Under rule 166(4) of the UCPR (Qld), a denial must be accompanied by a direct explanation for the party's belief that the allegation is untrue — not merely 'grounds for the denial'. The direct explanation is a subjective exposition of the party's rationale for joining issue, which fulfils the dual function of compelling early disclosure and requiring the party to formulate its reason for denying. The direct explanation itself is not a material fact under rule 149, but may necessitate the pleading of material facts. The formula 'denied on the grounds that' followed by factual matters, without clearly articulating why the defendant believes the allegation to be untrue, does not comply with rule 166(4).
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