annexures in plaint

Annexures in Plaint: 7 Best Steps to Fix Wrong Numbering

Annexures in Plaint Made Simple: Quick Answers First

Annexures in a plaint confuse almost every new advocate and law student. Here are the answers you came for, in one place.

  • What is an annexure? A document you attach to the plaint to support a fact you have written.
  • How do I label it? The main document gets a letter: Annexure A, B, C. Papers that belong to it get slash numbers: A/1, A/2, A/3.
  • What comes after A/3? A/4, A/5, and so on. When a new main document starts, move to the next letter: Annexure B, then B/1, B/2, then Annexure C, C/1, C/2.
  • Does the law fix this style? No. The law only requires you to produce your documents and file a list of documents. The lettering is court practice.
  • What else must I file? A List of Documents and copies for every defendant.
  • Annexure or exhibit? Annexure is your label at filing. Exhibit is the court’s label at the evidence stage.

Golden rule: One document, one label, used the same way in the plaint, the list of documents, and the evidence.

Annexures in Plaint Numbering: The Full A, A/1, A/2, A/3, B, B/1 Pattern

The pattern never changes: a letter for each main document, a slash number for each paper that belongs to it. This is how a full set looks.

LabelWhat it meansExample in a plot suit
Annexure AFirst main documentSale agreement
A/1First paper of APayment receipt
A/2Second paper of APossession letter
A/3Third paper of ASite plan
Annexure BSecond main documentSociety transfer letter
B/1First paper of BTransfer fee receipt
B/2Second paper of BSociety NOC
Annexure CThird main documentUtility bills
C/1First paper of CElectricity bill
C/2Second paper of CGas bill
Annexure DFourth main documentLegal notice
D/1First paper of DPostal receipt
D/2Second paper of DDelivery proof

And so on: Annexure E, E/1, E/2, then Annexure F, F/1, F/2, until your last document. Same pattern from start to end.

Five rules to remember

  1. The main document gets only the letter, like Annexure A. Never write A/0.
  2. Papers that belong to it are A/1, A/2, A/3, as many as needed.
  3. A new main document takes the next letter, and its papers start again from 1: Annexure B, B/1, B/2.
  4. Never skip, repeat, or change a label after filing. A document added later takes the next free letter.
  5. A long set of similar papers, like 12 bank statements, takes one letter: Annexure C, with C/1 to C/12.

The defendant usually uses a separate series in the written statement, so the two sides do not clash. More than 26 main documents is rare. In that case, group related papers under one letter, or follow your court’s practice.

Annexures in Plaint Example: How Labels Appear Inside the Plaint

Write the label in brackets in the paragraph where you use the document.

‘Para 3. That on 12.03.2018 the parties executed a sale agreement for Plot No. 45 (Annexure A). The plaintiff paid Rs. 5,00,000 as earnest money against receipt (Annexure A/1) and possession was handed over by letter dated 20.03.2018 (Annexure A/2). A site plan of the plot is attached as Annexure A/3.’

‘Para 4. That the society transferred the plot in the plaintiff’s name (Annexure B) after the plaintiff paid the transfer fee (Annexure B/1).’

‘Para 7. That the plaintiff sent a legal notice on 05.01.2024 (Annexure D) by registered post (Annexure D/1), and the delivery proof is Annexure D/2.’

This protects you from two common mistakes: attaching a document you never mention, and mentioning a document you forgot to attach.

Annexures in Plaint Example: Recovery Suit for Rs. 15,00,000

  • Annexure A: Loan agreement
  • A/1: Bank transfer slip
  • A/2: Repayment schedule
  • Annexure B: Cheque issued by the defendant
  • B/1: Bank return memo
  • B/2: Deposit slip
  • Annexure C: Legal notice
  • C/1: Courier receipt
  • C/2: Reply received from the defendant
  • Annexure D: CNIC copy of the plaintiff

Each letter tells one part of the story. The slash numbers are its supporting papers.

