1.      That the present application is not maintainable in the present form.

2.      That the present application is not maintainable as the Defendant no.1 has suppressed the relevant facts. Guilty of suppression of true facts and has not come before the Hon’ble Court with clean hands.

3.      That the present application is not maintainable as deliberately the defendant no.1 has filed the false application which is not meaning at all.

4.      That the present application is not maintainable as the defendant no. 1 along with other defendants came at the house of the plaintiffs at XXXX. The defendants told the plaintiffs that XXXX was a partner with eight other persons in the firm XXX, having head office at XXXXXXXXXX and they also handed over to the plaintiffs a photocopy of the partnership deed dated XX.XX.XXXX, in which XXXX was mentioned as one of the partners, thereafter the defendants also said that the said XXX farms had acquired some land in XXXXXXXXXX and since.

REPLY ON MERITS:

1.        That Para 1.

2.        That the contents of Para 2 is absolutely wrong and is specifically denied whereas the answering defendant is prepared to submit the court fee if any found deficient and as may be directed by the Hon’ble Court.  It is relevant to put on record that as per Hindu Succession Act Section 23 the possession cannot be demanded by the answering defendant only at the time of the division of the property by male and purpose as such only declaration has been sought and the answering defendant is prepared to submit the court fee at the time of handing over the possession in favour of the answering defendant and as may be directed by the Hon’ble Court.

3.        That the contents of Para 3 is absolutely wrong, false, frivolous and baseless and is specifically denied. It is relevant to put on record that at the time of division of the property the answering defendant has the right of the possession of her share as the case may be and since the share has been demanded by one of the male member as such the answering defendant has also got the right to claim the share whereas it is a deferred share as per section 3 of the Hindu Succession Act.

4.        That the contents of Para 4 is specifically denied. It is relevant to put on record that the share of the answering defendant is a un-divided share and may be quantified at the time of real parties and as may be decided at the time of actual division of the property.

5.        That the contents of Para 5 is absolutely wrong and denied.

PRAYER

Prayer Para is absolutely and specifically denied. The applicant is not entitled for any relief qua the answering defendant and the application is liable to be dismissed with exemplary cost in the interest of justice.

It is prayed according.

                                              DEFENDANT NO.3