Written Statement

IN THE COURT OF LD.
DISTRICT AND SESSION

JUDGE, SAKET
COURTS, NEW DELHI
CIVIL SUIT NO. OF 2019
INTHE MATTER OF:
M/s Dooa Impex
...PLAINTIFF
VERSUS
M/s P.C.Global
Merchandising Pvt. Lid.& Ors. ...DEFENDANT
WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT NoH-2|ol22

NO. 1
UNDER ORDER VIII RULE 1,CODE OF CIVIL PROCEDURE, 1908
MOST RESPECTFULLY SHOWETH:

1. That the defendant I is the company M/s P.C.
no.
Global Merchandising
which is a private limited company incorporated and registered under the
Companies Act having its registered office at B-24, Panchsheel Enclave
New Delhi - 110017. That Mr. Sudeep Ranjan Goel is the authorized
signatory of M/s P.C. Global Merchandising and is authorized to do all

acts on behalf of the company particularly to represent the company, to
sign and verify documents on its behalf, to swear affidavits, etc. before
the court of law and before any judicial and quasi judicial authority to
represent the defendant and to do all such other things as may be
necessary for the successful pursuit of the matter.
2. That at the outset, the answering defendant denies all the allegations
contained in the Suit for recovery except those which are specifically
admitted hereinafter in this Written Statement, and nothing stated in_jhe
Written Statement should be deemed to be admitted merely because the
same is not specifically traversed.
3. Before traversing in detail the averments and contentions made in the
Written Statement. the answering defendant takes preliminary

submissions to the civil suit on its maintainability as well as relating to
the jurisdiction before the Hon' ble Couit and as these objections goes to
the root of the case, a decision on these objections is essential.
PRELIMINARY SUBMISSIONS:
2
1. That the plaintiff are not coming
with clean hands and has
deliberately
suppressed the material facts and filed the present suit on the basis of
false and fabricated facts as well as documents. Therefore the said suit
needs to be rejected and dismissed at the very outset.
2. That the Plaintiff has filled the

present suit with a malicious intention to
cause harm to the reputation of the Defendant whereas no cause of action
has ever aroused between the
parties to the present suit.
3. That the plaintiff is engaged in business of supplying Elastic Inter Lining,
Buttons and all types of Garment Accessories under the name of M/s
Dooa Impex. The plaintiff and the defendant are engaged in business
dealing for a long period of time almost more than 8 years. The plaintiff
opened a running account in the name of defendant proprietorshipp
concern in the normal course of business. The dealings were done
through cash and credit basis on a mutual settlement.
4. That the statement of accounts relied upon by the plaintiff was

maintained by him in normal course of business. The same is easily
editable by the plaintiff for his own wrongful gain. It s important that
certain challans no amount was mentioned.
5. That the loss has been suffered by the defendant as he had committed th
delivery of the material to the buyer further. Rather than delivering the
goods/material to the defendant, the plaintiff had caused wrongful loss by
filing by the present suit.
6. That he Defendant intimated Plaintiff about the degraded quality and

high prices of goods by telephonic conversations and issuing the Debit
note for th same.
7. That the Plaintiff has delivered defected and degraded quality of goods
and has charged prices higher than the market value thereby causing a
huge loss to the answering Defendant. Certain goods were delivered on
higher price and later the plaintiff agreed to settle the account later. A
proof of the higher priee is annexed with the wtitten statement.

8. That due to use of un-professional techniques, and non-delivery of
3
prescribed quality of work by the plaintiff, the defendant was bound to
make repeated demands for the order placed by him on the plaintiff.
9. That 1he delendant has not breached any term or conditions of the
business dealings rather it is the plaintiff who has breached the years old
trust of Defendant just to cause wrongful loss to the defendant. Thus, the
plaintiff is falsely impleading the defendant in the present suit.
10.That the defendant has compare the plaintiff rate of price from the market
rate of price and with from the other dealers rate after comparing rate
defendants find the difference between the plaintiff rate and the market
rate. A sheet has been attached with the written statement.
11. That the Plaintiff is proprietorship firm, which is not a Legal identity
hence cannot due on its own name and the present suit is not
maintainable in its present form.
12.That the value of suit for the purpose of court fee and jurisdiction is fixed
for relief that the suit be dismissed with cost as there is
no cause of action and the appropriate court fee is duly fixed for the
same.
PARA-WISEREPLY:
That without prejudice to the above preliminary submissions taken by the

answering defendant, the Para-wise reply to Suit for recovery is also furnished as
below:
1. That the contents of Para l are the matter of fact and record, hence does
not call for any reply.
2. That the contents of Para 2 are matter of fact & record, hernce does not
call for any reply.
3. That the contents of Para 3 are incorrect, false and vehemently denied.
It is admitted to the extent that plaintiff is the proprietor of M/S Dooa
Impex and carrying the business of supplying Elastic lnter lining

