How to draft a written statement using AI: Learn how to give the right prompts

This article is your guide to drafting a written statement using AI. In the earlier article, we saw how to draft a plaint using AI, so this article is a continuation of the previous article. So, now you will learn how to give the right prompts that will help you draft faster, think more systematically, and present your client’s case without missing out on any information. If you are a lawyer or law student who has ever struggled with drafting a written statement from scratch, this guide is for you.

Introduction

It was a Monday morning when Rekha Mohan Sharma was doing what most of us do, sipping on her morning tea, when suddenly the doorbell rang.

“Who could that be so early?” she thinks, shuffling to the door

“Court summons for Rekha Mohan Sharma,” the bailiff announced in Hindi and handed over a thick envelope into her trembling hands.

She looked clueless and asked the bailiff, “What is this exactly as she could not read or understand English. “Court papers,” he replied, and walked away.

She panicked and immediately called her daughter. Within minutes, her daughter rushes over, you know how it is when your mom sounds terrified on the phone.

Her daughter tears open the envelope and scans through the papers, “Arjun has filed a case against you; he is claiming rights in this property, and you have to appear in the court on the next date.”

“We need a lawyer, and we need one NOW,” her daughter says.

Luckily, Rekha remembered her husband’s old friend, a lawyer who is family. She calls him up, and the very next day, they are sitting in his office, probably still in shock that Arjun could do something like this.

The lawyer went through the papers and said, “he has alleged that you are illegally occupying property that belongs to him”.

“What is the next step? Mom is 68, keeps unwell most of the time, and it is not possible for her to attend court every time.”, says her daughter.

He advised them, “You should appear in the court on the next date.”

He also mentioned that her entire case, whether she keeps her home or loses everything, would come down to just one document. One single piece of paper that could either save her or destroy her. Her case would be won or lost based on a single document, which would serve as her defence.

Can you tell me what that document is?

Those of you who know have got it right; it is the written statement.

Normally, drafting a written statement takes a lot of time, and it is exhausting too.

But what if I told you that there is a tool that drafts a written statement in minutes, and I have decided today to teach you how to use that tool effectively.

What do you think that game-changer could be?

AI! Yes, artificial intelligence is revolutionising the way we handle legal documents, and I will show you exactly how to use it like a pro, but let me tell you that it does not replace your knowledge and experience.

Today you are learning how to draft a written statement using AI., You can refer to my article on how to draft a plaint using AI, where I have taught how to draft one using AI. This article is going to teach you. Today, in this article, we are going to see how to draft a written statement using AI.

But first, let us make sure we are all on the same page about what a written statement actually is.

What is a written statement?

So, what exactly is this written statement?

Let me explain to you, when someone accuses you of something, will you simply stand there silently? You would obviously defend yourself and explain your side of the story. That is what a written statement is in legal terms.

A written statement is the defendant’s official response to the plaintiff’s claims in a civil lawsuit, as outlined in the Code of Civil Procedure,1908.

You already read that Arjun filed a case against Rekha, and the document received by Rekha is the Plaint. Now, Rekha’s written statement is going to be her point-by-point response to that plaint.

A well-drafted written statement helps the court understand what the defendant agrees with, disagrees with, or even something that the defendant is even unaware of, and also includes new facts or legal objections to challenge the suit can be included.

A well-drafted written statement can completely turn the tables. It can expose weaknesses in the plaintiff’s claims, or even get the entire case rejected before it even begins.

On the other hand, a poorly drafted one or missing deadlines can result in the court assuming the allegations to be true or proceeding without the defendant’s input.

You can refer to my article on how to draft a plaint using AI, if you

Let us now look at the legal framework that governs it.

What is the legal framework that governs a written statement?

Order VIII of the Code of Civil Procedure,1908, sets out how a written statement must be prepared and the time limit for filing it.

Rule 1: Filing deadline

You must file the written statement within 30 days of receiving the writ of summons.
In regular suits, the courts have the discretion to extend this up to 90 days if you have a valid reason.
In commercial suits, you get up to 120 days total (30 days + 90 days extension), but not more. If you miss this, you lose your right to file, and the court will not accept it as per the judgement of the Supreme Court in the case of [SCG Contracts India Pvt. Ltd. v. K.S. Chamankar Infrastructure Pvt. Ltd.(2019)12 SCC 210]

Rule 1A: Bring your documents

If your defence or claims (like set-off or counterclaim) rely on documents, list them and submit them with the written statement, along with copies.
If a document is not with you, then you need to say who has it.
If you do not rely on a document, then you cannot use it later in court unless the judge allows it.

Rule 2: Mention new facts or defences

Include any new facts or reasons why the suit should not proceed, such as if it is filed too late (limitation), involves fraud, or is legally invalid. This avoids surprising the plaintiff later.

Rule 3: Deny specifically

You simply do not have to just say, “I deny everything.” You need to respond to each point in the plaint clearly, admit, deny, or say you are not aware and explain why.

