Rule 3 of CPC : Rule 3: Denial to be specific.

Explanation using Example

Example 1:

Scenario: A property dispute between two neighbors, Mr. Sharma (plaintiff) and Mr. Verma (defendant).

Plaintiff's Allegation: Mr. Sharma claims that Mr. Verma has encroached upon 5 feet of his land and built a wall.

Defendant's Written Statement:

• Specific Denial: Mr. Verma denies the allegation of encroachment. He states, "I deny the allegation that I have encroached upon Mr. Sharma's land. The wall was built within the boundaries of my property as per the land survey conducted on 1st January 2022."
• Inability to Admit or Deny: Mr. Verma states, "I am unable to admit or deny the exact measurements of Mr. Sharma's property as I do not have access to his land records. I require Mr. Sharma to provide proof of his land measurements."
• Admission: Mr. Verma admits, "I admit that a wall has been constructed, but it is within my property boundaries."
• Jurisdiction Dispute: Mr. Verma states, "I dispute the jurisdiction of this Court as the property is located in a different district. The appropriate Court with jurisdiction is the District Court of XYZ."
• Valuation Dispute: Mr. Verma states, "I dispute the plaintiff's valuation of the suit at ₹10,00,000. The correct valuation should be ₹5,00,000 based on the current market rate of the land."

Example 2:

Scenario: A breach of contract case between a supplier, ABC Pvt. Ltd. (plaintiff), and a retailer, XYZ Stores (defendant).

Plaintiff's Allegation: ABC Pvt. Ltd. claims that XYZ Stores failed to pay ₹2,00,000 for goods delivered as per the contract dated 1st March 2023.

Defendant's Written Statement:

• Specific Denial: XYZ Stores denies the allegation of non-payment. They state, "We deny the allegation that we failed to pay ₹2,00,000 for the goods delivered. We made the payment on 15th March 2023 via bank transfer, transaction ID 123456."
• Inability to Admit or Deny: XYZ Stores states, "We are unable to admit or deny the exact quantity of goods delivered as we do not have the delivery receipts. We require ABC Pvt. Ltd. to provide proof of delivery."
• Admission: XYZ Stores admits, "We admit that there was a contract dated 1st March 2023 for the supply of goods."
• Jurisdiction Dispute: XYZ Stores states, "We do not dispute the jurisdiction of this Court."
• Valuation Dispute: XYZ Stores states, "We dispute the plaintiff's valuation of the suit at ₹2,00,000. The correct valuation should be ₹1,80,000 as per the agreed contract terms and the actual goods received."