Written Statement [Sample]

In the Court of Hon’ble Civil Judge, District Court, ______

Case No. ……/2018 

 

Smt. Shabnam W/o Kayyum, resident of Bhagwati Kunj, Nagla Sherkhan   ………..……Plaintiff/Petitioner

 

versus

 

Sri Shamshad S/o Sri Sohil Khan , resident North of Mohalla crazy Pura   ……….…………Defendant/Opposite party

 

Written Statement on behalf of Defendant

 

Most respectfully showeth

Preliminary objections:

  1. That present complaint being devoid of merits should be dismissed with heavy cost.
  2. That the provisions of The Uttar Pradesh Urban Buildings (Regulation of Letting, Rent And Eviction) Act, 1972 does not apply to the present case and therefore the Hon’ble Court cannot exercise jurisdiction under the Act.
  3. That at the very outset it is stated that the present plaint has been filed against the defendant with the mala fide intention and to extort the money and the property from the defendant.
  4. That the plaintiff has concealed various material facts form this Hon’ble Court such as that the defendant was never informed about the transfer of the property.
  5. That the plaintiff has concealed the factum that the defendant has paid 8 months advance rent to the previous owners
  6. That the complainant has not filed the present complaint within the period of limitation and therefore should be dismissed on this ground alone.

Parawise reply:

  1. That content of para no. 1 of the plaint is matter of record and hence need no reply.
  2. That content of para no. 1 of the plaint is matter of record and hence need no reply.
  3. That the contents of Para 3 states a fact and needs no reply.
  4. That the contents of para 4 are false and is denied by the defendant. That in reply to the instant para it is submitted that the defendant was not aware of any such transfer of property and was neither informed by the previous owners of the property.
  5. That the contents of para 5 of the plaint is incorrect. It is submitted that the defendant had paid the rent in advance for a period of 8 months along with the security amount to the previous owners.
  6. That the contents of para 6 are vague and denied in toto.
  7. That the contents of para 7 are denied in toto as already stated that the defendant had paid the rent previously and therefore cannot be termed as the defaulter.
  8. That the contents of para 8 are denied in toto.
  9. That the contents of para 9 are incorrect and therefore denied.
  10. That the contents of para 9 are incorrect and therefore denied.

 

 

PRAYER

That hence in the light of present facts stated, circumstances established, it is humbly prayed that this Hon’ble Court may graciously be pleased to dismiss the plaint with heavy cost.

 

Defendant

THROUGH

Mr. Karan Arjun,

[Advocate]

 

Place:

Date:    DD.MM.YYYY

 

Debolina Roy

Debolina is a final year law student at UPES, Dehradun. She aspires to become a litigator. Being an envrionmentalist she aims at serving and taking steps for preserving the environment. She lives by the motto of 'Nation First' and aims at bringing change for the benefit of our country.

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