Buttons of all types of Garment Accessories and Defendant No. 2 is the
Director of Defendant No.1. Further the contents of thè Para 3 in the

petitievn is false ared cdenied t is
specifically denied that
Defendant No
3&Deferdant No. 4 are the Directors of
The fendand No 1 (PC Global
Merchandising P1 td) tie specificali denied that De
has
fendant No
evet issed an cheques in favot
of Plaintiff It is submitted that
Defendan No.2 tated doing
husines with the plaintiff to purchase
lastie lntet lining. Ruttome of all
tvpes of Garment Accessories on
agreed tems of mutual settlement
4 That the contents of Para 4 are

fabricated. incorrect and false, hence
denicd li i
pertinent to mention that the quality of the
goods dejivered
by the Piaintiff were infetior in nature which lead to
irreversible loss to
the defemdant I1 s
pertinent to mention that it is the plaintiff who has
hreached the years old business relations
and trust of Defendant just to
cause
wrongful loss to the defendant
by using un-professional
techniques, and non-delivery of prescribed and pre-approved quality ot
asked by the Defendant.
5. That the contents

of Para are fabricated. incorect and false. hence
denied. It is pertinent 1o mention that the quality of the goods delivered
by the Plaintiff were inferior in nature which lead to imeversible loss to
the defendant.
6. That the contents of Para 6 are fabricated, incorect and false. nence
denied. It is pertinent to mention that the quality of the goods delivered
by the Plaintiff were inferior in nature which lead to irreversible loss to

the defendant and the plaintiif was adequately paid tor the goods
supplied.
7. That the contents of Para 7 are tabricated, incorect and talse, henee
by the Planuff were inferior in nature which lead to irreversible loss to
the delendant.
8. That the contents of Para 8 are fabricated, incorreet and false, hence
deniçd. It is pertinent to mention that the quality of the goods delivered

by the Plaintifl were inferior in nature which lead to irreversible loss to
5
the defendunt. It is pertinent to mention that it is the plaintiff who has
breached the years old business relations and trust of Defendant just to
cause wrongful loss 1o the defendant by using un-professional
lechniqucs, and non-delivery of preseribed and pre-approved quality ot

goods asked by the Defendant.
9. That the contents of Para 9 are fabricated, incorect and false, hence

the defendarnt. It is pertinent to mention that it is the plaintiff who has
cause wrongful loss to the defendant by using un-professional

techniques. and non-delivery of prescribed and pre-approved quality of
10.That the contents of Para 10 are fabricated, incorrect and false, hence
the defendant. It is pertinent to mention that it is the plaintiff who has

techniques, and non-delivery of prescribed and pre-approved quality of
11.That the contents of Para 1 are false and incorrect hence vehemently
denied in Lolality. It is pertinent to mention that the
quality of the goods
delivered by the Plaintiff were inferior in nature which lead to
irreversible loss to the defendant. It is pertinent to mention that it is the
plaintiff who has breached the years old business relations and trust of
Defendant just to cause wrongful loss to the defendant by using un-
professional techniques, and non-delivery of prescribed and pre-

approved quality of goods asked by the Defendant.
denied in totality. It is pertinent to mention that the of the goods
qua.
delivered by the Plaintiff 6
were inferior in nature which lead
irreversible loss to the defendant.
to
It is
pertinent to mention that it is the
plaintiff who has breached the
years old business relations and trust
Defendant just of
to cause
wrongful loss to the defendant by
professional techniques, and using un-
non-delivery of prescribed and pre-
approved quality of goods asked by the
Defendant.
13.That the contents of Para

