How to draft an interlocutory application to bring additional documents on record before the Supreme Court using AI (Part 3)

In this third part of our interlocutory application series, you are about to discover something that will completely revolutionise how you draft legal applications. We are not just learning another type of interlocutory application today, which is used to bring additional documents on record, but we are going to see how AI can transform your legal drafting forever by turning hours of struggle into minutes.

Introduction 

If you have been following our journey through Part 1 and Part 2, you already know the art of drafting interlocutory applications for Direction, Clarification, Rectification, Impleadment, and Intervention. 

But today, everything changes. Today, we are stepping into the future of legal practice.

Let me show it with a story.

Last month, I received a call from my friend advocate Priya Sharma.

She was handling a Special Leave Petition before the Supreme Court, where her client Amit Kumar was challenging a Delhi High Court Order that had declared Bharat Singh as the owner of a disputed property. 

The case had been pending for months, and the hearing was scheduled for the very next day.

“Urvi,” she said, her voice trembling with panic, “Amit just called me with explosive news.” 

The news was that Amit’s mother had found some documents that were buried in their family files,which could completely turn the case around.

She added, “I have never drafted an application for additional documents before, and if I mess this up, I lose the case.”

I could hear the desperation in her voice. 

This was not just any case; it was her biggest client, and the outcome would determine whether Amit’s family would lose their ancestral property forever.

Now this is where the magic happened. 

Instead of spending the entire night struggling to teach her manually how to draft an application to bring additional documents, I took only 30 minutes to teach her how to go about it.

You might wonder how? Well, that is the power of AI.

 I taught Priya exactly what I am going to teach you today, which is how to use AI as her drafting partner for this specific application. 

Using the exact prompting techniques that I will show you, she drafted a flawless application.

The result? The additional documents revealed the truth, the Supreme Court ruled in her client’s favor, and Priya discovered a game-changing approach to legal drafting that transformed her entire practice.

But here is what makes this story even more incredible: Priya was not a tech genius. 

She was just a determined advocate who learned to prompt AI correctly. And by the end of this article, you will have the exact same superpower.

But before that, first let us get our basics right and understand when you can file this particular application.

When can you file an interlocutory application to bring additional documents on record?

The following are the circumstances where you can file an interlocutory application to bring additional documents on record:

Purpose 1: Newly discovered evidence

The first circumstance is when newly discovered evidence emerges after you have filed your main petition or appeal. 

Think of it as finding the missing piece of a jigsaw puzzle after you thought the picture was complete. 

These are not just helpful additions; they are game-changing documents that could affect the entire outcome of your case.

Purpose 2: Previously unavailable documents

The second circumstance is when documents were genuinely unavailable during the initial filing but have since surfaced.

Maybe they were in someone else’s custody, perhaps they were created after your petition was filed, or they might have been discovered through subsequent legal proceedings. 

The key here is demonstrating that their absence was not due to your negligence.

Purpose 3: Ensuring complete justice

The third circumstance is to ensure complete justice by providing the court with all relevant evidence.

 Courts do not want to decide cases on incomplete information, and when you can show that these additional documents will help them make a more informed decision, you are aligning your request with judicial objectives.

Let us move on to the components of the interlocutory application.

What are the components of an interlocutory application to bring additional documents on record?

Let me break down each essential component of this application.

Component 1: Reference to the main matter

The first component is a crystal-clear reference to the main matter that sets the stage without unnecessarily repeating your entire case story. 

You want the court to immediately understand the context while moving ahead with the purpose of filing the application.

Component 2: Detailed document description

The second component is a detailed description of each document you want to bring on record.

You need to provide specific details, including exact dates, parties involved, nature of each document, and proper annexure markings that make the court’s job easier. 

Component 3: Explanation for delay

The third critical component is your explanation for why these documents were not produced earlier, and this is where legal careers are made or broken.

You cannot sound defensive or provide weak excuses. 

Instead, you need to present a compelling, honest explanation that demonstrates due diligence rather than negligence because courts can smell dishonesty from miles away.

Component 4: Relevance and necessity

The fourth component establishes the relevance and necessity of these documents to your pending case.

You are not just adding paperwork to an already thick file; you are providing essential evidence that will help the court reach a just decision. 

