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IN THE COURT OF THE JUNIOR CIVIL JUDGE:

CITY CIVIL COURT: HARIDWAR

Civil Suit No. 111 of 2017

A.B. s/o C.D.


H.N. 123, Ranipur More, Haridwar ……………Plaintiff

Vs.

M.N. s/o O.P.


H.N. 213, Kankhal, Haridwar ……………Defendant

WRITTEN STATEMENT FILED BY THE DEFENDANT UNDER ORDER VIII,


RULE.1, C.P.C.

The Defendant replies as under:

1. It is submitted that the Defendant has gone through the averments made in the plaint. The
averments, which are not specifically admitted, are denied. The Plaintiff is put to strict proof
of the same. Most of the averments are wrong and false and therefore the suit is not
maintainable.

2. In reply to Para II (1) of the plaint, it is submitted that I did not approach him for a hand loan
or executed a promissory note in favour of him. I have sufficient means to fulfil my family’s
needs. Therefore, the question of borrowing money by way of a hand loan does not come into
picture.

3. In reply to Para II (2) of the plaint, it is submitted that a notice was received by me on 1st May,
2016. Since I did not approach the Plaintiff for a hand loan and executed a pro-note, I chose
not to reply to the notice. The contents of the notice being vague and false. Hence, the
averments in the notice are denied.

4. Para II (3) of the plaint is denied. It is submitted that I did not approach the Plaintiff for
borrowing the said sum of Rs. 30,000 and executed a pro-note in favour of him. The allegations
of the Plaintiff are false. Therefore, the Defendant is not bound to pay any amount to him.

5. In reply to Para II (4) of the plaint, it is submitted that since the Defendant borrowed no money
from the Plaintiff and executed a pro-note, the outstanding figures stated in this para are false
and frivolous.

6. It is hereby submitted that I never approached the Plaintiff for any amount and executed a pro-
note. There is a vendetta between the two families regarding some disputes. The Plaintiff
fabricated the pro-note. The Plaint is a false and frivolous one by way of which the Plaintiff is
trying to mislead this Hon’ble Court.

7. Hence, it is prayed that this Hon’ble Court may be pleased to dismiss the suit.

Place: ......................
(Signature of the defendant)
Date: .......................

PQR
Advocate
VERIFICATION

I, ______, do hereby solemnly verify that the contents from paras...........are correct and true to
the best of my knowledge and contents from para........ are based on legal advice, which I
believe to be correct. Affirmed at............ this ........ Day of............2017.

(Signature)

Defendant