13 are false and incorrect
denied in totality. It is hence vehemently
pertinent to mention that the
delivered by the Plaintiff were
inferior in nature
irreversible loss to the defendant. It is which lead to
plainiff ho has breached the years old
business relations and trust of
Defendant just to cause
wrongful loss. to the defendant by using un-
professional techniques, and non-delivery of
prescribed and pre-
14.That the contents of Para 14 are false andincorrect hence vehemently

denied in totality. It is pertinent to mention that the quality af
the goods
irreversible loss defendant. It is pertinent to mention that it is the
to the
Defendant just to cause wrongful loss.to the defendant by using un-

15.That the contents of Para 15 are false and incorrect hence

vehemently
denied in totality. It is pertinent to mention that the quality of the goods
Defendant just to cause wrongful loss. to the defendant by using un-
inferior in nature which lead
irreversible loss to the defendant. It to
is pertinent
mention that it is the
to
plaintift who has breached the years old business
Defendant just relations and trust ot
to cause
wrongful loss to the defendant by using
professional techniques, and
un
non-delivery of
prescribed and pre-
17.That the contents of Para 17

are false and incorrect hence
denied in to1ality. It is vehemently
delivered by the Plaintiff were goods
inferior in nature which lead to
ireversilble loss to the defendant. It is
pertinent
to mention that it is the
plainiff who has breached the
years old business relations and trust of
wrongful loss to the defendant by using un-
professional techniques, and
non-delivery of preseribed and pre
approved quality
of goods asked by the Defendant.
18.That the contents of Para 18 false and incorrect hence

are
vehemently
denied in totality. It is pertinent to mention that the
plaintiff who has breached the years old business relations and
trust of
Defendant just to cause wrongful loss to the defendant
by using un-

19.That 1the contents of Para 19 are false and incorrect hence vehemently
denied in totality. It is pertinent to mention that the quality ofthe goods
20.That the contents of Para 20 are false and incorrect hençe vehemently
delivered by the Plaintiff
were inferior in nature which lead to
irreversible loss to the defendant. It is pertinent to
plaintiff who mention that it is the
has breached the years old
professional techniques, using 'un-
and
non-delivery of prescribed and pre-
Defendant.
21.That the eontents of Para 21
denied in totality. It is vehemently
delivered by the Plaintiff inferior in nature which lead to
were
irreversible loss to the defendant. It is
plaintiff who has breached the years old business
relations and trust of
wrongful loss to the defendant by using un
22.That the contents of Para 22 are admitted to the extent that Defendant
paid the sum of Rs.4,069/- to Plaintiff. Further the contents of para 22
are false and incorrect hence vehemently denied. It is pertinent to
mention that the quality of the goods delivered by the Plaintiff were
inferior in nature which lead to irreversible loss to the defendant. It is
pertinent mention that it is the plaintiff who has breached the
to
years
old business relations and trust of
Defendant just to cause loss wrongful
to the defendant by using un-professional techniques, and non-delivery
of prescribed and pre-approved quality of goods asked by the
Defendan.
paid the sum of Rs.28,826/- to Plaintiff. Further the contents of para 23
are false and incorect hence vehemently denied. It is pertinent to
mention that the quality of the goods delivered by the Plaintiff were
pertinent to mention that it is the plaintiff who has breached the years
old business relations and trust of Defendant just to cause wrongful loss
to the defendant by using un-professional techniques, and non-delivery
of' preseribed and pro-upproved qquality ol gouds unkod by-4ho
Defendat
24.Thut the contents ol Paru 24 ure ndmitted to the oxtent that Defendant
paid the sm of Rs.31,191/- lo PlaintilT, Further tho contents of paru 24
are false and ineorrect hence vehemently denied. It is pertinont to
nention tlhut the quulity of the goods dollverod by the Plaintilt wero
inforior in nature whieh lond to lrrovoruible losN to the desfendant. It in
pertinent to mentlon that lt IN' the plulnilr who han bronohod the yoarw
old business rolations and trust of Delendant just to cnune wronglul loss
o the delendant by using un-profensionnl techniques, and non-delivery
opreserihed und pro-upproved quality of goods sked by the
Defendant
25.That Ahe contentN of Purn 25 are ndmitled to the oxtent thut Delendant
pnid the NUm of RN,39,933/-1o PlalntiT. F'urther the contents ol para 25
Are lnlse nd ineorroet honce vehomently clenilod. In is pertinont to
montlon that the quality of the goods dellvervd by tho Plalntlff wero
inferior in nature wlhieh lead to irreversible lons to the dlelendant. tt is
ertinent lo mention that it is the plaintifl who hua breuehed the yeurs
old busie8N rolations and truil of' Dolondont just lo cnuso wronglul lons
lo the delendant by using un-prolossionul tochniques, nd non-delivery
of preserihed and pre-npprovod (quality of goods nskod hy the
Dolendan.
26.That the contonts of Parn 20 nre ndnilttod to tho oxtont that Dolondant
pnil the A1 of Ra.39,2:35/- 1o Pluintit. l'urther tho contonts of paru 20
inre fale ind incorrect hence vehomontly denied, li is portinent to
enlin tal the quality of the gooudw dolivered by the Pluintill were
inferior in alure whieh lend t Irreveruible lon lo the delenlant. I0 in
pertinent lo mention that I In the plalntIT who hn bronchod the yours
yll busine rolutlonN and trINt of Dolondunt junt
WIOnglul lonto euno
th delendant by using un-proolonnlonl tooniquON, ud iNdelivoy

