IN THE COURT OF SH. DINESH BHATT, LD. PRINCIPAL JUDGE; FAMILY COURTS; NORTH-WEST DISTT.

ROHINI COURTS; DELHI.

MT. CASE NO._____ OF 2023.

IN THE MATTER OF:-

__________________                                   : PETITIONERS

VERSUS

______________________                           : RESPONDENT

N.D.O.H.: ________

REPLY ON BEHALF OF THE RESPONDENT TO THE PETITION UNDER SECTION 125 OF CR.P.C. FILED BY THE PETITIONERS FOR GRANT OF MAINTENANCE.

MOST RESPECTFULLY SHOWETH :-

PRELIMINARY SUBMISSIONS / OBJECTIONS :-

1.              That the present petition filed by the petitioner is an abuse of process of law. The petitioner has approached this Hon’ble Court on the basis of false allegations of cruelty after a period of more than two years of marriage. This petition has been intentionally filed against the respondent to blackmail, harass and pressurize him and also to take benefit of her own wrongs.

2.              That no cause of action ever arose nor exists and therefore no cause is disclosed in the present petition against respondent and therefore the petition is liable to be dismissed with cost.

3.              The petitioner has come up with a concocted story with malafide intentions; therefore the present petition is liable to be dismissed on this single ground.

4.              That the marriage of the Petitioner and Respondent was a love marriage which was solemnized between the answering respondent and the petitioner on _______at________, Near Tis Hazari, Delhi in the absence of both parents and family members without any exchange of dowry / gifts which is against the principles of the family of the respondent. The parents of the Petitioner angry with the Respondent as their daughter i.e. Petitioner herein married with Respondent against their wishes and her parents also threatened to the Respondent that they will take revenge and Respondent will face the consequences of the same.

5.              Needless to say immediately after the marriage petitioner often used to pick up arguments over petty issues. Within month of marriage, signs of temperamental and behavioral disorders began to appear in petitioner’s conduct. There were instances of physical attacks. Also, respondent noticed anger management problems in her, for instance, Petitioner used to get furious at one moment and become normal in a split second, with time, frequency of such behavior increased, Petitioner got into the habit of discussing every detail of matrimonial house with her parents who told the respondent to always keep petitioner’s wishes over his concerns for her mother. Every time respondent visited her in laws, both had lectures to deliver on a man’s responsibilities towards his wife. There were instances wherein unnecessary discussions were conducted to explain what family is for an individual who gets married, meaning there by there was tremendous interference from the family of the Petitioner in the matrimonial life of the Respondent.

6.              That after the marriage of respondent and petitioner, the petitioner never showed any proper and due respect towards respondent and his mother, the petitioner always demanded from respondent to separate from his parents. That petitioner refused to perform the normal expected house hold duties and chores such as cooking washing etc. and used to frequently leave her matrimonial home without intimation.

7.              That however, interference of the parents of the petitioner growing so rapidly to the extent that they threatened the respondent that they will implicate the family of the respondent in a false case and would capture the entire property of the respondent.

8.              That however, the said marriage failed and turned into nightmare for respondent on account behavioral and temperamental issues, adamant, lack of sensitivity, unjustified conduct and behaviour, values, sustained course of abusive and humiliating treatment, threat to life, discommode by the petitioner. Therefore, the respondent feeling deep anguishes, disappointment, frustration due to act and attitude and conduct of the petitioner.

9.              That Petitioner started behaving abruptly with Respondent just after the few months of their marriage. Petitioner gets extremely agitated on any routine item/event, which any other normal person would not even notice.

10.           That the parents of the petitioner always gave ill advice and incite the Petitioner against the respondent and his family members and in result of which petitioner started making insult, misbehaving, abusing and assaulting to the respondent as well his parents. By manipulating to the Petitioner by her parents in order to take revenge with Respondent as their daughter married with Respondent against their wishes, they lodged a false and frivolous FIRs against the Respondent and his family members.

11.           That from the acts and conduct on the part of the petitioner, it is clear that Petitioner had buried the institution of marriage forever and it is not possible for the respondent to pull on the marriage any further due to said fraudulent and cruel behaviour of the petitioner.

12.           That in consideration to all the acts and circumstances mentioned above, it is very difficult for the respondent to live with the petitioner as the respondent not only apprehends danger to his life and liberty but the same is also detrimental to his honour, reputation and social status and as such, the respondent is entitled to the grant of the divorce on the ground of cruelty and desertion.

