DHINESH V 17040142007

IN THE COURT OF THE JUNIOR CIVIL JUDGE: AT LUCKNOW

O.S. No   OF 2020

Prakash

S/o Bajan Lal Aged 50 Years

Occupation: Manga enthusiast

R/o. Bengaluru     ...Plaintiffs

Vs

Punit

S/o Amenadial Aged 47 Years

Occupation: Technician

R/o. Bengaluru ...Defendants

WRITTEN STATEMENT OF PLAINTIFF FILED UNDER ORDER VII RULE 1

OF CPC

Save such of those Plaint averments that are explicitly and categorically
admitted herein, the remaining contents of the Plaint under the present reply
shall be deemed to have been admitted in toto and the Defendant is called
upon to substantiate the same.

1.The afore named Plaintiff most humbly submits that the suit under the
present reply is maintainable in law in fact as such is liable to be admitted
defendant agreed to execute simple mortgage of his house in favor of the
plaintiff as collateral security for the payment of Rs.30,000@interest of 10% for
5 years p.a.

2.It is submitted that the plaintiff has r cause of action & locus standi to
institute the present suit against the Defendant. It is submitted that the Plaint
allegations are by and large contrived for the purpose of laying a cause of
action against the Defendant which doo exist as per true facts of the case.  It is
also submitted that the same is amply reflected and the very averments of the
Plaint itself.

3. It is submitted that the suit schedule property as described in the Plaint

exist on the spot and the very own documents of the Defendant transparently
reveal the said fact.  As such the documents relied upon by the Defendants are
admissible in evidence as being barred by relevant provisions of law.

Verification: I, the above-named Plaintiff do hereby solemnly declare that the

contents of the above written statement have been duly appraised to me in my
vernacular. And on such appraisal and after thorough and fullest
understanding of the same I find the same to be true and correct to the best of
my knowledge, belief and available legal advice. Hence verified and signed on
this 10th October of 2020 at Bengaluru

Plaintiff

Filed by:

Counsel for Plaintiff

 IN THE COURT OF THE JUNIOR CIVIL JUDGE 

:: ……….

O.S.No   .of 2020

Between:

Prakash

     ..Plaintiffs

AND

Putin

..Defendants

WRITTEN STATEMENT OF PLAINTIFF

FILED UNDER ORDER VIII RULE 1 OF
CPC

Filed On :

Filed On Bhehalf of :