Order 11 rule 16 cpc

Hi, Simply make application stating that, the document sought by Hon'ble court is already on record at page no..(). Plaintiff/defendant don't have original copy of this document. You can request court to accept secondary evidence under section 63 of Indian Evidence Act.. u can satisfy requisites of producing secondary evidence..

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Proceed as advised by the lawyer engaged / paid by you who is well aware about facts/ documents of the case, an able, competent and intelligent enough to satisfy your query. 

It would be unfair to form an opinion and advise on incomplete facts posted by you.

If you are not satisfied with your lawyer's performance, capability or behaviour it would be better to change him / her immediately.

It clearly states that the adversary who is called upon to produce such a document must have referred to it in the pleading or affidavit.

Even though the notice given by the Counsel for  the plaintiff states that it was given under Order 11 Rule 16 CPC and even though it can be assumed that strict compliance with the requirement of Order 11 Rule 16 CPC by way of giving the same in the prescribed form cannot be insisted upon; the reason for calling upon the defendant to produce it has to be stated in order to lay the foundation for producing secondary evidence.