13.           That the above narrated conduct and attitude of the petitioner clearly, evidently and without any least doubt shows that (i) Petitioner has broken all relations with the Respondent as she on some occasions stayed with the respondent, after taking the Jewellery with her which is lying in her custody (ii) Petitioner is determined to implicate the respondent and his parents in false criminal case just to take revenge upon them by hook or crook for the reason best known to her,  (iii) it further proves that the petitioner / wife has abnormal behavior which has resulted all these abrupt behaviors in her. It is further submitted that the life of the respondent and his family would always be in danger and full of tension if they live with the petitioner in any manner in future.

14.           That it is stated that petitioner has already taken all her movable items including her Jewellery and clothes in the absence of the Respondent.

15.           That the petitioner is working lady at …….. and earning more than Rs.________/- per month and she is also providing a private tuition to the children from which she earning approx. Rs.______/- per month. The petitioner is also well educated lady and hence she has the capability to maintain herself. In view of the above submissions, the petitioner / wife is having sufficient source of income of her own. The petition as such is liable to be dismissed being meritless.

16.           That petitioner is a well-educated and well qualified more than respondent and competent is not entitled for any maintenance even if she is sitting idle at home with a view to seeks maintenance, which is not permitted as per catena of judgments passed by Hon’ble High Court of Delhi.

17.           That the law is well settled as regards maintenance that a spouse who is working and otherwise has capacity to earn is not at all entitled for maintenance.

18.           That the petitioner has not approached this Hon’ble Court with clean hands as she withheld her employment status, true income and correct financial status purposefully and mischievously with a view to mislead the court and also to coerce and extort the money from the respondent.

19.           It is submitted that is nothing but wherein loose phrases and adjectives were made without any material particulars and justification. The petitioner is full and contradiction which confirms and affirms that present petition is a gross misuse of the process of the law. The facts are not matching with fiction created in the petition and crumbling on its head in view of its own inherent contradiction.

REPLY ON MERITS :-

1.              That the contents of para 1 of the petition are matter of record, it is denied to the extent that the Petitioner presently living on the mercy of her parents.

2.              That the contents of para 2 of the petition are wrong and denied. It is not denied that marriage of the Petitioner was solemnized with the Respondent at _______on_______.

3.              That the contents of para 3 of the petition are wrong and denied. It is submitted that parents of the Petitioner already know about the marriage of the Petitioner with the Respondent as same was against their wishes of her parents.

4.              That the contents of para 4 of the petition are wrong and denied. It is denied that the family of the petitioner reached at the house of the respondent on the same day _________and told to the parents of the respondent that they are ready to accept their marriage and told to the parents of the respondent that we are the respectable person in our society so we arrange the other functions of the marriage according to the ritual of Hindu mythology further the parents of the petitioner requested to the parents of the respondent and said (kindly send our daughter/ petitioner with me) and come at our house on _______ for fulfillment of other function of the marriage.

5-8.        That the contents of paras 5 to 8 of the petition are wrong and denied. It is denied that finally on _______ the other ritual of the marriage was done before the family member of both petitioner and respondent. It is further denied that the parents of the petitioner spent huge amount in the Welcome and Bidai of the respondent and his family members in this function. It is further denied that father of the petitioner out of his financial capacity gave to the petitioner all the necessary articles and jewelry which is generally given in the marriage due to this they took the loan approx Rs. ______ from his relative and family friends. It is submitted that the marriage of the petitioner and respondent was a love marriage solemnized at________, Delhi and marriage was performed in low profile manner and without any exchange of dowry / gifts.

9.              That the contents of para 9 of the petition are wrong and denied. It is denied that on _______after the marriage the petitioner reached at her matrimonial home after the marriage the behavior of the respondent and his family members was very rude and unfair towards the petitioner.

10.           That the contents of para 10 of the petition are wrong and denied. It is denied that the respondent is quarrelsome person and used to create dispute on same petty issue and minor things. It is further denied that the respondent neither respects nor gives any love and affection to the petitioner which was his daily routine. It is further denied that the respondent never performed his marital and social obligations as required under law and customs, he always suspects on the loyalty of petitioner and used to harass the Petitioner on the tune of less dowries and non-fulfillment of same, the petitioner was beaten by the respondent without any mercy.

11.           That the contents of para 11 of the petition are wrong and denied. It is denied that after the few week of marriage, the Petitioner realized that she was brought as a house hold slave and was forced to do all the house hold work Further, all the articles which she received in the wedding from her family were confiscated by the mother and sister of the respondent.

