Draft a specimen written statement of a suit for ejectment and arrears of rent. Assume facts, as required.
CS Professional · Drafting, Pleadings and Appearances · PYQS · June 2022
Draft a specimen written statement of a suit for ejectment and arrears of rent. Assume facts, as required.
Answer & Explanation:
Format of Written Statement In the Court of Small Cause, ............ Suit No. ............ of ............ AB S/o CD Age..... Resident of ............ Plaintiff Versus PQ S/o RS Age..... Resident of ............ Defendant Written Statement on behalf of the defendant to the suit for Ejectment, Arrears of Rent and mesne profits. The above said named defendant states as follows: - That the defendant admit the facts stated in paragraph 1 of the plaint. That the defendant admits the agreement mentioned in paragraph 2 of the plaint and his occupation of the said house as alleged therein. That the defendant denies that he has not paid the rent from June 1, 20.., as stated in paragraph 3 of the plaint. That the defendant admits service of the notice alleged in paragraph 4 of the plaint, but does not admit that the plaintiff duly determined the defendant's tenancy thereby. The defendant admits that he continues to be in occupation of the said house but denies that he has not paid any part of the said arrears of rent or that he is liable to Ejectment under the provisions of law alleged in paragraph 4 of the plaint. That the defendant does not admit anyone of the several allegations made in paragraph 5 of the plaint. That no cause of action even occurred to the plaintiff alleged in paragraph 6 of the plaint. That the defendant admits the jurisdiction of the court. That paragraph 8 of the plaint relates to valuation of the suit and payment of court fee which is matter of record. Additional Pleas That the defendant has paid the rent for the months May, June, July.... 2021 to Sri EF, the plaintiff's authorized agent who has been collecting the rent of the said house on behalf of the plaintiff but no rent receipts in respect of the aforesaid months have been issued to the defendant even after repeated demands by the defendant. That the rent of month....of 2021, tendered to the said agent of the plaintiff and to the plaintiff himself but both have refused to accept it. That in fact only ₹ ............ are due from the defendant to the plaintiff as arrears of the rent and that the defendant is ready and willing to pay the said amount to the plaintiff. That there are absolutely no grounds for granting the relief prayed for by the plaintiff and the suit is liable to be dismissed with costs. Place: ............ Date: ............ AB Defendant Through Advocate Verification I, AB, he aforesaid, defendant, do hereby verify the contents of paragraphs ............ and ............ of the above plaint are true to my personal knowledge and the contents of the paragraphs ............ and ............ I believe to be true on information received. Signed and verified this ............ day of ............ 20 ............ at ............ AB Defendant
Topics: Pleadings
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