84. Discovery of documents and facts

to state by affidavit, any document he has or has had in his possession or power relating to the matters in question, or whether he has or has had in his possession or power any specified document, documents or class of documents and in either case, the present whereabouts of any documents formerly, but not now, in his possession or power; or

to produce any document in his possession or power; or

to answer orally or by affidavit, interrogatories delivered by the other party and approved by the Court.