Written Statement

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Download a CPC-compliant Written Statement template (DOCX): para-wise replies, specific denials, set-off/counterclaim, verification, timelines, and drafting tips for India.

Written Statement FormateDOCX

Quick Overview

This Written Statement page provides a CPC‑aligned DOCX template for defendants to respond effectively to a plaint. It covers para‑wise replies, specific denials, preliminary objections, and optional set‑off/counterclaims, with proper verification and document handling. Designed for Indian civil practice, including commercial suits, it helps prevent deemed admissions and preserves key defenses within statutory timelines.

All templates are provided for reference and should be reviewed by legal professionals before use.

Frequently Asked Questions

Common questions about Written Statement legal templates

What is a Written Statement under the CPC?

It is the defendant’s pleading responding to the plaint with para‑wise replies, specific denials, defenses, and any set‑off or counterclaim, verified per CPC.

Which CPC provisions govern a Written Statement?

Order 8 CPC, including Rules 1–5 (filing and denials), Rule 6 (set‑off), Rule 6A–G (counterclaim), and Rule 9 (additional written statement) govern the WS.

What should a standard Written Statement include?

Cause title, preliminary objections, para‑wise replies, specific denials or admissions, affirmative defenses, relief/prayer, list of documents, and verification/affidavit.

What are ‘specific denials’ and why do they matter?

Under Order 8 Rules 3–5, evasive or general denials can be deemed admissions. Deny each material allegation specifically with brief reasons and alternative facts.

What is the time limit to file a Written Statement?

Generally within 30 days from service of summons; courts may allow up to 90 days (and up to 120 days in commercial suits under the Commercial Courts Act with strict consequences).

Can I include a set‑off or counterclaim in the WS?

Yes. Monetary set‑off under Order 8 Rule 6 and counterclaim under Rules 6A–G can be pleaded, ideally with valuation and requisite court fee where applicable.

What are common preliminary objections to raise?

Jurisdictional bars, limitation, non‑joinder/mis‑joinder, lack of cause of action, valuation/court‑fee defects, contractual bars (arbitration, exclusive jurisdiction), and res judicata.

How should documents be handled with the WS?

List and annex relied documents, paginate, and file an affidavit of admission/denial of plaintiff’s documents as per local practice, especially in commercial suits.

Can I file an additional Written Statement later?

With the court’s leave under Order 8 Rule 9, for example to respond to amendments in the plaint or to bring subsequent facts on record.

Any drafting tips to avoid deemed admissions?

Respond para‑wise, avoid vague denials, plead alternative facts, reserve rights expressly, and ensure the verification aligns with knowledge/belief distinctions.