Rule 4: No vague denials

Denials must be direct and address the main issue. Vague or tricky answers are treated as admissions.

Rule 5: Silence means agreement

If you do not specifically deny any allegation in the plaint, then it is presumed that you admit it (except for claims about damages).
The court can still ask for proof of admitted facts or proceed based on the plaint if you don’t file a written statement.

Rule 8: New defences later

If subsequent events happen after the suit commences, then the written statement can be amended subject to the discretion of the court.

Rule 9: Extra pleadings

After the written statement, you cannot file more documents unless the court allows it. The court may also ask for additional statements and set a deadline.

Rule 10: Missing the deadline

If you do not file the written statement on time, the court can:

Decide based on the plaintiff’s plaint alone.
Make other orders that it thinks are fair.

Let us now proceed to the drafting bit.

How to use AI to draft a written statement?

I will guide you through the step-by-step process of drafting a written statement using AI.

First, think before you give a prompt.

Most people make the mistake of dumping the plaint into ChatGPT and saying: ‘Write a reply to this plaint.’

That is a wrong move.

AI will give you something back, which will be generic and often miss legal nuances.

Instead, we break it into stages.

We treat AI like a paralegal, super sharp, never tired, but only as good as the questions you ask.

Here are a few pro tips to succeed at using AI to draft a written statement, which we will learn in detail:

Are you ready? Let us begin.

Step 1:Summary of facts

So first, we start with a summary.

Here is the prompt that I gave:

“Summarise the key facts of this civil suit from the plaint attached in PDF. Just give me the parties, nature of the dispute, background, and the main allegations. Keep it under 200 words. This is the attached plaint in PDF.”

This is what ChatGPT generated based on the prompt given:

“Parties:

Plaintiff: Arjun Pradeep Sharma (35, Software Engineer, Borivali)
Defendant No. 1: Brihan Mumbai Mahanagar Palika (landlord)
Defendant No. 2: Rekha Mohan Sharma (68, Retired Teacher, sister-in-law of plaintiff’s father)

Nature of Dispute: Tenancy succession and possession dispute

Background: Late Pradeep Mohan Sharma was the original tenant of Flat No. 203, Navrang Chawl, Dadar (West). He died in March 1995. Plaintiff claims succession rights through his father, Suresh Pradeep Sharma (deceased tenant’s son). The family purchased an additional Borivali flat in 1998 and used both premises. Due to the mother’s heart condition, the Dadar premises were temporarily closed.

Main Allegations:

Defendant No. 2 illegally broke open and occupied the suit premises
The plaintiff has been paying rent and maintaining the property
Defendant No. 2 threatened the plaintiff when he tried to visit
Legal notice dated 8th April 2023 served but ignored
Plaintiff seeks a declaration of rights, possession, and a permanent injunction
Suit valued at ₹8,00,000/-”

Why does this step matter?

Because once you get the summary, you know what to attack on.

The cause of action, the lineage, the timing, that is what matters in tenancy and possession disputes. AI helps you filter the haystack.

Next, we break down the allegations contained in the plaint paragraph by paragraph.

This helps with structured rebuttal.

Step 2: Listing the allegations

This is the prompt that I gave:

‘List all the allegations made by the Plaintiff in each paragraph of the plaint, from para 1 to 17. Make it a simple bullet list.’

Based on the prompt, ChatGPT gave me the following response:

“Para 1: Plaintiff is the grandson of the original tenant Pradeep Mohan Sharma; father Suresh was the legal heir

Para 2: Defendant No. 2 is the sister-in-law illegally occupying without legal right

Para 3: Suit premises governed by the Maharashtra Rent Control Act; rent receipts in the deceased’s name

Para 4: Plaintiff derives succession rights through the father as the legal heir

Para 5: Plaintiff has been paying rent and all outgoings/utility bills

Para 6: The family resided at both Borivali and Dadar premises; Dadar closed due to the mother’s heart condition

Para 7: Defendant No. 2 illegally broke open the lock and forcibly occupied the premises

Para 8: Defendant No. 2 threatened the plaintiff when he tried to visit the premises

Para 9: Legal notice dated 8th April 2023 served but the defendant failed to comply

Para 10: Apprehension that the defendant may create third party rights or transfer tenancy

Para 11: The cause of action arose in 2023 when illegal occupation began

Para 12: Court has territorial jurisdiction; suit valued at ₹8,00,000/-

Para 13: Suit filed within the limitation period as illegal occupation started in 2023

Para 14: Suit valued at ₹8,00,000/- for court fees

Para 15: Will rely on documents listed as Exhibit E

Para 16: No other suit filed on the same cause of action

Para 17: Prayers for declaration, possession, injunction and costs”

“Good. Now we know exactly what we are dealing with.

But here is where most juniors go wrong: they immediately start writing responses.

Do not do that. First, we need to understand our client’s position and build our defence strategy.

Step 3: Know your client – getting our facts straight

Before we draft any defence, we need to provide ChatGPT with our version of the facts.

