1) yes Plaintiff can deliver interrogatories to you under order XI Rule 4 CPC
2) Order Xi Civil Procedure Code has the heading "DISCOVERY And INSPECTION". R. 1 of O. 11 has the heading "Discovery by Interrogatories". This shows that discovery can be by way of answer to interrogatories as also by way of affidavit qua documents sought to be discovered.
3) Rules 1 to 11 and Rules 21 to 23 deal with interrogatories,
4) Insofar as interrogatories are concerned, the law provides for three stages. In the first stage, the plaintiff or the defendant has to obtain leave of the Court for delivering interrogatories in writing on a defendant or defendants or the plaintiff or plaintiffs, as the case may be. Such interrogatories had to be separately served on each person requiring to answer. After obtaining permission from the trial Court, the interrogatories are to be served in Form No. 2 in Appendix-C on the person who is required to answer. The person receiving interrogatories is required to answer by way of an affidavit (see Rule 8 of Order XI). In second stage, if a person on whom interrogatories are served does not comply with by filing affidavit in answer to interrogatories, the plaintiff or the defendant who obtained leave of the Court to serve interrogatories has to again file another application under Order XI Rule 11 of CPC. Such application can be filed when the person omits to answer interrogatories or answers interrogatories insufficiently. At that stage, the Court can compel the person to answer interrogatories by passing an order either requiring to answer the interrogatories by affidavit or by vis-a-vis (sic. viva voce). In case such an order is not complied with, the same would result in penal consequences which can either be dismissal of the suit or striking off the defence.
