Written Statement

It must contain

1. 01Filing within 30 days of service of summons. The court may extend it for reasons recorded in writing, up to 90 days — Order VIII Rule 1.
2. 02Specific denial of every allegation not admitted — Rules 3 to 5. Denial must meet the allegation, point by point.
3. 03New facts raised specifically: limitation, fraud, discharge, and anything else that would take the plaintiff by surprise — Rule 2.
4. 04Set-off, with particulars, where an ascertained sum is claimed — Rule 6.
5. 05A counter-claim, if the defendant has one — Rule 6A.
6. 06Verification, on the same footing as the plaint.

Where it fails

• A general denial. An evasive or non-specific denial is treated as an admission — the fastest way to lose facts that were genuinely in dispute.
• Omitting limitation. It is not saved for later; unpleaded, it is very hard to argue.
• Missing the deadline in a commercial suit. In an ordinary suit the Order VIII Rule 1 period is directory (Kailash v. Nanhku, (2005) 4 SCC 480); under the commercial-courts regime the outer limit is 120 days and the right to file is forfeited.