You need to understand that ChatGPT just read the plaintiff’s story. Now it needs to hear the client’s story.

But how do I get our facts into AI?

It is simple. We tell ChatGPT our client’s position clearly.

Now you see what prompt I gave to ChatGPT:

“Here are the actual facts from our client Defendant No.2’s perspective:

-Our client Rekha Mohan Sharma married Rakesh Pradeep Sharma (younger son of the original tenant) in 1985 and has been residing in the suit premises since then. In 1998, there was a family arrangement where all legal heirs including Suresh Pradeep Sharma (plaintiff’s father) agreed that Rekha and her husband would continue in the premises as they were caring for elderly parents.

-Suresh took separate accommodation at Borivali and abandoned his rights. The plaintiff was born after 1998 and never resided in the suit premises. Rakesh died in 2015, mother-in-law Kavita died in 2020.

-Our client has been paying rent for 30+ years. The plaintiff only tried to interfere in 2023 when our client was away for medical treatment. Any family arrangement excludes the plaintiff’s father who voluntarily gave up rights. The suit is barred by limitation as any cause of action arose in 1995 upon the original tenant’s death, not 2023.”

This is the result generated by ChatGPT based on the aforesaid prompt.

“Thank you for providing the defendant’s perspective. Based on these facts, you have several very strong defences:

Primary Defences:

Valid Family Arrangement (1998) – All legal heirs, including the plaintiff’s father consented to the defendant continuing in the premises
Abandonment of Rights – Plaintiff’s father voluntarily abandoned tenancy rights by taking separate Borivali accommodation
Limitation – Any cause of action arose in 1995 upon the original tenant’s death, not 2023 (30-year delay)
No Derivative Rights – Plaintiff cannot claim rights through the father who abandoned his own rights
Continuous Possession – Defendant has been in lawful possession since marriage in 1985.

Factual Advantages:

Defendant has a 38-year continuous residence vs the plaintiff who never lived there
The defendant paid rent for 30+ years vs the plaintiff’s recent interference
Family arrangement with the consent of all heirs including the plaintiff’s father
The plaintiff only emerged in 2023 opportunistically

Legal Grounds:

Suit not maintainable due to the father’s abandonment
No cause of action as the plaintiff has no subsisting rights
Suppression of material facts (family arrangement)
Barred by limitation
Non-joinder of necessary parties (other family arrangement parties).”

“See the difference? Now, ChatGPT understands both sides and can give us strategic advice.

But we are not done yet. We need to structure this for the court.

Step 4: Building the defence strategy

Now we get tactical. We need to structure our written statement for maximum impact.

But remember – we ask for specific things, not everything at once.

So we give our next prompt as follows:

“Draft the preliminary objections section for a written statement in the Bombay Civil Court. Use the format: “At the outset, the Defendant No. 2 submits that…” for the first objection, then “At the further outset…” for subsequent ones. I want exactly 5 objections based on: (1) father’s abandonment making suit not maintainable, (2) no cause of action due to abandoned rights, (3) suppression of family arrangement facts, (4) 30-year limitation period, (5) parties’ issues.”

Based on the prompt ChatGPT gave me the following response:

“At the outset, the Defendant No. 2 submits that the suit is not maintainable.

At the further outset, the Defendant No. 2 submits that the suit discloses no cause of action.

At the further outset, the Defendant No. 2 submits that the suit is barred by limitation.

At the further outset, the Defendant No. 2 submits that plaintiff has suppressed material facts.

At the further outset, the Defendant No. 2 submits that there is misjoinder of parties.”

“Stop! See what happened?

ChatGPT gave us the structure but made it completely generic.

Each objection should tell our story with specific facts.

Also, it is missing the proper legal conclusion. Watch how I fix this.

I give the following corrective prompt:

“This is generic and incomplete. Each objection must include specific facts from our case and end with “liable to be dismissed with costs”. For example, the first objection should mention that the plaintiff’s father Suresh Pradeep Sharma abandoned all rights by executing a family arrangement in 1998 and taking separate Borivali accommodation, cutting off the plaintiff’s derivative rights. Make each objection tell our story with specific facts.”

See how ChatGPT understood what I wanted and generated the following result:

“At the outset, the Defendant No. 2 submits that the Suit is misconceived and not maintainable inasmuch as the Plaintiff’s father Suresh Pradeep Sharma had abandoned all rights in the suit premises by executing a family arrangement in 1998 and taking separate accommodation at Borivali, thereby cutting off any derivative rights that the Plaintiff might claim, and the same is liable to be dismissed with costs.

At the further outset, the Defendant No. 2 submits that the suit does not disclose any cause of action against Defendant No. 2 as the Plaintiff derives his alleged rights through his father Suresh Pradeep Sharma, who had abandoned all his rights in the suit premises by executing a family arrangement in 1998 and taking separate accommodation at Borivali, and since the Plaintiff’s father himself had no subsisting rights after 1998, the Plaintiff cannot claim any derivative rights, with the result that the suit is liable to be dismissed for want of cause of action.