peilweel ied re-pwed ulily f p n naked y tle
Delendan
27.That the contents of Para 27 are false and incorrect hence veheinently
ireversible loss to the defendant. It is pertinent to mention that it is the
Defendant iust to cause wrongful loss to the defendant by using un-
professional techniques, and non-delivery of prescribed and pre

28. That the contents of Para 28 are false and incorrect hence vehemently
denied ih totality. It is pertinent to mention that the quality of the goods
irreversible loss to the defendant, It is pertinent to mention that it is the
29.That the contents of Para 29 are false and incorrect hence vehemertly
denied in totality. It is pertinent to mention that the quality of the goods.

irreversible loss to the defendant. lt is pertinent to mention' that it is the
professional techniques, and norj-delivery of prescribed and pre-

31.That he contents of
Para 31 are admitted to the extent that
paid the sum of Defendant
Rs.31,132/-, 21669/- 31,033/- and
30.05.2016 and 08.06.2016 25,383/- on
contents of para 31
respectively to Plaintiff. Further the
are false and
incorrect hence
is pertinent to
mention that the
vehemently denied. It
quality of the goods delivered by the
Plaini Were inferior in nature which lead to
irreversible loss to the
defendan. ii is
pertinent mention that it is the
to
breached the
plaintiff who has
years old business relations and trust
of Defendant just to
cause
using un-professional
techniques. and non-delivery of prescribed and
goods asked by the pre-approved quality of
Defendant.

denied in
vehemently
totality. It is pertinent to mention that the quality of the goods
defendant. It is pertinent to mention that it is the
plainiff who has breached the years old business relations and
trust of
wrongful loss.to the defendant by using.un-.
33.That the contents of Para 33 are admitted to the extent

that Defendant
paid the sum of Rs.31,922/- on 15.06.2016 and 24,560/- on 18.06.2016
to Plaintiff. Further the contents of para 33 are false and incorrect hence
vehemently denied. It is pertinent to mention that the quality of the
goods delivered by the Plaintiff were inferior in nature which lead to
plaintiff who has breached the years old business relatiohs and trust of
34. That the contents of Para 34 false and incorrect hence

are vehemently
plaintiff who has breached the ycars old 2
Defendant just business relations and trust ot
to cause
professional echniqjues. and
un-
approv ed quality of goods asked

non-delivery of prescribed and pre
by the Dcfendant.

35 are admitted to the extent that
paid the sum of Defendant
Rs.36.225/-. 45,499/-. 42,890/-,
15.230- 30,487/-, 29,798/- and
on
30.06.2016 and Rs.18,738/- on
Futher the eontents of 01.07.2016 to Plaintiff.
para 26 arefalsc and incorrect hence
vehemently denied. lt is
ireversible loss to the defendant. It is
prescribed and-pre-
36.That the contents of Para 36 are admitted to the extent that