How to Set Annexures in Plaint: 7 Quick Steps

  1. Sort your documents. Make two piles: documents you sue upon (agreement, cheque, sale deed) and documents that support your facts (receipts, notices, photographs). Keep all originals safe.
  2. Remove the extras. Keep only what supports a fact you have pleaded. Extra papers invite objections and long cross-examination.
  3. Arrange in the order of your story. Agreement first, then payments, then default, then legal notice and reply.
  4. Label each document. Use the A, A/1, A/2, B, B/1 pattern above.
  5. Mark every annexure. Write or stamp the label on the top right corner of its first page and put continuous page numbers on the whole bundle. The order sheet refers to the page number of the document on which an order is made (Rule 28(3)), and papers in each court file are paged (Rule 25).
  6. Mention each annexure in the plaint. Write the label in brackets in the paragraph where you use it, as in the example above.
  7. Prepare the List of Documents and copies. Attach the list to the plaint, make a full set for each defendant (Rule 87-A) plus one for your own file, and initial any correction you make in the plaint (Rule 38).

Sample List of Documents for Annexures in Plaint

LIST OF DOCUMENTS RELIED UPON BY THE PLAINTIFF

Suit No. ____ of 2026, Ali v. Bilal

  1. Annexure A: Sale agreement dated 12.03.2018 (3 pages)
  2. Annexure A/1: Payment receipt dated 12.03.2018 (1 page)
  3. Annexure A/2: Possession letter dated 20.03.2018 (1 page)
  4. Annexure A/3: Site plan (1 page)
  5. Annexure B: Society transfer letter dated 10.04.2018 (2 pages)
  6. Annexure B/1: Transfer fee receipt (1 page)
  7. Annexure D: Legal notice dated 05.01.2024 (2 pages)
  8. Annexure D/1: Postal receipt (1 page)

Advocate for the Plaintiff

This is a common practice format. Adjust it to the style followed in your court.

Annexures in Plaint vs Exhibits: The Simple Difference

  • Annexure: Your label at the filing stage, like Annexure A. The document is attached but not yet proved.
  • Exhibit: The court’s mark after a document is admitted in evidence, often written as Ex.P/1 for the plaintiff and Ex.D/1 for the defendant. Rule 176 of the Sindh Civil Courts Rules says documents admitted in evidence are numbered 1, 2, 3 in one continuous series.

Court example: Your sale agreement is Annexure A in the plaint. In evidence, your witness produces the original, the court admits it, and the court marks it as an exhibit. Same paper, two labels. An annexure alone is not proof. It must still be proved in evidence.

Common Mistakes With Annexures in Plaint

A plaint that does not comply can be returned for compliance, usually with time to fix it (Rules 39, 91 and 92 of the Sindh Civil Courts Rules). A missing annexure does not by itself fall under the grounds for rejection of plaint under Order VII Rule 11, but a careless file invites objections and wastes hearing dates.

  • No List of Documents attached.
  • A document mentioned in the plaint but not attached, or attached but never mentioned.
  • Two documents with the same letter, or labels that change between the plaint and the list.
  • Not enough copies for all defendants.
  • Blurred, half-page, or one-sided copies where the back page matters.
  • Forgetting the original of the document you sue upon.
  • Annexures in random order instead of the order of the story.
  • Corrections in the plaint without initials.
  • A document you will not be able to prove later, such as a photocopy whose original is lost.

What If You Forget Annexures in Plaint?

A document that was not produced or listed with the plaint cannot be received in evidence without the leave of the court (Order VII Rule 18(1)). The exceptions are documents produced for cross-examination of the defendant’s witnesses, in answer to the defendant’s case, or only to refresh a witness’s memory (Order VII Rule 18(2)).

For anything else, file an application under Order XIII Rule 2 CPC giving the good cause for late production, supported by an affidavit. Courts have allowed late documents in genuine cases, normally subject to the other side’s objection and its right to cross-examine.

Practical tip: File the application early, give one clear and honest reason, attach copies of the documents, and never wait for the day of final arguments.

Red Flags in Annexures in Plaint: How to Spot Malafide Documents

Check every annexure the other side files for these warning signs:

  • The date on the stamp paper does not match the date written in the document.
  • Only a photocopy is produced, while the party says an original exists.
  • Signatures or thumb impressions look different from the party’s earlier documents.
  • Witnesses on the document cannot be identified.
  • The document appears for the first time at a late stage, with no mention in the pleadings.
  • The document contradicts what the same party has pleaded.
  • A legal notice with a postal receipt but no proof of delivery, or sent to the wrong address.

