Written Statement in Negligence Case

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IN THE COURT OF [COURT NAME]
[Jurisdiction]

Suit No.: [As given]

Plaintiff: [Plaintiff’s Name]
Defendant: [Defendant’s Name]

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WRITTEN STATEMENT ON BEHALF OF DEFENDANT

1. Preliminary Submissions:
   a) The Defendant denies each and every allegation except those specifically admitted herein.
   b) The plaint is vague, frivolous, and does not disclose a cause of action.

2. Brief Facts:

   • The Defendant states that they exercised due care and diligence in all their actions.

   • The alleged incident on [date] was not caused by any act or omission on part of the Defendant but was due to factors beyond control / an inevitable accident.

3. Specific Replies to Allegations:

   • Para [number] of the plaint is denied. The Defendant never owed a duty of care in the manner alleged or breached any such duty.

   • Para [number] is denied. There was contributory negligence on part of the Plaintiff, who failed to exercise reasonable caution.

   • Without prejudice, even if any harm occurred, it was minimal and the damages claimed are highly exaggerated.

4. Legal Grounds / Defenses:

   • There was no negligence attributable to the Defendant.

   • The principle of volenti non fit injuria applies, as the Plaintiff voluntarily assumed the risk.

   • The Plaintiff’s claim is barred by limitation / not maintainable.

5. Prayer:
   In light of the above, the Defendant respectfully prays that this Hon’ble Court:
   a) Dismiss the suit filed by the Plaintiff;
   b) Award costs of this proceeding to the Defendant;
   c) Pass such other orders as deemed just and proper.

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Place: [City]
Date: [Insert Date]

Defendant / Advocate’s Signature
[Name]