Written Statement format

IN THE COURT OF __________
AT __________

CIVIL SUIT NO. _____ OF [YEAR]

[PLAINTIFF NAME]
[DEFENDANT NAME]

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant above named most respectfully submits as under:

PRELIMINARY OBJECTIONS:

1. That the present suit is not maintainable in its present form.

2. That this Hon'ble Court has no jurisdiction to try the suit.

3. That the suit is barred by limitation.

4. That the Plaintiff has no locus standi to file the present suit.

5. That the suit is bad for non-joinder/mis-joinder of necessary parties.

PARA-WISE REPLY:

1. The contents of para 1 of the plaint are denied, for the following reasons: ___________. [Or: admitted / not admitted / matter of record. A bare denial may be treated as an admission — Order VIII Rule 5 CPC.]

2. The contents of para 2 of the plaint are denied.

3. The contents of para 3 of the plaint are denied.

ADDITIONAL PLEAS:

1. That the Defendant is the rightful owner of ___________.

2. That the Plaintiff's claim is false and frivolous.

PRAYER:

It is therefore prayed that this Hon'ble Court may be pleased to dismiss the suit with costs.

VERIFICATION:

Verified at __________ on this ___ day of __________, [YEAR], that the contents of paras __ to __ are true to my personal knowledge and paras __ to __ are based on information received and believed to be true. Nothing material has been concealed.

DEFENDANT
Through Counsel