At the further outset, the Defendant No. 2 submits that the Plaintiff has suppressed the material facts from this Hon’ble Court, particularly the family arrangement dated 1998 whereby all legal heirs including the Plaintiff’s father had consented to Defendant No. 2 continuing in the premises, and the Plaintiff has come out with false statements and ulterior motives to grab the suit premises in which the Plaintiff has no right or interest whatsoever, with the result that the suit is liable to be dismissed with cost.

At the further outset, the Defendant No. 2 submits that the present suit is hopelessly barred by limitation as any cause of action, if any, would have arisen upon the death of the original tenant in March 1995, and the suit filed after 30 years in 2025 is clearly beyond the prescribed period of limitation and is liable to be dismissed on this ground alone.

At the further outset, the Defendant No. 2 submits that the suit is bad for non-joinder of necessary parties as all legal heirs who were parties to the family arrangement have not been impleaded, and also suffers from misjoinder of parties as Defendant No.1 has no role in determining succession rights between private parties, and is liable to be dismissed with cost for misjoinder and non-joinder of parties.”

But we are still missing something.

We need to add the ‘without prejudice’ clause after preliminary objections.

So I ask ChatGPT to do the following:

“Add the standard clause: “The aforesaid submissions are without prejudice to one another and without prejudice to what is stated hereinafter.”‘

Accordingly, ChatGPT responded as under:

“The aforesaid submissions are without prejudice to one another and without prejudice to what is stated hereinafter.”

Now, each objection tells our story, and we have a proper legal format.

This is the difference between mechanical AI usage and strategic AI guidance.

Step 5: Building our positive case

Good preliminary objections set the tone, but now we need to establish our positive case.

We cannot just deny everything; we need to show why our client has superior rights.

Therefore, I gave the following prompt:

“Draft the factual background section starting with ‘The Defendant No. 2 submits that as far as the suit premises are concerned, the true facts are as under:’ Use numbered paragraphs covering the key facts chronologically.”

This is what ChatGPT responded with:

“The Defendant No. 2 submits that as far as the suit premises are concerned, the true facts are as under:

The original tenant was late Pradeep Mohan Sharma who expired in 1995.
Defendant No. 2 has been residing in the premises since her marriage in 1985.
A family arrangement was executed in 1998 between all legal heirs.
The plaintiff’s father took separate accommodation at Borivali.
Defendant No. 2 has been paying rent continuously for over 30 years.”

Wait, this is not what we wanted.

Why is that? Because we were not specific. We need to be very specific about what we want.

So I gave the following corrective prompt:

“Be more detailed and professional. Each paragraph should be substantial with specific facts, dates, and legal significance. Start with the original tenant’s death, then the defendant’s marriage and residence since 1985, then family arrangement with full details, then plaintiff’s father’s abandonment, then defendant’s continuous possession and rent payments, then recent interference by plaintiff in 2023.”

Now let us see the following result that ChatGPT has generated for us:

“The Defendant No.2 submits that as far as the suit premises are concerned, the true facts are as under:

(i) Originally one late Pradeep Mohan Sharma in whose name the rent receipts presently stands was the tenant of the said suit premises. The said Mr. Pradeep Mohan Sharma was the father-in-law of Defendant No. 2 and expired on or about 15th March 1995. After his death, his widow Kavita Pradeep Sharma continued to reside in the suit premises along with Defendant No. 2, who had been residing there since her marriage into the family in 1985. The said Kavita Pradeep Sharma also expired in the year 2020. A copy of the death certificate of Pradeep Mohan Sharma is hereto annexed and marked Ex. “A”.

(ii) Pursuant to the family arrangement executed in 1998, all the heirs of Pradeep Mohan Sharma namely Suresh Pradeep Sharma (elder son), Rakesh Pradeep Sharma (younger son) i.e. the husband of Defendant No. 2, and Priya Pradeep Nair (daughter) had mutually agreed that since Defendant No. 2 and her husband were taking care of the elderly parents, they would continue to reside in the suit premises. The said Suresh Pradeep Sharma had given his consent to this arrangement and had taken separate accommodation at Borivali when he purchased the flat there in 1998. A copy of the family arrangement dated 15.11.1998 is hereto annexed and marked Ex. “B”.”

But we still need more paragraphs to complete the story.

We need to continue with the remaining facts.

So I simply ask ChatGPT to do the following:

“Continue with paragraphs (iii) to (vi) covering: plaintiff’s birth after father left premises and never resided there, defendant’s continuous residence and rent payments, husband’s death in 2015, and recent interference by plaintiff in 2023 when defendant was away for medical treatment.”

You can see how ChatGPT responded:

“(iii) After Suresh Pradeep Sharma went to reside at Borivali, two sons were born to him, namely Vikash Suresh Sharma (elder son) and thereafter the Plaintiff Arjun Pradeep Sharma. Both sons were born and brought up at Borivali and never stayed in the suit premises. This shows that the Plaintiff had never resided at any time in the suit premises after his birth.

