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IN THE COURT OF THE LD.

RENT CONTROLLER, PATIALA


HOUSE COURT, DELHI

CIVIL RENT PETITION NO. 432 of 2020

MEMO OF PARTIES

Mr. A, aged 49 years, S/o Mr. J,


R/o House No. B-14/501, Patel
Chowk, Delhi

………PETITIONER
Versus

Mr. B, aged 37 years, S/o Mr. H,


R/o H.No. 24, New Lajpat Kunj,
Khandari, Near Choti Jail,
Master Plan Road, Transport
Nagar, Agra; currently residing
at H.No. B-41/501, First Floor,
Patel Chowk, Delhi.
……. RESPONDENT

Eviction Suit under Section 14 read with Section


25B of the Delhi Rent Control Act, 1958 directing
the respondent to vacate the premises on the
multiple grounds of the premises being used
commercial rather than residential purpose, default
in payment of 4 months’ rent by the respondents
and on the ground of bonafide personal necessity of
the petitioner for the use of the said premises.

Patiala Court, Delhi ………………….


Date: 20/08/2020 Sanya Gupta
Advocate
Counsel for Petitioner
If It May Please Your Worship

The Applicant most humbly requests and submits as follows:

1. That the titled suit is pending before this Ld. Court for adjudication and
has not been brought to the stage of trial. The applicant-cum-petitioner is
awaiting the reply to be filed by the respondent.
2. That through the instant application, the petitioner humbly seeks the
interference of this Ld. Court for seeking due permission to amend the
paragraphs bearing no. 4, 7 & 21 of the petition.
3. The proposed amendment in paragraph 4 stands as follows:
4. “That the standard rent agreement was signed between both the parties;
on “quarterly” basis which fixed the rent amount to the tune of Rs.
10,000/ - per ‘quarter’ respectively.
5. That the proposed amendment in paragraph no. 7 of the petition stands as
follows:
“That the respondent agreed to pay the rent on quarterly basis i.e January-
April, May-August, September- December respectively.”
6. That the proposed amendment in paragraph no. 21 of the petition stands
as follows: Quarter of Default Amt.-in-Arrears Total

RENT MONTH RENT AMOUNT


MAY- AUGUST Rs. 10,000/-

7. That inadvertently due to typographical error, the proposed amendments


were typed incorrectly in the concerned petition and therefore a bonafide
permission is sought from this Ld. Court for the amendment of petition to
serve the ends of justice and exercising due diligence on the part of the
petitioner.
PRAYER

In aforementioned circumstances, it is humbly prayed that the concerned


application in hand may kindly be accepted & the applicant may graciously
be allowed to amend his plaint as stated above.

Mr. A

(APPLICANT)

Through

Sanya Gupta

Counsel for the

Applicant

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