UNIVERSITY INSTITUTE OF LEGAL STUDIES

PANJAB UNIVERSITY
CHANDIGARH

CIVIL PROCEDURE CODE- 1

Project Report

Topic: “BASIC RULES OF PLEADINGS.”

Submitted To:- Submitted By:-

Dr. Karan Jawanda Akash Choudhary (122/19)

BA. LLB. (Hons.)

Sem:- 7
 ACKNOWLEDGMENT
History of all great works witness that no great work was ever
done without either active or passive support from a person
‘surrounding and from one’s close quarters. Thus, it is not
hard to conclude how active assistance from senior could
positively impact the execution of a project. I am highly
obliged to our faculty Dr. Karan Jawanda for her active
guidance throughout the completion of this project.
Last but not the least, I would also like to extend my
appreciation to those who could not be mentioned here but
have well played their role to inspire me behind the certain.
Akash Choudhary.
 CERTIFICATE OF ORIGINALITY

This is to certify that the Project Report studying “Basic Rules

of Pleadings” is an original work of Akash Choudhary. The
project report has not been submitted earlier either to this
University or Institution for the fulfillment of the requirement
of any course of study.
TABLE OF CONTENT
S.No. Particulars Page No.
1. Introduction 05
Definition of Pleading
2. (Rule 1) 06
3. Object of Pleadings 06
4. Importance of Pleadings 07
Basic Rules of Pleadings
5. (Rule 2) 08
6. Conclusion 16
7. Work cited 17
 INTRODUCTION
Order 6 deals with pleadings in general. Rule 1 defines pleadings, while Rule 2 lays
down the fundamental principles of pleadings. Rules 3 to 13 require the parties to
supply necessary particulars. Rules 14 and 15 provide for signing and verification
of pleadings. Rule 16 empowers a court to strike out unnecessary pleadings. Rules
17 and 18 contain provisions relating to amendment of pleadings.

DEFINITION OF PLEADING (RULE 1)

“Pleading” is defined as plaint or written statement.1 According to Mogha2,
“Pleadings are statements in writing drawn up and filed by each party to a case,
stating what his contentions will be at the trial and giving all such details as his
opponent needs to know in order to prepare his case in answer.”

A plaintiff’s pleading is his plaint, a statement of claim in which the plaintiff sets
out his cause of action with all necessary particulars 3, and a defendant’s pleading
is his written statement, a defense in which the defendant deals with every
material fact alleged by the plaintiff in the plaint and also states any new facts
which are in his favor, adding such legal objections as he wishes to take to the
claim.4 Where the defendant, in his written statement, pleads a set-off, the
plaintiff may file his written statement thereto. Again, in some cases, the
defendant after filing his written statement may file an additional written
statement with the leave of the court.

OBJECT OF PLEADINGS
The whole object of pleadings is to bring parties to definite issues and to diminish
1. Or.6 R.1; see also, Bharat Singh v. State of Haryana, (1988) 4 SCC 534: AIR 1988 SC 2181.
2. Mogha’s Law of Pleadings (1983) at p.1.
3. Ibid, for detailed discussion of “Plaint”, see infra, Pt. II, Chap.7.
4. Ibid, for detailed discussion of “Written Statement”, see infra, Pt. II, Chap.7.
expense and delay and to prevent surprise at the hearing. A party is entitled to
know the case of his opponent so that he can meet it. In other words, the sole
object of pleadings is to ascertain the real disputes between the parties, to
narrow down the area of conflict and to see where the two sides differ, to
preclude one party from taking the other by surprise and to prevent miscarriage
of justice.5

In the leading case of Throp v. Holdsworth6, Jessel, M.R. stated:

“the whole object of pleadings is to bring parties to an issue, and the meaning of
the rules (relating to pleadings) was to prevent the issue being enlarged, which
would prevent either party from knowing when the cause came on for trial, what
the real point to be discussed and decided was. In fact, the whole meaning of the
system is to narrow the parties to definite issues, and thereby to diminish expense
and delay, especially as regards the amount of testimony required on either side
at the hearing.”7

In Sayad Muhammad v. Fatteh Muhammad8, Lord Halsbury said:

“Whatever system of pleading may exist, the sole object of it is that each side may
be fully alive to the questions that are about to be argued in order that they may
have opportunity of bringing forward such evidence as may be appropriate to the
issues.”9

