An amendment that elevates previously pleaded factual matters (such as a policy or allocation) to contractual status by relying on a previously unpleaded agreement involving different parties and obligations introduces a new cause of action requiring leave. Lack of particularity in the proposed amendment — especially where the alleged agreement is oral and more than 20 years old — is a proper basis for refusing leave, and an appellate court will not intervene in such matters of practice and procedure absent appellable error.
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