S MOUNEESH

17040142015

IN THE COURT OF THE JUNIOR CIVIL JUDGE: AT DELHI

O.S. No   OF 2020

Prakash
S/o Veanugopal Aged 38 Years
Occupation: farmer
R/o. DELHI     ...Plaintiffs

Vs

Punit
S/o Mohan Das Aged 40 Years,
Occupation: Engineer.
R/o. DELHI ...Defendants

WRITTEN STATEMENT OF PLAINTIFF FILED UNDER ORDER VIII 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
to 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.

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
25thSeptember of 2020 at Delhi.

Plaintiff

Filed by:

Counsel for Plaintiff