(iv) In view of such family arrangement and the fact that Suresh Pradeep Sharma had given up his rights in the said premises by taking separate accommodation, the Plaintiff cannot now claim any right, title, interest, or claim in the said premises at all, as the Plaintiff’s father himself had abandoned his rights. At this juncture, it is pertinent to note that the Plaintiff has never stayed in the suit premises inasmuch as prior to his birth, only his father took separate accommodation at Borivali.

(v) The Defendant No. 2 further submits that after Suresh Pradeep Sharma went to reside at Borivali, Defendant No. 2, along with her husband Rakesh Pradeep Sharma and in-laws, continued to stay in the suit premises. The Defendant No. 2’s husband died in 2015, and thereafter Defendant No. 2 continued to reside with her mother-in-law until her death in 2020. After Suresh Pradeep Sharma left the premises, his name was removed from the ration card and in the ration card issued in 2000, only the names of Rakesh Pradeep Sharma, Defendant No. 2, Kavita Pradeep Sharma and Pradeep Mohan Sharma are mentioned. Hereto annexed and marked Ex. “C” is a copy of the said ration card.

(vi) The Defendant No. 2 further submits that she has been paying the rent of the suit premises and all outgoings along with her deceased family members. However, recently, for the first time in 2023, behind the back of Defendant No. 2, the Plaintiff attempted to interfere with the premises when Defendant No. 2 had temporarily gone to her sister’s place for medical treatment. Prior to 2023, right from 1995, the Plaintiff had never bothered to visit or show any interest in the suit premises. Hereto annexed and marked Ex. “D” is the new ration card containing only Defendant No. 2’s name.”

Now we have a complete story that builds our case chronologically.

Notice how we had to guide ChatGPT through multiple iterations to get professional quality.

This is the reality of working with ChatGPT – it requires patience and specific instructions.

Step 6: Responding to all allegations in the plaint

“Now comes the really tedious part, responding to EVERY paragraph of the plaint.

But here is where most juniors go wrong. They ask AI to figure out what to say.

That is a wrong approach.

You tell ChatGPT exactly what defence approach to take for each paragraph, then ask it to draft properly.”

Therefore, I gave the following prompt to ChatGPT:

“I need responses to ALL 17 paragraphs of the plaint. Here is my defence strategy for each paragraph – draft detailed responses using the format “With reference to para X of the plaint, the Defendant No.2…:

Para 1: Admit the relationship but deny the plaintiff has any rights as the father abandoned them

Para 2: Deny illegal occupation – the defendant has lawful rights under the family arrangement

Para 3: Admit rent receipts in the deceased’s name but the defendant is rightfully paying rent

Para 4: Deny plaintiff derives any rights as the father abandoned his rights, put to strict proof of documents

Para 5: Vehemently deny plaintiff paying rent – defendant has been paying for 30 years, plaintiff’s recent payments were surreptitious

Para 6: Admit Borivali purchase but deny family resided in both places – they permanently shifted leaving the defendant in the suit premises

Para 7: Vehemently deny breaking any lock – the defendant has continuously resided since 1985, no question of breaking the lock

Para 8: Deny threatening plaintiff – simply informed him he has no rights when he unlawfully interfered

Para 9: Not aware of legal notice, put plaintiff to strict proof, defendant filed a complaint with MCGM about the plaintiff’s interference

Para 10: Deny apprehensions – defendant has no intention of creating third party rights, this is her only home

Para 11: Deny cause of action arose in 2023 – defendant in continuous possession since 1985, plaintiff’s father abandoned rights in 1998

Para 12: Suit not properly valued as it seeks possession – should pay ad valorem court fees on market value

Para 13: No cause of action in favour of the plaintiff, but if any arose it was in 1995 on the original tenant’s death – clearly barred by limitation

Para 14: Repeat improper valuation

Para 15: Put the plaintiff to strict proof of all documents

Para 16: No knowledge, put to strict proof

Para 17: Deny plaintiff entitled to any reliefs – no right, title or interest”

You can see the paragraph-wise denial that ChatGPT has responded based on the prompt given.

You can see all 17 paragraphs covered with detailed, strategic responses.

This is what professional drafting looks like – every paragraph advances our case while addressing the allegations.

Step 7: The human touch

Now, here is something AI cannot do for you automatically: the emotional positioning.

We need to remind the court that our client is a 68-year-old widow with limited income, while the plaintiff is comfortably settled in his father’s ownership flat.”

So I give the following prompt to ChatGPT:

“Add a concluding section that positions our client sympathetically – mention she is 68 years old widow with limited income, has been exclusively residing since marriage in 1985, the plaintiff never lived in suit premises and stays in ownership Borivali flat, and conclude that plaintiff filed suit out of vengeance and greed having no legitimate rights”

Based on my prompt, ChatGPT generated the following result:

“The Defendant No.2 states that she is an old lady of 68 years of age with limited income and the Defendant No. 2 has been exclusively staying in the suit premises right from the day the Defendant No. 2 married into the family in 1985. Today, the Defendant No. 2 alone is residing in the suit premises while the Plaintiff is staying in the ownership flat at Borivali which was purchased by his father.

