IN THE COURT OF CMM, CENTRAL,

XXX (PLACE), XXX (CITY)

COMPLAINT CASE NO.XX/X/XXXX (YEAR)

Case No. XX/ XXX (YEAR)

IN THE MATTER OF :

1. ABC
2. DEF (XX Yrs Old Minor
Daughter through her mother)
…..Complainants

VERSUS

XYZ ……… Respondents

WRITTEN STATEMENT ON BEHALF OF THE

RESPONDENT TO THE COMPLAINANT TO THE
APPLICATION U/S 12 PROTECTION OF WOMEN FROM
DOMESTIC VIOLENCE ACT ,2005.

Most Respectfully Submitted as Under:-

REPLY TO THE BRIEF FACTS OF THE CASE :-

1. That in the reply of para 1 of the application it is true and

correct that complainant no 1 is wife and complainant no 2 is

minor daughter of the respondent no 1. The respondent no 2

is the mother-in-law of complainant no 1 and paternal

grandmother of complainant no 2. The respondent no 3 is

sister-in-law ( Nanad) of complainant no 1. It is wrong and

denied that both complainants are in Domestic Relationships

with the respondents and are aggrieved persons within the

meaning of Section 2 (a). It is submitted that the sister-in-law (

Nanad) is neither living with the complainant or nor is residing

in the said the same house where the applicant and the

respondent no.1 was earlier living. The complainant no.1 and

the respondent no.1 are wife and husband. It is wrong and

denied that the respondent no 1 and 2 has committed various

act of domestic violence mentioned in the complainant under

reply and /or in the XXX (ADDRESS) i.e. the matrimonial

home of the complainant. The Complainant/applicant has

already left the matrimonial home on XXX (DATE) to her own.

As a matter of fact she is guilty of committing domestic

violence. The respondents have not committed any kind of

domestic violence either to the applicant no.1 or 2. As the

applicant has herself left the matrimonial home so now she

 cannot say that the said house is shared house. The said

house belongs to the respondent no.2, who is the mother-in-

law of the complainant/ applicant and now she has left the

said home to her own hence the said house cannot be called a

shared house. It is submitted that the complainant/

applicants no 1 and 2 were residing in the said house and the

moment they have left the home with the intention of living

else where they have no right or lien on the said house. The

fact is that the complainant/applicant no.1 is living separately

with the minor daughter since XXX (DATE), then how can

respondent no 1 to 3 can commit domestic violence against

both of them. The respondent no.3 is not residing in the said

house then how can she commit domestic violence ? It is

wrong and denied that the respondent no 2 are residing in

the XXX (ADDRESS). As a matter of fact the complainant no.1

along with complainant no.2 has left the matrimonial home on

XXX (DATE). The respondent no 3 lives outside XXX (PLACE)

due to her professional requirements since XXX (DATE).

2. That in the reply of para 2, it is submitted that the fact about

employment of the complainant in XX is true and correct.

However the complainant has not disclosed her correct salary.

As a matter, the complainant is working with XX Manager

and earning XXX (AMOUNT) per month and income from other

sources is different which comes to Rs……….…besides she is

getting interest from FDRs. Which amounts to XXX (AMOUNT)

per annum. The complainant is having FDRs amounting to

XXX (AMOUNT) which she has got from her first husband

besides a rent of XXX (AMOUNT) from the flat in XXX

(ADDRESS). In fact she has made the marriage a weapon to

get money from the simple persons like the respondent no.1. It

is admitted that the respondent no 1 is working as language

instructor with XXXXXX but it is wrong and denied that his

per month income as Language Instructor is between XXX

(AMOUNT) pm and XXX (AMOUNT). It is further wrong and

denied that his total income from all sources is not less than

XXX (AMOUNT) per month. It is irrelevant to mention about

the retirement dues and other benefits of the respondent no.2

which she received as retirement dues. Even otherwise the

respondent is neither aware how much amount she had got

nor it is relevant for the present case to enquire about it from

the respondent no.2. Whatever she had got is her money and

the applicants have to do nothing with that. Even the

narration of the income of the respondent no.2 and 3 by the

complainant is irrelevant. It is submitted that all the

respondents are residing at XXX (ADDRESS). Further it is

wrong and denied that the same is too small floor to

accommodate all members of the family of in laws of the

complainant. It is submitted that the respondent no.3 is not

residing in the said house of XXX (ADDRESS). The respondent

no 3 is living and working in XXX (PLACE) and how much she

is earning is irrelevant and even otherwise the answering

respondent is not aware about her earning etc. It is wrong and

denied that all parties are living in XXX (ADDRESS). It is

submitted that only respondent no 1 & 2 are living in above

mentioned address. It is submitted that the respondent no 1

has never made promise with complainant no.1 that after

marriage they both will shift to another accommodation. It is

further wrong and denied to say that the respondent no.1 or 2

has any commitment to make any arrangement for the family.

