DEFENCE TO SUIT FOR FORECLOSURE

 

1. The defendant did not execute the mortgage.
2. The mortgage was not transferred to the plaintiff (if more than one transfer is alleged, say which is denied).
3. The suit is barred by articles __________ of the Second Schedule to the Indian Limitation Act, 1877 (15 of 1877).
4. The following payment have been made viz, :-?(Insert date)— Rs. ________ (Insert date) Rs. _______.
5. The plaintiff took possession on the ________ of _______ and has received the rents ever since. 6. The plaintiff released the debt on the _________ of ________.
6. The defendant transferred all his interest to A.by a document dated.