ABSTRACT

The defendant must set out all the facts on which he relies to dispute the claim, in as short a form as is practicable. In particular, by r 10.5 the defence must state: (a) which, if any, of the claimant’s allegations are admitted, in which event they will no

longer be in issue; (b) which, if any, are denied, in which event the defendant must state reasons for the

denial, and must state any alternative version of the facts asserted by him; and (c) which, if any, are neither admitted nor denied, because the defendant does not know

whether they are true, in which event the claimant will be required to prove those facts (for example, ‘It is not admitted that the claimant sustained injuries or was put to loss as alleged in paragraph 4 of the particulars of claim or at all’).