IN THE COURT OF CIVIL JUDGE (J.D.

) SAHIB, MALOUT

Neha

V/s.

Punjab Staff
Selection
Commission

Suit for Mandatory Injunction

Written Statement on behalf of
defendant no. 3 A.E.T.C.
------Respected Sir,
It is submitted as under :Pre-Objections :1.

That

the

suit

of

the

plaintiff

is

not

maintainable.

2.

That the plaintiff has no cause of action and

locus standie to file the present suit.

3.

That the plaintiff is not competent person to

file the present suit.

4.

That the plaintiff has not come to the court

with clean hands.

-25.

That the Honble Court has no jurisdiction to

try and decide such like cases.

On-Merits :1.That para no. 1 of the plaint is a matter of

record.

2.That para no. 2 of the plaint is a matter of

record.

3.That para no. 3 of the plaint is incorrect and

denied for want of knowledge as the same is
concerned with defendant no. 4 who can reply
this para better.

4.That para no. 4 of the plaint is incorrect and

denied for want of knowledge as the same is
concerned with defendant no. 4 who can reply
this para better.

5.That para no. 5 of the plaint is correct to

this extent that defendant no. 4 was posted as
Inspector in Excise and Taxation Department on
dated

06-07-2009

2009.

Rest

para

as

per

no.

letter
of

dated

the

06-04-

plaint

incorrect and denied for want of knowledge.

is

-36.That para no. 6 of the plaint is incorrect and

denied

for

want

of

knowledge.

The

plaintiff

never visited the office of replying defendant.

It is also to be worthwhile to mention here
that defendants no. 1 & 4 can reply this para
better.

7.That para no. 7 of the plaint is incorrect and

denied

for

want

of

knowledge.

The

plaintiff

never visited the office of replying defendant.

It is also to be worthwhile to mention here
that defendants no. 1 & 4 can reply this para
better.

8.That para no. 8 of the plaint is incorrect and

denied. The Honble Court has no jurisdiction
to try and decide such like cases.

9.That para no. 9 of the plaint is incorrect and

denied.

10.

That para no. 10 of the plaint is formal.

11.

That para no. 11 of the plaint is formal.

-4It is, therefore, prayed that the suit of the

plaintiff may kindly be dismissed with exemplary
costs.

Submitted By :-

A.E.T.C., Sri Muktsar Sahib.

Defednant no. 3

Verification :Verified that the contents of para no. 1 to 5

of pre-objections and para no. 1 to 11 of onmerits of written statement are true and correct
to the best of my knowledge and belief and prayer
is believed to be true.