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
article of the second schedule to the 2Indian Limitation Act, 1877. 15 of 1877.
4. The following
payments have been made, viz.:-- --
Rs.
(Insert
date)-- -- -- -- -- -- -- -- ,.....1,000
(Insert
date)-- -- -- -- -- -- -- -- ,..... 500
1.
2.
3.
4.
5. The plaintiff took
possession on ...........the of............, and has received the rents ever
since.
6. That plaintiff
released the debt on ...................the of.........
7. The defendant
transferred all his interest to A.B.by a document dated..............