IN THE
HIGH COURT OF DELHI AT NEW DELHI
C.M. NO.________ OF 20---
IN
W.P (C) NO.__________ OF 20--
In the matter of:
_____________ ...PETITIONERS
VERSUS
______________ …RESPONDENTS
INDEX
|
S.No. |
Particulars |
Page
No. |
|
1. |
An application on behalf of the
Petitioner for permission to file additional documents |
|
|
2. |
Annexure
P/---- : |
|
Filed By:-
New Delhi
Date : Advocate
IN THE
HIGH COURT OF DELHI AT NEW DELHI
C.M. NO.________ OF 20---
IN
W.P (C) NO.__________
OF 20--
In the matter of:
_____________ ...PETITIONERS
VERSUS
______________ …RESPONDENTS
AN APPLICATION UNDER SECTION 151 CPC ON BEHALF OF PETITIONER FOR PERMISSION TO FILE ADDITIONAL DOCUMENTS
MOST RESPECTFULLY SHOWETH :
1. That the petitioner has filed the accompanying writ petition inter-alia seeking quashing of the impugned order dated -------------.
2. That It is apparent from the aforesaid -------------------- The petitioner has further been -------without there being any justifiable cause.
3. It is submitted that the petitioner filed -------------------.
4. It is pertinent to state that the order dated-----------------. The petitioner had sought change in-----------------.
5. That, however, in a brazen disregard to the order passed by Hon’ble High Court--------, was continued by the respondents---------------.
6. The Enquiry Officer respondent no--------- and on the basis of the said report, the petitioner was dismissed from services vide impugned order dated -----------.
7. It is submitted that such dismissal of the petitioner, in pursuance --------------. The petitioner filed a contempt petition being ------------before this Hon’ble Court. The respondents,---------------..
8. That this Hon’ble Court vide order dated ----------as---------------. The copy of order dated ------------is enclosed herewith as Annexure P/-----.
9. That it is humbly prayed that the contents of the accompanying writ petition may kindly be read as part and parcel of the present application and the same are not being repeated herein for the sake of brevity.
10. That the aforesaid document is necessary to present the true and correct factual position as regards to legal remedies availed by the petitioner to challenge the impugned action of the respondent as being ex-facie arbitrary, discriminatory and illegal and is in utter disregard to the principles of natural justice.
11. That the interest of the justice will be served if the said documents are taken on record and is considered for the purposes of the present writ petition. The said documents will help in a just and fair adjudication of the writ petition.
12. That no prejudice shall be cause to the respondents if the said document is taken on record since there cannot be any dispute as to the veracity of the said document.
PRAYER
It
is, therefore, most respectfully prayed this Hon'ble Court may graciously be
pleased to:
(i)
Permit the petitioner to file
Annexure P/-- as an additional document; and
(ii)
Pass such other or further orders
as may deem fit and proper in the interest of justice.
Date : Petitioner
New Delhi
Through
Advocate
IN THE
HIGH COURT OF DELHI AT NEW DELHI
C.M. NO.________ OF 20---
IN
W.P (C) NO.__________ OF 20--
In the matter of:
_____________ ...PETITIONERS
VERSUS
______________ …RESPONDENTS
AFFIDAVIT
I, -----------W/o -----------R/o-------------, presently at Delhi aged about _____ years, do hereby solemnly declare and affirm as under:-
1) That I am the petitioner in the above mentioned petition and am well conversant with the facts of the case and thus competent to depose the present affidavit.
2) That the accompanying application for has been drafted by the counsel as per my instructions and has been read over and explained to me in vernacular and the same is correct to the best of my knowledge.
3)
That the contents of the application may kindly be read as
part and parcel of the present affidavit and the same are not being repeated
here for the sake of brevity.
DEPONENT
Verification
Verified at New Delhi on this day of ------ that the contents of the above writ petition are true and correct to my knowledge and belief and nothing material has been concealed therefrom.
DEPONENT
