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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SUMMON – NOTICE TO DEFENDANT FOR PERSONAL APPEARANCE IN COURT

In The Court of Civil Judge (Senior Division), _________

Plaintiff V/s Defendant

(SUIT FOR _____________________)

NEXT DATE DD-MM-YYYY

Summon to appear in person:

Notice to: Defendant name and address
 

Whereas the plaintiff has instituted a civil suit for ___________________ against you. You are hereby summoned to appear in the Court in person or through representative on DD-MM-YYYY at 09:30 AM in the before Noon to answer the claim and you are directed to produce on that day all the documents upon which you intent to reply in support of your defence.

Take notice that in default of your appearance, on that day aforementioned case will be heard and determined in your absence.

Given under my hand and the seal of this court on the ______ day of _______ 2017.

Civil Judge (Senior Division), __________

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Affidavit for Filing Correct Address in Suit – Complaint – Case

IN THE COURT OF __________________________

 

 

  

FIRST PARTY                     V/s                 SECOND PARTY 

 

(Suit for _______________)

AFFIDAVIT

 

I, ______________ SON OF _______________ RESIDENT OF _________________________________, do hereby solemnly affirm and declare as under:-

 

1. That the last known address of the defendant was as given in the plaint and at present the defendant has left that address. So the summons of this Hon’ble Court could not reach to the defendant.

 

2. That now the plaintiff has found the correct address of the respondent with his sincere efforts. At present the defendant is residing at the following address:-

 

__________________________________________

 

3. That the address given above is the correct and present address of the defendant, defendant may kindly be summoned at this address.

 

 

Deponent

 

Verification:-

 

Verified that the contents of the above affidavit are true and correct to the best of my knowledge and nothing has been concealed therein.

 

Verified at ______________ on:

 

Deponent

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Affidavit for Compromise in FIR – Complaint – Case – Suit

AFFIDAVIT

I, ____________ son of _____________ resident of ______________________________, do hereby solemnly affirm and declare as under:- 

1. That a case/FIR/Complaint No. _____ dated _________ was registered U/s _______________ at Police Station ____________, on my statement against ________________________________. 

2. That now with the intervention of the respectable, a compromise has been effected both the parties and I do not want to further pursue with the above noted case/FIR/Complaint and has got no objection, if the above said case/FIR/Complaint is cancelled/quashed/withdrawn. 

3. That I undertake to make the necessary statement for cancellation/quashment/withdrawal of the case/FIR/Complaint, before the Police or before the Court as and when required to do so.

Deponent

Verification:-
 

Verified that the contents of the above affidavit are true and correct to the best of my knowledge and nothing has been concealed therein.

Verified at _______________  on: _______________

Deponent

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