Drafting Plaints Written Statements LegalDraft-Templates

Written Statements General Defences Denial The defendant denies that facts The defendant does not admit that facts The defendant admits that but says that The defendant denies that he is a partner in the defendant firm of Protest The defendant denies that he made the contract alleged or any contact with the plaintiff The defendant denies that he contracted with plaintiff as alleged or at all The defendant admits assets but not the plaintiff s claim The defendant denies that the plaintiff sold to him the goods mentioned in the plaint or any of them Limitation The suit is barred by article or article of the Second Schedule to the Indian Limitation Act 1877 15 of 1877 Jurisdiction The Court has no jurisdiction to hear the suit on the ground that set forth the grounds On the day of a diamond ring was delivered by the defendan...

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...

Defence in suits for infringement of copyright 1 The plaintiff is no the author Assignee etc 2 The book was not registered 3 The defendant did not infrings...

Defence in suits for relating to nuisances 1 The plaintiff s lights are not ancient or deny his other alleged prescriptive rights 2 The plaintiff s lights will not be materially interfered with by the defendant s buildings 3 The defendant denies that he or his servants pollute the water or do what is complained of If the defendant claims the right by prescription or otherwise to do what is complained of he must say so and must state the grounds of the claim i e whether by prescription grant or what 4 The plaintiff has bee guilty of laches of which the following are particulars 1870 plaintiff s mill began to work 1871 plaintiff came into possession 1883 First complaint...

Defence to Suits for Specific Performance 1 The defendant did not enter into the agreement 2 was not the agent for the defendant if alleged by plaintiff 3 The plaintiff has not performed the following conditions Conditions 4 The defendant did not alleged acts of part performance 5 The plaintiff s title to the property agreed to be sold is not such as the defendant is bound to accept by reason of the following matter State why 6 The agreement is uncertain in the following respects State them 7 Or The plaintiff has been guilty of delay 8 Or The plaintiff has been guilty of fraud or mis representation 9 Or The agreement is unfair 10 Or The agreement was entered into by mistake 11 The following are particulars of 7 8 9 10 or as the case may be 12 The agreement was re...

Title of Suits In the Court of Add Description and Residence Plaintiff Against Add Description and residence Defendant DESCRIPTION OF PARTIES IN PARTICULAR CASES The Union of India or the State at the case may be The Advocate General of The Collector of The State of The Company Limited having its registered office at a public officer of the Company Add description and residence on behalf of himself and all other creditors of late of Add Description and residence Add description an...