In the premises aforesaid, the Plaintiff has as such no right, title, interest or claim in the suit premises but the Plaintiff has filed the present suit out of vengeance and greed and is liable to be dismissed.”

This creates the right emotional framework.

Notice how we position our client as vulnerable and deserving, while the plaintiff appears opportunistic.

Now we ask ChatGPT to put it all together with proper numbering and cause title as per the court’s format and ChatGPT generates the final draft.

The next step is to manually edit it and make it as per your taste.

I have manually edited the draft in red.

IN THE BOMBAY CITY CIVIL COURT AT BOMBAY

SUIT NO. ______ OF 2025

Arjun Pradeep Sharma

…Plaintiff

Versus

1. The Brihan Mumbai Mahanagar Palika,
Estate Department,
“E” Ward, Mumbai 400011

2. Rekha Mohan Sharma

…Defendant No.1

…Defendant No.2

WRITTEN STATEMENT OF DEFENDANT NO. 2 ABOVENAMED

At the outset, the Defendant No. 2 submits that the Suit is misconceived and not maintainable inasmuch as the Plaintiff’s father Suresh Pradeep Sharma had abandoned all rights in the suit premises by executing a family arrangement ion 15.11.1998 and taking separate accommodation at Borivali, thereby cutting off any derivative rights that the Plaintiff might claim, and the same is liable to be dismissed with costs.
At the further outset, the Defendant No. 2 submits that the suit does not disclose any cause of action against Defendant No. 2 as the Plaintiff derives his alleged rights through his father Suresh Pradeep Sharma, who had abandoned all his rights in the suit premises by executing a family arrangement ion 15.11.1998 and taking separate accommodation at Borivali, and since the Plaintiff’s father himself had no subsisting rights after 1998, the Plaintiff cannot claim any derivative rights, with the result that the suit is liable to be dismissed for want of cause of action.
At the further outset, the Defendant No. 2 submits that the Plaintiff has suppressed the material facts from this Hon’ble Court, particularly the family arrangement dated 15.11.1998 whereby all legal heirs including the Plaintiff’s father had consented to Defendant No. 2 continuing in the premises, and the Plaintiff has come out with false statements and ulterior motives to grab the suit premises in which the Plaintiff has no right or interest whatsoever, with the result that the suit is liable to be dismissed with cost.
At the further outset, the Defendant No. 2 submits that the present suit is hopelessly barred by limitation as any cause of action, if any, would have arisen upon the death of the original tenant ion 15.03.1995, and the suit filed after 30 years in 2025 is clearly beyond the prescribed period of limitation and is liable to be dismissed on this ground alone.
At the further outset, the Defendant No. 2 submits that the suit is bad for non-joinder of necessary parties as all legal heirs who were parties to the family arrangement have not been impleaded, and also suffers from misjoinder of parties as Defendant No. 1 has no role in determining succession rights between private parties, and is liable to be dismissed with cost for misjoinder and non-joinder of parties.
The aforesaid submissions are without prejudice to one another and without prejudice to what is stated hereinafter.
The Defendant No.2 submits that as far as the suit premises are concerned, the true facts are as under:

(i) Originally one late Pradeep Mohan Sharma in whose name the rent receipts presently stands was the tenant of the said suit premises. The said Mr. Pradeep Mohan Sharma was the father-in-law of Defendant No. 2 and expired on ~~or about~~ 15th March 1995. After his death, his widow Kavita Pradeep Sharma continued to reside in the suit premises along with Defendant No. 2, who had been residing there since her marriage into the family in 1985. The said Kavita Pradeep Sharma also expired in the year 2020. A copy of the death certificate of Pradeep Mohan Sharma is hereto annexed and marked Ex. “A”.

(iii) After Suresh Pradeep Sharma went to reside at Borivali, two sons were born to him, namely Vikash Suresh Sharma (elder son) and thereafter the Plaintiff Arjun Pradeep Sharma. Both sons were born and brought up at Borivali and never stayed in the suit premises. This shows that the Plaintiff had never resided at any time in the suit premises after his birth.

(vi) The Defendant No. 2 further submits that she has been paying the rent of the suit premises and all outgoings along with her deceased family members. However, recently, for the first time in 2023, behind the back of Defendant No. 2, the Plaintiff attempted to interfere with the premises when Defendant No. 2 had temporarily gone to her sister’s place for medical treatment. Prior to 2023, right from 1995, the Plaintiff had never bothered to visit or show any interest in the suit premises. Hereto annexed and marked Ex. “D” is the new ration card containing only Defendant No. 2’s name.

