Naradasmriti m2.21

m2.21

vādibhyāṃ likhitāc cheṣaṃ yat punar vādinā smṛtam /
tat pratyākalitaṃ nāma svapāde tasya likhyate //

Additional statements of the plaintiff (or defendant), which are not contained in the writings of both parties, shall be (subsequently) entered into his (their) declaration. They are called Pratyâkalita ('what is interposed').