5. Throp v. Holdsworth, (1876) LR 3 Ch D 637; Someshwar Dutt v. Tribhawan Dutt, (1933-34) 61 IA

224: AIR 1934 PC 130: 149 IC 480; J.K. Iron and Steel Co. Ltd. v. Mazdoor Union, AIR 1956 SC 231
at p.235: (1955) 2 SCR 1315; Ram Sarup v. Bishnu Narain Inter College, (1987) 2 SCC 555: AIR
1987 SC 1242; Maria Margarida Sequeira Fernandes v. Erasmo Jack de Sequeira, (2012) 5 SCC
370: (2012) 3 SCC (Civ) 126.
6. (1876) LR 3 Ch D 637.
7. Ibid, at p.639; see also, the following observations of Lord Halsbury in Sayad Muhammad v.
Fatteh Muhammad, (1894-95) 22 IA 4: ILR (1894) 22 Cal 324 (PC); “Whatever system of pleading
may exist, the sole object of it is that each side may be fully alive to the questions that are about
to be argued in order that they may have opportunity of bringing forward such evidence as may
be appropriate to the issues.”
8. (1894-95) 22 IA 4: ILR (1894) 22 Cal 324 (PC).
9. Ibid, at p.331 (Cal).
In Ganesh Trading Co. v. Moji Ram10, the Supreme Court observed, “Provisions
relating to pleadings in civil cases are meant to give to each side intimation of the
case of the other so that it may be met to enable courts to determine what is
really at issue between parties, and to prevent deviations from the course which
litigation on particular causes of action must take.”11

In Virendra Kashinath v. Vinayak N. Joshi12, the Supreme Court stated, “The

object of the rule is twofold. First is to afford the other side intimation regarding
the particular facts of his case so that they may be met by the other side. Second
is to enable the court to determine what is really the issue between the parties.”13

IMPORTANCE OF PLEADINGS
Importance of pleadings cannot be underestimated.

Jacob14 states, “Pleadings do not only define the issues between the parties for
the final decision of the court at the trial, they manifest and exert their
importance throughout the whole process of the litigation.”

Pleadings provide a guide for the proper mode of trial. They demonstrate upon
which party the burden of proof lies, and who has the right to open the case. They
also determine the range of admissible evidence which the parties should adduce
at the trial. They also lay down limit on the relief that can be granted by the court.
Pleadings are thus the “foundation” of litigation.15

It is settled proposition of law that a party has to plead his case and substantiate
10. (1978) 2 SCC 91: AIR 1978 SC 484.
11. Ibid, at p.93 (SCC): at pp. 485-86 (AIR). See also, Sayad Muhammad v. Fatteh Muhammad, (1894-
95) 22 IA 4: ILR (1894) 22 Cal 324 (PC).
12. (1999) 1 SCC 47: AIR 1999 SC 162.
13. Ibid, at p.52 (SCC): at p.165 (AIR).
14. The Present Importance of Pleadings (1960) at pp. 75-76, Bullen, Leake and Jacob, Precedents
and Pleadings, Mogha’s Law of Pleadings, supra.
15. Maria Margarida Sequeira Fernandez v. Erasmo Jack de Sequeira, (2012) 5 SCC 370; (2012) 3 SCC
(Civ) 126; A. Shanmugam v. Ariya, (2012) 6 SCC 430; (2012) 3 SCC (Civ) 735; Rajasthan SRTC v.
Bajrang Lal, (2014) 4 SCC 693: (2014) 2 SCC (L&S) 97.
it by leading sufficient evidence. If the pleadings are not complete, the court is
under no obligation to entertain pleas raised by him.16

Every litigant is expected to state the truth before a court of law, whether in his
pleadings, affidavits or evidence. Dishonest and unscrupulous litigants have no
place in law courts. If false averments or denials are introduced, the court should
keep that fact in mind while deciding the case.17

BASIC RULES OF PLEADINGS

(RULE 2)
Sub-rule (1) of Rule 2 lays down the fundamental principles of pleadings. It reads
as under:

“Every pleading shall contain, and contain only a statement in a concise form of
the material facts on which the party pleading relies for his claim or defense, as
the case may be, but not the evidence by which they are to be proved.”

On analysis, the following general principles emerge:

(i) Pleadings should state facts and not law;

(ii) The facts stated should be material facts;
(iii) Pleadings should not state the evidence; and
(iv) The facts should be stated in a concise form.

