IN THE MATTER OF REPLY

TO THE NOTICE OF THE

APPLICANT FOR INSPECTION

OF DOCUMENTS UNDER

ORDER XI, Rule 16 of the

C.P.C.

MAY IT PLEASE THIS HON’BLE COURT:

The Opponent above-named begs to state as under:

1) The Opponents state that the Applicant served on the

Opponent a Notice dated 26.10.2019 under Order XI,

Rule 16 of the C.P.C. (referred to herein after as “the

said Notice”), seeking purported inspection from the

Opponent of the documents mentioned therein.

2) of which purported “inspection” has been sought by the

Applicant from the Opponent have already been

annexed by the Applicant himself in the present

proceedings at Exhibit-A to Exhibit-E along with a List

of Documents in the main Application.

3) Without prejudice to the Opponent’s contention that the

Applicant has indulged in a fishing and roving enquiry

and has sought to shift his burden upon the Opponent,

the Opponent states that any party seeking inspection

of documents is required establish that the same are

not in his possession and is further required to plead,

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substantiate and justify as to how and in what manner

inspection of the said documents are necessary and

relevant, which the Applicant has completely failed to

do in the present case. The Opponent states that it is

relevant to note that the originals of all the documents

sought to be “inspected” by the Applicant are already in

the possession of the Applicant himself and it is thus

absurd and quixotic for the Applicant to purportedly

seek “inspection” of the same from the Opponent.