Framing Additional Issue Deponent Affidavit

In the court of
In the matter of:
_____   VERSUS   _____
   SUIT FOR SPECIFIC PERFORMANCE
  Application U/O _____  Rule _____  of CPC for Framing Additional Issue.
                                       Affidavit
I, _____ S/o _____ age _____ R/o _____, do hereby solemnly affirm and declare as under:-
1- That the above noted case is pending before this Hon’ble court for adjudication and is fixed for _____.
2- That the deponent has filed the application for framing the additional issue and contents of the application may kindly be read as part and parcel of this affidavit.
3- 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:- _____
4- 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.
5- That the Hon’ble court is very competent to amend/frame the additional issue at any stage for proper adjudication the case.                                                                                                                          

Deponent

VERIFICATION:

 Verified that the contents of paras No.1 to 2 of the affidavit are true to best of my knowledge and para no. 3 to 5 are also true to best of my belief as information received through my counsel. The contents of this affidavit have been read over to me in Hindi by my counsel.
 Verified at _____ on _____
 

Deponent