2.4 The Rejoinder (Pratiuttar Patra)

The purpose: the plaintiff's reply to the written statement — the reply's reply, confined to the defendant's new matters (the additional facts and the preliminary objections), not a re-arguing of the complaint. The anatomy: the cause-title; the replies to the new pleas (admit/deny/explain, paragraph-wise); the additional explanations the new facts require; the verification. Craft rules: the rejoinder is not the second complaint — new causes of action cannot be smuggled in; the tone measured (the denial is not the abuse); the brevity earned by confining to what the reply actually added.