Rule 8.General rules of pleading

Section A tells you what a claim for relief needs — whether it is a complaint, a counterclaim, a cross-claim, or a third-party claim: a short, plain statement showing you are entitled to relief, plus a demand for the relief you want. You can ask for alternative or multiple kinds of relief in the same pleading. One notable Indiana limit: if you are suing for personal injury, wrongful death, or punitive damages, the demand cannot name a dollar figure — you ask for damages without putting a number on them.

Section B governs how a party responds to allegations. The response has to admit or deny each one in short, plain terms. A pleader acting in good faith can issue a general denial covering everything, subject to the rule requiring reasonable pre-filing investigation. Short of that, a party can specifically deny particular paragraphs, or generally deny everything except the parts it expressly admits — and a statement of insufficient knowledge to form a belief counts as a denial. A partial denial has to say what part is true and deny the rest, and every denial has to address the substance of what is being denied rather than dodge it on a technicality. This denial framework does not apply to uncontested divorce cases or to answers clerks or guardians ad litem are required to file.

Section C lists defenses a responding party must raise affirmatively — and prove — rather than merely deny: accord and satisfaction, arbitration and award, discharge in bankruptcy, duress, estoppel, failure of consideration, fraud, illegality, injury by a fellow servant, laches, license, payment, release, res judicata, statute of frauds, statute of limitations, waiver, lack of subject-matter jurisdiction, lack of personal jurisdiction, improper venue, insufficient process or service of process, another case pending in an Indiana state court, and any other matter amounting to an avoidance or affirmative defense. If a party mislabels a defense as a counterclaim, or a counterclaim as a defense, the court treats it as if it had been labeled correctly. Section D sets the consequence for silence: an allegation that calls for a response is treated as admitted if nobody denies it — except a claimed dollar amount of damages is never automatically admitted this way — while an allegation that neither calls for nor allows a response is treated as denied.

Section E asks for plain, direct pleadings — no required form, no legal fictions to observe. A party can plead alternative or even inconsistent claims and defenses in the same pleading, in one count or in separate ones, and an alternative statement that is not good on its own does not sink a pleading if another one is. Motions or pleadings aimed at multiple paragraphs, or filed by multiple parties, are treated as separate motions or pleadings against each paragraph or party, so a problem with one does not take down the rest. Section F closes the rule with an instruction to judges: read every pleading in a way that serves substantial justice, favors a decision on the merits, and steers around fights over procedural form.