Moot Court Problem - Defendant

IN THE COURT OF THE HON’BLE JUNIOR CIVIL JUDGE, CITY CIVIL
COURT, NAMPALLY, AT HYDERABAD
O.S.NO. 01/2024
Between:
1) M/s Sinha & Sinha, represented by Ms.Jimi Sinha,
Managing Partner, W/o ABC, aged about 35 Years, Occ: Business
R/o Hyderabad - Plaintiff
AND
1) Mr.Raj Kumar, S/o XYZ, aged about 19 Years, Occ: Singer

R/o Hyderabad - Defendant
WRITTEN STATEMENT FILED BY THE DEFENDANT UNDER ORDER VIII,

RULE 1 OF THE CIVIL PROCEDURE CODE, 1908
The above named defendant respectfully submits as follows:
1) The address for service of all notices and processes of this Hon’ble Court on this defendant is that of his
counsel Mr.XXX, Advocate, having office at Ho.No.XX-XX/XXX, Phase-II, K.P.H.B.Colony, and
Hyderabad – 500072.
2) The defendant at the outset denies all the averments made in the Plaint except those that are specifically
and expressly admitted herein. The Plaintiff has not approached to prove his case with clean hands and
also has not approached with any valid or true documents. The defendant submits that this suit is not
maintainable either on facts or in law and is liable to be dismissed in limine.
3) The defendant, claiming to be a minor at the time of signing a construction agreement on 01/04/2015,
argues that the suit should be dismissed on both facts and law.
1
Books Referred:
1. Avtar Singh’s – Contract & Specific Relief, Authored by Mr. Rajesh Kapoor, 13th Edition, 2022
2. Indian Evidence Act, 1872, Published by Eastern Book Company, Lucknow
4) The defendant claims that the plaintiff used substandard material for constructing a multi-purpose
building, which was not in line with the plaintiff's description. After assessing the material, the
construction cost was Rs.3,00,000/-. The plaintiff's suit for recovery of Rs.7,00,000/- from the date of
filing is false and vexatious.
5) The defendant is denied para no.9 of the plaint, indicating that there is no written or oral agreement
between the plaintiff and the defendant.
6) The Plaint does not disclose and valid cause of action against the defendant and the cause of action
alleged is itself false. The suit claimed by the Plaintiff against the defendant is frivolous.
7) The defendant states that the suit has been filed by the plaintiff on the basis of surmises and the
averments made in the plaint are cooked up and the interested for the purpose of filing this suit against
the defendant only to harass the defendant being the Minor at the time of signing the Construction
Agreement which is void under Section 10 & 11 of the Indian Contract Act, 1872.
8) The defendant vehemently denies the averments made in the suit is false and malicious.
9) That the Plaintiff’s suit is liable to be dismissed arrantly as the plaintiff enter into an Agreement is
“unfair contract” under Section 20, Sub-Section (2) of the Specific Relief Act, 1963.
Hence, the plaintiff cannot file the suit before this Hon’ble Court and the suit has to be dismissed on the above
grounds pleaded.
The cause of action alleged is false and the suit is liable to be dismissed as the suit claim against the defendant is
devoid of merits. The defendant states that the plaintiff’s claim against the defendant is false and frivolous
which is not sustainable in the eye of law.
It is therefore prayed that his Hon’ble Court may be pleased to dismiss the suit with costs and thus render justice.
Dated XX/XX/2024
Hyderabad DEFENDANT
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Books Referred:
VERIFICATION
I, Mr.Raj Kumar, the defendant herein, do hereby verify and declare that the facts stated in the above paragraphs
are true to the best of my knowledge, belief and information.
Dated: XX/XX/2024 DEFENDANT
ADVOCATE
COUNSEL FOR DEFENDANT
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Books Referred:
SUMMARY OF ARGUMENTS ON BEHALF OF DEFANDANT
1) Whether there is a valid contract between M/s Sinha & Sinha and Mr.Raj Kumar?
Yes. Under Section 11 of the Indian Contract Act, 1872, affirm that “Every person is competent to contract who
is of the age of majority according to law to which he is subject, and who is of sound mind, and is not
disqualified from contracting by any law, to which he is subject.”
In the above, Age of Majority means in general 18 years, expect when a guardian of a minor’s person or property
has been appointed by the court, in which case it is 21 years. The age of majority of a persons is to be
determined “according to the law which he is subject.”
The above is affirmed in a land mark judgment i.e. Mohori Bibee V. Dhurmodas Ghose where Sir Lord North
observed looking at Section 11 of the Act, makes it essential that all contracting parties should be competent to
contract and expressly provides that a person who by reason of infancy is incompetent to contract cannot make a
contract within the meaning of the Act.
2) Whether M/s Sinha & Sinha are entitled to get the decree of Injunction restraining Mr.Raj Kumar from
selling the property until the suit is disposed-off?
The question is not relevant as the agreement is void, and the court has discretion under Section 9 & 10 of the
Specific Relief Act, 1963.
When the entire Construction Agreement is under void ab-initio, succeeding an injunction order from the court
cannot arise and thus, the court cannot entertain suit against a minor under Order XXXII of the CPC, 1908.
The main objective behind the Order XXXII is the protection of the interest of or minors and persons of
unsound mind. The origin of this concern rests in common law. The Common Law position is that persons who
are unable to understand the nature and consequences of their actions (of immature intelligence and discretion)
ought not to be liable for their actions so undertaken.
Thus, the plaintiff cannot succeed in granting him a temporary injunction under Order XXXIX, Rule 1, as the
defendant is protected under Order XXXII of the Civil Procedure Code, 1908.
3) Whether Mr. Raj Kumar has committed Breach of Contract?
The validity of the entire contract is in question, not just for breach of contract involving a minor signing of the
construction agreement.
4) Whether the Construction of Building is not in accordance with the promise made by M/s Sinha &
Sinha?
Yes. Mr. Raj Kumar, through technical experts, discovered that M/s Sinha & Sinha used substandard materials
in their construction of a building, despite having quality test reports, and brought the issue to their attention.
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Books Referred:
IN THE COURT OF THE HON’BLE JUNIOR CIVIL JUDGE, CITY CIVIL
COURT, NAMPALLY, AT HYDERABAD
O.S.NO. 01/2024
Between:
1) M/s Sinha & Sinha, represented by Ms.Jimi Sinha,

