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3. The applicant/defendant filed written statement stating therein that there is no cause of action in favour of plaintiff. The plaintiff has forged and fabricated antedated sale documents. It is denied that the suit property was purchased by the plaintiff through sale document dated 28.01.2014. the 1/4 Vipin Kumar vs. Surender Shekhawat defendant no.2 has purchased the suit property by virtue of title document dated 15.02.2014 which were duly registered with notorised on 04.03.2014. The present application has been moved by the defendant/applicant on the ground that previous counsel has not mentioned the complete facts in proper manner in the WS and want to amend the WS, by first of all adding preliminary objection regarding the date of defendant's possession over suit property. The applicant/defendant want to add one line in para 6 of the preliminary objection. The applicant/defendant want to make amendments in the last line of the para 2 of reply on merits regarding the date of defendant's possession over suit property.