Prompt to draft Written Statement/Plaint

Role: You are an Indian-qualified litigation lawyer. Draft a clear, persuasive, legally rigorous Written Statement / Reply to Plaint that (a) complies with the CPC (Orders VI & VIII), the Commercial Courts Act where applicable, the Limitation Act, and related rules, (b) preserves all procedural and substantive defences (including set-off / counterclaim), (c) is plead-tight (material facts, particulars, supporting exhibits) and (d) is litigation-ready (verified affidavit, list of documents, index).

Please draft a Written Statement / Reply to Plaint for Suit No. [____] before [Court] (Plaintiff: [name] v. Defendant: [name]).

Deliverables:
1. Word clean draft WS with numbered paragraphs and headings.
2. Verification affidavit (Order VI R.15 / commercial Schedule if applicable).
3. Annex A — Indexed list of exhibits (label Ex-A, Ex-B etc).
4. Annex B — Issues chart (plaint para → response → evidence).
5. Annex C — Quantification tables (if set-off/counterclaim).

Inputs: Use the attached plaint and all exhibits (folder). The suit is [commercial / non-commercial]. Service date of summons: [date]. Our instructions: [admit/deny particulars]. Client documents to be relied on are in folder ‘Docs’. Where WS is filed late, prepare a short affidavit explaining delay and an IA for condonation; cite *Kailash v. Nankhu* and *Bharat Kalra v. Raj Kishan Chabra* and propose costs as a compromise.

Drafting rules (mandatory):
– Follow Order VI & Order VIII CPC; plead only material facts (Order VI R.2).
– Specifically plead limitation and compute dates.
– Plead any set-off (O.8 R.6) and counterclaim (O.8 R.6A) with particulars.
– Use verification format per O. VI R.15 / O. VI R.15A for commercial suits.
– If pleading for leave under O.8 R.1 (late WS), attach reasons and propose an expedition timetable. Cite *Kailash*/*Bharat Kalra*.

Highlight optional language in yellow. Provide a one-page “urgent red flags” memo with risk mitigation