What to do: Raise a specific objection in time, ask for the original, check certified copies, cross-examine the record where possible, and plan your cross-examination around the weak points.

Your own side: Never annex a document you suspect is backdated or forged. It can destroy your whole case and your credibility. Ask the client for the original and satisfy yourself before it goes into the file.

Advocate’s Role at Each Stage of Annexures in Plaint

  1. Drafting: Study every document first. Plead facts that match the papers, not the other way round.
  2. Filing: Present the plaint with the list of documents and all copies. The court office examines the plaint, and documents produced with it are received into safe custody and registered (Rule 93).
  3. Written statement stage: Read the defendant’s list of documents carefully. Under Rule 117-A, no written statement or list of documents is filed without leave unless a copy has been served first, and copies are authenticated by signature or initials on each page.
  4. Evidence stage: Bring the originals. The witness produces them, the court admits them, and the court staff endorses and marks them (Rules 175 and 176).
  5. After the case: Apply early for return of your original documents (Rule 504).

Rules Behind Annexures in Plaint: Short Reference

  • Order VII Rule 14(1) CPC: A document you sue upon must be produced in court with the plaint, and the document or a copy filed with it.
  • Order VII Rule 14(2) CPC: Other documents you rely on, whether with you or not, must be entered in a list added or annexed to the plaint. PLD 2007 Karachi 448 discussed this rule and explained that a party who wants to rely on documents or evidence must disclose it in the list.
  • Order VII Rule 9 CPC: The list of documents produced with the plaint is endorsed on the plaint or annexed to it.
  • Order VII Rule 18 CPC: A document not produced or listed needs the leave of the court to be received in evidence.
  • Order XIII Rule 2 CPC: Late production is allowed only on good cause.
  • Sind Civil Courts Rules, Rule 92: The court office checks that the document sued upon is produced, the list of documents is attached and the copies are filed.
  • Rule 87-A: Sufficient copies must be filed for service on each party.
  • Rule 93: Documents produced with the plaint are received into safe custody and registered.
  • Qanun-e-Shahadat Order, 1984: Decides how a document is proved in evidence.

No rule says Annexure A or A/1 must be used. That naming is practice, so if your court or senior follows a different style, follow it and stay consistent.

Annexures in Plaint Checklist Before You Go to the Counter

  • Every annexure has its label written on the first page.
  • Page numbers run continuously through the bundle.
  • Every annexure is mentioned in the plaint with its label.
  • The List of Documents matches the plaint exactly.
  • The original of the document sued upon is with you.
  • Copies are ready for each defendant, plus your own set.
  • Corrections in the plaint are initialed.
  • Nothing in the file is a document you doubt.

Frequently Ask Questions

1. Can I use numbers instead of letters?

Yes, if you stay consistent from plaint to evidence. Most chambers use letters, so follow your court’s practice.

2. Should I attach originals or photocopies?

The document you sue upon must be produced in court, with a copy filed with the plaint (Order VII Rule 14(1)). For other documents, file clear copies and keep the originals ready.

3. Are annexures evidence?

No. They must still be proved and admitted in evidence, after which the court marks them as exhibits.

4. Can I add documents after filing?

Only with the leave of the court, through an application with good cause under Order XIII Rule 2 and subject to Order VII Rule 18.

5. Does the defendant also attach annexures?

Yes, with the written statement, along with a list of documents served in advance as required by Rule 117-A.

Final Thoughts on Annexures in Plaint

Good annexures do not win a case by themselves, but bad annexures can quietly weaken one. Sort your documents, label them with the A, A/1, B, B/1 pattern, mention each one in the plaint and keep one list that matches everything. If you want to see where annexures fit in the bigger picture, read how a suit moves from institution to judgment in civil procedure in Pakistan.

Which part of annexures in a plaint confused you the most when you started practice, whether it was numbering like A, A/1, A/2, your court’s own style, or something the court office objected to? Share your experience in the comments, and tell us which topic you want us to cover next.

Disclaimer

This article is for educational purposes only and is not legal advice. Court practice and rules can change and may differ between courts. Always check the latest rules and the practice of your court before filing.

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