Each document should feel indispensable to the final outcome.

Component 5: Bona fide statement

The fifth component is your bona fide statement, which is essentially your personal guarantee to the court that this application is not a delaying tactic or legal gimmick. 

Component 6: Specific prayer

The final component is a specific and clear prayer that asks for exactly what you need without any ambiguity whatsoever. 

Vague prayers lead to unclear orders, which create complications that can haunt you throughout the case. Be precise, be clear, and be strategic.

Moving on to the drafting bit now using AI.

How to use AI to draft an interlocutory application to bring additional documents on record?

Now, here is where I am going to take you behind the scenes and show you exactly how this AI magic works. 

Imagine you are sitting in my office, and I am teaching you step-by-step how to prompt AI like a seasoned advocate, the exact same conversation I had with Priya that night.

The first thing you need to understand is that AI is only as good as the instructions you give it. 

Think of it like briefing a brilliant junior advocate; the better your brief, the better their output.

But how do you even start?  You do not want generic legal language.

Let me show you the secret in a step-by-step process.

Step 1: The foundation conversation

The first prompt is the most crucial because it sets the AI’s entire mindset. 

You are not just asking for help; you are creating a legal persona within the AI. 

But here is the key: you need to be specific about what you want from AI, not just give it background information.

I will be using ChatGPT for drafting this application.

So this is my first prompt:

“I need to draft an application for additional documents in the Supreme Court. Give me the key strategic points I should focus on when presenting newly discovered evidence.”

Based on the prompt, this is the response ChatGPT generated:

“Key strategic points:

1. Frame as serving complete justice, not causing delay

2. Present documents in order of legal impact  

3. Explain the discovery timeline credibly

4. Show immediate action upon discovery

5. Make each document feel essential, not optional.”

See how this short prompt gave us exactly what we need? 

The logic here is to get AI thinking strategically first before diving into drafting. 

What you should never do is dump all your case facts in the first prompt; AI gets overwhelmed and gives generic responses. 

By asking for strategy first, we prime AI to think like an advocate.

Step 2: Setting up your case context

Now we move to case-specific prompting, but with focused instructions. 

Here is how I did it.

I gave the following prompt:

“My case: SLP challenging property dispute, need to bring 3 documents on record:

1. Relinquishment deed from 2020

2. Letters from 2019 showing acknowledgment  

3. Recent court admission by opposite party

How should I structure the application?”

Based on the prompt, this is the response ChatGPT generated:

“Structure for your application:

1. Brief SLP reference without repetition

2. State discovery of crucial documents

3. Present each document with an impact explanation

4. Explain why not filed earlier

5. Standard good faith statement

6. Specific prayer for documents and consideration”

Notice how AI gave us a practical roadmap? 

The logic here is getting the framework right before writing content. 

What you must avoid is asking AI to draft everything at once, which leads to template language. 

By getting the structure first, we can now tackle each section with specific instructions.

Now, how do we get the opening paragraphs right? That brings us to step 3.

Step 3: Drafting the opening paragraphs

The opening paragraphs set the tone for your entire application. 

So I give the following prompt:

“Draft two concise and formal paragraphs for an interlocutory application to bring additional documents on record in a Special Leave Petition. 

The first paragraph should briefly mention about filing of the SLP and challenge to Delhi High Court’s order dated 15.03.2023, which upheld the Respondent’s ownership of the disputed property. Do not repeat facts and refer to the facts in the petition.

The second paragraph should mention the discovery of material and necessary documents during the pendency and the consequences of non-consideration. Use precise and legal language.”

Based on the prompt, this is the response that ChatGPT generated:

1. The Petitioner has filed the present Special Leave Petition challenging the order dated 15.03.2023 passed by the Hon’ble High Court of Delhi, whereby the High Court upheld the order declaring the Respondent as the owner of the disputed property. The facts have been set out in the petition and are not repeated for brevity. 

2. During the pendency of these proceedings, the Petitioner has discovered certain crucial documents essential for proper adjudication. Their non-consideration would result in incomplete justice.

See how AI helped us build this step by step? 

What you should not do is try to write everything yourself,  let AI help with the legal phrasing and structure, then guide it to match your specific needs.”

Now, for the presentation of documents, we move on to the next step

Step 4: Presentation of the document 

We enlist the documents and ask AI to show relevance to the case. 

