The defendant must raise by his pleading all matters which show the suit not be maintainable, or that the transaction is either void or voidable in point of law, and all such grounds of defence as, if not raised, would be likely to take the opposite party by surprise, or would raise issues of fact not arising out of the plaint, as, for instance, fraud, limitation, release, payment, performance, or facts showing illegality.
Order VIII Rule 1 CPC Written Statement
Order VIII Rule 2 CPC New facts must be specially pleaded
Order VIII Rule 3 CPC Denial to be specific
Order VIII Rule 4 CPC Evasive-denial
Order VIII Rule 5 CPC Specific denial
Order VIII Rule 6 CPC Particulars of set-off to be given in written statement
Order VIII Rule 6A CPC Counter-claim by defendant
Order VIII Rule 6B CPC Counter-claim to be stated
Order VIII Rule 6C CPC Exclusion of counter-claim
Order VIII Rule 6D CPC Effect of discontinuance of suit
Order VIII Rule 6E CPC Default of plaintiff to reply to counter-claim
Order VIII Rule 6F CPC Relief to defendant where counter-claim succeeds
Order VIII Rule 6 G CPC Rules relating to written statement to apply