Defendant
paid the sum of Rs.40,335/-, 32,482/- on 10.07.2016 and 36,404/- on
15.07.2016 and 24,360/- 21.07.2016
on to Plaintiff. Further the
contents of para 36 are false and incorrect hence vehemently denied. It
is pertinent to mention that the quality of the goods delivered by the
Plaintiff were inferior in nature which lead to irreversible loss to the
defendant. It is pertinent to mention that it is the plaintiff who has
breached the years old business relations and trust of Defendant
just to
37.That 1he contents of Para 37 are false and incorrect hençe vehemently

plaintif who has breached the years old business relations and trust of
Defendant just to cause wrongful loss to the defendant by uSing un-

professional techniques, and 3
approved quality non-delivery of prescribed and pre-
of goods asked by the Defendant.
38.That he contents of
Para 38 are false and incorrect
denied in hence vehemently
10tality. It is
delivered by the Plaintiff quality of the goods
were inferior in nature
which lead to
defendant. It is pertinent to
plaintiff who has breached the mention that it is the
years old business relations and
trust of
Defendan just to eause wrongful loss to the
defendant by using un-
professional techniques. and
non-delivery of
prescribed and pre-

denied in vehemently
totality. It is
delivered by the Plaintiff quality of the goods
inferior in nature, which lead to
were
irreversible loss to the defendant. It
is pertinent to mention that it is
thee
plaintiff ho has breached the years old business relations
and trust of
wrongful loss to the defendant un- by using
40.That the contents of Para 40 are false and incorrect hençe

vehemently
denied in totality. It is pertinent to mention that
the quality of the goods
delivered by the Plaintiff were inferior in nature
which lead to

made the payment of Rs.44,225/-, dated 18.10.2016/-, 1,396/- dated
22.10.2016 and Rs.28,654/, 25,113/, 25,688/, 22,657, 28,796/- and

15,225/-on 29.10.2016 respectively to Plaintiff. Further the contents of
para 36 are false and incorrect hence vehemently denied. It is pertinent
to mention that the quality of the goods delivered by the Plaintiff were
plaintiff who has breached the years
old business relations and trust of Defendant
just to cause wrongful loSs
to the defendant by using
un-professional techniques, and non-delivery
of prescribed and pre-approved quality of goods asked by the
Defendant.
42.That the contents of Para 42 admitted

are to the extent that Defendant
made the payment of Rs.66,610/-, Rs.1,18,227/-, Rs.11,928,
Rs.23.319/-, Rs.22,522/- dated 15.11.2016 and Rs.30,088/- on
18.11.2016 to Plaintiff. Further the contents
of para 36 are
false and
incorect hence
vehemently
denied. It is pertinent to mention that the
quality of the goods delivered by the Plaintiff were inferior in nature
which lead to irreversible loss to the defendant. It is
pertinent to
mention that it is the plaintiff who has breached the years old business
relations and trust of Defendant
just to cause wrongful loss to the
defendant by using un-professional techniques, and non-delivery of
prescribed and pre-approved quality of goods asked by the
Defendant.
43.That the contents of Para 43 are false and inoorrect hence
vehemently
delivered by the Plaintiff were inferior in nature
which lead to
ireversible loss to the defendant. It is pertinent to mention that it is the

44.That the contents of Para 44 false and

are inçorrect hence vehemently
denied intotality. It is pertinent to mention that the quality of the goods
delivered by the Plaintiff were inferior in nature which
lead to
ireversible loss to the defendant. It ispertinent to mention that it is the
45.That the contents of Para 40 are false and incorrect
denied in totality. It is
hence vehemently
prtinent to mention that the quality of the
goods
plaintiff who has breached the years old business relations and
trust of
Defendant just to cause wrongful loss to the
defendant by using un-
approved quality of' goods asked by the Defendant.
made the payment of Rs.33,226/- and Rs.18,183/- dated 10.01.2017 to
Plaintiff. Further the contents of
para 36 are false and incorrect hence
plaintiff whohas breached the years old business relations and trust
of

made the payment of Rs.16,616/- dated 20.01.2017 and also a debit

note worth Rs.18,800/-, 2,100/- and 1,050/- to Plaintiff. Further the
is pertinent to mention that the quality of the goods delivered by the
Plaintiff wvere inferior in nature which lead to irreversible loss to the
techniques, and non-delivery of prescribed and.pre-approved quality of

