Written Statement IN THE COURT OF CIVIL JUDGE SENIOR DIVISION AT ALLAHABAD Suit No, of 2017 A slo B, aged about 51 years, occupation, business, residing at “10, Geeta Colony, Allahabad Plaintiff versus C s/ D, aged about 45 years, occupation, business, residing at Defendant 5, Gopal Nagar, Allahabad Suit for an account against an Agent Written Statement on behalf. of, Defendant The defendant replies as under : 1.- Para 1 is admitte: 2. Para 2 is zoe) 3. Para 3 is admitted. or. The defendant did not receive the alleged notice. . 4. Para 4 is_not admitted'The accounts have been duly rendered periodically and-the vouchers and documents relating to the above accounts have been delivered from time ‘to time to the plaintiff. The last occasion on which the account made up to. on. ; 5. Para 5 is not correct and is not admitted. The accounts made up to......have already been rendered. The plaintiff ceased to finance the steps to be taken for recovery and realisation of the arrears of rent, hence no further recoveries could be made. The plaintiff has himself contributed to the several items of rent to become time-barred. As the plaintiff has himself, in his possession, the accounts Telating to period.......tOj.hence no account can be rendered by the defendant for this period. ; 8. The defendant does not contest the jurisdiction of the court. 7. Para 7 is legal. was delivered along with documents relating thereto wasni PLEADING, DRAFTING AND CONVEYANCING § It is submitted that the suit of the plaintiff be dismissed with costs. Additional pleas . The plaintiff is estopped from claiming rendition of accounts as he himself is in possession of the accounts in question up to.......which were delivered to him along with the papers and documents relating thereto on... a The plaintiff was negligent in omitting to furnish the defendant with sufficient funds to file suits against recalcitrant tenants against whom suits had to be filed for realisation of dues. The defendant is not liable for any arrears having become barred by time. oO 10. The plaintiff has himself been dealing with the tenants personally and realizing sums due as rent from time to time. The plaintiff has not apprised the defendant of such realisations. In case accounts are directed to be taken in this matter, the plaintiff be also directed to render account of such realisations and give credit to the defendant for commission at the stipulated rate on such realisations. Sa- Advocate Sd- Date. b Defendant ove named di 7 verify that the contents of para nos. 1-6, 8-11 are ae 7 ae and the contents of the remaining paras are based on legal Co ana Verification.—I, C, s/o D, the al my Advocate which I believe to be true Place... Sd- FORM 3 Defendant