Let us discuss these principles in detail:

(1) Facts and not Law

The first principle of pleadings is that they should state only facts and not
law. It is the duty of the parties to state only the facts on which they rely
upon for their claims. It is for the court to apply the law to the facts

16. Rajasthan SRTC v. Bajrang Lal, (2014) 4 SCC 693: (2014) 2 SCC (L&S) 97.
17. Ibid.
 pleaded.18
The law of pleading may be tersely summarized in four words; “Plead facts
not law.”19
Thus, existence of a custom or usage is a question of fact which must be
specifically pleaded. Similarly, intention is a also a question of fact and it
must be pleaded.
Again, waiver or negligence is a plea of fact and must be pleaded in the
pleading.
But a plea about maintainability of the suit raises a question of law and
need not be pleaded.20 Likewise, when Hindu sons are sued for a debt
incurred by their deceased father, it is not necessary to formulate in the
plaint the Hindu Law as to the pious obligation of Hindu sons to pay their
father’s debt. Legal consequences which flow from facts also need not be
stated in the pleading. So also, inferences of law to be drawn from pleaded
facts need not be stated in the pleading. “The practice of the courts is to
consider and deal with the legal result of pleaded facts, although the
particular result is not stated in the pleading.”21 A construction or
interpretation of a document, being a point of law, need not be pleaded.
This is based on the principle that a judge is bound to apply correct law
even if incorrect law is pleaded by a party.
A mixed question of law and fact, however, should be specifically pleaded. 22
Similarly, a point of law which is required to be substantiated by facts,
should be pleaded with necessary facts.23

18. Kedar Lal v. Hari Lal, AIR 1952 SC 47 at p.51: 1952 SCR 179; Manoj v. Shanti, (1997) 1 SCC 553:
AIR 1997 SC 2153; Lakhi Ram v. Trikhu Ram, (1998) 2 SCC 720: AIR 1998 SC 1230; Syed Dastagir
v. T.R. Gopalkrishna Setty, (1999) 6 SCC 337: AIR 1999 SC 3029.
19. Gouri Dutt Gnaesh Lall Firm v. Madho Prasad, AIR 1943 PC 147: 209 IC 192.
20. State of Rajasthan v. Rao Raja Kalyan Singh, (1972) 4 SCC 165: AIR 1971 SC 2018 at p. 2019.
21. Bell v. Lever Bros. Ltd., (1931) 1 KB 557.
22. Ram Prasad v. State of M.P., (1969) 3 SCC 24: AIR 1970 SC 1818.
23. H.D. Vashishta v. Glaxo Laboratories, (1978) 1 SCC 170: AIR 1979 SC 134; Union of India v. Sita
Ram Jaiswal, (1976) 4 SCC 505: AIR 1977 SC 329.
(2) Material Facts
The second principle of pleadings is that they should contain a statement of
material facts and material facts only. Though the expression “material
facts” has not been defined in the Code, it means all facts upon which the
plaintiff’s cause of action or the defendant’s defense depends, or, in other
words, all those facts which must be proved in order to establish the
plaintiff’s right to relief claimed in the plaint or the defendant’s defense in
the written statement.24
In Udhav Singh v. Madhav Rao Scindia25, the Supreme Court has defined
the expression “material facts” in the following words:
“All the primary facts which must be proved at the trial by a party to
establish the existence of a cause of action or his defense are material
facts.”26
Recently, in Virender Nath v. Satpal Singh27, the Supreme Court stated:
“The phrase ‘material facts’ may be said to be those facts upon which a
party relies for his claim or defense. In other words, ‘material facts’ are
facts upon which the plaintiff’s cause of action or the defendant’s defense
depends. What particulars could be said to be ‘material facts’ would
depend upon the facts of each case and no rule of universal application can
be laid down. It is, however, absolutely essential that all basic and primary
facts which must be proved at the trial by the party to establish the
existence of a cause of action or defense are material facts and must be
stated in the pleading by the party.”28
The distinction between “material facts” and “particulars” cannot be

