Defence in suits for injuries caused by negligent Driving

1.	The defendant denies that the carriage mentioned in the plaint was the defendant’s carriage, and that it was under the charge or control of the defendant’s servants. The carriage belonged to …………… of ………… Street, Calcutta livery stable keepers employed by the defendant to supply him with carriage and horses; and the person under whose charge and control the said carriage was, was the servant of the said.

2.	The defendant does not admit that the said carriage was turned out of Middleton Street either negligently, suddenly or without warning or at a rapid or dangerous place.

3.	The defendant says the plaintiff might and could, by the exercise of reasonable care and diligence, have seen the said carriage approaching him, and avoided any collision with it.

4.	The defendant does not admit the statements contained in the third paragraph of the plaint.