Managing Partner, W/o ABC, aged about 35 Years, Occ: Business
R/o Hyderabad - Plaintiff
AND
1) Mr.Raj Kumar, S/o XYZ, aged about 19 Years, Occ: Singer

R/o Hyderabad - Defendant
WRITTEN AURGUMENTS FILED BY THE DEFENDANT UNDER ORDER 18,

RULE – 2(3A) AND (3B) of the CIVIL PROCEDURE CODE, 1908
BRIEF FACTS OF THE CASE
1) The plaintiff firm was approached by defendant Mr. Raj Kumar to construct a multi-purpose building in
Hyderabad, including a recording studio, live musical theatre, and roof-top pool. After discussions, the
firm agreed to the defendant's specifications and offered Rs.10,00,000/-, despite the low price being
unrealistic. The amount will be paid in instalments to complete the work phase-wise, as per the
Construction Agreement dated April 1, 2015.
2) The plaintiff claims the defendant paid Rs. 3,00,000/- as part of an installment for the construction of a
ground floor, music theatre, recording studio, and roof-top pool. The plaintiff claims they completed the
ground and first floor by December 2015, but due to escalation of material costs, the funds ran out, and
they couldn't proceed with further construction. The defendant was informed to the defendant that they
couldn't complete further work until further funds were made available.
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Books Referred:
3) The plaintiff claims that the defendant averred that he had invited top music directors and ABC
producers to fund his dream music album project. The defendant is eager to complete the roof-top pool
as per the contract and requests the plaintiff to pay out Rs.7,00,000/- for additional construction. The
plaintiff completed Roof-Top Pool in April 2016, and the defendant signed a contract with ABC
Producers on 01/06/2016, funding the fusion albums and world tour. The defendant assured the plaintiff
that he had saved his career and not worry about the outstanding amount, but the project failed, and he
was unable to pay the plaintiff.
4) It is further submitted that the plaintiff requested the defendant to perform a music performance for their
daughter's birthday in exchange for an unpaid amount of Rs.7,00,000/-. However, the defendant
developed a sour throat and did not perform as assured by the Defendant. The plaintiff offered to pay the
due amount through an equated monthly instalment (EMI) of Rs. 20,000 per month starting from
January 1, 2017 to November 30, 2019, which is agreed in writing.
5) The defendant, surprised by the plaintiff, revealed that the construction material used was substandard
and not in line with the agreement. He estimated the total cost of the building at Rs.3,00,000/- and
claimed to have already paid for it.
6) The plaintiff discovered that the defendant decided to dispose of his property without clearing the debt
amount to the plaintiff. The plaintiff exerted significant pressure to recover the Rs.7,00,000/- debt
amount, which they spent on construction and amenities. Despite offering multiple payment options and
a long period, the plaintiff was unable to recover the debt from the defendant.
7) The plaintiff had to send a legal notice to the defendant on November 1, 2019, requesting payment
within 15 days, or face legal recourse and hold the defendant liable for the cost and consequences, but
the defendant did not respond to the notice.
8) It is submitted that the defendant owed an amount of Rs.7,00,000/- due amount which was to be paid for
the completion of the construction work.
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Books Referred:
CONTENTS OF DEFENDANT
1) The defendant at the outset denies all the averments made in the Plaint except those that are specifically
and expressly admitted herein. The Plaintiff has not approached to prove his case with clean hands and
also has not approached with any valid or true documents. The defendant submits that this suit is not
maintainable either on facts or in law and is liable to be dismissed in limine.
2) The defendant, claiming to be a minor at the time of signing a construction agreement on 01/04/2015,
argues that the suit should be dismissed on both facts and law.
3) The Plaint does not disclose and valid cause of action against the defendant and the cause of action
alleged is itself false. The suit claimed by the Plaintiff against the defendant is frivolous.
4) The defendant states that the suit has been filed by the plaintiff on the basis of surmises and the
averments made in the plaint are cooked up and the interested for the purpose of filing this suit against
the defendant only to harass the defendant being the Minor at the time of signing the Construction
Agreement which is void under Section 10 & 11 of the Indian Contract Act, 1872.
