The plaintiff has filed a reply statement along with the application to receive the same. The following pleas are found in the affidavit:

a. The written statement contains the factual inaccuracies and these have been deliberately made for reasons best known to the defendants. In view of these discrepancies, it is necessary for the applicant/plaintiff to file a reply statement to the written statement of the 1st and 2nd defendants for a more and detailed understanding of the facts in disputes.

b. Even if the reply statement is received, no loss or hardship would be caused to the defendants.

2. In the counter filed by the defendants 1 and 2 it is alleged that the plaintiff has taken out this application to get over the legal bar. On the eve of commencement of trial, an application for amendment may not be permissible. It is an attempt to improve upon the pleadings of the plaintiff to fill up the latches, after seeing the written statement. The plaintiff virtually attempting to substitute the plaint, which is impermissible. One of the three documents, produced along with the reply statement is purported acknowledgment of liability dated 06.08.2002. It has been gotten up afte