12.           That the contents of para 12 of the petition are wrong and denied. It is denied that the jewellery articles and cash given by the family members and other relatives of the petitioner to the petitioner were taken by the mother-in-law and the sister-in-law (Pooja) took all the jewellery and cash in her custody.

13.           That the contents of para 13 of the petition are wrong and denied. It is denied that the sister-in-law of the petitioner along with their two children resides in the matrimonial home of the petitioner. It is further denied that the sister-in-law of the petitioner labels false allegations on the petitioner due to which the respondent and mother-in-law of the petitioner use to abuse or to give beatings to the petitioner.

14.           That the contents of para 14 of the petition are wrong and denied. It is denied that in the first week of the marriage, the Respondent started to get abusive with the Petitioner and would often scratch hand bite her while indulging in his sexual intercourse. It is further denied that the Applicant realized that there were no love and affection between them when the Respondent physically punished the Applicant even in those intimate moments. Respondent despite the Applicant/Petitioner clear refusal the respondent was force her into unnatural sex and even he had not any remorse for his illegal and disgusting acts. It is further denied that during this time, the Applicant also realized that Respondent was an alcoholic and every night he was cross all boundaries for his fetishes and vindication.

15.           That the contents of para 15 of the petition are wrong and denied. It is denied that on the occasion of Maker Sankranti the respondent told the petitioner that tell your parents to send gold jewellery & Rupees 1 lakh cash and deeent clothes for all the family members of the respondent, upon which the petitioner told the respondent that "MERE MUMMY PA PANE JITNA HO SAKA USSE BADHKAR SABKUCH TO DIYA HAI SHAM MAIN, AB JO KUCH USNE BANEGA WO LEKE HI AYENEGE" the respondent and the mother of the respondent after hearing this started abusing in filthy language which can't express in the mouth of the petitioner and also beating the petitioner.

16.           That the contents of para 16 of the petition are wrong and denied. It is denied that on ________ the brother of the petitioner brought the gifts for the family members of the respondent. It is further denied that the mother-in-law and sister-in-law of the petitioner after seeing all the gifts taunted in front of the brother of the petitioner that "YEH KOI SAMAN HAI, AAISA GHATIA SAM AN TO HUMRE YAIIAN KOI BHIISTMAAL HI NAHI KRTA". It is further denied that the brother of the petitioner after hearing all these humiliating words of the mother-in-law of the petitioner kept mum for saving of the matrimonial life of the Petitioner and said to the brother of the petitioner for left the matrimonial home of the Petitioner.

17.           That the contents of para 17 of the petition are wrong and denied. It is denied that on ________the respondent told the petitioner that "CHAL AAJ MAIN TUJHE TERE PAPA KE GUAR LE CHALTA HOON, AUR APNE GHAR PE PHONE KARKE KEH DE KI BADHIYA KHANE KA INTEZAAM KARLEN MERE SATH MERE KHACH DOST BHI CHALENGE UNKI AACHI KHATIR DARI KRNE KO BOLDE KAHI MERI NAK NA KATWA DEIN TERE GHAR WALE" then the petitioner said "PAPA KI TABIYAT BOHOT KHARAB HAI RECENTLY HI HOSPITAL SE AA YE HAIN OR BHUT KHARCHA BHI HUA HAI WO APNI OKAAT SE JAYADA HI KRENGE CHINTA MAT KRO PER APNE DOSTON KE SATH KABHI OR CHALE JANA" upon which the respondent started abusing and beating the petitioner with fists and feet.

18.           That the contents of para 18 of the petition are wrong and denied. It is denied that was a program at the house of the uncle of the petitioner in which the petitioner and the respondent were invited, the petitioner requested the respondent to go the house of the uncle of the petitioner on which the respondent denied to go there then the petitioner again requested to the respondent that "CHACHA JI NE ITNE PYAAR SE HIMEIN BULAYA HAI HUM NAHI GAYE TO UNHE KITNA BURA LAGEGA" on which the respondent replied "MUJAHE KOI FARK NHI PADTA BURA LAGE TO LAGE WESE BHI UN FAKIRON KE PASS HAI HI KYA DENE KO UN FKEERON KE PASS MUJHE TUMHARE GHR WALON SE KOI MATLB NAHI HAI OR TUJHE BHI IN KI ITNI YAD AATI HAI TO UNKE HI PASS CHALI JA" then the petitioner became silent thinking this in the hope that one day everything will be fine.