5) The defendant vehemently denies the averments made in the suit is false and malicious.
6) That the Plaintiff’s suit is liable to be dismissed arrantly as the plaintiff enter into an Agreement is
“unfair contract” under Section 20, Sub-Section (2) of the Specific Relief Act, 1963.
CONTENTS OF PLAINTIFF
1) The Plaintiff has agreed to construct multi-purpose building with all amenities as defined under the
Construction Agreement Dtd. 01/01/2015 with the cost of Rs.10,00,000/- as per the specification
mentioned in the agreement.
2) The Plaintiff and the Defendant was signed the said agreement and the construction work was started
after receiving the first instalment amount of Rs.3,00,000/- at the time of signing the agreement.
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Books Referred:
3) The plaintiff completed the construction work on the ground floor and the first floor by December 2015
and ran out of money due to the escalation of material costs and was unable to proceed with further
construction due to a lack of material.
4) The plaintiff has informed the defendant that they could not complete the construction unless further
capital was made available to them.
5) The defendant had requested to the plaintiff that he arrange a poolside party to which he had invited top
music directors, producers, and other renowned individuals in the music industry whom he believed
would fund his dream music album and music tours to enable the plaintiff to spend the remaining
amount of Rs. 7,00,000 on the work out of their own funds and assured that the money would be paid as
soon as his album is released.
6) Accordingly, the plaintiff completed the rest of the construction work by April 2016, and the defendant
organized the poolside party in the newly constructed building on the roof-top pool, which was a
success, and he expressed his happy moments with the plaintiff that, due to the on-time completion of
the roof-top pool, his career was saved and also informed to the Plaintiff don’t worry about
Rs.7,00,000/-.
7) The plaintiff, having belief in the defendant’s promise, M/s Sinha and Sinha started a new project.
Meanwhile, the defendant’s new fusion music album was a disastrous flop. Social media enthusiasts and
meme pages massively trolled him for his raucous and bizarre fusion music, and then the defendant
found himself unable to pay the amount of Rs. 7,00,000 to the plaintiff.
8) Knowing the facts and circumstances of the defendant, the plaintiff made a proposal to the defendant to
do a music performance for her daughter’s birthday to release him from the outstanding debts, and the
defendant agreed to the proposal. Accordingly, the plaintiff invited her relatives, friends, and other high-
profile personalities. Yet, before the birthday party, the defendant suffered from a severe sore throat due
to over repetition of rehearsals, and he failed to perform at the plaintiff's party on the advice of his
doctors.
9) On December 1, 2016 (the defendant’s 18th birthday), both parties agreed to alter the contract due to
humanity reasons. The defendant acknowledged the debt from M/s Sinha & Sinha for past services and
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Books Referred:
agreed to pay the debt through an Equated Monthly Instalments (EMI) of Rs.20,000/- per month starting
January 1, 2017, until a competition of Rs. 7,00,000 per month was reached.
10) Suddenly, the defendant had taken volte-face, claiming that the construction material used was
substandard and not in line with the description provided by M/s Sinha & Sinha, estimated it to cost only
Rs.3,00,000/- and claimed to have already paid the amount.
11) The defendant has consented to sell his property without paying M/s Sinha and Sinha, causing the
plaintiff to exert pressure to recover their outstanding money. Despite the opportunity of a prolonged
period and a different payment method, M/s Sinha and Sinha were unable to recover the debt from the
defendant. At last, the plaintiff sent him a legal notice stating that the money would be repaid within 15
days. However, the defendant did not respond to the said legal notice.
ISSUES FRAMED BY THE HON’BLE COURT
1) Whether there is a valid contract between M/s Sinha & Sinha and Mr. Raj Kumar?
2) Whether M/s Sinha & Sinha are entitled to get the decree of Injunction restraining Mr. Raj Kumar from
selling the property until the suit is disposed of?
3) Whether Mr. Raj Kumar has committed breach of contract?
4) Whether the construction of building is not in accordance with promise made by M/s Sinha & Sinha?
WRITTEN AURGUMENTS ON DOCUMENTARY PROOF, RATIFICATION OF ORIGINAL