Further it is wrong and denied that instead of making

 arrangement of proper accommodation for the family , the

respondent no.2 sold the plot. Any family member has to do

nothing with the said plot. The respondent no.2 was owner of

the said plot and if the respondent no.2 had sold the plot , the

complainant has can neither object that being the property of

her mother in law nor she can claim any money from the said

plot. It is submitted here that the fact that the respondent no

2 has sold her plot located at XXX (ADDRESS) in XXX (YEAR),

and bought a HIG flat at XXX (ADDRESS) for the respondent

no 3 for XXX (AMOUNT) for which respondent number 3 has

raised a huge loan is none of the concern of the complainant

in any manner whatsoever.

3. That in the reply of para 3, it is admitted and is matter of

record that on XXX (DATE), the marriage of the respondent no

1 and complainant no 1 was solemnized as per Hindu Rites at

XXX (ADDRESS) as per Hindu rites and customs. After

marriage , complainant no 1 was welcomed at XXX

(ADDRESS) as bride of the respondent no1 and daughter in

law of the respondent no.2. It is admitted that since then they

resided together at the said matrimonial home till XXX (DATE)

the day the complainant no.1 along with the complainant no.2

left the matrimonial home. It is admitted that the respondent

no 1 and complainant no 1 knew each other since XXX

(YEAR). It is wrong and denied that the respondent no 1 has

taken Rs XXX (AMOUNT) from complainant no 1 prior to the

marriage for an investment purpose, with promise to pay XXX

(AMOUNT) per month profit on the said amount till the return

of the principal and only XXX (AMOUNT) were returned before

marriage. Whatever amount was taken by the respondent no.1

, the same was returned by him before marriage itself. It is

matter of the record that marriage between both parties was

solemnized as arranged marriage with the consent of parents

of the both parties and in presence of relatives and friends

from both side. About the first marriage of the complainant the

complainant informed that her husband was a man of loose

character and after XX years she filed for divorce. Her father

also told that her husband was caught with several women in

XXX (PLACE) read handed with XX women in the room. The

complainant has always told that the flat in XXXX and FD’s

worth XXX (AMOUNT) in XX Bank, XXX (ADDRESS) was the

 compensation from her first mother in law, Mrs. XXX (NAME)

and husband Mr. XXX (NAME).

4. That in the reply of para 4, it is matter of the record that on

dated XXX (DATE) a daughter DEF was born out of the said

wedlock. It is wrong and denied that complainant no 1 and 2

are the victims of domestic violence. It is submitted that

complainant no1 is working in XX Bank as a Manager, and

generally comes home in late evening, and after coming home

she was busy with baby. Then how and when respondent no 1

and 2 would had done domestic violence with her is matter to

be considered!

5. That in the reply of para 5, it is matter of the record that the

complainant no.1 has done Fashion Designing from XXX,

B.SC , M.Com, MIB from XXX University while the respondent

no.1 ( husband) told the complainant that he is MBA. It is

wrong and denied that the respondent had told complainant

that he has MBA degree. It is wrong and denied that the

complainants has been forced & compelled by respondents to

live separately, the fact is that the complainant has left her

matrimonial home by her own will and wish on XXX (DATE).

