(1) If the defendant serves a notice of defence, and the plaintiff intends at the hearing to prove or establish any fact or matter which—
(a) makes the defence stated in the notice of defence not maintainable; or
(b) if not stated specifically in the notice, might take the defendant by surprise; or
(c) raises questions of fact not arising out of the notice—
the plaintiff must serve and file a reply.
(2) A reply must be divided into paragraphs numbered consecutively, and each fact or matter stated so far as practicable must be contained in a separate paragraph.
(3) A reply must be served and filed within 21 days after service of the notice of defence.