Defendant reply under Order VIII CPC covering preliminary legal objections, para-wise reply on facts, and a set-off / counter-claim skeleton.
When to use this draft
Use to answer a plaint within the time allowed by the court, ordinarily thirty days from service of summons.
Essential contents
- Preliminary objections - maintainability, limitation, cause of action, jurisdiction, non-joinder
- Para-wise reply admitting, denying or requiring strict proof
- Version of facts pleaded by the defendant
- Set-off or counter-claim where money is due to the defendant
- Verification and affidavit
Drafting notes
- Anything not specifically denied is taken as admitted under Order VIII Rule 5 CPC - deny every adverse paragraph.
- Raise limitation and jurisdiction as preliminary objections so they can be framed as issues.
- Attach the defendant documents at this stage; leave is required later.
Adapt before filing
This is a structural template, not advice on your matter. Facts, dates, valuation, jurisdiction and the prayer must be settled by a lawyer licensed to practise in Pakistan.