None of the respondents have forced her to leave the house

nor they had form any collusion and connivance with each

other for not allowing entry of the complainant in the

matrimonial home. It is matter of record that the respondents

are living XXX (ADDRESS) is permanent address of answering

respondent’s mother i.e. the respondent no.2. The

complainant has left that house to her own on XXX (DATE). As

a matter of fact XXX (ADDRESS) is the address of

complainant. Besides, the complainant is having her own

house in XXX (PLACE). It is wrong and denied that

complainant has been cheated, harassed physically, mentally,

threatened abused, raped and duped of her movables, money,

and jewellery etc by the respondents with common objectives

and common intentions as well as in pursuance of continuous

demand of money for the last more than XX years. The truth is

that the answering respondent had never concealed any fact

from the complainant about their family matters. The

respondents have never harassed physically & mentally to the

complainant as immediately after the marriage the

complainant was pregnant from respondent no.1 and after

delivering child she went to her parents house for fulfilling

various family customs hence the question does not arise for

any physical & mental harassment to the complainant. It is

wrong and denied that the respondents have ever threatened,

abused and raped her. Putting the allegation such as ‘rape’

and other wrong and immature allegations against the

respondent itself amounts to cruelty against the answering

respondent. This clearly shows that the complainant is not a

clear hearted woman and is putting such baseless allegations

against the answering respondent. The respondent no.1 and

complainant were married with family consent hence there is

no question of threaten, abusing and raping of complainant.

The respondents has not duped complainant money, movables

and jewellery. The truth is that the complainant has put all

her jewellery in XX bank locker number XX and she is the only

authorized person to operate the locker, her money is safely

placed in her bank account and other movables items are

safely placed where she had left them without informing the

respondents. The complainants never informed about her plan

to rent an apartment and live there. The complainant has

 taken away all her jewellary on XXX (DATE) and changed the

nominee from respondent number 1 to her elder sister Mrs.

XX (NAME) on XXX (DATE) with an intention to cause mental

cruelty, to the respondent and not because the complainant

has taken away all the jewellary but because the complainant

does not have trust upon the respondent no.1. The

complainant does not have even this much trust that even if

she wants to take any decision, she should at least consult the

answering respondent before taking any such steps. But no,

she did not even bothered to inform the answering respondent

what to say to repose confidence and trust upon the

respondent ! Further, by the conduct and action of the

complainant to take away all jewellery and valuables clearly

shows that the complainant wanted to end the relationship

with the respondent. This fact is further established when the

complainant had left the matrimonial home on XXX (DATE).

