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    Written Statement of Summery Suit Order 37 Rule 1,2

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    Lawyer45
    This document summarizes a civil suit filed in an Additional District Court in Sahiwal, Pakistan. The plaintiff, Aqil Rasheed, has sued the defendant, Tahir Karamat, for the recovery of Rs. 25,000 based on a promissory note and receipt dated April 28, 2007. However, the defendant denies the authenticity of these documents and claims they are forged. In his written statement, the defendant raises several legal objections to the suit and denies the plaintiff's allegations. The defendant requests that the suit be dismissed with costs as it is based on a concocted and frivolous story.

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    Written Statement of Summery Suit Order 37 Rule 1,2

    Uploaded by

    Lawyer45
    4K views3 pages
    This document summarizes a civil suit filed in an Additional District Court in Sahiwal, Pakistan. The plaintiff, Aqil Rasheed, has sued the defendant, Tahir Karamat, for the recovery of Rs. 25,000 based on a promissory note and receipt dated April 28, 2007. However, the defendant denies the authenticity of these documents and claims they are forged. In his written statement, the defendant raises several legal objections to the suit and denies the plaintiff's allegations. The defendant requests that the suit be dismissed with costs as it is based on a concocted and frivolous story.

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    Written Statement of Summery Suit order 37 Rule 1,2

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    This document summarizes a civil suit filed in an Additional District Court in Sahiwal, Pakistan. The plaintiff, Aqil Rasheed, has sued the defendant, Tahir Karamat, for the recovery of Rs. 25,000 based on a promissory note and receipt dated April 28, 2007. However, the defendant denies the authenticity of these documents and claims they are forged. In his written statement, the defendant raises several legal objections to the suit and denies the plaintiff's allegations. The defendant requests that the suit be dismissed with costs as it is based on a concocted and frivolous story.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC or read online from Scribd
    Download as doc
    4K views3 pages

    Written Statement of Summery Suit Order 37 Rule 1,2

    Uploaded by

    Lawyer45
    This document summarizes a civil suit filed in an Additional District Court in Sahiwal, Pakistan. The plaintiff, Aqil Rasheed, has sued the defendant, Tahir Karamat, for the recovery of Rs. 25,000 based on a promissory note and receipt dated April 28, 2007. However, the defendant denies the authenticity of these documents and claims they are forged. In his written statement, the defendant raises several legal objections to the suit and denies the plaintiff's allegations. The defendant requests that the suit be dismissed with costs as it is based on a concocted and frivolous story.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC or read online from Scribd
    Download as doc
    of 3

    Before:

    Mr, Javaid Iqbal Wariach, Additional District Judge, Sahiwal.

    Between:

    Aqil Rasheed
    ………. Plaintiff

    And:

    Tahir Karamat
    ………. Defendant

    Suit for Recovery of Rs 25,000/- on basis of Promissory Note with Receipt,


    dated 28-04-2007 , U/o 37, R 1,2 C.P.C..

    Written Statement on behalf of Defendant (Tahir Karamat):

    The defendant submits as under:-

    Legal Objections:

    1. That the instant suit comes under the Jurisdiction of “The


    Conciliation Court”, the honorable court has “No
    Jurisdiction” of entertain the instant suit which is bard by law
    and liable to be Rejected.

    2. That the stamp duty on the so called (promissory Note), Document


    is not paid as per provisions of the relevant law (Stamp Act) hence
    the instant suit is not maintainable in its present form.

    3. That the Adhesive Stamps affixed on the so called “promissory


    note” Document are not properly cancelled.

    4. That the plaintiff has no cause of action against the defendant. The
    instant suit is liable to be rejected.

    5. That the so called “promissory note” is lacking in essential


    ingredients. It does not fall within the definition of the Promissory
    Note. The suit is liable to be rejected.

    6. That the defendant has no locus standai to file the instant suit
    against the defendant.

    7. That the litigation between the parties are pending into various
    courts of law before filling the instant suit. The plaintiff wants to
    harrash & to counter the suit of the defendant. The plaintiff has
    failed this suit on the basis of Forged, False and Vexatious so
    called promissory note dated 28-04-2007 (document). Plaintiff has
    not come to court with clean hands and lacks in material substance,
    which is liable to dismissed with cost.
    Para wise Reply:

    1. That paragraph # 1 is admitted to extent of residence at Farid Town


    Sahiwal, remaining paragraph # 1 is incorrect which is false.

    2. That the paragraph # 2 is incorrect which is heavily denied on facts.


    The story narrated in the paragraph is self-made ad concocted. The
    so called promissory note (Document) & Receipt dated 28-04-2007
    are Forged, Fake, & without consideration. The signature of the
    defendant on the so called promissory note and receipt are forged.
    The defendant has neither signed nor executed the so called
    promissory note & receipt dated 28-04-2007. the defendant has
    never borrowed the alleged Rs 25,000/- from the plaintiff.

    3. That paragraph # 3 is incorrect which is false, & Frivolous and


    based on concocted story. The defendant has not ever borrowed Rs
    25,000/- from the Plaintiff and has not ever made any promise with
    the plaintiff for the repayment of the said amount.

    4. That paragraph # 4 is totally incorrect and False. The plaintiff never


    came to the defendant house and never such untoward so called
    incident occurred.

    5. That the paragraph # 5 is incorrect which is denied.

    6. That paragraph # 6 is incorrect which is denied. The Plaintiff has no


    Cause of Action against the defendant.

    7. That the paragraph # 7 is accepted upto the extent of the Residence


    of parties, rest of paragraph is denied. The plaintiff has no cause of
    action against the defendant.

    8. That paragraph # 8 is legal.

    P R A Y E R

    It is therefore humbly
    prayed that suit of the
    plaintiff is barred by law
    false, frivolous,
    vexatious and based on
    concocted and baseless
    story is liable to be
    dismissed with cost.

    Signature of defendant.
    Tahir Karamat s/o Karamat Ali Nasir, caste
    Janjua, Muslim, Adult, r/o House # 72, Block
    W, Farid Town, Tehsil & District Sahiwal.

    Through Counsel:
    Ejaz Rasheed
    Advocate High Court
    239 – District Courts Sahiwal

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