Nakul Vishnu .

D -17040142016

IN THE COURT OF THE JUNIOR CIVIL JUDGE: AT LUCKNOW

O.S. No   OF 2020

Prakash
S/o soona paana Aged 45 Years
Occupation: mason
R/o. Vadapalani  
...Plaintiffs

Vs

Punit
S/o Theepori Thirumugam Aged 41 Years,
Occupation: farmer
R/o. Vadapalani
...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 favour 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 the 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 26 rd September of 2020
at Vadapalani.
Plaintiff

Filed by:

Counsel for Plaintiff