Rule 34. Written Statement

(1) The opposite party may, and, if so required by the court, shall, at or before the first hearing or within such time as the court may permit, present a written statement of his defense along with the documents on which he relies, and an accurate list thereof in Form – V.

(2) Every such written statement shall be verified in the same manner as a pleading in a civil court and shall be accompanied by two copies thereof.

(3) In every written statement submitted under sub-rule (1), the opposite party shall deal specifically with each allegation of fact alleged by the applicant, of which he admitted or does not admit or denies the allegation. The written statement must also contain all matters which show that the application is not maintainable and all such grounds of defense as, if not raised would be likely to take the applicant by surprise or would raise issues of fact not arising out of the application as for instance – fraud, undue influence or coercion, performance or fact showing illegality of the transaction.