Ontario Superior Court of Justice Trials

How to Draft a Reply

This article is an abbreviated version of a chapter in Civil Litigation D.I.Y., a litigation book on how to value, assemble and settle lawsuits.

The book does a deep dive into how to draft a reply. The book and this article are legal information, not legal advice.

A reply is not a mandatory pleading. All allegations in the defence are automatically denied as as starting point. A reply is necessary where the plaintiff wants to set out a version of facts that is different than the defence and not already alleged in the statement of claim. A reply is also necessary to avoid surprising the other side.

If proceeding with a reply, what precedent or template are you using for your reply? You should be able to re-use your statement of claim, typing in the Court file no. or you can download a professional formatted reply, including a backsheet from our Court form library by clicking here.

Like anything you write, it is important to review and edit. With drafting complete, a reply is ready to be served and filed.


For a more detailed discussion of how to write a reply, please take a look at the corresponding chapter in Civil Litigation D.I.Y. called “How to Draft a Reply”.

We are regularly consulted on draft pleadings, including replies. Please feel free to set up a trial consultation to discuss further.

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