(1)  Subject to rule 228(2) , in any pleading subsequent to a defence, a party may join issue on an allegation of fact alleged in the immediately preceding pleading by pleading the joinder of issue on any particular paragraph of, or allegation in, that preceding pleading.

(2)  A joinder of issue is a denial of the fact or facts alleged in the paragraph or of the particular allegation on which issue is joined.

(3)  If a reply contains both a reply to a defence and a defence to a counterclaim, this rule applies only to –

(a) an allegation of fact in the defence; and

(b) any allegation of fact in the counterclaim that is only a repetition of an allegation in the defence on which issue is joined.