IN THE COURT OF THE PRINCIPAL JUNIOR CIVIL
JUDGE, ADDANKI
O.S.105/2013
Between:
Atluri Veeramma
..Plaintif
Vs
Duddu Kotaiah ..Defendant
WRITTEN STATEMENT FILED U/Or R1 OF C.P.C.
ON !EHALF OF THE DEFENDANT
The defendant submits the following written
statement:-
1. The suit is not maintainable either in law or on fats
and the same is liable to be dismissed in limine.
!. "#e$t the allegations those are s$ei%all& admitted
hereunder' the rest of the other allegations ha(e to be
denied b& this defendant and the $laintif is $ut to strit
$roof of the same.
). The allegations of the $laint that the defendant for his
famil& e#$enses borrowed an amount of *s.+,',,,-- .*u$ees
/ift& thousand 0nl&1 from the $laintif on 1!-,2-!,11 and
e#euted a demand $romissor& note on the same da& in
fa(our of $laintif e(idening the said borrowing and
underta3ing to re$a& the said sum together with interest at
!45 $er annum either to the $laintif or to her order on
demand the original $romissor& note' dt.1!-,2-!,11
e#euted b& defendant in fa(our of $laintif for *s.+,',,,--
and subse6uentl& the $laintif has been demanding the
defendant both $ersonall& and through mediators to
disharge the debt due under the said $romissor& note and
the defendant did not hoose to disharge the same and had
been $ost$oning the $a&ment on some $rete#t or the other
while admitting his liabilit& and the $laintif got issued a
legal notie' dt.,4-1,-!,1) to the defendant demanding
disharge of debt due under the aforesaid $romissor& note
and the defendant ha(ing reei(ed the said legal notie' got
sent a re$l& notie with date 17-1,-!,1) with all false
allegations' similar and other allegations are all false and
in(ented for the $ur$ose of this suit.
4. 8t is submitted that the defendant did not borrow an&
amount from the $laintif and e#euted a $romissor& note in
fa(our of the $laintif. The defendant has no neessit& to
borrow suh huge amount from the $laintif and the $laintif
has no a$ait& to lend the mone&. The $laintif used to lend
small amounts to the $eo$le with interest 9 *s.1,-- or
*s.1+-- $er month. There are misunderstandings between
the two families. The $laintif bore grudge of the dis$utes
and %led the suit against this defendant to get wrongful gain
and harass the defendant.
+. The suit $romissor& note is ran3 forged doument. The
$laintif fabriated this doument with ati(e su$$ort of his
henhmen. The $laintif got issued legal notie with false
allegations. The defendant got issued registered re$l& notie
stating that to send the attested :ero# o$& of the alleged
$romissor& note immediatel& for the $ur$ose of gi(ing
$ro$er re$l& with neessar& $artiulars' failing whih the
defendant on%rms that there is no suh doument. The
$laintif did not ae$t the re6uest and demand of the
defendant and failed to send the :ero# o$& of alleged
$romissor& note. ;o after that %ling this suit. The alleged
$romissor& note and the thumb im$ression on the said
doument are not belonging to this defendant.
2. The defendant need not $a& an& amount to the $laintif
as alleged in the $laint as he did not borrow an& amount
from the $laintif. The $laintif did not ome to ourt with
lean hands.
<. There is no ause of ation to %le this suit.
=. The defendant reser(es his right to %le additional
written statement in future at an& $oint of time.
>ene this defendant $ra&s that the >on?ble @ourt ma&
be $leased to dismiss the suit with osts.
Be $leased to @onsider
Ad(oate for Defendant D"/"ADAAT
The fats stated abo(e all are true to the best of m&
3nowledge' belief and information.
0ngole'
Dt. D"/"ADAAT
N.S.K.S
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D"/"ADAAT
FILED BY:-
;ri A.;.K.;ATHAA*AHAAA'
;ri V.V"AKATA PAVAA
KBGA*'
ADV0@AT";'
0AE0C".
IN THE COURT OF THE PRINCIPAL JUNIOR CIVIL
JUDGE, ADDANKI
O.S.105/2013
Between:
Atluri Veeramma
..Plaintif
Vs
Duddu Kotaiah ..Defendant
AFFIDAVIT FILED UNDER SECTION 13" C.P.C
8' Duddu Kotaiah ;-o.Bhag&alu' aged about 4, &ears'
>indu' *-o.Bhaga(anraIu$alem .V1' D.Pangulur Gandal'
Pra3asam Distrit.' do hereb& solemnl& aJrm and sinerel&
state as follows:-
8 am the de$onent herein and defendant in the main
suit and 8 am well a6uainted with the fats of the ase.
8 ha(e instruted m& ounsel and got $re$ared the
written statement. After the said written statement is
$re$ared' 8 ha(e gone through the ontents therein and
found them as true and orret and then 8 ha(e subsribed
m& signatures.
8 hereb& delared that the ontents in $aras 1 to = of
the abo(e said written statement are true and orret to m&
3nowledge' information and belief.
D"P0A"AT
;olemnl& aJrmed and aJ#ed his C.T.8 before me the
ontents of the aJda(it is read o(er and e#$lained in
Telugu to the de$onent and admitted him to be orret on
this the da& of Garh' !,14.
ADV0@AT"'
0AE0C"
