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    Written Statement Sample

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    MUHAMMAD SAQIB GURGAIJ
    The defendant denies the claims made in the plaintiff's suit. Specifically, the defendant argues that: 1) The plaintiff's suit is not valid or factual. 2) The deceased did not purchase the plot of land in question. 3) The defendant denies requesting the transfer of the land's title deed to the plaintiffs.

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    Written Statement Sample

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    MUHAMMAD SAQIB GURGAIJ
    5K views4 pages
    The defendant denies the claims made in the plaintiff's suit. Specifically, the defendant argues that: 1) The plaintiff's suit is not valid or factual. 2) The deceased did not purchase the plot of land in question. 3) The defendant denies requesting the transfer of the land's title deed to the plaintiffs.

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    The defendant denies the claims made in the plaintiff's suit. Specifically, the defendant argues that: 1) The plaintiff's suit is not valid or factual. 2) The deceased did not purchase the plot of land in question. 3) The defendant denies requesting the transfer of the land's title deed to the plaintiffs.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    5K views4 pages

    Written Statement Sample

    Uploaded by

    MUHAMMAD SAQIB GURGAIJ
    The defendant denies the claims made in the plaintiff's suit. Specifically, the defendant argues that: 1) The plaintiff's suit is not valid or factual. 2) The deceased did not purchase the plot of land in question. 3) The defendant denies requesting the transfer of the land's title deed to the plaintiffs.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 4

    IN THE HONORABLE COURT OF SENIOR CIVIL JUDGE-I,

    KARACHI, SOUTH
    IIIrd Class Suit No. 37 of 2005

    Nadia W/O Hussein And Others…..…………………...………………..……………....Plaintiffs

    VERSUS

    Kabeer Ali ………..……….....………..…..…..………….….Defendants

    WRITTEN STATEMENT

    The above-named defendants submits the written statement as under:

    PRELIMINARY LEGAL OBJECTIONS

    i. That, plaintiff’s suit is not maintainable either in law or on facts.

    ii. That, the plaintiff’s suit is not true on facts.

    iii. That, the plaintiff’s suit is not maintainable in its present form.

    iv. That, the plaintiff’s suit is false and frivolous, and has been filed to harass the defendants for
    ulterior motives. This is not a bona fide suit at all.

    v. That, the suit is barred by law.

     
    WITHOUT PREJUDICE TO THE ABOVE LEGAL OBJECTIONS,

    the parawise reply of the plaint is as under: -

    1. That, the contents of para No.1 of the plaint are admitted to the extend that the Plaintiffs
    Are Legal Representatives Of The Deceased Party Named Hussein, And Are Residing At The Address
    Mentioned in plaint.

    2. That, the contents of para No.2 of the plaint are strongly denied that is that Deceased
    Hussein In His Life Time Purchase A Plot, Measuring 500 Sqr,Yrds Approximately Priced 15 Lacs,
    Situated In Clifton Block 4, Karachi on 8th of January 2020.

    3. That, the contents of para No.3 are denied for want of knowledge.

    4. That, the contents of para No.4 are vehemently denied.

    6. That, the contents of para No.05 of the plaint are not admitted to the extent for Transferring
    The Title Deed In the Name of plaintiff.

      

    Karachi South Defendant

    Dated:25-08-2020 Through Their Authorized

    Agent / Representative
    VERIFICATION

    I,Kabeer Ali S/o Hassan Muslim, adult, R/O House no 13/C, Punjab Colony, Karachi, do
    hereby state on oath on this 25th the day of Septemeber 2020 that whatever stated above is true
    and correct to the best of my knowledge and belief.

    DEPONENT

    The deponent above named is known to me and is identified by me to the commissioner for
    taking affidavit.

    ADVOCATE

    Affirmed on oath on this 25th day of Septemeber 2020 by the applicant, who is identified by
    Mr.Advocate, who is personally known to me.

    COMMISSIONER FOR TAKING AFFIDAVITS

    DOCUMENTS FILED

    1. Photocopy of CNIC of Plaintiff


    2. Photocopy of Birth Certificate

    DOCUMENTS RELIED UPON.

    1. Original of the Above.


    2. All Other Relevant Documents

    Karachi (South) Advocate For


    Plaintiff

    Dated: 25-09-2020

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