Section 22(3) in Bihar Employees Insurance Courts Rules, 1952
(3)In every written statement submitted under sub-rule (1) the opposite party shall deal specifically with each allegation of fact alleged by the applicant, or which he admits or does not admit or denies the truth. The written statement must also contain all matters which show that of the application is not maintainable and all such grounds of defence as, if not raised, would be likely to take the applicant by surprise or would raise issues of fact not arising out of the application as, for instance, fraud, undue influence or coercion, release, payment, performance or facts showing illegality of the transaction.
