An answer shall state in short and plain terms the pleader’s defenses to each claim asserted and shall admit or deny the allegations upon which the adversary relies. A physician defending against a malpractice claim who admits to treating the plaintiff must include in his or her answer the field of medicine in which he or she specialized at that time, if any, and whether his or her treatment of the plaintiff involved that specialty. A pleader who is without knowledge or information sufficient to form a belief as to the truth of an allegation shall so state and, except as otherwise provided by R. 4:64-1(c) (foreclosure actions), this shall have the effect of a denial. Denials shall fairly meet the substance of the allegations denied. A pleader who intends in good faith to deny only a part or a qualification of an allegation shall specify so much of it as is true and material and deny only the remainder. The pleader may not generally deny all the allegations but shall make the denials as specific denials of designated allegations or paragraphs.
Rule 4:5-3.Answer; Defenses; Form of Denials
Last amended September 4, 2012 · Current through June 18, 2026 · Last verified July 7, 2026
In one sentenceRule 4:5-3 governs the answer, requiring the pleader to state defenses in short and plain terms, admit or deny each allegation (with a want-of-knowledge statement operating as a denial), and make denials specific rather than general.
Full Text of Rule 4:5-3
Amendment History
New Jersey publishes each rule’s amendment record in a “History” note beneath the rule. It is reproduced verbatim below; the “R.R.” citations refer to the former Revised Rules numbering the current rules replaced.
Source - R.R. 4:8-2; amended July 13, 1994 to be effective September 1, 1994; amended August 1, 2006 to be effective September 1, 2006; amended July 19, 2012 to be effective September 4, 2012.
Plain-English Summary
The answer joins issue. Under this rule a defendant must state defenses to each claim in short and plain terms and must admit or deny the allegations the other side relies on. A pleader who lacks knowledge or information sufficient to form a belief says so, and that statement has the effect of a denial.
Denials have to be honest and precise. They must meet the substance of what is denied, and a pleader who means to deny only part of an allegation must admit the true and material part and deny the rest. A blanket denial of everything is not allowed; denials must be specific to designated allegations or paragraphs. The rule also requires a physician answering a malpractice claim to state the field of medicine involved.
Frequently Asked Questions
How must a defendant respond to a complaint?
By stating defenses in short and plain terms and admitting or denying each allegation. A pleader without sufficient knowledge to form a belief says so, and that operates as a denial.
Can a defendant deny the whole complaint at once?
No. General denials of everything are not allowed. Denials must be specific to designated allegations or paragraphs and must meet the substance of what is denied.
Source & verification. The rule text and amendment history are reproduced verbatim from the
official New Jersey Rules of Court (N.J. Ct. R. 4:5-3). Prescribed by the Supreme Court of New Jersey (N.J. Const. art. VI, § 2, ¶ 3). The plain-English summary is original and written by us. Last verified July 7, 2026. ·
Official source
Also known as: answerdenialsadmit or denywant of knowledgeform of denialsresponding to a complaint