IN THE COURT OF CIVIL JUDGE (S.D.

), DEHRADUN

ORIGINAL SUIT NO. _____ OF 2018

Mr. Sandeep Gupta, s/o Mr. Prabhakar Gupta, aged 53 years old r/o House No. 49, BSF
Colony, Jogiwala, Dehradun
…………………. Plaintiff
Versus

Mrs. Aastha Agarwal, w/o Suraj Agarwal, aged 39 years old, r/o C-49, Galaxy
Apartments, Rajpur Road, Dehradun
………………. Defendant

WRITTEN STATEMENT

Sir,
The defendant above-named submits this statement, praying to state as follows:
1. That the contents of Para 1 states a fact and needs no reply.
2. That the contents of Para 2 of the plaint are true and correct, and hence,
admitted by this Defendant.
3. That the contents of Para 3 of the plaint are likewise true and correct, and
hence, call for no comments.
4. That the contents of Para 4 of the plaint are true and correct, and hence,
admitted by this Defendant.
5. That the contents of Para 5 of the plaint are false, and the defendant submits
that the Plaintiff didn’t come and inform the Defendant about his wish to
not renew the rent agreement until the last two weeks of the 11th month and
not 2 months prior as claimed by the Plaintiff.
6. That the contents of Para 6 of the plaint are true and correct, and hence,
admitted by this Defendant.
7. That the contents of Para 7 of the plaint are partially true and partially false,
the Plaintiff did send a legal notice dated 05.09.2018 and the contents stated
in it are true but the Defendant submits that how can the Plaintiff send a
legal notice when the Plaintiff himself informed about not renewing of rent
2 weeks prior before the actual end of the agreement period and hence,
violating the terms of their rent agreement clause.
8. That the contents of Para 8 & 9 are baseless, false, and frivolous, and while
denying the same, this Defendant submits that she did acknowledge the
legal notice and had a verbal argument over it with the Plaintiff over phone
call. The Defendant further submits that she did not avoid the Plaintiff’s
phone call nor meeting him in person and tried to negotiate to let her keep
the floor until she finds a new place whenever they talked or met in person,
this usually led to the Plaintiff calling vulgar and indecent names of the
Defendant.
9. That the contents of para 10 of the plaint are denied by this Defendant, and
this Defendant submits that the Plaintiff be put to the strict proof of the
same.
10. That the contents of Para 11 of the plaint is wrong, baseless and malafide,
hence denied. It is wrong to say that the Defendant holds illegal possession
 of the said rent property when no proper time was given to her for eviction
accordingly given under their rent agreement clauses. The plaintiff has no
cause of action to file the present suit. The plaintiff has not come with clean
hands. True facts have been stated above.
11. That the contents of Para 12 of the plaint is wrong, baseless and malafide,
hence denied. The plaintiff has no cause of action. The allege cause of action
is wrong and specifically denied.

12. That in Para 13 of the plaint, it is admitted that the property is in the
municipal limits of Dehradun and the Ld. Court has the jurisdiction to hear
and adjudicate it.

13. That in Para 14, it is admitted that the Court fee for the suits valued at Rs.
1,100.

14. That the plaintiff is not entitled for the relief claim.

Hence, it is prayed that this Hon’ble Court may be pleased to dismiss the suit
with cost.

Counsel for the Defendant Defendant

Verification

I, Mrs. Aastha Agarwal, w/o Suraj Agarwal, aged 39 years old, r/o C-49, Galaxy
Apartments, Rajpur Road, Dehradun do hereby verify that the contents of para 1 to 14
of the above are true to the best of knowledge & belief. Nothing material has been
concealed herewith & no part of it is untrue. So, help me God.

Verified at Dehradun on 01.11.2018

……………..
Defendant