AFFIDAVIT FOR CLAIMING PRIVILEGE FOR PRODUCING DOCUMENTS
 
In the Court of Senior-Sub Judge . ................
		Suit No ……………………of 20  ……………
	M/s X & Co. 			…………………………			Plaintiff
v
	Union of India and others 	…………………………			Defendants
 
	Affidavit of ………………………………..………
             son of Shri…………………………………………..
             aged…………………..years  
             resident of ........................................................................
 
I ………………………………………………………..
son of Shri ………………………………………………
aged about ......................years,
 do hereby solemnly affirm and state on oath as under:
 
1	I am the Secretary, Ministry of ………………………………………………          Government of India, New Delhi and as such, in charge of the general superintendence and direction of the affairs and business of the said department. A summons dated has been	served on Shri.............................Director, 
             Department of ........................Ministry of…………………….Government of India at New Delhi for production of the file containing the correspondence and related papers for the 	award of contract for defence installation at 	to M/s.
	2.	I say that I have carefully gone through the said file.
3.	I say that the said file listed in the summons pertains to affairs of state and for the reasons hereinafter set out its disclosure will lead to public injury.
4.	I say that the file containing the correspondence and related papers for the award of contract for defence installation at contains top secret information and drawings of defence installation, the production  of which will endanger the security and defence of the country. I further say that it is imperative that such material relating to the defence installation is not published or disclosed, otherwise the security or defence of the country will be endangered.
5.	I say that none of the above record summoned by the court under my control nor any part thereof, has been published in any manner by the Government of India.
6.	I say that the Government of India is claiming privilege under section 123, Indian Evidence Act and therefore, I withhold permission, to produce the documents referred to in this affidavit or give any evidence derived therefrom.
 
Deponent
 
Verification
 
I ……………………………………. 	the above named, do hereby verify that the contents of paragraphs 1 to 5 of this affidavit are true to my personal knowledge, that the contents of paragraph 6 are my submissions to this Honourable Court.
 
	Verified at…………………….	this……………………..day of……………
 
Signature
 
Date .....................