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The facts denying all the allegations made by the plaintiff in the plaint;
The facts showing that the court has jurisdiction or not or any cause of
action arise or not.
V Claim for relief against the averments made by plaintiff in the Plaint.
V j
That the defendant denies that he entered into an agreement to sell and that
the plaintiff paid Rs. 1,oo,000 or any other amount to him as earnest money
as alleges in Para 1 of the plaint.
2.
That defendant denies that on June 1, 1991 or on any other date, the Plaintiff
tendered any amount to him and called upon him to execute the sale deed as
alleged in Para 2 of the plaint. Since it is not true that defendant executed any
agreement to sell the suit property to the plaintiff and the plaintiff being
ready and willing to perform his part of the alleged contract did not arise at all
and the whole story is got up and false.
ABC
Defendants advocate
..
Defendant
j, Ramanbhai Mohanbhai Patel, the defendant abovenamed do solemnly declare that what is stated in Paras
1 and 2 is true to my knowledge and that what is stated
in remaining paras is stated on information received
by me & j believe it to be true.
.
Defendant
The defense can not be rejected on the ground that the legal effect of the facts
was not stated.
2.
3.
4. Every allegation of fact if not denied specifically and stated to be not admitted
6. For any new ground arisen after institution of suit, court is empowered to take
notice of it.
7.
jf the defendant fails to present his written statement within the time
permitted , the court will pronounce the judgment against defendant.
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