IN THE COURT OF CIVIL JUDGE (JUNIOR DIVISION), AT BENGALURU

Suit No.____/2021

Ramesh Nayyar s/o Suresh Nayyar

Occupation : Entrepreneur
#9, 2nd Cross, Thimmappa Reddy Layout,
Opp Hulimavu Arch, Bannerghatta Road Bengaluru-560 076

Versus

Aaravind Gada s/o Vishal Gada

Occupation : Freelance Photographer
#70, Bannerghatta Main Road
Janatha Colony, Hulimavu, Bengaluru 560076 

Suit for recovery of money on account of outstanding payment

The abovementioned Defendant humbly submits as under:

1. That the contents of Para 1 are admitted;

2. That the contents of Para 2 are admitted;

3. That the contents of Para 3 are admitted;
4. That the contents of Para 4 are admitted;
5. That the contents of para 5 of the plaint are false and incorrect, therefore, are
emphatically denied. It is vehemently denied that my client has not advanced any
amount towards the money borrowed.

6. That the contents of Para 6 are admitted;

7. That the contents of Para 7 are incomplete and false, therefore, are emphatically
denied. My client has advanced a sum of Rs. 10,000 on 30th July 2021 to the Account
Number 12345678910;
8. That the contents of para 8 are denied;
 9. That the contents of para 9 are denied;
10. That the contents of para 9 are admitted: it is pertinent to note that the email id is still
active and no update of the change of contact information was intimated;
11. The contents of para 11 are admitted;
12. The contents of para 12 are denied. The urgency of the said prior financial
commitments of your client wasn’t intimated whatsoever;
13. That the contents of para 13 are false, therefore, are denied;
14.
15. That the content in para 15 is denied as the valuation of the suit is inflated and is an
attempt to extract extra money from my client.
16. That the contents of para 16 are denied; The plaintiff is not entitled for any relief. It is
therefore prayed that the suit may be dismissed with cost.

Additional Pleas

The above-mentioned Defendant do submit the additional pleas as under:

That the defendant is a freelance photographer and works on contractual basis for his
clientele. The pandemic has affected the defendants livelihood adversely despite of which a
payment of Rs. 10,000/- was advanced.

That the defendant had requested for extension of 6 months from the plaintiff for payment of
the principal amount along with interest.

Place: Bengaluru

Date: 10th November 2021

Sd- Counsel Sd- Defendant

 Verification 

I, Mr. Aravind Gada, s/o Vishal Gada, the above mentioned defendant, do hereby verify that
the contents from para 1 to 16 are true and correct to the best of my knowledge and belief and
contents of the remaining paras are on basis of information and legal advice from my counsel
which I believe to be true, and verify this on 10th November, 2021 at Bengaluru.

Sd- Defendant