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Purpose of a Reply to a Statement of Defence

Purpose of pleadings

The legal effect of a Reply being inconsistent with the averments pleaded in the Statement of Claim

The principle that a party is bound by his pleadings

The principle that only facts and not evidence are pleaded

The rule that where a party leads inconsistent evidence with the said party’s pleadings, the party’s evidence as a whole cannot be relied on

whether or not evidence led contrary to a party's pleadings will jeopardize a party's case

Whether or not failure to file a reply to a statement of defence amounts to an admission of facts pleaded in the statement of defence

Whether or not pleadings not subjected to cross-examination can be relied on as the true state of affairs

Whether the court must consider evidence in respect of a fact not pleaded, where no objection is raised against it

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