6. That there is no necessity to point out about the relationship

of the respondent no.2 and her husband. The respondent no.2

( mother in law) and her husband have been divorced and

answering respondent does not want to speak or say anything

about them, However all the allegations mentioned against the

respondents are wrong and denied. In fact, neither the

complainant nor the answering respondent is concerned about

the relationship of the respondent no.2 and her husband. It is

submitted that the respondent 2 and Mr. XX (NAME) who is ex

husband of respondent no. 2 have been living separately since

XXX (YEAR) and have been divorced since XXX (YEAR). Mr. XX

(NAME) was not even invited at the wedding of the

complainant and the answering respondent. The Complaint is

well versed about the bitter relations between respondents and

Mr. XX (NAME). Thus just to cause mental harassment and

cruelty to the respondents, the complainant contacted him,

started writing letters without the knowledge of respondents

and even the respondent no.1 and to the extent invited him to

the house on XXX (DATE) at XXX (TIME) in the morning with

the intensions better known to the complainant and her

family. Further with the intervention of local police Mr. XX

(NAME) was warned that if he enters the house again he will

be arrested under trespassing. Certainly, the conduct of the

complainant is suspicious and it speaks some foul play. It

 shows how the complainant is interested to speak and have

relationship with someone who is not the family member and

on the contrary she is not interested in maintaining the

relationship with those who are family members i.e. the

respondent no.1 and 2. The complainant has written that she

will abide by the suggestions of Sh. XX (NAME). It is really

strange ! A person , who is not even a family member is being

given so much importance, whereas the answering

respondents have never been given due respect and rewards

7. That in the reply of para 7 of the complaint, it is submitted

that all the allegations mentioned in para 7 are wrong and

denied./…………/ It is submitted that the respondent no 1

borne entire household expenses, and the respondent no 1

never asked the complainant to share information about her

income and deposits. Also this part of para is wrong and

denied that complainant’s mother–in–law told complainant on

very next day after marriage to share XXX (Amount) per month

then raised for XXX (Amount) for monthly expenses of house

and from in XXX (YEAR) onwards was asked to bear fifty

percent of all expenses of family and this fact is entirely wrong

and denied that after daughter was born she was told to bear

her and her daughter’s all expenses separately by herself. In

fact it was respondent no.1’s mother who looked after the

expected mother (the complainant) and the child during

pregnancy and at the time of delivery along with the

complainant’s mother as only these two old ladies were having

good experience to handle such sensitive issues. It is further

wrong and denied that in XXX (YEAR) , the complainant was

asked to bear fifty percent of all expenses of the family and to

bear exclusively all expenses of minor daughter. It is

submitted that the complainant used to spend a lot whereas

the respondent no.1’s salary was not that much hence the

complainant to her own used to spend some amount on

herself and her minor daughter. It is wrong and denied that

the respondents started ignoring the complainants. It is

further wrong and denied that the respondent stopped sharing

meal with her and celebrations of functions. However,

whenever the complainant has gone to her parents house to

celebrate the function, that was her own wish and if on certain

occasions, the answering respondent could not go with her,

there was/is nothing wrong because functions like Diwali

everyone wish to celebrate in his own home. It is wrong &

denied that respondents had started ignoring the complainant,

stopped sharing meal with her and celebration of the

functions. It is the complainant who ignored respondents

living in her matrimonial house, stopped eating meals with

them and used to visit her paternal homes instead of

attending functions celebrations with the answering

respondent and in matrimonial home. It is wrong and denied

that the respondents started cooking for themselves and she

was left to cook for herself and minor child. The correct and

actual fact is that the respondents arranged cook in house for

2 times as complainant spend long time in her office due to

her professional commitments and or otherwise. It is

submitted that there was a cook who used to cook food hence

the allegation put by the complainant stands nowhere. It is

wrong and denied that respondents no1 & 2 visited Finland

and respondent no1 told complainant that if she and her baby

wants to visit with them then she has to deposit XXX

(AMOUNT). The fact is that respondent asked complaint to give

her passport for applying visa but she denied stating the

reason that she is busy with her professional commitments.

The complainant whenever have any occasion, used to take

the complainant along with him but there has been a number

of occasions when she used to refuse to go along with the

answering respondent on one excuse or the other. The

incident of the birthday of the respondent no.1 has been

narrated wrongly. The complainant herself used to withdraw

herself from the company of the answering respondent. She

used to refuse to go out whenever she would come to know

that the respondent no.2 ( the mother of the respondent no.1 )

is accompanying them. So the same way, on the occasion of

birthday of the answering respondent, the complainant

refused to dine outside because the mother of the answering

respondent was also going out with them. On this, the

answering respondent tried to make her ( the complainant)

understand that let his mother go along with them because

the answering respondent had already told her to accompany

but the complainant made a issue not to take the respondent

no.2 along with. The answering respondent also promised to

take the complainant alone to a Restaurant on some other day

but the complainant made it an issue and herself chosen not

to go out. It is absolutely wrong and denied that the answering

respondent did not invite her for participation. It is further

wrong and denied that thereafter the respondents started

isolating the complainant and stopped taking her with them to

social gatherings and in relatives functions. It is further wrong

and denied that in XXX (YEAR) the respondents started

planning to throw the complainant out of the matrimonial

house and as a part of their conspiracy the respondent no.2

asked the complainant to get lease of this house (matrimonial

house) from her employer in her name. It is further wrong and

denied that any of the respondent ever said that it would be

beneficial for them to get a lease deed. In view of the fact that

things never happened the way these are mentioned. All the

allegations in this regard are wrong and denied. Although the

issue of Lease Deed is irrelevant as far as the matrimonial

dispute is concerned between the parties. However it is

submitted that the answering respondent and his mother

never pressurized the complainant to get lease of matrimonial

home i.e XXX (ADDRESS). It is wrong and denied that at any

point of time the answering respondent and /or his mother

ever pressurized the complainant to get lease of matrimonial

home i.e XXX (ADDRESS) from her employer in her name. In

fact the answering respondent and his mother were not even

aware of this fact that the complainant can get a lease deed

from her employer. The complainant before this had the lease

deed from the neighborhood XXX (ADDRESS) for an year and

was seeking full reimbursement of the rent. When he refused

for this arrangement the complainant had requested the

respondent number 2 to enter into this contract with her

bank. The respondent number 2 has been paying tax on the

rent received from her pocket just to run the show. As matter

of fact the respondent herself managed to get lease deed as a

part of the matrimonial home in her name from her employer.

It is wrong to say that there was any pressure from the mother

of the answering respondent or any none else for getting the

lease deed executed between the employer and the respondent.

