noted case is pending before this Hon’ble court for adjudication and is fixed for _____
2- That inadvertently the necessary issue could not be framed while it was mentioned in the preliminary objections and the following issue is necessary for proper adjudication the case. The  issue as under:- _____
3- That if the application for framing the additional issue is allowed then there is no loss to any one and if the application has not been allowed then there will be great prejudice to the defendant.
4- That the Hon’ble court is very competent to amend/frame the additional issue at any stage for proper adjudication the case
 It is, therefore, prayed that in the interest of justice, the application for framing the additional issue no. __ as mentioned in the para no. 2 of the application may kindly be accepted and the additional issue may kindly be framed. It is prayed accordingly.
Dated: _____                  

       APPLICANTS/DEFENDANT
_____ S/o _____ R/o _____   

Through counsel:
_____ Advocate, _____