A civil suit is filed by Arvind against Birbal for recovery of money based on an alleged agreement. The Court issues summons to Birbal and the matter now reaches the stage where Birbal has to file his written statement.

A Written Statement is the pleading of the defendant in answer to the plaint filed by the plaintiff. It is governed principally by Order VIII of the Code of Civil Procedure, 1908. The object of a Written Statement is to place before the Court the defence of the defendant and identify the real issues in controversy. While drafting a Written Statement (especially when multiple and different kinds of defences are to be taken), the following points should be kept in mind: 1. Specific Denial of Allegations The defendant must specifically deal with each allegation contained in the plaint. General or evasive denials are not sufficient. Under Order VIII Rules 3, 4 and 5 CPC, allegations not specifically denied may be deemed to be admitted. 2. Paragraph-wise Reply The Written Statement should answer the plaint paragraph by paragraph. Each averment should be expressly admitted, denied, or stated to be not within the defendant's knowledge. 3. Material Facts Only Only material facts constituting the defence should be pleaded. Evidence by which such facts are to be proved should not ordinarily be stated in the pleading. 4. Pleading of New Facts Any new facts constituting a defence, such as fraud, payment, release, limitation, estoppel, waiver, accord and satisfaction, or discharge, should be specifically pleaded. 5. Preliminary Objections Objections relating to jurisdiction, maintainability, limitation, misjoinder or non-joinder of parties, valuation, court fees, or other legal bars should be raised at the outset. 6. Set-off and Counterclaim If the defendant has any claim against the plaintiff arising out of the same transaction or otherwise permissible under law, the same may be pleaded by way of set-off or counterclaim in accordance with Order VIII CPC. 7. Consistency in Defence The defence should be clear, coherent and consistent. Alternative pleas may be taken where permissible, but mutually destructive or contradictory pleas should be avoided. 8. Legal Grounds Relevant statutory provisions, contractual clauses, and legal grounds supporting the defence should be properly stated. 9. Documents Relied Upon The defendant should disclose and produce documents on which reliance is placed in support of the defence in accordance with procedural requirements. 10. Prayer or relief Clause The Written Statement should conclude with an appropriate prayer seeking dismissal of the suit, costs, or any other relief claimed by the defendant. 11. Verification The Written Statement must be properly verified by the defendant, clearly specifying which statements are based on personal knowledge and which are based on information and belief. 12. Timely Filing The Written Statement should be filed within the period prescribed under the Code of Civil Procedure, 1908, as delay may result in adverse procedural consequences. Thus, a properly drafted Written Statement should contain clear and specific denials, material facts constituting the defence, all preliminary objections and legal grounds, together with proper verification and supporting documents, so as to enable the Court to effectively determine the real issues in dispute.