Appendix A - General Defences

Updated at:March 2010

General defences


The defendant denies that (set out facts).

The defendant does not admit that (set out facts).

The defendant admits that but says that


The defendant denies that he is a partner in the defendant firm of of

The defendant denies that he made the contract alleged or any contract with the plaintiff.

The defendant denies that he contracted with the plaintiff as alleged or at all.

The defendant admitsassets but not the plaintiff's claim.

The defendant denies the tthe plaintiff sold to him the goods mentioned in the plaint or any of them.

Of Limitation

The suit is barred by article or article or the second schedule to the {See now the Indian Limitation Act, 1908 (9 of 1908).}Indian Limitation Act, 1877 (15 of 1877.).


The Court has no jurisdiction to hear the suit on the ground that (set forth the grounds).

On the day of a diamond ring was delivered by the defendant to and accepted by the plaintiff inn discharge of the allegee cause of action.


The defendant has been adjudged ann insolvent.

The plaintiff before the institution of the suit was adjudged an insolvent and the right to sue vested in the receiver.


The defendant was a minor at the time of making the alleged contract.

Payment into Court

The defendant as to the whole claim (or as to Rs., part of the money claimed, or as the case may be) has paid into Court Rs. and says that this sum is enough to satisfy the plaintiff's claim [or the part...

To continue reading