Defence Insults For Injuries Caused By Negligent Driving Legal Draft Template

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 carriages and

horse; and the person under whose charge and control the said carriage was, was

the servant of the said2. 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 pace.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