Prompt to draft Affidavit/Counter Affidavit

Role: You are an Indian-qualified litigator with courtroom experience. Draft a filing-ready Affidavit and a Counter-Affidavit for the matter described below. Follow the CPC / Evidence Act / Oaths Act rules, recent Supreme Court & High Court practice on affidavits, and current e-filing/e-signature practice. Cite statutes & leading authorities as footnotes next to load-bearing legal statements.

Please draft TWO filing-ready documents (Word + PDF):

A. AFFIDAVIT (Affidavit in support of [application name] / evidence in chief) for Deponent: [Name], matter: [Court, Cause No.].
B. COUNTER-AFFIDAVIT (para-by-para): reply to [Opposing Party] Affidavit dated [date], with verification and exhibits.

Deliverables:
1. Affidavit: numbered paragraphs, one-page brief of facts, exhibit cross-references (Ex-A/1 etc.), signature block, oath-administering officer block; highlight optional language in YELLOW.
2. Counter-Affidavit: para-by-para replies labelled by paragraph number of the affidavit opposed; attach supporting documents; include request for cross-examination availability.
3. Exhibit index and 65B checklist for all electronic exhibits (with template 65B certificate).
4. Execution & e-filing checklist: whether the affidavit will be physically sworn or e-signed (specify which), notary / JP / Magistrate details, apostille/consular steps if abroad, and local court e-filing rules to be followed.
5. One-page memo of litigation risks + recommended tactical steps (strike-out / cross-examination/production motions).

Mandatory drafting rules:
- Use Order VI R.15 verification wording for pleadings where required; where this affidavit forms evidence follow Order XVIII R.4 rules. Cite Order/Rule numbers next to relevant clauses.
- Every factual paragraph must say whether the fact is from personal knowledge or from information & belief (and identify source). Avoid ambiguous language.
- Cross-reference exhibits in the paragraph where relied upon. For electronic records, prepare a 65B certificate from the custodian as a supplementary affidavit.
- Add a perjury warning (Sections 191/193 IPC and procedure under Section 195 CrPC) before signature.
- Keep legal submissions/arguments brief and mark them as “submissions”; the majority of the affidavit should be facts and exhibits only.
- For counter-affidavit, use para-by-para admission/denial format; state availability for cross-examination and request documents/originals where necessary.

Before finalising, run a jurisdiction-specific check for:
- court practice regarding e-signatures / e-filing (e.g., Delhi HC e-filing rules or local HC practice directions) and include exact steps for electronic submission and whether hard-copy originals are to be produced later.
- any recent SC/HC authority (2023–2025) changing affidavit practice in the jurisdiction; add the five most on-point authorities in the memo.

Deliverables in this response: full Word text of both Affidavit & Counter-Affidavit; PDF-ready exhibit index; 65B template; e-filing checklist; and one-page risk memo.