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CIVIL
WRITTEN
STATEMENT
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What is civil written statement?
A written statement is a formal legal document filed by a defendant in a civil
lawsuit as a reply to the plaintiff's claims (the plaint). It serves as the
defendant's primary opportunity to present their defence, admit or deny
allegations, and set out their version of the facts.
Purpose
The main purposes of a written statement are:
To respond specifically to each factual allegation made in the plaintiff's plaint.
To present all available legal defences and material facts that show the suit is
not maintainable or should be dismissed.
To narrow down the issues in dispute for the court's evaluation.
To raise preliminary objections, such as lack of jurisdiction or the suit being
time-barred by the Limitation Act, 1963.
To include a "set-off" (a counter-claim for an ascertained sum of money owed
by the plaintiff to the defendant) or a "counter-claim" (a separate cross-suit
by the defendant against the plaintiff).
Key Requirements and Rules (Governed by Order VIII of
the CPC, 1908)
Specific Denial: The defendant must specifically deny or admit each allegation
of fact, paragraph by paragraph. General or evasive denials are insufficient
and may result in the unaddressed facts being deemed admitted.
Material Facts Only: The statement must contain only the material facts on
which the defence relies, not the evidence used to prove those facts.
Concise and Clear: The facts should be stated concisely, with precision and
certainty, usually with each allegation in a separate paragraph.
Verification and Affidavit: The written statement must be signed by the
defendant and their legal representative, and verified by an affidavit
confirming the truthfulness of the contents.
Production of Documents: The defendant must produce all documents in their
possession or power upon which their defence is based at the time of filing the
written statement.
Timeline for Filing
The time limit for filing a written statement varies depending on the nature of
the suit: Non-Commercial Suits: The defendant generally has 30 days from
the date of service of summons. This period may be extended by the court to a
maximum of 90 days for reasons recorded in writing, and in exceptional
circumstances, the court retains discretion to accept it even later.
Commercial Suits: The timeline is stricter. The initial 30 days can be extended
to a maximum of 120 days from the date of service of summons. Beyond this
period, the defendant typically forfeits the right to file the statement, and
courts cannot use their inherent powers to grant further extensions.
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IN THE COURT OF THE CIVIL JUDGE (SENIOR DIVISION),
KANPUR NAGAR, UTTAR PRADESH
Civil Suit No. 112 of 2025
(For Recovery of Money)
Written Statement on behalf of the Defendant
U/O VIII Rule 1 of the Code of Civil Procedure, 1908
Between
Aman Verma
… Plaintiff
Versus
Rohit Singh
… Defendant
WRITTEN STATEMENT
The Defendant above named respectfully submits this Written Statement:
PRELIMINARY SUBMISSIONS
1. That the present suit filed by the plaintiff is based on false, fabricated, exaggerated and
one-sided allegations. The plaintiff has concealed several material facts and has approached this
Hon’ble Court with unclean hands.
2. That although the defendant and plaintiff are acquaintances, the defendant never took a
friendly loan of ₹1,50,000 as alleged. The plaintiff has manipulated facts for unlawful monetary
gain.
3. That the alleged written acknowledgment-cum-promise letter dated 16 February 2023 is
forged, fabricated and not signed by the defendant. The defendant has never executed such a
document at any point of time.
PARA-WISE REPLY TO THE PLAINT
Para 1 (Parties)
Contents of Para 1 of the plaint are admitted to the extent of correctness of addresses and
personal details. Other allegations are denied as they are irrelevant.
Para 2–4 (Loan Request & Friendly Relations)Denied.
The defendant denies that he approached the plaintiff in February 2023 or at any other time for a
friendly loan of ₹1,50,000 or any other amount. The plaintiff has created a false narrative of
“financial emergency” to give colour to his fabricated story.
Para 5–6 (Loan Transfer & Evidence)Wholly [Link] defendant never received any amount
of ₹1,50,000 from the plaintiff through UPI, bank transfer, cash or any other mode. The alleged
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transaction number and UPI ID quoted in the plaint seem manipulated, and strict proof is
demanded.
The alleged “written acknowledgment” dated 16 February 2023 is completely forged. The
handwriting and signature are not of the defendant. The defendant reserves his right to initiate
criminal proceedings for forgery under Sections 463, 468 and 471 IPC.
Para 7–8 (Repeated Demands & Refusal)Denied in totality.
The plaintiff never approached the defendant for repayment of any amount. As no loan was ever
taken, the question of demanding repayment does not arise.
Para 9–10 (Legal Notice)Denied.
It is admitted that the defendant received a notice dated 05 January 2024, but the defendant
immediately replied to the plaintiff stating that all allegations were false, fabricated and
concocted. The plaintiff has mischievously concealed the defendant’s reply.
Para 11–12 (Interest)Denied.
As no principal amount was ever taken, the question of interest @ 12% p.a. does not arise. The
plaintiff is trying to illegitimately enrich himself.
Para 13–17 (Cause of Action)Denied.
The plaint discloses no cause of action whatsoever. The plaintiff has created an imaginary and
legally unsustainable cause of action to harass the defendant.
Para 18–20 (Jurisdiction & Valuation)
The defendant is not disputing the territorial and pecuniary jurisdiction of this Hon’ble Court.
However, the plaint is liable to be dismissed for want of cause of action.
ADDITIONAL DEFENCE OF THE DEFENDANT
21. No Financial Capacity of Plaintiff
The plaintiff’s income is just around ₹30,000 monthly, and he had no financial capacity to extend
a loan of ₹1,50,000 at one time. This raises serious doubt on the genuineness of the alleged
transaction.
22. Misuse of Friendly Relations
The plaintiff and defendant were previously on friendly terms. Differences arose due to personal
disputes, and to settle personal scores, the plaintiff has filed this false and malicious suit.
23. Forgery of Documents
The plaintiff has fabricated the alleged acknowledgment letter and is misusing manipulated bank
screenshots. The defendant challenges the plaintiff to prove them through a handwriting expert
and IT audit.
24. No Legally Enforceable Debt
Even assuming without admitting that some minor casual amounts were exchanged between
parties as friends in the past, such transactions do not constitute a legally enforceable debt under
law.?
The present suit filed in 2025 for an alleged loan of 2023 is hopelessly delayed, as the plaintiff
alleges the due date was August 2023. The suit is thus liable to be dismissed as time-barred. (If
court finds limitation otherwise, defendant reserves the right to argue.)
26. Abuse of Process of Law
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The plaintiff is misusing the process of this Hon’ble Court to pressurize the defendant and to
extort money. The suit is frivolous, vexatious and deserves to be dismissed with heavy
exemplary costs
PRAYER
In light of the above submissions, it is most respectfully prayed that this Hon’ble Court may
kindly be pleased to:
a) Dismiss the Plaintiff’s Suit in entirety;
b) Impose exemplary costs upon the Plaintiff for filing a false, frivolous and vexatious suit;
c) Pass any other or further order(s) which this Hon’ble Court may deem fit and proper in the
interest of justice.
VERIFICATION
I, Rohit Singh, the defendant above named, do hereby verify that the contents of paragraphs 1 to
26 are true and correct to my personal knowledge and belief. Nothing has been concealed.
Verified at Kanpur Nagar,
This 30th day of February, 2025.
(Signature of Defendant)
Rohit Singh