(l) The opposite party may, and, if so required by the court, shall, at or bofore the first hearing or within such time as the court may perrnit present written statement of his defence along rvith the documents on which he relies and an accurate list thereof in form-2.
(2) Every such written statement shall be verified in the same manner as a pleading in a civil court and shall be acco,xpanied by two copies thereof.
(3) In every written statement submitted under sub-rule (l) the opposite parfy shall deal specifically with each allocation of fact alleged by thc applicant, of which he admits or does not adnrit or denies the truth.
10 The written statemcnt nrust also contain all matters which show that the application is not maintainable and all such grounds of defence as, if noi raised, rvould be Iikely to take the applicant by surprisc or would raise issues ol firct not arising out of the application as for instance, fraud, undue inJluencc or cocrc lon, release, paymcnt, performance or facts showing illegalrry of the transaction'