Specimen Format of Written Statement — Complete Defence Template 2026

   IN THE COURT OF THE [Civil Judge (Sr. Divn.) / District Judge],
                        [City / District]

                Civil Suit No. ______ of 2026

[Name of Plaintiff]                                 ... PLAINTIFF
                           VERSUS
[Name of Defendant]                                 ... DEFENDANT

     WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant above-named most respectfully submits as under:

PRELIMINARY OBJECTIONS

1.  That the suit is not maintainable in law or on facts and is
    liable to be dismissed with costs.

2.  That the suit is barred by limitation, the alleged cause of
    action (if any) having arisen more than [__] years prior to the
    institution of the suit.

3.  That this Hon'ble Court has no [territorial / pecuniary]
    jurisdiction to entertain the suit, inasmuch as [reason].

4.  That the plaint does not disclose any cause of action against
    the Defendant and is liable to be rejected under Order VII
    Rule 11 CPC.

REPLY ON MERITS (PARA-WISE)

5.  That the contents of paragraph 1 of the plaint are matters of
    record and need no reply / are admitted only to the extent of
    the description of the parties.

6.  That the contents of paragraph 2 of the plaint are wrong and
    denied. It is denied that the Defendant entered into the alleged
    Agreement on the alleged terms. The true facts are that [state
    the Defendant's version].

7.  That the contents of paragraph 3 are denied. The Defendant never
    received the alleged goods/amount, and the Plaintiff is put to
    strict proof thereof.

8.  That the contents of paragraph 4 (breach) are emphatically
    denied. It was in fact the Plaintiff who committed breach by
    [___], and the Defendant is not liable to pay any sum.

9.  That the contents of paragraph 5 regarding the legal notice are
    admitted to the extent of receipt; the Defendant duly replied
    vide reply dated [DD/MM/YYYY] denying the claim.

10. That the contents of paragraphs 6, 7 and 8 regarding cause of
    action, jurisdiction and limitation are denied as stated in the
    Preliminary Objections above.

11. That paragraph 9 regarding valuation and court fee is denied;
    the suit is over-valued/under-valued and the relief claimed is
    misconceived.

12. That the Plaintiff is not entitled to any interest, much less at
    the exorbitant rate claimed.

  (SET-OFF / COUNTER-CLAIM, if any: The Defendant claims a set-off /
   counter-claim of ₹[amount] on account of [___], for which the
   requisite court fee is paid herewith.)

                          PRAYER

It is, therefore, most respectfully prayed that this Hon'ble Court
may be pleased to dismiss the suit of the Plaintiff with costs
[and decree the counter-claim of the Defendant for ₹[amount]], and
grant such other relief as deemed fit.

                                          [Name of Defendant]
Place: [City]                             Through Counsel
Date : [DD/MM/2026]                       [Name of Advocate], Advocate

                       VERIFICATION

I, [Name of Defendant], the above-named Defendant, do hereby verify
that the contents of paragraphs 1 to 12 are true to my knowledge,
and nothing material has been concealed therefrom.

Verified at [City] on this [__] day of [Month], 2026.

                                          ____________________
                                              DEFENDANT