Defence to Suit for Redemption

1.      The plaintiff's right to redeem is barred by article .........of the second schedule to the {See now the Indian Limitation Act, 1908 (9 of 1908).} Indian Limitation Act, 1877 (15 of 1877).

2.      The plaintiff transferred all interest in the property to A.B.

3.      The defendant, by a document dated the ............day of ..........................transferred all his interest in the mortgage-debt and property comprised in the mortgage to AB

4.      The defendant never took possession of the mortgaged property, or received the rents thereof.

(If the defendant admits possession for a time only, he should state the time and deny possession beyond what he admits.)