Objection Written Statement in Civil Suit

BEFORE THE COURT OF LD.
MUNSIFF/JMIC/ASMM
THANAMANDI
In the case of:
Yaseen Shah
……….Plaintiff
VERSUS
Ali Shah & Ors.
……….Replying Defendants
In the matter of: Suit for permanent prohibitory injunction
AND
In the matter of: Written statement/objections on behalf of defendants
MAY IT PLEASE YOUR HONOUR:-

The defendants most humbly & respectfully submits as under:
1. That the instant suit is not maintainable as the plaintiff has suppressed
material facts from this Hon’ble Court and did not approached this
Hon’ble Court with clean hands. That the defendants are owner in
possession of suit land comprised under Khasra No. 807 min measuring
06 Kanals situated at village Hasplote, Tehsil Thannamandi district
Rajouri. That the suit land is in possession of the defendants and they are
cultivating in the same for the decades.
2. That the suit land was purchased by the defendants for the total
consideration of rupees
3. That the plaintiffs had instituted civil suits before this Hon’ble court two
times earlier pertaining to same suit land and same party which were
withdrawn by the plaintiff himself because there was no grounds and
facts to prove the case of the plaintiff.
4. That the plaintiff has filed the instant suit only in order to harass the
replying defendants and the instant suit is false and frivolous which
deserves to be dismissed.
5. That the plaintiff who after in conniving with the Patwari obtained Nakal
Khasra Girdawri illegally and on the basis of same the plaintiff while
suppressing the material facts misguided this Hon’ble Court and obtained
interim relief fraudulently and under the garb of said interim order the
plaintiff is harassing and threatening the replying defendants of their no
fault.
6. That the plaintiff did not approached this Hon’ble court with clean hands
and the plaintiff suppressed the material facts from this Hon’ble Court.
Hence, the suit is liable to be dismissed forthwith on this score.
7. That the defendants are absolute owner in possession of the suit land and
and they are also enjoying the suit land for the decades.
8. That the Nakal Khasra Girdawri which is attached with the suit by the
plaintiff is obtained by illegal means. That since the defendant are absolute
owner in possession of their own land comprised under Khasra No. 807
min measuring 06 Kanal , then there is no cause of interference arises in
the suit land as alleged by the plaintiff in the instant suit.
IN THE PREMISES:-
It is therefore, most humbly and respectfully submitted that the

plaintiff has suppressed material facts from this Hon’ble Court and the
instant suit is not based on true facts. The suit is totally fabricated,
concocted, false and frivolous and on the basis of these fabricated facts the
instant suit is liable to be dismissed.
PRAYER:-
It is most humbly and respectfully prayed that this Hon’ble

Court may kindly be please to:
1. Dismissed the suit of plaintiff

2. Award costs to the defendants
3. Pass any other just and equitable order as this Hon’ble Court deem fit
in the interest of justice equity and fair play.
4. It is also prayed that the objections in the main suit may kindly be
considered/treated as objections in the interim-application.
VERIFICATION:-
Verified today on ________ December 2021 at Thanamandi
that all the contents cited above are true and correct on the basis of legal advice
received and believed to be true. Last para is prayer to this Hon’ble Court.
Defendants
Through Counsel: Advocate Babar Mirza
BEFORE THE COURT OF LD. MUNSIFF/JMIC/ASMM
THANAMANDI
In the case of:
Mohd Jameel & Ors.
……….Plaintiff
VERSUS
Mohd Youis & Ors.
……….Replying Defendants
In the matter of: Suit for permanent prohibitory injunction
AND
In the matter of: Written statement/objections on behalf of defendants
MAY IT PLEASE YOUR HONOUR:-

The defendants most humbly & respectfully submits as under:
9. That the instant suit is not maintainable as the plaintiff has suppressed
material facts from this Hon’ble Court and did not approached this
Hon’ble Court with clean hands. That the defendants are owner in
possession of suit land comprised under Khasra No. 1029/1 measuring up
to the extent of their respective share out total land measuring 05 Kanal
and 01 Marla situated at village Saaj, Tehsil Thannamandi district Rajouri
and revenue record is also running in the name of defendants.
10. That the plaintiff has filed the instant suit only in order to harass the
replying defendants and plaintiff are influential persons who are bent
upon to dispossess the replying defendants from their share while suing
them in the courts and the instant suit is false and frivolous which
deserves to be dismissed.
11. That neither the replying defendants are causing any sort of interference
in the suit land nor they are bent upon to sell or alienate the suit property
and the replying defendants are owner in possession of the suit property
since long and revenue records speaks itself about the ownership. That the
plaintiff who after in conniving with the Patwari obtained Nakal Khasra
Girdawri illegally and on the basis of same the plaintiff while suppressing
the material facts misguided this Hon’ble Court and obtained interim relief
fraudulently and under the garb of said interim order the plaintiff is
harassing and threatening the replying defendants of their no fault.
12. That the plaintiff did not approached this Hon’ble court with clean hands
and the plaintiff suppressed the material facts from this Hon’ble Court.
Hence, the suit is liable to be dismissed forthwith on this score.
13. That the defendants are absolute owner in possession of the suit land and
as per the revenue record the names of the defendants are reflecting in the
cultivation column and ownership column as well and they are also
enjoying the suit land for the decades.
14. That the Nakal Khasra Girdawri which is attached with the suit by the
plaintiff is obtained by illegal means. That since the defendant are absolute
owner in possession of their own land comprised under Khasra No.
1029/1 out of total measuring 05 Kanal 01 Marlas, then there is no cause of
interference arises in the suit land as alleged by the plaintiff in the instant
suit.
15. That all the pleadings pleaded in the body of this plaint are baseless which
are vehemently denied by the replying defendants at all.
IN THE PREMISES:-
It is therefore, most humbly and respectfully submitted that the

plaintiff has suppressed material facts from this Hon’ble Court and the
instant suit is not based on true facts. The suit is totally fabricated,
concocted, false and frivolous and on the basis of these fabricated facts the
instant suit is liable to be dismissed.
PRAYER:-
It is most humbly and respectfully prayed that this Hon’ble
Court may kindly be please to:
5. Dismissed the suit of plaintiff
6. Award costs to the defendants
7. Pass any other just and equitable order as this Hon’ble Court deem fit
in the interest of justice equity and fair play.
8. It is also prayed that the objections in the main suit may kindly be
considered/treated as objections in the interim-application.
VERIFICATION:-
Verified today on ________ December 2021 at Thannamandi
that all the contents cited above are true and correct on the basis of legal advise
received and believed to be true. Last para is prayer to this Hon’ble Court
Defendants
Through Counsel: Advocate Babar Mirza

Objection Written Statement in Civil Suit

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BEFORE THE COURT OF LD.

MAY IT PLEASE YOUR HONOUR:-

It is therefore, most humbly and respectfully submitted that the

It is most humbly and respectfully prayed that this Hon’ble

1. Dismissed the suit of plaintiff

MAY IT PLEASE YOUR HONOUR:-

It is therefore, most humbly and respectfully submitted that the

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