WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

 

🏛 IN THE COURT OF ____________

(Case Title)
Suit No. _________ of _________

Between:
[Plaintiff’s Name],
… Plaintiff

Vs.

[Defendant’s Name],
… Defendant

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WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

1. Preliminary Submissions:
   Without prejudice to the rights and contentions and reserving the right to file additional pleadings and submissions, the Defendant respectfully submits this Written Statement.

2. Para-wise Reply:

Para No. (of Plaint)	Reply
Para 1	The contents of Para 1 are admitted to the extent they are matter of record; the rest are denied.
Para 2	The contents of Para 2 are denied for want of knowledge; the Plaintiff is put to strict proof.
Para 3	The Defendant denies the allegations made in Para 3 as false and baseless. The correct facts are that… (provide your version).
Para 4	The contents of Para 4 are wrong and denied. The Defendant states that… (provide explanation or defense).
Para 5	The contents of Para 5 are admitted/denied as per record… (respond specifically).

(Continue for all paragraphs of the plaint.)

3. Preliminary Objections / Defenses:
   a) The suit is not maintainable on facts and law.
   b) The suit is barred by limitation (if applicable).
   c) The Plaintiff has not come to court with clean hands and has suppressed material facts.
   d) There is no cause of action against the Defendant.
   e) (Any other objections, such as lack of jurisdiction, misjoinder, etc.)

4. Without Prejudice Statement:
   Without prejudice, the Defendant submits that even if the Plaintiff’s allegations are assumed (which is denied), the Defendant is not liable because… (briefly outline your key defenses).

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PRAYER

In view of the above, the Defendant humbly prays that this Hon’ble Court may be pleased to:
a) Dismiss the suit with costs;
b) Grant any other relief(s) as deemed fit in the interest of justice.

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Place: ___________

Date: ___________

Defendant
(Through Counsel)
(Signature)

Advocate for Defendant
(Name and Address)

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🔹 Checklist before filing:

✅ Attach the Vakalatnama (if appearing through advocate).
✅ Affidavit verifying the written statement.
✅ File within the prescribed time limit.