19.           That the contents of para 19 of the petition are wrong and denied. It is denied that on ________ the petitioner was very ill so the petitioner told the respondent and her mother-in-law to take her to the doctor but the respondent and mother in law of the petitioner said to the petitioner that "PATA NAHI KONSI BIMARI HUMARE MATTHE DAAL DI TERE GHR WALON NE, MAIN KAHI BHI NAHI JAANE WALI, TUJHE KAHIN MAUT NA AARAHI TUJE, CHUPCHAP PADI RAH MARR NAHI JAEGI, AGAR JAYADA HI SHAUK HAI DOCTOR KE PASS JAANE KA TO APNE GHAR SE APNE BHAI BAAP KO BULA LE, MERE PASS TIME NAHI HAI" then the petitioner called her mother and told that come and took Petitioner to the doctor as the respondent has denied taking Petitioner to the doctor even they merciless beating to the Petitioner.

20.           That the contents of para 20 of the petition are wrong and denied. It is denied that on the same day i.e. _________ the Brother and the sister of the Petitioner came to the matrimonial home of the petitioner and both brother and the sister of the petitioner requested the in-Laws of the petitioner with touching their feet that kindly send the petitioner with them but the in-laws of the Petitioner specifically sister in law of the petitioner adamant to not send the petitioner with her brother and sister even the sister law of the petitioner said to the petitioner and brother and sister of the petitioner "AGAR TUM LOG APNI BHEN KO YAHA SE LEJANE KI KOS1S KARI TO YAHA LASHEN BICH JAINYNGI" after listing the version of the in laws of the petitioner the sister of the petitioner was compel to call the Police and the sister of the petitioner called on 100 number but due to 2nd phase of the corona police did not come there on time and the petitioner went away with her brother and sister. It is further denied that after that the petitioner stayed at the parental home for three month for peruse her treatment.

21.           That the contents of para 21 of the petition are wrong and denied. It is denied that after about 3 months the respondent came to the parental home of the petitioner and the respondent apologized to the parents of the petitioner and said that he made a mistake he will not do any mistake in future. It is further denied that then the respondent took the petitioner to her matrimonial home but after reaching the matrimonial home of the petitioner the respondent and his other family members told to the petitioner AB AA TO GAI HAI LEKIN ITNA SAMAJH LE AAJ SE TERE MAA BAAP BHAI BHEN SARE TERE LIYE MAR CHUKE HAIN AGAR AAGE SE UNSE KABHI BAAT BHI KAR NE KI KOSIS KARI TO TERIKHAIR NAHI" after that the petitioner didn't call to her parents, brother and sister for three month in front of respondent and his family members for saving her matrimonial life and she thought that one day everything will be okay.

22.           That the contents of para 22 of the petition are wrong and denied. It is denied that on the occasion of Karwa Cahuth was held on ____________ the brother of the petitioner reached on the same day i.e. __________ with Shagan of the karwa Chauth according to the status of the parents of the petitioner, After seen the Shagan the in laws of the petitioner started abusing in front of her brother and saying "YE KOI SHAGAN HAI PEHLA SHAGAN HAI MERE BETE KA OR DEKHO KITNE GHATIA SAMAN LAYAHAI YE MATTI KE BHANDE LEKE AA GYA HUMNE TO APNI BETI KE YAHAN BHI CHANDI KE BARTAN DIYE THE.

23.           That the contents of para 23 of the petition are wrong and denied. It is denied that on _________ when the petitioner told the respondent that she is suffering from fever so please takes her to the doctor, on this the respondent told the petitioner that he does not have time for these useless things, so the petitioner called his mother and told her the whole thing, on which she consoled her and said that she is coming right away. It is further denied that when the mother of the petitioner came ate matrimonial home of the petitioner and wanted to take petitioner to the doctor for her treatment then the mother-in-law of the petitioner told the petitioner in the front of petitioners mother that "DEKHO DEKHO DONO MA BETI KAISE HUMARE GHAR KI IJJAT SAMAJ ME NILAAM KRTI GHUM RAMI HAIN, ISKI TO TAANGE TODH DUNGI TERI AGAR, APNIMAA KE SATH KAHIN BHI GAYI TO YA PHIR IS GHAR KI DEHLEEJ BHI PAAR KRI TO AAGE SE IS LAYAK NAHIRAHEGI Kl KAHIN BHI JANE LAYAK NAHI RAHEGI WESE BHI TUMNE SARE SAMAJ ME HUMARI NAAK KATWANE ME KOI KASAR NAHI RAKHI HAI TUM LOGO NE". It is further denied that before her mother could say anything, Petitioner told her mother to leave then the mother of the petitioner went away from there with hard heart and that time the sister-in- law of the petitioner snatched the mobile of the petitioner and locked her in the room.