With reference to para 1 of the plaint, the Defendant No. 2 admits that the Plaintiff is the grandson of late Pradeep Mohan Sharma but denies that he has any legitimate rights in the suit premises. The Defendant No. 2 has been occupying the said premises right from her marriage in 1985 and the Defendant No. 2 has been in exclusive use, occupation and possession thereof along with her deceased husband and mother-in-law. The Plaintiff’s father Suresh Pradeep Sharma, had abandoned his rights by taking separate accommodation at Borivali in 1998.
With reference to para 2 of the plaint, the relationship is truly described; however, it is absolutely false that Defendant No. 2 is illegally occupying the premises without any legal right. The Defendant No. 2 repeats that the Defendant No. 2 is rightfully in use, occupation and possession of the said premises since last more than 35 years as per family arrangement and neither the Plaintiff nor his father has stayed in the suit premises after 1998.
With reference to para 3 of the plaint, it is true that the rent receipt stands in the name of Mr. Pradeep Mohan Sharma who was the father-in-law of Defendant No. 2 and the Defendant No. 2 was staying in the said premises with the father-in-law and mother-in-law of Defendant No. 2 after marriage and after the death of her husband and mother-in-law as stated above, the Defendant No. 2 is residing alone in the said premises and the same is in exclusive possession of Defendant No. 2.
With reference to para 4 of the plaint, the Defendant No. 2 admits the relationship but denies that the Plaintiff derives any rights through his father, as the father himself had abandoned his rights by taking separate accommodation. The Defendant No. 2 puts the Plaintiff to strict proof of the documents mentioned as Exhibit “B” Colly.
With reference to para 5 of the plaint, the Defendant No. 2 vehemently denies that the Plaintiff has been paying the rent of the said premises and in this behalf the Defendant No. 2 repeats what is stated hereinabove, that the rent since about last 30 years has been paid by Defendant No. 2 along with her deceased family members. However, behind the back of Defendant No. 2, the Plaintiff surreptitiously attempted to pay rent for a few months in 2023 to which the Defendant No. 2 has objected before Defendant No. 1. In any case, such alleged payment of rent behind the back of Defendant No. 2 does not create any right or interest in favour of the Plaintiff. The Plaintiff has been staying at his father’s flat at Borivali, which was purchased on an ownership basis. Copies of rent receipts and utility bills paid by Defendant No. 2 for the last 10 years are hereto annexed and marked Ex. “E” Colly.
With reference to para 6 of the plaint, the Defendant No. 2 admits that the Plaintiff’s father purchased the flat at Borivali in 1998, however, he denies that the family used to reside at both places. The Defendant No. 2 submits that after purchasing the Borivali flat, the Plaintiff’s father with his entire family permanently shifted to Borivali, leaving the suit premises and thereafter it is the Defendant No. 2 who has been staying in the suit premises along with her husband and mother-in-law. The Defendant No. 2 denies any temporary closure of the premises as the same was continuously occupied by Defendant No. 2 and her family members. With regard to the alleged serious heart condition of Kavita Sharma, the same has nothing to do with the subject matter of the suit and in any case, such alleged illness did not result in the closure of the premises.
With reference to para 7 of the plaint, the Defendant No. 2 vehemently denies the allegations made therein and the Defendant No. 2 denies that the Defendant No. 2 broke open any lock of said premises as falsely alleged. The said allegations are absolutely false and baseless. The Defendant No. 2 has been continuously residing in the premises since 1985 and there is no question of Defendant No. 2 breaking any lock. There is no question of the Plaintiff even having any right to put any lock on the premises, as the Plaintiff has no concern whatsoever with the suit premises and has never resided therein.
With reference to para 8 of the plaint, the Defendant No. 2 denies that the Defendant No. 2 threatened the Plaintiff in clear and unambiguous terms as falsely alleged. The Defendant No. 2 denies that the Defendant No. 2 has given any threat of any nature whatsoever to the Plaintiff. The Defendant No. 2 submits that when the Plaintiff unlawfully attempted to interfere with the premises, Defendant No. 2 simply informed him that he had no rights in the premises and requested him not to create any disturbance.
With reference to para 9 of the plaint, the Defendant No. 2 denies the allegations made therein. The Defendant No. 2 is not aware of and does not admit any allegations with regard to the legal notice dated 8th April 2023, as allegedly served and the Defendant No. 2 puts the Plaintiff to the strict proof thereof. The Defendant No. 2 denies receiving any such legal notice and puts the Plaintiff to prove the service of the same. The Defendant No. 2 has objected to the attempted interference by the Plaintiff and has filed a complaint with Defendant No. 1 regarding the same. A copy of the complaint dated 15th May 2023 filed by Defendant No. 2 with Brihan Mumbai Mahanagar Palika is hereto annexed and marked Ex. “F”.
With reference to para 10 of the plaint, the apprehensions set out therein are absolutely baseless, imaginary and falsely made and the Defendant No. 2 hereby states that the Defendant No. 2 has no intention of creating third party rights as this is the only premise for residence and roof over head of Defendant No. 2 and the Defendant No. 2 cannot afford to part with possession of the suit premises. The Defendant No. 2 has been paying rent regularly and has no intention of transferring tenancy.
With reference to para 11 of the plaint, the Defendant No. 2 denies that any cause of action arose in 2023 as falsely alleged. The Defendant No. 2 has been in continuous possession since 1985 and the Plaintiff has no right to interfere with the same. The Defendant No. 2 repeats that the Plaintiff’s father had abandoned his rights in 1998 itself.
With reference to para 12 of the plaint, the Defendant No. 2 submits that the suit is not properly valued as the suit is for possession of the suit premises and as such the Plaintiff ought to pay the ad valorem court fees on the market value of the premises. The Defendant No. 2 repeats and confirms what is stated hereinabove regarding jurisdiction.
With reference to para 13 of the plaint, the Defendant No. 2 submits that there is no cause of action in favour of the Plaintiff in 2023 or at any other time, and therefore the question of limitation does not arise. However, if any cause of action is held to have arisen in favour of the Plaintiff, the same would have arisen in 1995 upon the death of the original tenant, and the suit filed in 2025 is clearly barred by limitation.
With reference to para 14 of the plaint, the Defendant No. 2 repeats what is stated in para 212 hereinabove regarding improper valuation.
With reference to para 15 of the plaint, the Defendant No. 2 puts the Plaintiff to strict proof of all documents mentioned and reserves the right to object to the same at the time of evidence.
With reference to para 16 of the plaint, the Defendant No. 2 has no knowledge of the same, and the Plaintiff is put to strict proof thereof.
With reference to para 17 of the plaint, the Defendant No. 2 denies that the Plaintiff is entitled to any reliefs claimed therein. The Plaintiff has no right, title, or interest in the suit premises, and in view thereof, the suit is liable to be dismissed with costs.
The Defendant No. 2 states that she is an old lady of 68 years of age with limited income and the Defendant No. 2 has been exclusively staying in the suit premises right from the day the Defendant No. 2 married into the family in 1985. Today, the Defendant No. 2 alone is residing in the suit premises while the Plaintiff is staying in the ownership flat at Borivali which was purchased by his father.
In the premises aforesaid, the Plaintiff has ~~as such~~ no right, title, interest or claim in the suit premises ~~but the Plaintiff has filed the present suit out of vengeance and greed~~ and the suit is without merit and is liable to be dismissed with costs.

