Suit For Breach of Contract
Suit For Breach of Contract
I, Stavan Telgote, advocate on record for Ms. Rekha Jha director of Saptrangi Pvt. Ltd.
having principal office at, Office No 407-408, Zenith complex 4th Floor, Opposite Krishi
under :
1. Being duly authorized for the same, the present written argument is filed on behalf of
2. At the outset, it is submitted that all the allegations made in the Complaint are false,
invalid, illegal and such allegations are made to deliberately harass my client and to
supress true facts hence anything not accepted by my client shall be consider
denied.
3. My client further states that the Plaintiff has filed the Case U/s 74 and 26 of the
Indian Contract Act, read along with Code of Civil Procedure where the Opposite
Party have suppressed material facts with a malafide intention to gain unlawful
4. My client states that the plaintiff has filed this case deliberately to harass my client
5. Moreover, my client states that the facts stated in para 1, 2, 3, 4 and 5 are true and
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SUIT FOR BREACH OF CONTRACT
correct to my client’s knowledge.
6. With reference to para 6 my client denies the statement made in the said paragraph
which says that “The Plaintiff further submits that shortly after the delivery of the
consignment, profits for the Plaintiff company reduced significantly which resulted
in the Plaintiff company to suffer horrific losses due to loss of profitable contract
with its major booking agents.” is absolutely false and concocted as the said
statement is not supported by any documentary evidence hence the case shall be
7. With reference to para 7 the statement of profit and loss are forged hence
inadmissible.
8. The facts stated in para 8 and 9 are true and correct to my client's knowledge.
9. With reference to para 10 my client denies the said allegations and further states that
if the consignment was of poor quality then you were bound to return it.
10. The fact stated in para 11 is true and correct to my client’s knowledge.
11. With reference to para 12 my client states that she was looking forward to amicable
settlement with respect to the said issue therefore if such notice/letter would have
been received by my client, she would have absolutely replied for the same.
12. My Client submits that the plaintiff is approaching this court with an dishonest
intention to malign our company’s image in the business field. Therefore my client is
entitled to claim damages amounting to Rs.5,00,000 for the crime committed by the
opposite party under section 499 of Indian Penal Code by initiating frivolous
13. With the facts and circumstances mentioned herein in above the suit of the plaintiff
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SUIT FOR BREACH OF CONTRACT
VERIFICATION
I, Ms.Rekha Jha, director of the Defendant company above named, do hereby state and
declare on solemn affirmation that whatever stated hereinabove is true and correct to my
own knowledge.
Before me
Identified by me