Rejoinder

IN THE [court_name] CASE NO. [case_number] IN THE MATTER OF: [plaintiff_name] ... PLAINTIFF VERSUS [defendant_name] ... DEFENDANT REJOINDER ON BEHALF OF THE PLAINTIFF TO THE WRITTEN STATEMENT FILED BY THE DEFENDANT MOST RESPECTFULLY SHOWETH: 1. That the contents of the plaint may kindly be read as an integral part of this rejoinder and are not repeated here for the sake of brevity. Nothing stated in the written statement is admitted unless specifically admitted herein. 2. That the written statement filed by the Defendant is a bundle of falsehoods, evasive denials and afterthoughts, designed to mislead this Hon'ble Court and to delay the adjudication of the suit. REPLY TO PRELIMINARY OBJECTIONS [reply_to_preliminary_objections] Each of the preliminary objections raised by the Defendant is misconceived, untenable in law, and liable to be rejected. PARAGRAPH-WISE REPLY Save as expressly and specifically admitted herein, EVERY averment, allegation and contention contained in the written statement is DENIED as if the same were set out and traversed seriatim. [paragraph_wise_rejoinder] ADDITIONAL SUBMISSIONS A. That the Defendant has failed to specifically deny the material averments in the plaint, and such averments are liable to be treated as admitted under Order VIII Rule 5 of the Code of Civil Procedure, 1908. B. That the Defendant has raised pleas that are inconsistent with each other and with the documents on record. C. That the Plaintiff reiterates and reaffirms every averment made in the plaint, and craves leave to refer to and rely upon the documents already filed. D. That the Plaintiff craves leave of this Hon'ble Court to urge such further submissions as may be advised at the time of hearing. PRAYER It is therefore most respectfully prayed that this Hon'ble Court may be pleased to decree the suit in favour of the Plaintiff as prayed for in the plaint, with costs, and to dismiss the defence raised by the Defendant. AND FOR THIS ACT OF KINDNESS, THE PLAINTIFF SHALL AS IN DUTY BOUND EVER PRAY. Place: ______________ Date: [filing_date] [plaintiff_name] PLAINTIFF Through ______________________ ADVOCATE FOR THE PLAINTIFF VERIFICATION I, [plaintiff_name], do hereby verify that the contents of this rejoinder are true and correct to the best of my knowledge, information and belief, and that nothing material has been concealed therefrom. Verified at ______________ on this [filing_date]. [plaintiff_name] NOTE: A rejoinder is filed with the leave of the court. It should be confined to answering the new facts pleaded in the written statement, and must not be used to introduce a new case or to amend the plaint.