Written Statement by Proforma Respondent supporting the Plaintiff

Format of Written statement by proforma respondent accepting plaintiff's claim in a suit

 

IN THE COURT OF HON'BLE SHRI _________, ADJ-I, ________ COURTS, DELHI.

CS / DJ / __/20__

IN THE MATTER OF:-
____________ ALIAS ____                                         ...PLAINTIFF
VERSUS
_____ & ORS                                                             ...DEFENDANTS

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT NO. 2 TO THE PLAINT OF THE PLAINTIFF

MOST RESPECTFULLY SHOWETH:-
1. That the Defendant No. 2 has read and understood the contents of the Plaint and his reply to it is set as below.

2. That the Defendant No. 2 is filing the instant Written Statement to bring on record correct facts and circumstances of the case.

3. That the omission on the part of Defendant No. 2 to deal with any statement or contention made in the present Plaint shall not be treated as admission thereof. The Defendant No. 2 hereby denies each and every allegation, contention and submission contained in the present Plaint under reply which is contrary to or inconsistent with what is stated by him hereunder. Defendant No. 2 reserves his right to file additional documents in the matter if need arises.

PRELIMINARY OBJECTIONS & SUBMISSIONS:-
1. That the Defendant No. 2 has no objection on the Plaint filed by the Plaintiff. The material facts mentioned in the Plaint are true and correct to the extent the Defendant No. 2 has seen the documents and has knowledge about the facts.
2. That the Plaintiff is the father of Defendant No. 1 and Defendant No. 2. Defendant No. 3 is their paternal uncle.
3. That Defendant No. 2 is the owner of ___________________.
4. That father of Defendant No. 2, Shri __________ expired on __________, leaving behind his following legal heirs in respect of the above mentioned one-half undivided portion of the entire property.
Sl No. Name of Legal Heirs Relation Remarks

5. The above-mentioned legal heirs are entitled for 1/3rd share each of the unspecified & unpartable share in the entire property.
6. That the Plaintiff informed Defendant No. 2 that Defendant No. 1 had fraudulently got a Relinquishment Deed dated ___.__.20__ executed from him in respect of her undivided share in the said property, in his favour through concealment and misrepresentation. The Plaintiff said that she had no knowledge or intention of executing the said Relinquishment Deed dated _____.
7. That the right of the Defendant No. 2 is also affected as the Defendant No. 1 had tried to grab property of his mother, the Plaintiff, by fraudulent means.
8. That the present suit has been filed by the Plaintiff on reasonable grounds, hence the same needs to be allowed.

PARA WISE REPLY:-
1. That the contents of Para 1 of the Plaint of the Plaintiff is correct and admitted. It is true that the Plaintiff has inherited undivided 1/3rd share of the undivided Property bearing Municipal No. ______________, forming part of Khasra __________ _____.
2. That the contents of Para 2 of the Plaint of the Plaintiff is correct and admitted.
3. That the contents of Para 3 of the Plaint of the Plaintiff is correct and admitted.
4. That the contents of Para 4 of the Plaint of the Plaintiff is correct and admitted.
5. That the contents of Para 5 of the Plaint of the Plaintiff is correct and admitted.
6. That the contents of Para 6 of the Plaint of the Plaintiff is correct and admitted.
7. That the contents of Para 7 of the Plaint of the Plaintiff is correct and admitted.
8. That the contents of Para 8 of the Plaint of the Plaintiff is correct and admitted.
9. That the contents of Para 9 of the Plaint of the Plaintiff need no reply.
10. That the contents of Para 10 of the Plaint of the Plaintiff need no reply.

In view of the fact and circumstance as well as the Preliminary submission, and Para-wise Reply narrated hereinabove, the Defendant No. 2 above, most respectfully pray to this Hon'ble Court to graciously be pleased to admit the Plaint / Suit of the Plaintiff and pass Judgment/Order in favour of the Plaintiff.
Pass an order that that the Plaintiff is entitled to relief in the fact, and law as mentioned herein above by the Defendant No. 2.

Any other or further Order as this Hon'ble Court may deem fit and proper in favour in the interest of Justice.

(DEFENDANT NO. 2)
Through
__________________
Advocates for the Defendant No. 1 &2.

VERIFICATION:-
Verified at Delhi on this day of_________, 20__ that the content of initial para 1 to _ and para 1 to __ of the Preliminary Objections and submission and para 1 to __ of para wise reply of the written statement are true and correct to my knowledge and belief and the legal advice received, no part of it is false and nothing material has been concealed there from.



(DEFENDANT NO. 2)