Written Statement Swapnil

BEFORE THE HON’BLE COURT OF CIVIL JUDGE CLASS II
AT BHATAPARA DISTRICT BALODA BAZAAR (C.G.)
Civil/Recovery Suit No. 12B/2018
Corporation bank …PLAINTIFF
VERSUS
Swapnil Marketing and Anr. ….DEFENDANT
WRITTEN STATEMENT FILED ON BEHALF OF

DEFENDANT NO. 01
The defendant no. 01 above named most humbly and

respectfully begs to submit as under: -
Para wise reply:
1. Para no. 01 is the matter of record and needs no

reply. Not repeated for the sake of brevity.
2. Para no. 02 is the matter of record and needs no

reply. Not repeated for the sake of brevity.
3. Contents of Para no. 03 of the plaint, except which

are the matter of record are wrong and denied.

are the matter of record are wrong and denied. It is
an accepted fact that the defendant no. 01 has
borrowed loan of Rs. 4,00,000 from the Plaintiff
Bank.
5. Contents of Para no. 05 of the Plaint is the matter

of the record and needs no reply.
6. Contents of the Para no. 06 of the Plaint are not
specifically admitted herein and denied. The
plaintiff is put to strict proof of the same. The
defendant no. 01 from time to time paid the
interest amount from the initial date of the Loan
i.e. 24/09/2013 till year 2016, after which the
defendant no. 01 had a great loss in his trade due
to which the financial status of the defendant no.
01 was at stake and consequently he went insolvent.
He even communicated the same with the bank
regarding his financial status.


plaintiff is put to strict proof of the same.
9. Contents of the Para no. 09 of the Plaint is the

matter of the record and needs no reply.

plaintiff is put to strict proof of the same. The
defendant is more than willing to pay the said
amount. It is condition of the defendant that he had
a great loss in his trade due to which he was unable
to repay the amount though he has paid the interest
till year 2016 without any fail. In the present
scenario the defendant no. 01 also made
representation dated 23/03/2019 to the bank
manager, Corporation Bank regarding the
settlement of the above stated case which is
pending before the bank manager for consideration.

specifically admitted herein and denied. As the
defendant no. 01 being unaware of the legal
recourse never acted to the notice in written or
made reply but defendant no. 01 had several
communications with the bank regarding the same
for settlement of the above said issue. The
defendant no. 01 even approached the bank
premises several time regarding the settlement of
the said issue.

specifically admitted herein and denied.

14. Contents of Para no. 14 of the Plaint are not

specifically admitted herein and denied.

are the matter of record are wrong and denied. The
defendant is more than willing to pay the said
amount and towards which also made a
representation before the bank regarding
settlement and the answering defendant even
express the willingness to comply the same.
It, is therefore prayed that, this Hon’ble Court may be
pleased to dismiss above case as the defendant is more
than willing to pay the amount and enter into a
settlement with the plaintiff bank.
COUNSEL FOR DEFENDANT NO. 01 DEFENDANT
THROUGH
(MAYANK KUMAR)
COUNSEL FOR DEFENDANT NO. 01
HIGH COURT, BILAPSUR (C.G.)
DATE 16TH APRIL 2019

BHATAPARA
VERIFICATION
I, Ravi Tanwani, S/o Late Shri Asumal Tanwani, aged

about 45 years, do hereby declare that the facts stated in
paras 1 to 15 are correct and true are to the best of my
knowledge, information and belief and I believe the same
to be true and correct. Hence, verified the same on this
16th day of April, 2019 at Bhatapara, District Baloda
Bazaar(C.G.).
DEFENDANT
BEFORE THE HON’BLE COURT OF CIVIL JUDGE CLASS II
AT BHATAPARA DISTRICT BALODA BAZAAR (C.G.)
Civil/Recovery Suit No. 12B/2018
Corporation bank …PLAINTIFF
VERSUS
Swapnil Marketing and Anr. ….DEFENDANT
AFFIDAVIT
I, Ravi Tanwani, S/o Late Shri Asumal Tanwani, aged

45 years, R/o Tanwani Building, Mahasati ward,
Bhatapara, District- Baloda Bazaar (C.G) do hereby
solemnly affirm on oath and declare as under: -
1. That I am the defendant no.1 in the instant case and

as such I am aware of the facts and circumstances of the
same.
2. That the attached written statement has been
drafted as per my instructions and the contents thereof
from paragraphs 1 to 15 are true and correct to the best
of my personal knowledge and belief.
VERIFICATION
I, Ravi Tanwani, the above named deponent do

hereby verify that the contents of paragraphs 1 and 2 of
this affidavit are true and correct to the best of my
personal knowledge and belief.
Verified and signed on this 16th day of April 2019 at

Bhatapara.
Identified by me.

Written Statement Swapnil

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BEFORE THE HON’BLE COURT OF CIVIL JUDGE CLASS II

AT BHATAPARA DISTRICT BALODA BAZAAR (C.G.)

Civil/Recovery Suit No. 12B/2018

Corporation bank …PLAINTIFF

Swapnil Marketing and Anr. ….DEFENDANT

WRITTEN STATEMENT FILED ON BEHALF OF

The defendant no. 01 above named most humbly and

Para wise reply:

1. Para no. 01 is the matter of record and needs no

2. Para no. 02 is the matter of record and needs no

3. Contents of Para no. 03 of the plaint, except which

4. Contents of Para no. 04 of the plaint, except which

5. Contents of Para no. 05 of the Plaint is the matter

7. Contents of Para no. 07 of the Plaint is the matter

8. Contents of the Para no. 08 of the Plaint are not

9. Contents of the Para no. 09 of the Plaint is the

10. Contents of the Para no. 10 of the Plaint are not

11. Contents of the Para no. 11 of the Plaint are not

12. Contents of the Para no. 12 of the Plaint are not

13. Contents of Para no. 13 of the Plaint is the matter

14. Contents of Para no. 14 of the Plaint are not

15. Contents of Para no. 15 of the plaint, except which

COUNSEL FOR DEFENDANT NO. 01 DEFENDANT

DATE 16TH APRIL 2019

I, Ravi Tanwani, S/o Late Shri Asumal Tanwani, aged

Civil/Recovery Suit No. 12B/2018

Corporation bank …PLAINTIFF

Swapnil Marketing and Anr. ….DEFENDANT

I, Ravi Tanwani, S/o Late Shri Asumal Tanwani, aged

1. That I am the defendant no.1 in the instant case and

I, Ravi Tanwani, the above named deponent do

Verified and signed on this 16th day of April 2019 at

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