2. The said R. Raja Rao assigned the promissory note date 12.6.1978 to the plaintiff, for a valid consideration of Rs. 60,000/- (Rupees Sixty Thousand only).
3. The plaintiff informed the defendant of the said assignment by a notice dated 18.8.1980 to the plaintiff. Although the plaintiff demanded the defendant to discharge the debt and though a notice had been given, the defendant failed to discharge the debt. Hence, this suit.
1. The Defendant denies all the averments of the Plaint except those which are specifically admitted.
2. The Defendant submits that the Plaintiff is not the assignee for consideration, and that the assignment is pleaded only to obviate the plea of the Defendant. The suit as laid by the Plaintiff is bad and is not maintainable.
3. The Defendant submits that he does not know Sri R. Raja Rao. The Defendant never executed the suit pronote. The suit pronote is rent forgery. Further the suit pronote is not supported by consideration. Added to it, the Defendant submits that there are patent material alterations in the Suit pronote invalidating the same. Even on this count, the suit is bad.
4. The Defendant therefore submits that the suit be dismissed with exemplary costs.