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