24. Union of India v. Sita Ram Jaiswal, (1976) 4 SCC 505: AIR 1977 SC 329; Brahma Parkash v.
Manbir Singh, AIR 1963 SC 1607,: 1964 SCD 485; Calcutta Discount Co. Ltd. v. ITO, AIR 1961 SC
372: (1961) 2 SCR 241.
25. (1977) 1 SCC 511: AIR 1976 SC 744.
26. Ibid, at p.523 (SCC): 752 (AIR). See also, Mohan Rawale v. Damodar Tatyaba, (1994) 2 SCC 392 at
p.398; Gajanan Krishnaji v. Dattaji Raghobaji, (1995) 5 SCC 347: AIR 1995 SC 2284. Mogha,
supra, at p.22.
27. (2007) 3 SCC 617: AIR 2007 SC 581.
28. Ibid, at p.628 (SCC) (per Thakker, J.); see also, Harkirat Singh v. Amrinder Singh, (2005) 13 SCC
511.
 overlooked. Material facts are primary and basic facts which must be
pleaded by the party in support of the case set up by it. Since the object
and purpose is to enable the opposite party to know the case it has to
meet, in absence of pleading, a party cannot be allowed to lead evidence.
Failure to state material facts, hence, will entail dismissal of the suit.
Particulars, on the other hand, are the details of the case. They amplify,
refine and embellish material facts. They give the finishing touch to the
basic contours of a picture already drawn so as to make it full, more
detailed and more informative. Thus, the distinction between “material
facts” and “particulars” is one of degree.29
In Virender Nath v. Satpal Singh30, the Supreme Court said:
“A distinction between ‘material facts’ and ‘particulars’, however, must not
be overlooked. ‘Material facts’ are primary or basic facts which must be
pleaded by the plaintiff or by the defendant in support of the case set up by
him either to prove his cause of action or defense. ‘Particulars’, on the
other hand, are details in support of material facts pleaded by the party.
They amplify, refine and embellish material facts by giving distinctive touch
to the basic contours of a picture already drawn so as to make it full, more
clear and more informative. ‘Particulars’ thus ensure conduct of fair trial
and would not take the opposite party by surprise.”31
Whether a particular fact is or is not a material fact which is required to be
pleaded by a party depends on the fact and circumstances of each case. 32
All material facts must appear in the pleadings and the necessary
particulars must be there so as to enable the opposite party to know the
case he is required to meet and to put him on his guard. The rule is not of

29. D. Ramachandran v. R.V. Janakiraman, (1999) 3 SCC 267: AIR 1999 SC 1128; Udhav Singh v.
Madhav Rao Scindia, (1977) 1 SCC 511: AIR 1976 SC 744.
30. (2007) 3 SCC 617: AIR 2007 SC 581.
31. Ibid, at p.629 (SCC) (per Thakker, J.); see also, Harkirat Singh v. Amrinder Singh, (2005) 13 SCC
511.
32. Virender Nath v. Satpal Singh, (2007) 3 SCC 617; Ramachandran v. Janakiraman, (1999) 3 SCC
267; Udhav Singh v. Madhav Rao Scindia, (1977) 1 SCC 511; Gajanan Krishnaji. Dattaji
Raghobaji, (1995) 5 SCC 347: AIR 1995 SC 2284; Charan Lal Sahu v. Giani Zail Singh, (1984) 1 SCC
390: AIR 1984 SC 309; Calcutta Discount Co. Ltd. v. ITO, AIR 1961 SC 372: (1961) 2 SCR 241.
 mere technicality and, therefore, if a party omits to state material facts, it
would mean that the plea has not been raised at all and the court will not
allow the party to lead evidence of that fact at the trial, unless the court
gives that party leave to amend his pleadings. The reason is that non-
mention of material facts amounts to non-pleading and, therefore, no
cause of action arises in favor of such party.
What particulars are to be stated depends upon the facts of each case, but
it is absolutely essential that the pleading, not to be embarrassing to the
defendant, should state those facts which will put his opponents on their
guard and tell them what they have to meet when the case comes up for
trial.33
Thus, it has been held that a plaintiff, filing a suit on the basis of title, must
state the nature of the deeds on which he relies in deducing his title.
Similarly, a party relying upon the fact that the notice of dishonor is not
necessary, or that the woman claiming maintenance has lost her right on
account of incontinence, or that the person who has signed the plaint in a
suit by a corporate body has authority under the Code, is bound to allege
those facts in his pleadings.
(3) Facts and not evidence
The third principle of pleadings is that the evidence of facts, as
distinguished from the facts themselves, need not be pleaded. In other
words, the pleadings should contain a statement of material facts on which
the party relies but not the evidence by which those facts are to be
proved.34
The facts are of two types:
(a) Facta Probanda: The facts required to be proved (material facts); and
(b) Facta Probantia: The facts by means of which they are to be proved
(particulars or evidence).
33. Ibid, see also, Charan Lal Sahu v. Giani Zail Singh, (1984) 1 SCC 390 at pp. 405-06: AIR 1984 SC 309 at
p.317; Mohan Rawale v. Damodar Tatyaba, (1994) 2 SCC 392; Bullen, Leake and Jacob, Precedents of
Pleadings (1975) at p.112.
34. R.M. Sheshadri v. G. Vasantha Pai, (1969) 1 SCC 27 at pp.34-35: AIR 1969 SC 692 at p.699; Manphul Singh
v. Surinder Singh, (1973) 2 SCC 599 at p.608: AIR 1973 SC 2158 at pp.2164-65; Khushalbhai Mahijibhai v.
Firm of Mohammadhussain Rahimbux, 1980 Supp SCC 1: AIR 1981 SC 977.
 The pleadings should contain only facta probanda and facta probantia. The
material facts on which the plaintiff relies for his claim or the defendant
relies for his defence are called facta probanda, and they must be stated in
the plaint or in the written statement, as the case may be. But the facts or
evidence by means of which the material facts are to be proved are called
facta probantia and need not be stated in the pleadings. They are not the
“fact in issue”, but only relevant facts required to be proved at the trial in
order to establish the fact in issue.