Conclusion

AI revolutionises written statement drafting by summarising facts, structuring defences, and generating detailed responses swiftly, as demonstrated in Rekha’s case.

We saw how tools like ChatGPT can streamline repetitive tasks, from breaking down allegations paragraph-wise to crafting preliminary objections, but their outputs require careful refinement to align with legal standards under the Code of Civil Procedure,1908 and court expectations.

The legal profession is evolving, and AI is here to stay. Use it wisely, and it will make you a better, more efficient lawyer. Use it carelessly, and it might just embarrass you in front of your senior, judge, or client that you are trying to impress.

So the next time you have to draft a written statement, you now have a powerful ally that can help you draft faster, think more systematically, and present your client’s case with the precision and persuasiveness that great lawyers have always provided.

Frequently asked questions

1. How does AI help in drafting a written statement?

AI tools like ChatGPT streamline drafting by summarising facts, structuring defences, listing allegations, and generating detailed responses quickly. They save time on repetitive tasks, allowing lawyers to focus on strategy and refinement. However, AI requires precise prompts and iterative guidance to produce professional, court-ready drafts that align with legal standards and specific case facts.

2. What mistakes should I avoid when using AI to draft a written statement?

The common mistakes include:

Using generic prompts like “Draft a written statement,” which produces vague outputs.
Dumping the entire plaint into AI without summarising or strategising.
Skipping client fact-checking that leads to inaccurate defences.
Not refining AI outputs to ensure legal precision, court format compliance, and emotional positioning.
Failing to respond to each plaint paragraph specifically.

3. What happens if I fail to address a specific allegation in the written statement?

Under Order VIII, Rule 5 of the Code of Civil Procedure,1908, any allegation in the plaint not specifically denied or addressed is deemed admitted by the defendant, except for claims related to damages. This can weaken your defence, as the court may proceed assuming those allegations are true. To avoid this, respond to each paragraph of the plaint clearly, using AI to ensure no allegation is missed, and deny or clarify with specific facts.

4. Can I amend a written statement after filing it?

Yes, under Order VIII, Rule 8 of the Code of Civil Procedure,1908, you can amend a written statement if new facts arise after filing or with court permission. However, amendments are subject to the court’s discretion and may require a formal application explaining the need.

5. How do I use AI to ensure my written statement is persuasive?

To make your written statement persuasive, guide AI with prompts that emphasise both legal and emotional elements. For example, prompt AI to “highlight the defendant’s vulnerability, like being a 68-year-old widow, while denying allegations with evidence.” Refine AI outputs to balance factual denials, legal objections, and a compelling narrative that positions your client sympathetically, ensuring alignment with court expectations.