48.That the contents of Para 48 are admitted to the extent that De fendant
made the payment of Rs.28,918/- dated 30.01.2017 to Plaintiff. Further

the contents of para 48 are false and incorrect hence vehemently
denied. It is
pertinent to mention that the 6
by the
Plaintiff were inferior
quality of the goods delivered
in nature which
the defendant. It is lead to irreversible loss to
breached the years old plaintiff who has
cause Defendant just to
techniques. and
non-delivery of prescribed un-professional
and
goods asked by the Defendant. pre-approved quality of
49.That he contents of Para 49

are admitted
the extent that
to
made the payment of Defendant
Rs.31,750/- dated 10.02.2017 and Rs.22,011/-
dated 20.02.2017 to Plaintiff.
Further the contents of
para 47 are false
and incorrect hence
vehemently denied. It is pertinent to mention that
the quality of the
goods delivered by the Plaintiff were inferior in
nature which lead to
irreversible loss to the defendant. It
is pertinent to
mention that it is the
relations and trust of Defendant to just wrongful loss to the
cause
defendant by using
un-professional techniques, and non-delivery of
prescribed and pre-approved quality of goods asked by the Defendant.
made the payment of Rs.20,653/-, 20,545/, 19,845/-, 26,303/-, 22,990/-
, 27,431/- and Rs.29,138/- dated 15.03.2017 to Plaintiff. Further the
is pertinent to mention that the quality. of the goods delivered by the
Plaintiff were inferior in nature which lead to irreversible loss to the

made the payment of Rs.49,293/- to Plaintiff. Further the contents of

para 51 are false and incorrect hence vehemently denied. It is pertinent
to mention that the quality of the goods delivered by the Plaintiff were
old business relations and
plaintiff who has breached the years
trust of Defendant just to cause
to the defendant
by using wrongful loss
of un-professional techniques, and non-delivery

prescribed and
pre-approved quality of goods asked by the
Defendan.

vehemently
denied in
totality. lt is pertinent to mention that the
plaintiff who has
breached the years old business relations and trust of
Defendant just to cause wrongful loss to
the defendant by using un-
53.That the contents of Para 53 false and incorrect hence vehemently

are

made the payment of Rs.63,698/- on dated 31.05.2017 to PIantiff.
Further the contents of para 51 are false and incorrect hence

in nature which lead to
goods delivered by the Plaintiff were inferior
to mention that it is the
irreversible loss to the defendant. It is pertinent
relations and trust of
to wrongful loss to the defendant by using un-

Defendant just cause
of prescribed and pre-

professional techniques, and non-delivery
Defendant.
are admitted
to the extent that
Defendant
8
made the paynent of
Rs.32,543/-, 24,769/-, 20,545/- and 32.,178/- on
dated 10.06.2017 and
Rs.56,018/- dated 19.06.2017 and
dated 23.06.2017 and Rs.32,036/- on
Rs.18,761/- on dated 23.06.2017 to Plaintilf.
Further the contents of
para 51 are false and incorrect hence.
plaintiff whohas breached the
years old Business relations and trust of
prescribed and pre-
delivered by the Plaintiff were inferior in
nature which lead to
made the payment of Rs.26,077/, 33,844/- and 8,767/- dated
04.07.20 17 to Plaintiff. Further the contents of para 51 are false and.
incorrect hence vehemently denied. It is pertinent to inention that the
quality of the goods delivered by the Plaintiff were inferior in nature
which lead to irreversible loss to the defendant. It is pertinent to
mention that it is the plaintiff who has breached the years old business
relations and trust of Defendant just to cause wrongtul loss to the
defendant by using un-professional techniques, and non-delivery of
prescribed and pre-approved quality of goods asked by the Defendant.
made the payment of Rs.24,570/-, 30,254/- dated 21.07.2017 to
Plaintiff. Further the contents of para 58 are false and incorrect hence
vehemenly denied. It is pertinent to mention that the quality of the
plaintiff who has
breached the years old business
relations and trust or
59.That he contents of Para 59 are false and incorrect hence

veheimently
denied in totality, It is
delivcred by the Plaintiff were
plainiff who has breached the years old business relations and trust of
wrongful loss to the defendant bý using un-

denied in totality. It is pertinent to mention that the of the
quality goods
plaintiff who has breached the years old business relations and-trast of
Defendant just to cause wrongful loss to the defendant by using un:
approved quality ofgoods asked by the Defendant. It is submitted that
Plaintiff has filed the false case on the basis of a false facts and framed
the concocted story of his own.
delivered' by the Plaintiff were inferior in nature which lead to
approved quality of goods asked by the Defendant. It is submitted that
2