As observed by Denman, C.J.,35 “It is an elementary rule in pleading, that,

when a state of facts is relied on, it is enough to allege it simply, without
setting out the subordinate facts which are the means of producing it, or
the evidence sustaining the allegations.”

Brett, L.J.36 also stated, “I will not sya that it is easy to express in words
what are facts which must be stated and what matters need not be
stated…. The distinction is taken in the very rule itself, between the facts on
which the party relies and the evidence to prove those facts…. The facts
which ought to be stated are the material facts on which the party pleading
relies.”

In Virender Nath v. Satpal Singh37, after referring the leading English and
Indian decisions on the point, the Supreme Court observed:

“There is distinction between facta probanda (the facts required to be

proved i.e. material facts) and facta probantia (the facts by means of which
they are proved i.e. particulars or evidence). It is settled law that pleadings
must contain only facta probanda and not facta probantia. The material
facts on which the party relies for his claim are called facta probanda and
they must be stated in the pleadings. But the fact or facts by means of
which facta probanda (material facts) are proved and which are in nature
of facta probantia (particulars or evidence) need not be set out in the
35. Williams v. Wilcox, 112 ER 957: (1835-42) All ER Rep 25: (1838) 2 Ad&El 314 at p. 331.
36. Philipps v. Philipps, (1878) LR 4 QBD 127 (CA).
37. (2007) 3 SCC 617: AIR 2007 SC 581.
 pleadings. They are not ‘fact in issue’, but only relevant facts required to be
proved at the trial in order to establish the fact in issue.”38

The foresaid principle is well illustrated in the case of Borrodaile v.

Hunter39. A was insured with an insurance company. One of the terms of
the policy was that the policy would be void if the insured committed
suicide. A actually committed suicide by shooting himself with a pistol and
thereupon an action was brought against the company on the policy. The
company should only plead that A committed suicide. This is facta
probanda. Other facts, that A was melancholy for weeks, that he bought a
pistol a day before his death, shot himself with the said pistol and that a
letter was found with him addressed to his wife stating that he intended to
kill himself- all these facts are facta probantia and they need not be
pleaded. Similarly, it is wrong to set out admission made by the opposite
party in the pleading, as that fact is only evidence.

