WRITTEN
STATEMENT IN A SERVICE MATTER [CD1] 
IN
THE COURT OF....................
Written
statement
in
Suit
No..................... of 19........................................
A.
B................................................................... Plaintiff
versus
C.
D............................................................... Defendant
Written statement on behalf of
Defendants Nos. 1 and 2.
Sir,
The defendants above mentioned
most respectfully submit as follows: Para wise reply to the plaint:
1.
That para No. 1 of the plaint as stated is not
correct and is not admitted. The correct facts are disclosed in Additional
Pleas.
2.
That para No. 2 of the plaint is wrong and is
not admitted.
3.
That para No. 3 of the plaint also is not
admitted being not correct.
4.
That in para No. 4 of the plaint it is admitted
that the plaintiff was suspended for his misconduct and embezzlement and
mis-deeds, and insubordination. The rest of the contents thereof are denied.
5.
That para No. 5 of the plaint as stated is not
correct except the facts that the plaintiff was dismissed in June 1960 for
various reasons and made it incumbent on the defendant to dismiss the plaintiff
immediately.
6.
That the allegations of para No. 6 of the plaint
as stated are not correct. Correct facts are disclosed in the Additional Pleas.
7.
That the para 7 of the plaint, it is admitted
that the plaintiff voluntarily and willingly submitted his resignation to the
defendant fearing the charges against him to be proved and he might be dealt
with criminally also and no force was brought on him to submit the resignation.
It was an after-thought on his part to circumvent with ulterior motives.
8. That
the fact of the appeal by the plaintiff having been rejected as not
entertainable is admitted. 9. That in para No. 9 of the plaint, the rejection
of writ and dismissal of special appeal is admitted.
10.
That the contents of para No. 10 of the plaint
are totally false and are denied emphatically. The plaintiff was not entitled
to any payment after suspension.
11.
That para No. 11 of the plaint it is admitted as
the District Inspector of Schools called the defendant to discuss matters and
came to the conclusion that the plaintiff is not entitled to any amount or any
pay or any emolument of dues under the circumstances of the case. 12. That para
No. 12 of the plaint as stated is not admitted. The plaintiff was
practically in charge of the
whole institution and everything was in his charge and after dismissal and
resignation, he did not hand over charge of various items and withheld
important documents and paper, registers etc., did not hand over to the
defendant, hence the District Inspector of Schools did not take any action.
13.
That the contents of para 13 are wrong and
denied.
14.
That the allegations of para 14 are incorrect
and not admitted, the defendant never admitted the dues of seven months.
15.
That the contents of para No. 15 are wrong and
denied.
16.
That the contents of para No. 16 are wrong and
denied.
17.
That the contents of para No. 17 are false and
emphatically denied.
18.
That the allegations of para No. 18 are wrong
and as such are denied.
19.
That the contents of para No. 19 of the plaint
are wrong and denied.
20.
That the contents of para No. 20 are wrong and
denied and the plaintiff is not entitled to any relief.
ADDITIONAL PLEAS
21.
That the Plaintiff has no cause of action for
the suit against the defendant and the suit is misconceived.
22.
That the suit is not maintainable being time
barred and multifarious.
23.
That the plaintiff never acted as Principal of
the College nor he was promised to pay his salary in that grade, but he had
been only an assistant master throughout his career in the College.
24.
That the suit deserves to be dismissed with
costs. It is accordingly prayed.
Plaintiff
Through
Advocate
VERIFICATION
Verified that the contents of
paras 1 to 20 and 23 of this written statement are true to my personal
knowledge, and those of paras 21, 22 and 24 thereof are based on legal advice
which I believe to be true.
Verified on....................
19.................... at....................
Plaintiff
Filed by
Counsel
for the defendant.
LIST OF DOCUMENTS RELIED BY THE
DEFENDANT
1.....................
2.....................
3.....................
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