The plaintiff is put to strict proof of one and all of the allegations in the plaint. 2. The suit is a most vocations action and an abuse of process of Court. The plaintiff has invented a cause of action to file this suit. 3. It is true to say that the plaintiff is a tenant of the suit property under the defendant. 4. The allegation in para 5 of the plaint stating that the plaintiff is not issuing receipts for the rent paid by the plaintiff is false and not correct. The plaintiff and her husband never demanded any enhanced rent The plaintiff is put to strict proof of the same. The defendant has issued receipts to the plaintiff for the rent whenever he has paid. The defendant has rightly refused the rent sent through money order which is not a valid tender. Further allegation of complaint to police or seeking the help of police to get possession of the suit property is not admitted.
It is false to state that the Police personal are threatening the plaintiff to vacate. 6. The allegations in para 7 of the plaint stating that the defendant and her hencement have got their own hencemen behind the police personnel are baseless and untenable. The defendant has not threatened the lplaintiff at any pint of time through police to vacate the plaintiff from the suit property be hook or cook as falsely alleged in the plaint. The plaintiff is put to strict proof of the same.
There is no jurisdiction at all for the plaintiff to come forward with this suit. 7. The defendant submits, that she never attempted to disturb possession and enjoyment of the denied building by illegal methods. The defendant is prepared to contest any application under the Rent Control Act if and when taken against her. The defendant never proclaimed that she would throw away the plaintiff. There was no need or occasion for the plaintiff to file this suit. 8. The defendant further submits that the plaintiff had committed willful default in payment of rent.
Anticipating that the defendant would take action against him, the plaintiff forestalled defendant’s action and has filed this suit and injunction petition with a view to course the defendant for terms. 9. The suit as well as the injection petition is not maintainable either in law or on facts. The plaintiff has not come forward with clear hands and there is absolutely no cause of action in this suit. 10. The defendant submits, that she never attempted to disturb the possession of the plaintiff and also undertakes not to dispossess the plaintiff otherwise than under due process of law. 1. There is absolutely no cause of action for the plaintiff to file this suit. The suit is not at all maintainable for want of a cause of action. It is therefore prayed that the suit may be dismissed with costs.