AGREEMENT AND IMPORTANT CASE LAWS:
1) ANSWER TO ISSUE NO.1
Under Section 11 of the Indian Contract Act, 1872, affirm that “Every person is competent to contract who is
of the age of majority according to law to which he is subject, and who is of sound mind, and is not disqualified
from contracting by any law, to which he is subject.”
9
Books Referred:
In the above, Age of Majority means in general 18 years, expect when a guardian of a minor’s person or property
has been appointed by the court, in which case it is 21 years. The age of majority of a persons is to be
determined “according to the law which he is subject.”
Further, Section 3 of the Indian Majority Act, 1875, states that the age of a majority of persons in India says
“Every person domiciled in India shall attain the age of majority on his completing the age of “eighteen years”
and not before. In computing the age of any person, the day on which he / she has born is to be included as a
whole day and he shall be deemed to have attained majority at the beginning of the eighteenth anniversary of
that day.
The above is affirmed in a land mark judgment i.e. Mohori Bibee V. Dhurmodas Ghose (1902-03) 30 IA 114:
ILR (1903) 30 Cal 539, where Sir Lord North observed: Looking at Section 11 of the Act, makes it essential
that all contracting parties should be competent to contract and expressly provides that a person who by
reason of infancy is incompetent to contract cannot make a contract within the meaning of the Act.
In view of the above, the construction agreement signed on 01/04/2015 shall stand void ab-initio.
2) ANSWER TO ISSUE NO. 2
The Indian Contract Act, 1872, is important legislation in the field of commercial law in India. It is basically
responsible for regulating contractual relationships and obligations. A common legal complexity often arises
when an agreement with minor parties takes place. This is problematic because the Act does not permit such
agreements outright.
This is one of the important rule that the Agreement with minor parties is void, and, hence, no obligations can
ever arise for him thereunder.
Further, in the Case of Mohori Bibee V/s Dhurmodas Ghose (1908-10) 30 IA 114: ILR (1903) 30 Cal 539, it
is observed while looking into Section 11 of the Indian Contract Act, 1872 makes it essential that all contracting
parties should be competent to contract and expressly provides that a person who by reason of infancy is
incompetent to contract cannot make a contract within the meaning of the Act. The question whether a contract
is void or voidable presupposes the existence of a contract within the meaning of the Act, and cannot arise in the
case an infant.
Under Order 39, Rule-1 of the Civil Procedure Code, 1908, Property in dispute is in danger of being wasted,
damaged or alienated by any party to the suit, or wrongfully sold in execution of decree. Where defendant
threatens or intends to remove or dispose of his property with a view to defraud creditors, shall not arise in this
case.
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Books Referred:
When the entire Construction Agreement is under void ab-initio, succeeding an injunction order from the court
cannot arise and thus, the court cannot entertain suit against a minor under Order XXXII of the CPC, 1908.
The main objective behind the Order XXXII is the protection of the interest of or minors and persons of
unsound mind. The origin of this concern rests in common law. The Common Law position is that persons who
are unable to understand the nature and consequences of their actions (of immature intelligence and discretion)
ought not to be liable for their actions so undertaken.
Thus, the plaintiff cannot succeed in granting him a temporary injunction under Order XXXIX, Rule 1, as the
defendant is protected under Order XXXII of the Civil Procedure Code, 1908.
In the Case of Padma Vithoba Chakkayya V/s Mohd Multani, AIR 1963 SC 70, 74: (1963) 3 SCR 229, the
Supreme Court said that “A minor’s agreement being void, ordinarily it should be wholly devoid of all effect.
A minor’s agreements are void ab-initio and ordinarily, it should be wholly devoid of all effects. The effect of
minor contract can be well-understood into different ways. However, in one of the effect is that “ No liability in
contract or in tort arising out of contract.”
A minor’s agreement is, of course, in principle devoid of all legal effects. “A minor is in law incapable of giving
consent, and, there being no consent, there could be no change in the character” or status of the parties. In
England it was laid down as early as 1665 in the Case of Johnson V/s Pye (1665) 1 Sid 258:82 ER 1091 states
that “an infant who obtains a loan of money of the by falsely representing his age cannot be made to repay
the amount of the loan in the form of damages for deceit”. Hence a minor cannot be held responsible for
anything which would be an indirect way of enforcing his agreement. In India, in the Case of Harimohan V/s
Dulu Miya, ILR (1934) 61 Cal. 1075, said that “If the tort is directly connected with the contract and is the
means of effecting it and is a parcel of the same transaction, the minor is not liable in tort”.
In view of the above information, the plaintiff cannot succeed for breach of contract therein if any damages