Here is my prompt to ChatGPT:

“Draft three detailed and formal paragraphs listing the documents the Petitioner is filing through the application. For each paragraph:

• Begin with the name and date of the document (e.g., a relinquishment deed, correspondence, or court order);
  
• Briefly describe who issued or signed it, and its legal significance (e.g., admission, acknowledgment, contradiction of the impugned judgment);
  
• Conclude by stating that the document is annexed, give the annexure number and page number (e.g., Annexure A-1, Pages 10–12).
  
• Use formal and persuasive language suitable for the Supreme Court.”

This is what ChatGPT responded with:

“Sure, I will follow the format and draft each paragraph. I will wait for the details to draft the relevant paragraphs.”

You can see that ChatGPT understood and responded to my prompt and did not start drafting directly.

This is because I have trained my AI to do so. You also need to train your AI in a similar manner.

I gave the following prompt:

“Here are the details that you need to mention in continuation of earlier paragraphs:

i: Relinquishment deed dated 10.06.2020, executed by Respondent Bharat Singh in favour of Petitioner Amit Kumar, relinquishing all rights in the disputed property. It supports the Petitioner’s title. To be marked as Annexure A-1 (Pages 10–12).

ii: Four letters dated 05.07.2019, 12.08.2019, 20.09.2019, 15.10.2019, where Respondent acknowledges Petitioner’s rights. These provide context and recognition of the Petitioner’s title. To be marked as Annexures A-2 to A-5 (Pages 13–20).

iii: Order dated 25.01.2023 passed by Ld. District Judge, Tis Hazari, in “Bharat Singh v. MCD”, where Respondent admits no claim on the disputed property. Judicial admission. To be marked as Annexure A-6 (Pages 21–24).”

Based on the prompt, this is the response that ChatGPT generated:

“3. The documents that are sought to be brought on record, which are essential for the complete adjudication of the present matter, are as follows:

“i. Relinquishment deed dated 10.06.2020 executed by the Respondent Bharat Singh in favour of the Petitioner Amit Kumar, thereby relinquishing all his rights, title, and interest in the disputed property. This document conclusively establishes the Petitioner’s superior title and directly contradicts the findings of the courts below. The same is filed herewith and marked as Annexure A-1 (Pages 10-12).

ii. Correspondences exchanged between the parties dated 05.07.2019, 12.08.2019, 20.09.2019, and 15.10.2019, wherein the parties discussed the property arrangements and the Respondent acknowledged the Petitioner’s rights over the disputed property. These letters provide crucial context to the relationship between the parties and establish a pattern of recognition by the Respondent of the Petitioner’s superior claim. The same are filed herewith and marked as Annexure A-2 to A-5 respectively (Pages 13-20).

iii. Order dated 25.01.2023 passed by the Ld. District Judge, Tis Hazari Courts, Delhi in the matter titled “Bharat Singh v. Municipal Corporation of Delhi” wherein the Respondent Bharat Singh, while appearing in person, categorically admitted that he has no claim whatsoever over the disputed property. This judicial admission made by the Respondent in a separate proceeding is binding upon him and completely demolishes the foundation of his claim in the present case. The same is filed herewith and marked as Annexure A-6 (Pages 21-24).”

The logic here is letting AI handle the legal drafting while you provide the specific details and strategic direction. 

What you should never do is try to draft legal language from scratch when AI can help you structure it professionally.

Moving on to the next step.

Step 5: The explanation for bringing the additional documents

For explanations, AI is great at creating credible narratives from basic facts.

So I give the following prompt:

“Draft explanation for delay in filing these documents in continuation with the earlier paragraphs:

– Some documents were with the client’s mother, and he didn’t know about them

– Court admission happened after we filed SLP (chronologically impossible to include earlier)  

– Show party acted with due diligence

Make it sound genuine and reasonable.

End with it the standard bona fide statement wherein you state that it is filed for bona fide purpose and not for any other purpose whatsoever.”

Based on the prompt, this is the result that ChatGPT generated:

“4. The Petitioner could not produce the aforementioned documents at the time of filing the Special Leave Petition or during the proceedings in the courts below due to the following genuine circumstances: The relinquishment deed and the correspondence were in the custody of the Petitioner’s mother, who had preserved these documents but the Petitioner was unaware of their existence until recently when they were handed over to him during the course of family discussions about the case.