24.           That the contents of para 24 of the petition are wrong and denied. It is denied that on _______ toe of the mother of the petitioner got wounded and the petitioner was very much worried about this so the petitioner requested the respondent to take the petitioner to her parental home on which the respondent slapped the petitioner on her face. It is further denied that the mother-in-law of the petitioner, and sister-in-law of the petitioner said "KOI JARURAT NAHI HAI KAHI BHI JANE KI HUMARE RISTEDARI ME EK FUNCTION HAI HUM SABHI USME JA RAHE HAIN OR TUMHE BHI WAHAN JANA HAI".

25.           That the contents of para 25 of the petition are wrong and denied. It is denied that on ________ the brother of the petitioner on the occasion of the birthday of the petitioner brought cake and gifts for the petitioner then the family members and the respondent got very much angry and they started abusing the brother of the petitioner and thrown the gifts and the cake outside the home. It is further denied that then the petitioner requested to her mother-in-law and sister-in-law that "why you both are humiliating my brother like this, please for god sake do not say these words" upon which the mother-in-law and sister-in-law of the petitioner started beating the petitioner mercilessly in front of the brother of the petitioner. It is further denied that then the brother of the petitioner after pacifying the altercation left the matrimonial home of the petitioner. It is further denied that the petitioner told the entire incident to the respondent but the respondent did not paid any heed to the petitioner and even gave her beating.

26.           That the contents of para 26 of the petition are wrong and denied. It is denied that on ________ when the petitioner went in the kitchen to cook food then the sister-in-law of the petitioner also came in the kitchen and started pulling the hair of the petitioner and said "TERI ISS KITCHEN MAIN GHUSNE KI HIMMAT KAISE HUI" the mother-in-law of the petitioner also came there and slapped the petitioner in her face and said "KI YEH KOI TIME HAI UTHNE KA, DIN BHAR TO SOOTI HITO RAHTI HAI”. It is further denied that even the sister in law of the petitioner kicked to the petitioner kicked to the stomach of the petitioner then the petitioner was feeling pain in her stomach and went to her room.

27.           That the contents of para 27 of the petition are wrong and denied. It is denied that the petitioner then told to the respondent "YE AAP MERE SATH KYA KAR RAHE HO MAIN TO AAP KE LIYE APNE PARIVAR KE KHILAF JAKAR BHI ARYA SAMAJ MANDIR ME SHADI KI KYONKI MAI AUR AAP EK DUSRE SE PAYR KARTE THE AUR AAJ AAP MERI DURDASHA PAR KUCHH NAHI KAR RAHE HO ULTA AAP IN LOGO KA HI SATH DE RAHE HO" then the respondent replied that "all this is happening with you because no one here is happy with the articles which your parents have given to you in the marriage so, if you want to stop all these things then call your parents and tell them to give us Rs.___________/- cash and a car". It is further denied that the petitioner denied over the said demands of the petitioner that she is not going to tell anything about your demands to her parents then the petitioner was subjected to merciless beatings by the respondent. It is further denied that the petitioner was very much shocked and heartbroken so she called her parents and narrated whole incident to them, then the parents of the petitioner called again on 112 and the police came to the matrimonial home of the petitioner.

28.           That the contents of para 28 of the petition are wrong and denied. It is denied that on _________ the petitioner was again feeling in her stomach due to beating by the respondents then the petitioner reached at __________ Hospital.

29.           That the contents of para 29 of the petition are wrong and denied. It is denied that on __________ the petitioner gave birth to a male child  in a private hospital in Delhi and the father of the petitioner bore all the expenses of the hospital. It is further denied that since then, the respondent has not taken any responsibility for his child.

30.           That the contents of para 30 of the petition are matter of record. It is submitted that the parents of the petitioner always gave ill advice and incite the Petitioner against the respondent and his family members and in result of which petitioner started making insult, misbehaving, abusing and assaulting to the respondent as well his parents. By manipulating to the Petitioner by her parents in order to take revenge with Respondent as their daughter married with Respondent against their wishes, they lodged a false and frivolous FIRs against the Respondent and his family members.