claimed.
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Books Referred:
The defendant informed the plaintiff that the work done was not as specified under the contract. The defendant
further pointed out that the material used for construction is substandard and not in accordance with the
description provided by the plaintiff firm. Thus, the defendant, after due diligence, concluded that the cost of
construction would not have cost more than ₹ 3,00,000/-, and he claimed that he had already paid the money.
Having known to the plaintiff about the concerns, he never tried to put in efforts by appointing technical experts
to prove his innocence by conducting various competency tests and simply sending a legal notice to the
defendant asking for the debt amount, which has no relevancy in this case.
Thus, it is implied that the plaintiff might have used substandard material in the construction; therefore, he
directly came into action for legal litigation without proving his innocence. Now, the burden lies upon to the
plaintiff to prove the quality of material was used in the construction.
ADVOCATE
STATEMENT OF JURISDICTION
Jurisdiction means and includes any authority conferred by the law upon the court, tribunal, or judge to decide or
adjudicate any dispute between the parties or pass judgement or order.
The Plaintiff invokes its jurisdiction under section 15 of the Civil Procedure Code, 1908 as well as under section
9 of the Act. It sets forth the laws and evidence that support the allegations.
Section 15 states that every suit shall be instituted in the court of the lowest grade competent to try it.
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Section 9 states that the courts shall have jurisdiction shall have to try all suits of a civil nature executing suits of
which their cognizance is either expressly or impliedly barred.
STATEMENT OF FACTS
DATE EVENT
01/01/2015 Mr. Raj Kumar by representing himself as Major and task out tender for multi-purpose,
ultra-modern architectural marvel to have recording studio, theatre for live musical
performance.
M/s Sinha & Sinha a leading building constructor offered to do entire work for ₹
10,00,000/-
01/04/2015 Mr. Raj Kumar and M/s Sinha & Sinha entered into a Construction Agreement for
construction of the multi-purpose building on the Land of Mr. Raj Kumar. Hence, Mr. Raj
Kumar paid ₹ 3,00,000/- as part payment.
According to the contract, the Ground Floor for Parking, the First Floor for Music Theatre,
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the Second Floor was for Recording Studio and the last floor for roof-top pool.
December, M/s Sinha & Sinha completed the Ground Floor and First Floor and ran out money due to
2015 escalation of building material cost. The same is informed to Mr. Raj Kumar.
Meantime, Mr. Raj Kumar planned for poolside party and he is disparate to complete the
roof-top floor. Hence, Mr. Raj Kumar requested M/s Sinha & Sinha to pay out remaining
amount while assuring the money would be paid as soon as his album is released.
April, 2016 M/s Sinha & Sinha believing Mr. Raj Kumar, has completed rooftop floor. Then, Mr. Raj
Kumar performed the party successfully.
01/06/2016 M/s ABC Producers entered into a contract with Mr. Raj Kumar for fusion albums and
world tours. Meantime, the fusion music album was disastrous flop and he then unable to
pay amount of ₹7, 00,000/- to M/s Sinha & Sinha.
01/10/2016 Ms. Jimi Sinha who is a Managing Partner of M/s Sinha & Sinha compelled Mr. Raj Kumar
to render music performance on her daughter’s birthday on 01/10/2016 and she agreed to
release from paying outstanding debt amount, which Mr. Raj Kumar agreed. In fact, before
birthday party, Mr. Raj Kumar suffered from severe throat and failed to attend music
performance.
01/12/2016 Mr. Raj Kumar attained 18th birthday. M/s Sinha & Sinha and Mr. Raj Kumar decided to
alter the contract while amending the debt amount to be paid through EMI of ₹ 20,000/-
per month starting 01/01/2017 till the competition of the payment of ₹ 7,00,000/-.
Afterwards, Mr. Raj Kumar felt that the work done by M/s Sinha & Sinha was not in
accordance with the description provided by M/s Sinha & Sinha and he estimated the work
done by them is of ₹ 3,00,000/- because of substandard building material was used.
Accordingly, he informed to M/s Sinha & Sinha, the amount is already paid.
Mr. Raj Kumar decided to dispose-off his property without settling the matter with M/s
Sinha & Sinha for the debt amount. While come to know the foul play by Mr. Raj Kumar,
M/s Sinha & Sinha tried to restrain him by putting enormous pressure in order to recover
their debt amount. Even after prolonged period and altered mode of payment, they could
not recover the debt amount.
Later, M/s Sinha & Sinha sent a Legal Notice stating that the debt amount to be paid within
15 days from the date of receipt of notice. But they did not received any reply
communication.
Hence, M/s Sinha & Sinha filed civil suit at Hyderabad, in the State of Telangana on the
above grounds. Also, they prayed for Injunction Order to restrain Mr. Raj Kumar from
selling the property until the suit is disposed-off.
LIST OF ISSUE RAISED

