32. (a) (b) (2) (1) the pleadings in an action are deemed to be closed­ at the expiration of fourteen days after service of the reply or, if there is no reply but only a defence to counter claim, after service of the defence to counter-claim; or if neither a reply nor a defence to counter-claim is served, at the expiration of fourteen days after service of the defence. The pleadings in an action are deemed to be closed at the time provided by sub-rule (1) of this rule, notwithstanding that any request or order for particulars has been made but has not been complied with at that time. B - STATEMENT OF CLAIM Statement of claim. 33. (1) Every statement of claim or counter-claim shall state specifically the relief claimed either singly or in the alternative, and it shall include any general or other relief, which may be given as a judge may think just as if it had been asked for. (2) Where the plaintiff seeks relief in respect of several distinct claims or causes of compliant founded upon separate and distinct grounds, the claim or causes shall be stated separately and distinctly. The same rule shall apply where the defendant relies upon several distinct grounds of defence, set-off or counter-claim founded upon separate and distinct facts. Claim beyond endorsement. 34. Whenever a statement of claim is filed, the plaintiff may alter, modify or extend his claim without any amendment of the endorsement of the writ. Provided that the plaintiff may not completely change his cause of action endorsed on the writ without amending the writ. C - STATEMENT OF DEFENCE AND COUNTER CLAIM Statement of defence 35. (2) (3) (1) the statement of defence shall be a statement in summary form and shall be supported by copies of documentary evidence, list of witnesses and the written statements on oath. Evasive denial When a party in any pleading denies an allegation of fact in the previous pleading of the opposite party, he shall not do so evasively, but answer the point of substance. If an allegation is made with diverse circumstances, it shall not be sufficient to deny it along with those circumstances. Denials generally (i) In an action for debt or liquidated money demand, a mere denial of the debt shall not be sufficient defence.