WRITTEN STATEMENT

In the City Civil Court, at Ahmedabad

Civil Suit No. 100 of 2016

Piyush Pandey, Hindu, Adult aged about 20 years . . Plaintiff;

residing at 15, A-Block, Indira Nagar, Lucknow

Versus

Aman Kumar Saini, Hindu, Adult, aged about 22 . . Defendant;

years, residing at 21, Lakhshmanpuri, Faizabad

The written statement on behalf of the defendant above named:

1. The defendant denies that he entered into an agreement to sell the suit property to the
plaintiff on 1 January 2016 or on any other date and that the plaintiff paid Rs. 1,00,000 or
any other amount to him as earnest money as alleged in para 1 of the plaint.
2. The defendant denies that on 1 June 2016 or on any other date, the plaintiff tendered
Rs. 9,00,000 or any other amount to him and called upon him to execute the sale deed as
alleged in para 2 of the plaint. The defendant says that since it is not true that he executed
any agreement to sell the suit property to the plaintiff, the question of the plaintiff, the
question of the plaintiff tendering the balance of consideration and the plaintiff being
ready and willing to perform his part of alleged contract did not arise at all and the whole
story is got and false.
3. The defendant says that in the view of what is stated above, the plaintiff has no cause of
action to file the suit against him.
4. The defendant, therefore, submits that the plaintiff is not entitled to any of the reliefs
claimed by him in the plaint and the suit filed by him be dismissed with costs.
 DEF …………………..
Defendant’s Advocate Defendant

Verification

I, Aman Kumar Saini, defendant above named do solemnly declare that what is stated in
para 1 and 2 is true to my knowledge and that what is stated in the remaining paras is
stated on information received by me and I believe it to be true.

………………….

Defendant