31.           That the contents of para 31 of the petition are wrong and denied.

32.           That the contents of para 32 of the petition are wrong and denied.

33.           That the contents of para 33 of the petition are wrong and denied. It is denied that the respondent is a man of status and has an income of Rs. ________/- to Rs. __________/- per month as the respondent is skilled hair stylist and that the Respondent is maintaining a luxurious life. It is submitted that the petitioner is working lady at …….. and earning more than Rs._______/- per month and she is also providing a private tuition to the children from which she earning approx. Rs.________/- per month. The petitioner is also well educated lady and hence she has the capability to maintain herself. In view of the above submissions, the petitioner / wife is having sufficient source of income of her own. The petition as such is liable to be dismissed being meritless.

34.           That the contents of para 34 of the petition are wrong and denied. It is denied that the respondent has no other liability and the only person dependent upon the respondent is the petitioner being his lawfully wedded wife.

35.           That the contents of para 35 of the petition are wrong and denied. It is denied that the petitioner has no independent source of income for her support at present and the petitioner at least requires a sum of Rs. _______/- per month as maintenance for herself.

36.           That the contents of para 36 of the petition are wrong and denied. It is denied that the respondent is extremely cruel and self-conceited men without an iota of humanity and sympathy and has flatly refused to maintain the petitioner though the respondent is able bodied person and is earning Rs. _______/- per month from his job and respondent is skilled hairstylist and also having own moveable and immovable property but petitioner is living on the mercy of her parents and not having sufficient funds to maintain herself. It is submitted that petitioner is a well-educated and well qualified more than respondent and competent is not entitled for any maintenance even if she is sitting idle at home with a view to seeks maintenance, which is not permitted as per catena of judgments passed by Hon’ble High Court of Delhi.

37.           That the contents of para 37 of the petition are wrong and denied. It is denied that the respondent is legally bounded to maintain the petitioner but is not doing so willfully. That the law is well settled law in regards of maintenance that a spouse who is working and otherwise has capacity to earn is not at all entitled for maintenance.

38.           That the contents of para 38 of the petition are wrong and denied.

39.           That the contents of para 39 of the petition are legal para, need no reply.

Prayer clause along with sub-paras of the petition is not admitted and is denied. However, it is submitted that the petitioner is not entitled to any relief of the petition and the petition of the petitioners is liable to be dismissed with heavy cost.

It is, therefore, prayed that the petition since is against the provisions of law, the same is based on false and frivolous allegations and averments. The petitioner is not entitled for maintenance, as submitted above, accordingly, the same may kindly be dismissed with costs.

It is prayed accordingly.

DELHI                                                                    RESPONDENT

THROUGH

DATED :-

    _________________________________

ADVOCATES

______________, Delhi-110054.

Mob.No_________________

Email: ______________________

VERIFICATION :-

          Verified at Delhi on this ____, day of October, 2024 that the contents of paras 1 to 39 of the written statement on merits and the facts stated in the preliminary objections / submissions are true and correct to our knowledge while those of paras 1 to ….. of the written statement on merits and those of paras of the preliminary objections are true upon information received and believed to be true and correct. Last para is a prayer clause before this Hon’ble Court.

RESPONDENT

IN THE COURT OF SH. DINESH BHATT, LD. PRINCIPAL JUDGE; FAMILY COURTS; NORTH-WEST DISTT.

ROHINI COURTS; DELHI.

MT. CASE NO. ______ OF 2023.

IN THE MATTER OF:-

_________________                                     : PETITIONERS

VERSUS

___________________                                 : RESPONDENT

AFFIDAVIT

Affidavit of ______________________________, do hereby solemnly affirm and declare as under: -

1.       That I am the respondent in the above noted matter and am well conversant with the facts of the case and as such, am competent to swear this affidavit.

2.       That the submissions as to facts made in the accompanying reply to the petition U/s 125 CrPC, has been drafted by my counsel as per my instruction and the same have been read over and explained to me in my vernacular language and the same may be read as part and parcel of this affidavit, which are not reproduced herein for the sake of brevity.

DEPONENT

VERIFICATION :-

          Verified at Delhi on this ___ day of October, 2024 that the contents of my above affidavit are true and correct to my knowledge and no part thereof is false and nothing material has been concealed therefrom.

DEPONENT