Written Statement Suit for Ejectment and Arrears of Rent
In the Court of Small Cause, …………..
Suit No. ……. of …..
(Space for Court-fee Stamp)
AB S/o CD Age…..
Resident of ………… Plaintiff
Versus
PQ S/o RS
Age…..
Resident of ………… Defendant
Written Statement for Ejectment,
Arrears of Rent and Mesne Profits The above-named defendant states as follows: -
1. That the defendant admits the facts stated in paragraph 1 of the plaint.
2. That the defendant admits the agreement mentioned n paragraph 2 of the plaint and his his occupation of the said house as alleged therein.
3. That the defendant denies that he has not paid the rent from June 1, 20.. , as stated in paragraph 3 of the plaint.
4. That the defendant admits service of the notice alleged in paragraph 4 of the plaint, but does not admit that the plaintiff duly determined the defendant’s tenancy thereby. That the defendant admits that he continues to be in occupation of the said ouse but denies that he has not paid any part of the said arrears of rent or that he is liable to Ejectment under the provisions of law alleged in paragraph 4 of the plaint.
5. That the defendant oes not admit anyone of the several allegations made in paragraph 6 of the plaint.
6. That no cause of action even occurred to the plaintiff alleged in paragraph 6 of the plaint.
7. That the defendant admits the jurisdiction of the court as alleged in paragraph 7 of the plaint.
8. That paragraph 8 of the plaint relates to valuation of the suit and payment f court fee. Additional Pleas
9. That the defendant has paid the rent for the months May, June, July, August and September, 20…, toSri EF, the plaintiff’s authorized agent who has been collecting the rent of the said house on behalf of the plaintiff but no rent receipts in respect of the aforesaid months have been issued to the defendant even after repeated demands by the defendant.
10. That the rent for the October, 20.. , and that for the subsequent months was tendered to the said agent of the plaintiff and to the plaintiff himself but both have refused to accept it.
11. That in fact only Rupees ….. , are due from the defendant to the plaintiff as arrears of the rent , being the rent for the months mentioned in paragraph 10 above and that the defendant is ready and willing to pay the said amount to the plaintiff.
12. That the notice mentioned in paragraph 4 of the plaintiff is invalid in that it did not purport to give sufficient period of time of the defendant as stipulated in section 30 of the U.P. Act No. XIII of 1972.
13. That there are absolutely no grounds for granting the relief prayed for by the plaintiff and the suit is liable to be dismissed with costs. Place: …….. AB Date: ……..
Defendant
Through Advocate
Verification
I, AB, he aforesaid, defendant, do hereby verify the contents of paragraphs …… and …….. of the above plaint are true to my personal knowledge nd the contents of the paragraphs ………. And ……., I believe to be true on information received. Signed and verified this …… day of . 20.. ….., at …… AB
Defendant
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