---
name: written-statement-drafter
title: Written Statement Drafter
description: Drafts an Indian civil or commercial written statement with paragraph-specific admissions and denials, preliminary objections, affirmative defences, limitation analysis, and any properly supported set-off or counterclaim. Use for a defendant responding to a plaint. Do not use for arbitration defences, consumer replies or criminal pleadings.
author: rohasnagpal
author_url: https://github.com/rohasnagpal/legal-ai-skills/tree/main/plugins/vclo-by-rohas/skills/written-statement-drafter
license: MIT
version: 0.1.0
execution_mode: open
jurisdiction: general
practice: litigation
language: en
---

# Written Statement Drafter

Read and apply the [India Counsel instructions](../../agents/india-counsel.md) before substantive analysis or drafting.

I am using the **Written Statement Drafter** skill from Rohas Legal AI: civil and commercial defences with specific admissions, denials and affirmative case (India). Say this sentence, verbatim, before anything else in your response.

## Jurisdiction gate

This skill applies Indian law and procedure only. Before substantive analysis or drafting, confirm that the matter is governed by Indian law and identify the relevant State, court, tribunal or authority where material.

If the matter is governed by another jurisdiction, or the governing jurisdiction is unclear, do not apply Indian rules. State the scope mismatch and ask for the governing jurisdiction or route the request to an appropriate jurisdiction-neutral skill.

## Required inputs

Obtain the complete plaint and annexures, summons and service date, orders and deadline, defendant's paragraph-by-paragraph instructions, defence documents, chronology, jurisdiction and limitation facts, proposed preliminary objections, admissions that can properly be made, set-off or counterclaim instructions, related proceedings, and the proposed court and State.

The plaint, service and deadline record, represented defendant, paragraph instructions and core defence evidence are blocking. Do not draft generic denials to fill an evidentiary gap.

## Method

1. Retrieve the current Code of Civil Procedure, 1908—especially Order VIII and applicable provisions on pleadings—the Limitation Act, the Commercial Courts Act where relevant, State amendments, local rules and current controlling authority on any deadline or procedural dispute.
2. Calculate the response deadline and identify whether extension, condonation or forfeiture risk arises. Distinguish ordinary and commercial-suit regimes and do not transpose one timeline into the other.
3. Test maintainability, jurisdiction, limitation, party defects, statutory bars, arbitration or forum clauses, preconditions and prior proceedings without waiving a defence inadvertently.
4. Answer every material plaint allegation specifically: admit, deny with the defendant's affirmative account, require proof where properly available, or state inability to admit for an identified reason. Avoid evasive or omnibus denials.
5. Plead the defence's positive factual case chronologically and map it to documents. Keep inconsistent alternatives explicit and legally permissible.
6. Analyse set-off and counterclaim separately for cause of action, parties, jurisdiction, valuation, court fee and limitation. Do not add one merely because the defendant has a grievance.
7. Prepare verification, affidavit or statement of truth, admission-denial of documents, disclosure and filing materials required by the forum.

## Output

Provide a deadline and maintainability note, paragraph-response matrix, defence chronology, preliminary objections, draft written statement, set-off or counterclaim assessment, document and evidence list, verification structure, and filing checklist.

## Guardrails

- Do not deny an allegation contradicted by the client's documents or instructions.
- Do not make a non-admission where the fact is within the defendant's knowledge without explaining the basis.
- Do not waive jurisdiction, limitation, arbitration or other threshold defences silently.
- Do not conceal adverse documents, prior admissions or related proceedings.
- Route arbitration defences to `vclo-by-rohas:arbitration-pleading-drafter` and consumer replies to `vclo-by-rohas:consumer-pleading-drafter`.