The judicial admission could not have been produced earlier as the same was recorded by the Tis Hazari Court on 25.01.2023, which is subsequent to the filing of the present Special Leave Petition. The Petitioner has acted with all due diligence and is producing these documents immediately upon their discovery and availability.

5. That the present application is filed for a bona fide purpose and for no other purpose whatsoever.”

The logic here is giving AI the core circumstances and letting it craft believable legal explanations. 

For prayers, AI knows the standard format; we just need to tell it what relief we want:

Step 6: Prayer clause

I simply ask ChatGPT to do the following:

“In continuation with earlier paragraphs, draft prayer section asking to:

– Allow application and bring documents A-1 to A-6 on record

– Direct the Court to take documents on record and to consider these documents during case adjudication

– Standard additional relief clause

Use formal Supreme Court prayer format.”

Based on the prompt, this is the result that ChatGPT generated:

“PRAYER

In the premises aforesaid, it is most respectfully prayed that this Hon’ble Court may graciously be pleased to:

a) Allow the present application and grant permission to the Petitioner to bring on record the additional documents marked as Annexure A-1 to A-6 filed along with this application;

b) Direct that the said documents be taken on record and be considered while adjudicating the Special Leave Petition; and

c) Pass such other and further orders as this Hon’ble Court may deem fit and proper in the circumstances of the case.”

It is always advisable in all prompts to give a reference to earlier prompts so that the AI understands the context and generates results accordingly.

Now, finally, you ask ChatGPT to do the following:

“Now collate the result from all the prompts and give me the complete draft. Ensure that you include the following in the beginning as per Court’s format:

• Jurisdiction heading: “IN THE SUPREME COURT OF INDIA – CIVIL APPELLATE JURISDICTION”
• IA Number: IA No. 456 of 2023
• In: SLP (Civil) No. 78901 of 2023
• Parties: Amit Kumar (Petitioner) vs. Bharat Singh (Respondent)
• Title of Application: “APPLICATION FOR PERMISSION TO FILE ADDITIONAL DOCUMENTS ON BEHALF OF THE PETITIONER”
• Address the application to: “THE HON’BLE CHIEF JUSTICE OF INDIA AND HIS COMPANION JUSTICES OF THE HON’BLE SUPREME COURT OF INDIA”
• Begin with: “MOST RESPECTFULLY SHOWETH:”

Accordingly, ChatGPT has generated the final draft.

I have made the manual edits in red to make it ready for filing in the Court.

          IN THE SUPREME COURT OF INDIA 

CIVIL APPELLATE JURISDICTION

IA NO. 456 OF 2023 

IN 

     SPECIAL LEAVE PETITION (CIVIL) NO. 78901 OF 2023

IN THE MATTER OF: 

Versus 

APPLICATION FOR PERMISSION TO FILE ADDITIONAL DOCUMENTS ON BEHALF OF THE PETITIONER

TO, 

THE HON’BLE CHIEF JUSTICE OF INDIA 

AND HIS COMPANION JUSTICES OF THE

 HON’BLE SUPREME COURT OF INDIA

MOST RESPECTFULLY SHOWETH:

1. The Petitioner has filed the present Special Leave Petition challenging the order dated 15.03.2023 passed by the Hon’ble High Court of Delhi, whereby the High Court upheld the order of the court below declaring the Respondent as the owner of the disputed property.  The facts have been set out in the petition and are not repeated for brevity.  The Petitioner seeks leave of this Hon’ble Court to refer to and rely upon the said petition for the purpose of this application.
   
2. That dDuring the pendency of these proceedings, the Petitioner has discovered certain crucial documents essential for proper adjudication. Their non-consideration would result in incomplete justice and lead to erroneous and incomplete conclusions being drawn on the core issues involved in the case.
   