1) Whether there is a valid contract between M/s Sinha & Sinha and Mr. Raj Kumar?
2) Whether M/s Sinha & Sinha are entitled to get the decree of Injunction restraining Mr. Raj Kumar from
selling the property until the suit is disposed-off?
3) Whether Mr. Raj Kumar has committed Breach of Contract?
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4) Whether the Construction of Building is not in accordance with the promise (description) made by M/s
Sinha & Sinha?.
PRAYER
IN LIGHT OF THE ISSUES RAISED, THE AUTHORITIES CITED, AND THE ADVANCED
ARGUMENTS, IT IS THEREFORE PRAYED THAT THIS HONOURABLE COURT MAY BE
KINDLY PLEASED TO:
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1) Since the contract is void ab initio, the appeal against the defendant, Mr. Raj Kumar, ought to be
dismissed with immediate effect.
2) Since the defendant already suffered irreparable damage, Mr. Raj Kumar, the defendant, shall not be
restrained from selling his own property, and his application for an injunction order shall be dismissed.
3) The defendant shall be awarded an appropriate amount of money as compensation for the loss of
construction quality and needed for property disposal resulting from the plaintiff's inadequate, low-
quality construction, which occurred due to a breach of contract.
4) The plaintiff undertakes not to force, harass, or degrade our client, Mr. Raj Kumar (the defendant), in
any manner in the future.
AND FOR THIS ACT OF KINDNESS, THE DEFENDANT, AS IN DUTY BOUND, SHALL
EVER PRAY.
Date: XX/ XX/ XXXX
Place: Hyderabad
ADVOCATE
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Moot Court Problem - Defendant