62 are false and incorrect
hence vehemently
denied in totality. It is
irmeversible loss to the defendant. It is
prescribed and pre-
approved quality of goods asked by the Defendant. It is
Plaintiff has filed the false case
submitted that.
on the basis of false facts
a
and framed

vehemently
pertinent'to mention that it is the

irreversible loss to the defendant. It is pértinent to mention that it is the
DefendarkN just to cause wrongful loss to the defendant by using un-

Plaintiff has filed the false case on the. basis of a false facts and framed
21
are false and incorrect hence vehemently
denied in totality. It is pertinent to mention that the
plaintiff who has breached the years old business relations and trust o

Plaintiff has filed the false case 'on the basis of a false façts and framed
the conçocted story of his own.

are vehemently
denied in 1otality. It is pertinent to mention that the quality of the goods


67.That the contents of Para 67 are false and incorect hence vehemently
delivered by the Plaintiff were inferior in, nature which lead to
irreversible loss to the defendarnt. It is pertinent to mention that it is the

68.That the contents of Para 68 are false and incormrect hence vehemently

22
Deiendant just to cause wrongfiul loss to the defendant by using un-
prolessional techniques, and non-delivery of prescribed and pre

Plaintiff has filed the falsc case on the basis of a false facts and framed
denied in totality. It is pertinent to mention that the quality ofthe goods
delivered by the Plaintiff werc inferior in nature which lead to

iTeversible loss to the defendant. It is pertinent to mention that it is the
plaintiffwho has breached the years old business relations and trustof

approved quality of goods asked by the Defendant. It is submitled that
Plaintifl has filed the false case on the basis of a false facts and framed
71.That the contents of Para 71 are matter of fact & record, hence does not
call for any reply.
72.That the contents of Para 72 are matter of fact & record, hence does not
call for any reply.

are
vehemently
denied in totality. It is Pertinent to mention that the Defendant daes not
owe any liability in favor of the 23
Petitioner. Further the Petitioner
indulging into un-professional and devious
is
techniques.
74. That the contents of Para 13 are false and incorrect
denicd in hence vehementiy
totality, It is Pertinent to
mention that the Defendant does not
owe any liability in favor of he
Petitionei. Further thie Petitioner is
indulginng into un-professional and devious
techniques
75.That 1he contents of Para
75 are false and incorrect hence vehemently
denied in totality. It is Pertinent
mention that the Defendant does not
to
Owe any liability in favor of the Petitioner.
Further the Petitioner is
indulging into un-professional and devious techniques.
76. That the contents of Para 76 are matter of fact & record, hence does not
call for any reply.
REPLY ON PRAYER:
That, the plaintiff has filed the present suit with ulterior motive and
malafide intention to cause harassment and prejudice to the answering
defendant no.l M/s P.C. Global Merchandising Pvt. Ltd., a company of

long standing high repute and as a ruse to extract money without just cause
or valid reason. As the plaintiff has instituted a frivolous and vexatious suit
for recovery which is liable to be dismissed and the answering defendant
No.1 is entitled to receive cost from the plaintiff on this account.
Further the answering defendant requests that the present suit may
indly be dismissed with heavy cost, for which act of kindness the
answering defendant shall ever pray.
For P.C. Global Merchandising Pvt. Lt.

.
A!i 'Fi
ANSWERING DEFENDANT
Place WesAL Through

Dated 24 |2-2o CREDO ADVOCATES
Chamber No.20,
Patiala House Court
NewDelhi-110001
+91-9971686852; +91-9873826852
VERIFICATION
2
, Sudeep Goel, the above-nanmed defendant do hereby
Contents solemnly verify that tne
of my above reply are true and correct to
is false and my knowledge, no part or
nothing material has heen conccaled therein.
Verified on thisof_
2020 at New Delhi.
Ld
Prer lota!crki.n Pvt
DEPONENT
25
IN THE COURT OF SH. RAJ KUMAR CHAUHAN LD. DISTRICT JUDGE
(COMMERCIAL COURT) SAKET, NEW DELHI.
CS (Comm) No. 273 OF 2019
INTHE MATTER OF:

..PLAINTIFF
Ms Dooa Impev
VERSUS
..DEFENDANT
MsP.C. Giohal Merchandising PM. LId.& Ors.
AFFIDAVIT
S/o Sh. Kamaljeet Goel, aged about 54 years, R/o B-24;