3. The documents that are sought to be brought on record, which are essential for the complete adjudication of the present matter, are as follows:
   
   i. True copy of the Rrelinquishment deed dated 10.06.2020 executed by the Respondent Bharat Singh in favour of the Petitioner Amit Kumar, thereby relinquishing all his rights, title, and interest in the disputed property. This document conclusively establishes the Petitioner’s superior title and directly contradicts the findings of the courts below. The same is filed herewith and marked as Annexure A-1 (Pages 10-12).
   
   ii. True copies of the Ccorrespondences exchanged between the parties dated 05.07.2019, 12.08.2019, 20.09.2019, and 15.10.2019, wherein the parties discussed the property arrangements and the Respondent acknowledged the Petitioner’s rights over the disputed property. These letters provide crucial context to the relationship between the parties and establish a pattern of recognition by the Respondent of the Petitioner’s superior claim. The same are filed herewith and marked as Annexure A-2 to A-5 respectively (Pages 13-20).
   
   iii. True copy of the order dated 25.01.2023 passed by the Ld. District Judge, Tis Hazari Courts, Delhi in the matter titled “Bharat Singh v. Municipal Corporation of Delhi” wherein the Respondent Bharat Singh, while appearing in person, categorically admitted that he has no claim whatsoever over the disputed property. This judicial admission made by the Respondent in a separate proceeding is binding upon him and completely demolishes the foundation of his claim in the present case. The same is filed herewith and marked as Annexure A-6 (Pages 21-24).
   
4. That the Petitioner could not produce the aforementioned documents at the time of filing the Special Leave Petition or during the proceedings in the courts below due to the following genuine circumstances: The relinquishment deed (Annexure A-1) and the correspondence (Annexures A-2 to A-5) were in the custody of the Petitioner’s mother, who had preserved these documents but the Petitioner was unaware of their existence until recently when they were handed over to him during the course of family discussions about the case.
   
   The judicial admission (Annexure A-6) could not have been produced earlier as the same was recorded by the Hon’ble Tis Hazari Court on 25.01.2023, which is subsequent to the filing of the present Special Leave Petition. The Petitioner has acted with all due diligence and is producing these documents immediately upon their discovery and availability.
   
5. That the present application is filed for a bona fide purpose and is made in the interest of justice and for no other purpose whatsoever.

 PRAYER

In the premises aforesaid, it is most respectfully prayed that this Hon’ble Court may graciously be pleased to:

a) Allow the present application and grant permission to the Petitioner to bring on record the additional documents marked as Annexure A-1 to A-6 filed along with this application;

b) Direct that the said documents be taken on record and be considered while adjudicating the Special Leave Petition; and

c) Pass such other and further orders as this Hon’ble Court may deem fit and proper in the circumstances of the case.

AND FOR THIS ACT OF KINDNESS, THE PETITIONER AS IN DUTY BOUND SHALL EVER PRAY.

Conclusion

You have just witnessed the future of legal practice, where human expertise and artificial intelligence create something more powerful than either could achieve alone. 

Think about what just happened in our conversation: in the time it would have taken you to outline a traditional application, we created a complete, court-ready document that addresses every possible concern a judge might have. 

The AI became your research assistant, writing partner, and strategic advisor all rolled into one, but you remain the legal mind making the critical decisions about strategy, facts, and law. But, you must remember that AI can assist with drafting; it cannot replace legal analysis. This is the perfect partnership between human judgment and artificial intelligence, where technology serves wisdom rather than replacing it.

The revolution in legal drafting has begun, and you are now equipped to be at the forefront of that revolution, serving justice more effectively than ever before.

Frequently asked questions (FAQs)

1. What is the difference between additional documents and fresh evidence? 

Additional documents typically refer to documents that existed at the time of filing but were not produced due to genuine reasons. Fresh evidence usually refers to documents created after the petition was filed or evidence that has come to light through subsequent developments.

2. Can I file additional documents if I simply forgot to include them initially? 

Mere forgetfulness or oversight is generally not a sufficient ground. You must demonstrate that despite due diligence, the documents were not available or their significance was not apparent at the time of filing.

3.  How do I establish the relevance of additional documents? 

You must demonstrate that the documents:

• Directly relate to the issues in dispute
• Have probative value for your case
• Would influence the court’s decision
• Fill gaps in the existing evidence
• Contradict opponent’s claims or support your position

4. Can the court impose costs for filing additional documents? 

Yes, courts may impose costs, especially if they find the application was filed due to negligence or to cause delay. However, if the application is genuine and necessary for justice, costs are usually not imposed