Repeatedly typed Preliminary Objections in Written Statement–Case–Defendant–Respondent

• That the suit of the plaintiff is not maintainable in the present form at all and deserves to be dismissed
• That the suit of the plaintiff is without any cause of action, no cause of action has ever been arose against the answering defendants.
• That the plaintiff is estopped from filing the present suit by his own acts, conducts, admission or acquiescence.
• That the plaintiff has got no locus-standi to file the suit against the answering defendants.
• That the suit does not lie against the answering defendant, therefore, the suit of the plaintiff is liable to be dismissed.
• That the plaintiff has not come to this Hon’ble court with clean hands.
• That the plaintiff has filed the wrong and incorrect site plan. The site plan depicting the actual and factual situation about the property in question is attached with the written statement. 
• That the plaintiff is estopped from filing the present suit by his own acts, conducts, admission or acquiescence. The suit of the plaintiff is a result of misrepresentation, the same has filed by him just to harass the defendants and to extort money by adopting illegal means from the defendants intentionally and deliberately, thus, the plaintiff is not entitled for any relief.
• That the suit of the plaintiff is without of any cause of action. No cause of action has ever been accrued to the plaintiff against the defendants but the plaintiff filed the present false suit on the wrong basis just to harass the defendants and to deprive them from their legal right.
• That the no proper court fee has been affixed on the plaint.
• That the suit of the plaintiff is liable to be dismissed for non compliance of mandatory provisions of CPC as amended upto date.
• That the present suit has been filed by the plaintiff in order to unnecessarily harass the defendants, whereas the plaintiff has no concern or link with the said path, hence the suit of the plaintiff is liable to be dismissed.
• That the suit of the plaintiff is bad for non-joinder and mis-joinder of necessary party.

Note: Please Comment, If said list is incomplete.