1. Sudeepoel:
Panchsheel Enclre: New Delhi. presently at New Delhi do hereby solemnly
affirm and state as under:
That I am the authorized signatory of the Defendant Company in the
above noted case and as such I am fully conversant with the façts and
CIrcumstances of the case and able to depose to the same.
been read
That the contents of the accompanying Written Statement have
in my vernacular language and the same have been understood

out to me
therein are true and correct to my

by me and state that the facts stated
knowledge and belief and are not repeated herein for the sake of brevity.
eal ofOath
S
y
No- 34/201 9
Advoca!9 HA
Cein High Court
Commis i10neon DEPONENT
SakaEt Coun.o 26/09/2021

Period Frpm 27/09/2019
NeN -110917
'ERIFICATION:
above named do hereby verify that the contents of my above

I. the Deponent
ddavit are true and correct to my knowledge, no part of it is false and nothing
material has been concealed therefrom.

2 . 6 0C 20
Verified at New Delhi on this day of October, 2020.
CERTIFID THAT THEDEPCCNT

*
Shr... . ******
*************
dentiied Dy
ne
has solemniy DEPONENT
Deihi oi..**
ns R..UWI3Ja 2020
2 6 0C
correct
to himi are thand
Commissioner
New Düihi
Oath

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IN THE COURT OF LD.

DISTRICT AND SESSION

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT NoH-2|ol22

MOST RESPECTFULLY SHOWETH:

signatory of M/s P.C. Global Merchandising and is authorized to do all

represent the defendant and to do all such other things as may be

necessary for the successful pursuit of the matter.

same is not specifically traversed.

3. Before traversing in detail the averments and contentions made in the

Written Statement. the answering defendant takes preliminary

2. That the Plaintiff has filled the

concern in the normal course of business. The dealings were done

through cash and credit basis on a mutual settlement.

4. That the statement of accounts relied upon by the plaintiff was

certain challans no amount was mentioned.

filing by the present suit.

6. That he Defendant intimated Plaintiff about the degraded quality and

note for th same.

proof of the higher priee is annexed with the wtitten statement.

maintainable in its present form.

That without prejudice to the above preliminary submissions taken by the

call for any reply.

Impex and carrying the business of supplying Elastic lnter lining

Director of Defendant No.1. Further the contents of thè Para 3 in the

4 That the contents of Para 4 are

5. That the contents

by the Plaintiff were inferior in nature which lead to irreversible loss to

denied. It is pertinent to mention that the quality of the goods delivered

by the Planuff were inferior in nature which lead to irreversible loss to

deniçd. It is pertinent to mention that the quality of the goods delivered

cause wrongful loss 1o the defendant by using un-professional

lechniqucs, and non-delivery of preseribed and pre-approved quality ot

denied. It is pertinent to mention that the quality of the goods delivered

cause wrongful loss to the defendant by using un-professional

the defendant. It is pertinent to mention that it is the plaintiff who has

cause wrongful loss to the defendant by using un-professional

professional techniques, and non-delivery of prescribed and pre-

13.That the contents of Para

14.That the contents of Para 14 are false andincorrect hence vehemently

professional techniques, and non-delivery of prescribed and pre-

15.That the contents of Para 15 are false and incorrect hence

17.That the contents of Para 17

18.That the contents of Para 18 false and incorrect hence

professional techniques, and non-delivery of prescribed and pre-

th delendant by using un-proolonnlonl tooniquON, ud iNdelivoy

professional techniques, and non-delivery of prescribed and pre

delivered by the Plaintiff were inferior in nature which lead to

irreversible loss to the defendant, It is pertinent to mention that it is the

Defendant just to cause wrongful loss to the defendant by using un-

professional techniques, and non-delivery of prescribed and pre

approved quality of goods asked by the Defendant.

denied in totality. It is pertinent to mention that the quality of the goods.

approved quality of goods asked by the Defendant.

professional techniques, and norj-delivery of prescribed and pre-

approved quality of goods asked by the Defendant.

32.That the contents of Para 32 are false and incorrect hence

33.That the contents of Para 33 are admitted to the extent

34. That the contents of Para 34 false and incorrect hence

approv ed quality of goods asked

35.That the contents of Para

36.That the contents of Para 36 are admitted to the extent that

denied in totality. It is pertinent to mention that the quality of the goods