Thus, in an election petition the plea that cars were used by the successful
candidate for the purpose of conveying voters contrary to the Act must be
state din the pleadings since it is a fact in issue (facta probanda). But the
facts as to from where the cars were obtained, who hired them and used
them for conveyance of voters are merely evidentiary facts (facta
probantia) and need not be stated in the pleadings.40

It is, however, not easy to express in words what are facts which must be
stated in the pleadings and what are matters which need not be so set out.
The question must be decided in the light of facts and circumstances of
each case.41 To put it differently, the dividing line between these two
classes of facts (facta probanda and facta probantia) is often very difficult
to draw; but a fact as to which there is a doubt as to whether it should be
38. Ibid, at pp. 631-32 (SCC) (per Thakker, J.); see also, Harkirat Singh v. Amrinder Singh, 92005) 13 SCC 511.
39. (1845) 5 M&G 639.
40. Virender Nath v. Satpal Singh, (2007) 3 SCC 617: AIR 2007 SC 581; R.M. Sheshadri v. G. Vasantha Pai,
(1969) 1 SCC 27.
41. Philipps v. Philipps, (1878) LR 4 QBD 127 (CA); Mohan Rawale v. Damodar Tatyaba, (1994) 2 SCC 392.
 placed in the one class or the other should be pleaded.42

(4) Concise form

The fourth and the last general principle of pleadings is that the pleadings
should be drafted with sufficient brevity and precision. The material facts
should be stated precisely, succinctly and coherently.
The importance of a specific pleading can be appreciated only if it is
realized that the absence of a specific plea puts the defendant at a great
disadvantage. He must know what case he has to meet. He cannot be kept
guessing what the plaintiff wants to convey by a vague pleading. Therefore,
the pleading must be precise, specific and unambiguous. A party cannot be
allowed to keep his options open until the trial and adduce such evidence
as seems convenient and handy.43
The words “in a concise form” are definitely suggestive of the fact that
brevity should be adhered to while drafting pleadings. Of course, brevity
should not be at the cost of excluding necessary facts, but it does not mean
niggling in the pleadings. If care is taken in the syntactic process, pleadings
can be saved from tautology.44
Every pleading should be divided into paragraphs and sub-paragraphs. Each
allegation should be contained in a separate paragraph. Dates, totals and
numbers must be mentioned in figures as well as in words.45 Rule 3 lays
down that the forms in Appendix A of the Code should be used where they
are applicable; and where they are not applicable, forms of like character
should be used.
The facts must be pleaded with certainty. In other words, they should be
definitely stated as facts, and should not be left to be inferred from vague

42. Millington v. Loring, (1880) 6 QB 190 (CA).

43. Charan Lal Sahu v. Giani Zail Singh, (1984) 1 SCC 390 at pp. 405-406: AIR 1984 SC 309 at p. 317.
44. Virendra Kashinath v. Vinayak N. Joshi, (1999) 1 SCC 47 at p. 52: AIR 1999 SC 162 at p. 165
(“Elaboration of facts in pleading is not the ideal measure and that is why the sub-rule embodies
the words ‘and contain only’ just before the succeeding words “a statement in a concise form of
the material facts.”)
45. R.2(2), (3).
or ambiguous expressions. All material facts must be stated in a summary
form, as briefly as the nature of the case requires. Immaterial averments
and unnecessary details must be omitted and material allegations and
necessary particulars must be included.

CONCLUSION
Pleadings are the backbone of legal profession. It is the foundation stone
on which case of a party stands. The case of a party must be set out in the
pleadings. Pleadings do not only define the issues between the parties for
the final decision of the court at the trial, they manifest and exert their
importance throughout the whole process of the litigation. Pleadings
provide a guide for the proper mode of trial. They demonstrate upon which
party the burden of proof lies, and who has the right to open the case. They
also determine the range of admissible evidence which the parties should
adduce at the trial. They also lay down limit on the relief that can be
granted by the Court.
Four fundamental rules of pleading are: (1) Pleadings should state facts and
not law; (2) The facts stated in pleadings should be material facts; (3)
Pleadings should not state the evidence; and (4) The facts in pleadings
should be stated in a concise form. The main points to be considered
before a party is allowed to amend his pleading are: firstly, whether the
amendment is necessary for the determination of the real question I
controversy, and secondly, can the amendment be allowed without
injustice to other side.
 WORK CITED
1. Thakker, C.K. Justice. Civil Procedure with Limitation Act, 1963 and Chapter
on Commercial Courts, 8th ed., EBC, 2017.
2. Kumar, Ritesh. Pleadings: Its Rules and Amendments, Legal Desire, August
22, 2017 https://legaldesire.com/pleadings-rules-amendments/
3. Agarwal, Ashish. Definition and Fundamental Rules of Pleading Under CPC,
1908, February 8, 2020, Legal Bites https://www.legalbites.in/definition-
and-fundamental-rules-of-pleading-under-cpc-1908/