However it is factual correct that as per wish of the

respondent the said lease deed was executed and renewed and
subsequently terminated. The contents of para 8 of the

complainant are irrelevant as far as the matrimonial dispute is

concerned between the parties. However it is submitted that

the answering respondent and his mother never pressurized

the respondent to get lease of matrimonial home i.e XXX

(ADDRESS). It is wrong and denied that at any point of time

the answering respondent and /or his mother ever pressurized

the respondent to get lease of matrimonial home i.e XXX

(ADDRESS) from her employer in her name. In fact the

answering respondent and his mother were not even aware of

this fact that the respondent can get a lease deed from her

employer. As matter of fact the respondent herself managed to

get lease deed as a part of the matrimonial home in her name

from her employer. It is wrong to say that there was any

pressure from the mother of the answering respondent or any

one else for getting the lease deed executed between the

employer and the respondent no.2. However it is factual

correct that as per wish of the complainant the said lease

deed was executed and renewed and terminated as mentioned

herein above.
8. That in the reply of para 8, it is submitted that the contents of

para 8 /???/ are wrong and denied. It is wrong and denied

that the answering respondent and his mother are very greedy

person and from the date of marriage are taking per month an

amount towards half of the total monthly house hold expenses

from the respondent and she has to separately bear her own

and minor daughter’s day to day expenses. All he allegations

are wrong and denied. In fact, the answering respondent was

not earning sufficient whereas the complainant was in habit of

living a luxurious life there for, she herself started

contributing the household expenses for the sake of living a

luxurious life and spending lavishly. It is wrong and denied

that the answering respondent / husband ever took XXX

(AMOUNT) for their Honeymoon tour. Whenever the answering

respondent had to take an amount from the complainant he

had returned the same to the complainant after getting his

money/salary. It is wrong and denied that the answering

respondent/ husband had compelled the complainant to pay

the rent of the lease deed from XXX (YEAR) to XXX (YEAR). It

is wrong and denied that from XXX (YEAR) answering

respondent forced the respondent to pay rent for the

matrimonial home by compelling her to apply for lease in her

name for residence in respect of matrimonial home i.e XXX

(ADDRESS). However it is admitted that the mother of the

answering respondent is land lady (lessor) and the XX Bank

was employer of the respondent and lessee in the lease deed. It

is also admitted that during the lease period all the parties

were residing at the said house for which rent amount was

paid by the bank towards HRA facility given to the

complainant. It is submitted as matter of fact the mother of

the answering respondent wanted to give her portion of the

house on rent but the respondent herself suggested that

instead of giving on rent it is better to take HRA against this

house. Therefore the complainant has got the lease deed

executed as mentioned above. It is wrong and denied that it is

deep rooted conspiracy of the answering respondent & his

mother to get the complainant evicted from the matrimonial

home without returning Istridhan, gifted goods & jewellery. It

is wrong and denied that there is deep rooted conspiracy to

evict the complainant from the matrimonial house. As a

matter of fact, it is submitted that the complainant was not

willing to live with answering respondent and herself left the

matrimonial home as the complainant was finding it difficult

to give answer to the answering respondent and his mother

regarding her alleged friendship with XX (NAME). It is wrong

and denied that the complainant left the home without

istridhan, gifted goods, jewellery. All the valuable, Istridhan,

gifted items, jewellary etc were in possession of the

complainant and she had taken away all that with her. As a

matter of fact, in XXX (YEAR), the complainant took a

separate locker in her name in ‘XX Bank’ under Single

ownership. Thereafter, all jewellery worth XXX (AMOUNT) was

taken away by the complainant and was kept into that locker.

The complainant has admitted in a note that all jewellery is

with her. A photocopy of the said note is annexed as Annexure

R-1. It is wrong and denied that the answering respondent and

his mother were aware that the comp being employee of XX

Bank is entitled for accommodation provided by the bank on

lease of the matrimonial home. The answering respondent

and his mother were not aware of the bank policy and neither
 forced the comp to execute the lease deed nor asked her to

terminate the lease deed. As stated herein above, it was the

comp , who did the execution and termination of lease deed by

her own will. It is admitted fact that after termination of lease

deed, answering respondent’s mother has written mails for the

removal of the goods and reason to do so was that she never

wanted to indulge in any litigation on this account. Rest of the

allegations are wrong and denied.

