Can a ws be allowed after three and a half years ?

1.Can the honorable judge allow a WS after three and a half years?
As per the Order 8 rule 1 of Code of civil procedure the duration for filing of written statement is 30 days from the date of service  of the summon  to present his defences .
Provided that where the defendant fails to file the written statement within the said period of thirty days, he shall be allowed to file the same on such other day, as may be specified by the Court, for reasons to be recorded in writing, but which shall not be later than ninety days from the date of service of summons.] 
So the court shall not entertain the written statement  after three and half years  until  and unless the service of summon does not taken place.
2.In a case if the honorable judge allows  the opposite party to file WS what are the costs we can ask for ?
If the honourable judge allows the opposite party to file a written statement even beyond the lapse of reasonable opportunity and time , and if the court thinks fit shall impose a cost for non complinace of the orders of courts and delay in the court proceedings .The amount of cost shall be decided by the court itself and it’s completely on the discretion of court.
3.These costs well be given to us by the opposite party or deposited in the court?
The courts shall decide the cost paid by the Opposite  party for non compliance of the previous orders of the court and not filing any documents within the specified time period .Also the Curt may direct the opposite party to submit the cost(whatever the court thinks fit) directly to the court.
4.In case is the honorable judge allows WS where do we go in appeal: The appellate co operative court or the high court?
The appeal shall be filed in the appellate co operative court .