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12)

That para no. 12 of the plaint is matter of record.

13)

That para no. 13 of the plaint is incorrect and denied. The plaintiffs have filed the false affidavit.

It is, therefore, requested that the suit of the plaintiff is false frivolous against law and facts may kindly be dismissed with costs.

Submitted By :-

Verification :-

Verified that the contents of para no. 1 to 5 of the pre-objections and para no. 1 to 13 of the reply on-merits are true and correct to the best of my knowledge and belief and prayer is believed to be true. Verified at Malout onIN THE COURT OF CIVIL JUDGE (Jr.D.), MALOUTJatinder Singh etc.

V/s.

Sanjay Bansal etc.

Suit for Mandatory Injunction

Written Statement on behalf of defendants no. 1 to 3Respected Sir,

It is submitted as under :-

Pre-Objections :-

1)

That the suit is not maintainable in the present form.

2)

That the plaintiffs have neither any cause of action nor locus standie to file the present suit.

3)

That the plaintiffs have concealed the material facts from the Honble Court and has not come to the court with clean hands.

4)

That the suit is barred by the provisions of Specific Relief Act.

5)

That the suit is bad for the non-joinder of necessary parties.On-Merit :

1)

That para no. 1 of the plaint is incorrect and denied as alleged. That the plaintiffs were worker as labourer on daily wages in nursery of Forest Department at Village Alamwala since 2012 to July 2014 as alleged. It is incorrect and denied that they are illegally and forcibly removed from their job as alleged. The whole story