9. That in the reply of para 9 of the Complainant , the fact about

demonetarization is admitted. It is submitted that those days

and even after that the complainant used to come late.

However whenever the answering respondent offered the

service to pick up the complainant from bank she either used

to discourage or refused to do so. Further it is submitted that

the answering respondent had never taunted the complainant

regarding dropping of her in late evening by any colleague. It is

a matter of the fact is that the answering respondent was

aware of the colleagues with whom the complainant no.1 was

working in office. Hence he never objected the same. However

it is important to mention here that during demonetization the

complainant no.1 was frequently coming home late. Whenever

the answering respondent asked about the complainant no.1

about her late coming she did not give any satisfactory answer

hence the answering respondent checked her metro card

which shows that she has met Mr XXX (NAME) in morning at

XXX (PLACE) and in evening on same day. Coming late on

account of demonetarization was a wrong excuse given by the

complainant no.1. This fact was initially concealed by the

complainant no.1 but later on when the answering respondent

has made enquiries and got her (the complainant)’s metro card

checked up she disclosed her meeting with Mr XXX (NAME). It

is wrong and denied that the complainant no.1 produced the

entire attendance record before the answering respondent. It is

further wrong and denied that the answering respondent ever

started talking to her senior officers and started defaming her

(the complainant no.1). It is further wrong and denied that the

answering respondent and his mother wanted to harass the

complainant no.1 and /or wants to create nuisance in the

Bank. All these are wrong allegations. It neither happened nor

the answering respondent or her mother ever intended to do

so, may be in the month of XXX (YEAR) and or on any other

occasion. However, it is admitted that the complainant no.1

expressed her desired to terminate the Lease Deed with XX

Bank, for which the answering respondent’s mother gave her

consent. It is stated that the complainant no.1 with the

consent of the answering respondent & his mother applied

with the XX Bank /her employer for Lease Deed and it was

wish of the complainant no.1 to terminate the Lease Deed as

she was not interested to carry on the relationship of couple

with the answering respondent hence was interested in

terminating the Lease Deed. The answering respondent never

forced the complainant no.1 to terminate the lease deed. In

fact this was issue between the answering respondent‘s

mother and the complainant no.1 and the respondent no.1

never gave his personal opinion either to execute the Lease

Deed and/or to terminate the Lease Deed. In fact, it is most

respectfully submitted that the answering respondent and his

mother never asked the complainant no.1 to get lease deed of

the matrimonial house i.e XXX (ADDRESS). It is submitted

that in XXX (YEAR), when the complainant no.1 cancelled the

 lease deed with the consent of answering respondent and his

mother, In fact, this situation arose because there was conflict

between the parties, and the complainant no.1 wanted to leave

the matrimonial home. Therefore she created such scene and

that parties mutually decided to cancel the Bank’s lease Deed.

It is the matter of record that the bank informed the same to

the answering respondent’s mother. On the same context,

answering respondent’s mother wrote to XX Bank for the

removal of goods of the complainant no.1, because the

complainant no.1 was not living with answering respondent

and his family. The rest of the contents are matter of record.

As far as the correspondence with Bank is concerned, the

answering respondent is not at all concerned being neither

executor of the Lease Deed nor being owner of the said house.

10. That in reply to para 10 of the complainant, it is accepted

that complainant 1 was compelled to send mails to her office

for clarification of the being of diamond ring for Mr. XXX

(NAME) and involvement of Mr. XXX (NAME) who the

complainant said was present at XX Jewellers though the

cashier of XX Jewellers conformed that complainant had come

with only one man i.e. XXX (NAME). Further immediately after

heart attack to respondent 1, complainant started writing

weried and abusive text messages to one woman called XXX

(NAME) who is a colleague of respondent number 1. Further

XXX (NAME) was molested in broad day light in XX office and

her mobile was snatched. ( Annexed is the letter from her).

