Preliminary Objections in Written Statement format

1. That the instant suit is false and frivolous, hence liable to be dismissed with special cost.

2. That the plaintiff has no cause of action to file the instant application against the defendant.

  1. That the plaintiff has not approached before this Honourable Court with clean hands and has suppressed material facts from this Honourable Court therefore not entitled for any discretionary relief.
  1. That the plaintiff has been estopped by his own words and conducted to file the instant application.
  1. That the applicant has no locus standi to file the instant application, hence the same is liable to be suit
  1. That the instant suit is neither maintainable not proceedable in its present form, hence liable to be dismissed.
  1. That the suit suffered from inherent legal defects and the same is filed with malafide intentions and ulterior motive and the same is false and frivolous, hence liable to be dismissed.
  1. That plaintiff twisted the material facts from this Honourable Court and did not approach this Honourable Court with clean hands, hence not entitled for any discretionary relief and defendant is entitled for commentary cost under section 35-A CPC.
  1. That the plaintiff has not affixed the prescribed court fee on the plaint, hence the suit of plaintiff be dismissed on this score alone.

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