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.

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WRITTEN REPLY TO THE APPLICATION UNDER ORDER 6 RULE 17 READ WITH SECTION 151 CPC

IN THE Hon’ble Court ADDITIONAL DISTRICT JUDGE, _______

First party            V/s               Second Party

Reply to the application U.O. 6 Rule 17 read with section 151 CPC filed by the applicant

Sir

It is respectfully submitted as under:-

Preliminary objections:-

1.      That the present application is not maintainable in the eyes of law. 

 2.  That the application has been filed at much later stage. Despite the applicant was having the knowledge of the fact which it intends to add now at the last stage of the proceedings, he cannot be allowed to plead inadvertence at this stage.

On Merits:-

1.       That para No.1 of the application is matter of record.

2.     That para No.2 of the application is wrong, incorrect and hence vehemently denied. The applicant was having full knowledge of the fact which it intends to add, since the filing of the present application.

3.      That para No.3 of the application is wrong, incorrect and hence vehemently denied. the applicant though was fully aware of the above said fact at the time of filing the petition, yet was grossly negligent in mentioning of the above said fact and to cover its negligence or to fill up its lacuna, the applicant cannot take the plea of inadvertence at last stage of proceedings.

4.       That para No.4 of the application is wrong, incorrect and hence vehemently denied.

            Last para is prayer clause, which is on the basis of wrong pleadings of the applicant, hence wrong, incorrect and denied of which the applicant is not entitled any relief.

                   It is therefore, respectfully prayed that the application in reply may kindly be dismissed, in the interest of justice, equity and fair play.

Dated:

Respondent

Through Counsel

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