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IN THE HON’BLE CITY CIVIL AND SESSIONS COURT, MUMBAI.

ORDINARY ORIGINAL CIVIL JURICDICTION

Civil suit No. 319 of 2012

Chetan Bhagat s/o Shekhar Bhagat, Hindu, aged 40 years,


r/o 121/C, Jalsa bungalows, Santacruz, Mumbai, 302021. [Plaintiff]

Versus

Raju Hirani s/o Sanjay Hirani, Hindu, aged 43 years,


r/o G-22, Galaxy Apartment, Bandra, Mumbai, 302011. [Defendant]

I.A. No – 3

Mr. Raju Hirani [Applicant]

v/s

Mr. Chetan Bhagat [Opponent]

APPLICATION U/O-11 RULE-1 CPC FOR INTERROGATORIES


CODE OF CIVIL PROCEDURE – APPENDEX C-FORM NO 1
INTERROGATORIES (O. 11, r. 1)

1
The Applicant abovementioned most respectfully submits as herein under: -

i) That the above titled case is pending in this Hon’ble Court.

ii) As the matter of facts, the entire case can be decided on merit via discovery by

Interrogatories under Order 11 of the code of civil procedure.

iii) Therefore, the applicant requests that the opponent may be ordered to admit or to

deny on oath the document list and the question list which is to submitted by the

applicant.

iv) That, the reason behind filing this application is to save the expenses by enabling

the applicant to obtain from the opponent necessary and relevant information to

the issues in the dispute between the parties and to obtain admissions on the facts

which the opponent needs to prove or have as issue with.

v) That, all the details relating the interrogatories and the list of the questions will be

submitted to the court by the applicant after once the court passes this order of

interrogatories. (o.11, r.1)

vi) That, the present filed application should be passed in the interest of the justice

and as the court thinks fit as this order can either play major part to support the

case of the opponent or it will destroy it completely.

vii) That, under Rule-1 of Order-11 CPC a party is given the power to interrogate his

opposite party with a view to discover what case he has to meet and facts to relied

upon and to find out what is really in issue.

viii) That, if the present application is permitted by this Hon’ble Court, the time for

concluding following trial would be cut short and will also save the expenses of

the litigants.

ix) The list of questions is attached in Annexure A. The defendant is willing to

pay the costs.

2
PRAYER: -

In the light of the above, the applicant in the above matter most respectfully and

humbly prays that this Hon’ble court under the circumstances that the Interrogatories

application may kindly accepted and allow the applicant to put the Interrogatories

after the required notice, in the interest of justice.

Place: Mumbai (Maharashtra) Mr. Raju


Hirani

Date: 20th June, 2012 (Applicant)

3
ANNEXURE A
(ORDER 11 RULE 4)

List of Questions

Interrogatories on behalf of the above-named Applicant (Defendant), Mr. Raju

Hirani, for the examination of the above-named Opponent (Plaintiff) Mr. Chetan

Bhagat:

1. What are the exact similarities between the script of the play and the film?

2. Was the plaintiff not given compensation for the entire six months he worked

with the defendant by cheque?

3. If you contend that the defendant has committed fraud and misused your

playwright without your permission, present the circumstances which state the

basis of your contention.

4. Was the plaintiff not given compensation for the credit of the original script?

5. Identify every representation that you contend is false or misleading that the

Defendants expressly made in their statements and state the basis of your

contention.

6. Did any kind of contact that had taken place between you and the defendant

that had taken place after you came to know about the fraud.

7. Please explain the conversation under question 6.

The Opponent (plaintiff), Mr. Chetan Bhagat, is required to answer the

interrogatories numbered 1 to 7.

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Date – 20th June 2012 Sahil Shah

Advocat

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