Need format of rejoinder

IN THE COURT OF HON’BLE________________________________________

<STATE>

Case No:

<Name>                                                                                                              Petitioner

Versus

<Name >                                                                                                             Respondent

Rejoinder to the reply filed by the replying respondent

Respectfully Sheweth :

Reply to Preliminary Objections/Submissions:

1. That the contents of this para of reply are wrong and denied. __

2. That the contents of this para of reply are wrong and denied. __

3. That the contents of this para of reply are wrong and denied. __

4. That the contents of this para of reply are wrong and denied. __

Rejoinder to the Reply on Merits:

1. That the contents of para 1 of the reply so far as it does not admit of the contents of corresponding para of the application are wrong and denied and the contents of corresponding para of the application are re-asserted and reiterated. __

2. That the contents of para 2 of the reply so far as it does not admit of the contents of corresponding para of the application are wrong and denied and the contents of corresponding para of the application are re-asserted and reiterated. __

3. That the contents of para 3 of the reply so far as it does not admit of the contents of corresponding para of the application are wrong and denied and the contents of corresponding para of the application are re-asserted and reiterated. __

4. That the contents of para 4 of the reply so far as it does not admit of the contents of corresponding para of the application are wrong and denied and the contents of corresponding para of the application are re-asserted and reiterated. __

5. That the contents of para 5 of the reply so far as it does not admit of the contents of corresponding para of the application are wrong and denied and the contents of corresponding para of the application are re-asserted and reiterated. __

6. That the contents of para 6 of the reply so far as it does not admit of the contents of corresponding para of the application are wrong and denied and the contents of corresponding para of the application are re-asserted and reiterated. __

7. That the contents of para 7 of the reply so far as it does not admit of the contents of corresponding para of the application are wrong and denied and the contents of corresponding para of the application are re-asserted and reiterated. __

8. It is, therefore, most humbly prayed that this application deserves to be allowed and may kindly be allowed in the interest of justice. Such other order may also be passed as deemed fit and proper in the facts and circumstances of the case.

Applicant

IN THE COURT OF HON’BLE________________________________________

<STATE>

Case No:

<Name>                                                                                                              Petitioner

Versus

<Name >                                                                                                             Respondent

Affidavit

I, ______, do hereby solemnly affirm and declare as under :-

1. That the accompanying rejoinder to the reply to the application has been prepared under my instructions.

2. That the contents of paras 1 to ______ of the reply to the Preliminary Objections/Submissions and paras 1 to ______ of the rejoinder to the reply on merit of the accompanying rejoinder are correct and true to the best of my knowledge.

3. That I further solemnly affirm and declare that this affidavit of mine is correct and true and no part of it is false and nothing material has been concealed therein.

Affirmed at ____________on date______________________

<Name>

Rejoinder and affidavit will be submitted.

May i know why do you want to submitt rejoinder because i find written argument at the time of argument more effective?

Sachin,

Rejoinder is a tool given only to the petitioner to deny any false allegation in the counter statement filed by respondent.As well by submitting rejoinder we can speed up the process like you can ask court to summon the witness or you may file affidavit from your witness etc..Only very few advocates use this option perfectly on time.Rejoinder can be filed in an IA too.I need to learn more on it.

Experts may provide more information on it.