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IN THE COURT OF THE HON’BLE JUNIOR CIVIL JUDGE, CITY CIVIL

COURT, NAMPALLY, AT HYDERABAD

1) Mr.Raj Kumar, S/o XYZ, aged about 19 Years, Occ: Singer

WRITTEN STATEMENT FILED BY THE DEFENDANT UNDER ORDER VIII,

The above named defendant respectfully submits as follows:

Dated: XX/XX/2024 DEFENDANT

3) Whether Mr. Raj Kumar has committed Breach of Contract?

1) M/s Sinha & Sinha, represented by Ms.Jimi Sinha,

1) Mr.Raj Kumar, S/o XYZ, aged about 19 Years, Occ: Singer

WRITTEN AURGUMENTS FILED BY THE DEFENDANT UNDER ORDER 18,

BRIEF FACTS OF THE CASE

ISSUES FRAMED BY THE HON’BLE COURT

3) Whether Mr. Raj Kumar has committed breach of contract?

WRITTEN AURGUMENTS ON DOCUMENTARY PROOF, RATIFICATION OF ORIGINAL

1) ANSWER TO ISSUE NO.1

2) ANSWER TO ISSUE NO. 2

3) ANSWER TO ISSUE NO. 3

4) ANSWER TO ISSUE NO. 4

LIST OF ISSUE RAISED

3) Whether Mr. Raj Kumar has committed Breach of Contract?

Date: XX/ XX/ XXXX

COUNSEL FOR DEFENDANT

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