IN THE COURT OF THE III ADDITIONAL JUNIOR CIVIL JUDGE :
CITY CIVIL COURT : AT HYDERABAD.
O.S. No.
of
2007
Between:-
Mr.Rama
Rao,
S/o………………..
Aged …. years,
Occ:
………….
R/o.Hyderabad
… Plaintiff
And
Mr.Appa
Rao,
S/o………………………,
Aged …. Years,
Occ:…………….
R/o.Hyderabad.
…Defendant
WRITTEN STATEMENT FILED BY THE DEFENDANT
UNDER ORDER VIII, RL.1, C.P.C.
1)
It is submitted that the defendant has
gone through the averments made in the plaint and affidavit filed in support of
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 not
correct and false and the suit is not maintainable.
2)
In reply to Para III (1) of the plaint, it
is submitted that I have no acquaintance with the plaintiff and did not
approach at any point of time for hand loan to meet my son’s education and
executed promissory note in favour of the plaintiff. I have sufficient means to
support my family. Hence, there is no question of taking hand loan from the
plaintiff and execution of promissory note in favour of the plaintiff.
3)
In reply to para III (2) of the plaint, it
is submitted that the notice issued by the plaintiff was received by me
on………….. The contents of the notice are vague and false. Since I did not
approach the plaintiff for any hand loan and executed promissory note, I did
not choose to reply the notice. Hence, the allegations in the notice are
denied.
4)
In reply to para III (3) of the plaint, it
is submitted that I did not borrow any amount from the plaintiff and executed
promissory note in favour of him. The allegation of the plaintiff is false and
I need not bound to pay any amount to the plaintiff. It is not correct to say
that I have borrowed a sum of Rs.25,000/- from the plaintiff and executed a
promissory note in favour of him.
5)
In reply to Para III (4) of the plaint, it
is submitted that since there is no amount is borrowed from the plaintiff and
executed pro-note, the figures of outstanding stated in para therein is false
and fabricated one.
6)
It is submitted that I have never
approached the plaintiff for any amount said to have been borrowed by me and
executed pro-note. Since we reside in the same street and due to rivalry
between our two families regarding some disputes relating to colony problems,
the plaintiff has fabricated the pro-note and filed the present suit alleging
that I have borrowed a sum of Rs.25,000/- from plaintiff and executed a
pro-note. The plaintiff is trying to mislead this Hon’ble Court and made false
allegations in the plaint.
7)
The other allegations of the plaint which
are not specifically admitted herein are denied. The plaintiff is put to strict
proof of the same.
Hence, it is prayed that this Hon’ble Court may be pleased to dismiss the suit
with costs.
Counsel
for the
Defendant
Defendant
Verification
I, Appa Rao,
S/o
aged about years, Occ: Employee, do hereby
declare that the facts stated in paras 1 to 7 are true and correct to the best
of my knowledge, information and belief and I believe the same to be true and
correct. Hence, verified on this the day
of June, 2007 at Hyderabad.
Defendant
Accepted
by:
Falak Sher Bhati
Advocate
Kasur
Chamber
No 96-97
District Bar
Association Kasur
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