Regarding writing of mails by respondent number 1,

complainant had written two mails on XXX (DATE) and XXX

(DATE) stating that everyone in the family should respect her

as she is the only person who is working full time. The

complainant had also sent the same mail to respondent

number 3 in XXX (PLACE) to cause mental cruelty to everyone

without any reason. Neither respondent number 2 and 3 never

replied back to cruel mails just to maintain peace and

harmony in the family. Her bank accounts and bank balance

is a clear expression that complainant has never contributed

anything towards the household and was even denied to pay

hospital bills during discharge which were paid by

respondents mother and sister. submitted that the answering

respondent deny all allegations put against him as they are

 baseless. He never sent any mail by himself to any one

regarding any clarification for anything. Perhaps the

complainant might had hacked his mail-id and might had sent

those mails. The answering respondent is not at all aware

anything about those emails. However, about incident of

purchasing of a ring, the comp had admitted the same in front

of the answering respondent. ( to add reply about ring incident

11. That the contents of para 11 of the complaint are wrong

and denied………..removal of goods …….written to

employer……

12. That about DEF’ admission respondent had denied to

visit the school for admission that year as just XX months ago

respondent had suffered a massive heart attack and got 2

stents implanted. Thus to save from the running around for

the admission the respondent chose not change daughter’s

school this year due to his own health reasons. Further going

to office in the morning was a compulsion for him to earn to

buy his expensive medicines and pay other bills as

complainant had flatly refused to pay medical bills during

 discharge at the hospital and buy any medicine for

respondent. To the extent on each doctor’s visit respondent

had to visit alone as complainant would never bother to visit.

13. The complainant had sent a runner from office and

confirmed by mail that the form has been submitted in time

thus the reason of denial the admission is wrong. Further the

respondent never knew that the form was filled at Mater Dei

and no such form has been signed by the respondent. Rather

Sister XXX (NAME), head mistress of the school confirmed that

CV complainant had declared herself as single mother during

admission.

14. The expenditure was made to please their guests and

high-profile people whom they had invited to show off their

wealth. Further the jeweller and gifts are in the custody of the

complainant and nomination in her sister XXX (name). Rather

respondent number 2, grandmother of complainant number 2

had hosted the first birthday of complaint number 2 and

invited large family of complainant number 1 and her family

friends.

15. That it is wrong and denied that jewellary retained…….

16. That father of the resp has been living separately since

XXX (YEAR) and was not even invited on their wedding further

respondent number 2 and father of respondent number 1 got

divorced in XXX (year). Thus the intension to connect with him

was just to cause mental cruelty to the respondents. …..

17. It is wrong and denied that respondent has ever

physically manhandled complainants as there has been no

incidents nor any FIR lodged by complainants from XXX

(DATE) to XXX (DATE) (till they stayed in the matrimonial l

home) Rather on XXX (DATE) during the mediation

complainant filed a false police complaint at XXX (PLACE) and

bruised her shoulder stating the respondents have beaten her

in the broad day light at the court premises. After XX days of

investigation the complaint was disposed off .

18. That minor

19. That the contents of para 19 are wrong and denied. It is

absolutely wrong and denied that the respondent no.1 and 2

have exploited and abused the complainant emotionally,

economically, financially physically and sexually and all the

respondents have caused mental pain and agony to the

 complainant and have endangered the health, safety, life and

wellbeing both mental and physical of the complainant and

have caused domestic violence of grave magnitude. It is

further wrong and denied that the respondents are continuing

with their acts of domestic violence and there is clear

apprehension that in future the respondents would cause

Physical , Economical & financial harms and abuses to the

complainants. All these allegations are wrong and baseless.

There is no truth in it.

20. That in view of the facts and submissions made herein

above, it is respectfully submitted that the complainant has

left the matrimonial home as per her own desire with the

intention of lead an independent life. Hence, before parting

with the answering respondent ,she wants to grab the huge

amount, as she has done earlier, from her 1 st husband. The

complainant is a greedy and self-centered person. She cannot

live in family atmosphere being a person on non-adjustment

by nature hence is putting allegations on the respondents

unnecessarily. There is no occasion to pass any orders under

Section 18, 19, 20, 21 and 22 or any of the sections of the Act
 43 of 2005. It is respectfully submitted that keeping in view

over all circumstances, it is a clear case of misuse and

abusing the process of the court hence this Hon’ble Court may

dismiss the complainant of the applicant with cost.

21. That in view of the last para, prayer clause, it is most

respectfully submitted that keeping in view over all

circumstances, it is a clear case of misuse and abusing the

process of the court hence this Hon’ble Court may dismiss the

complainant of the applicant with cost.

It is respectfully submitted that in view of the reply of ‘Prayer’

clauses, it is