Defence to Suit for Redemption

1. The plaintiff’s right to redeem is barred by article ………of the second schedule to the {See now the Indian Limitation Act, 1908 (9 of 1908).} Indian Limitation Act, 1877 (15 of 1877).
2. The plaintiff transferred all interest in the property to A.B.
3. The defendant, by a document dated the …………day of ……………………..transferred all his interest in the mortgage-debt and property comprised in the mortgage to AB
4. The defendant never took possession of the mortgaged property, or received the rents thereof.

(If the defendant admits possession for a time only, he should state the time and deny possession beyond what he admits.)