IN THE COURT OF SH.

SANJAY JINDAL, PRINCIPAL

JUDGE, NORTH DISTRICT, FAMILY COURT, ROHINI,

DELHI

Ex-………../2023.

IN THE MATTER OF:-

RITU …DECREE HOLDER

THROUGH

SH. AMIT …JUDGMENT DEBTOR

OBJECTIONS ON BEHALF OF THE JUDGMENT DEBTOR TO THE

EXECUTION FILED BY THE DECREE HOLDER

Most respectfully Showeth:-

1. That the objection no 1 of the execution is that

the Decree Holder as after the marriage, the

Judgment Debtor started to reside at the prenatal

house of the Decree Holder. The Judgment Debtor has

been tortured mentally as well as physically by the

Decree Holder. The marriage was a “Love- Marriage”

(running marriage) which was solemnized on

21.05.2015 in Arya Samaj Mandir, A-75, 3rd Floor,

 Prashant Vihar, Delhi-110085. Thereafter the

marriage was registered in the office of Registrar,

District North, Delhi. The Judgment Debtor never

created any unpleasant atmosphere in the parental

house of the Decree Holder. The Judgment Debtor

never harassed the Decree Holder on the other hands

the Judgment Debtor was forced to cooking and other

household work. The behaviour of the Decree Holder

has always been uncooperative quarrelsome and rude.

The marriage between the parties was a dowry less

marriage an affidavit to this effect had been

prepared by the Decree Holder at that time.

(AFFIDAVIT OF THE DECREE HOLDER AND THE JUDGMENT

DEBTOR ARE ENCLOSED HEREWITH).

2. That the objection no 2 of the execution is that

after sometime of the marriage, the behaviour of

the Decree Holder changed towards the Judgment

Debtor, he was shocked to see her behaviour. He was

neglected frustrated with his married life. The

Judgment Debtor was working in R2C company at

Subhash Place, Delhi as per the requirement the

Judgment Debtor has to open his own bank for

transfer of salary, however he was not allowed by

 the Decree Holder instead off it, a joint account

was opened by the Decree Holder with the Judgment

Debtor, wherein the Decree Holder became the

primary account holder so that she have full

control of the same not only this the Decree Holder

kept the Debit card of the Decree Holder with her,

the Judgment Debtor was not allowed to operate the

said account. It is pertinent to mentioned here

that the Judgment Debtor was not having any

financial freedom in all respect.

3. That the objection no 2 of the execution is that

the Decree Holder has suppressed the material fact

before this Hon’ble Court and brought a false

concocted and baseless story before this Hon’ble

Court. The Judgment Debtor was beaten up by the

Decree Holder and his sister. The Decree Holder

forced the Judgment Debtor to executed an affidavit

at the time of marriage that the family of the

Judgment Debtor will not have any concerned in the

married life of the Decree Holder and the Judgment

Debtor. (AFFIDAVIT IS ENCLOSED HEREIN). She kept on

threatened the Judgment Debtor if he objected any

of her wish, she will file false cases against the

 Judgment Debtor as mentioned in the present

affidavit. The Judgment Debtor was not allowed to

go outside the house of the Judgment Debtor with

his own wish. He was not even permitted to meet his

friends and relative if the Judgment Debtor somehow

stayed a bit longer in the market then his wife

forced him to come on video call to prove his where

about. The Judgment Debtor was forced to file many

complaints against the family members of the

Judgment Debtor. The Decree Holder totally failed

to discharge her matrimonial duties towards her

husband, on the other hands the Judgment Debtor

made all possible efforts but all in vain.

4. That the objection no 4 of the execution is that

due to behaviour of the family member of the Decree

Holder, Judgment Debtor started living him utmost

stress and tension and it became very difficult for

the Judgment Debtor to live the parental home of

the Decree Holder and the Judgment Debtor left her

parental home on 12.11.2020. The condition of the

Judgment Debtor became more critical due to the

mental stress and harassment given by the Judgment

Debtor and after that the Judgment Debtor has to

 get treatment in IHDAS Hospital Delhi. (Copy of

medical report is enclosed herewith).

5. That the objection no 5 of the execution is that

the decree holder is an educated lady and she is

post graduate having Diploma of Librarian. It is

also pertinent to mention here that from

01.03.2012, she was working in the APG Public

School, Sapla Road, Kharkhoda, Sonipat, Harayana-

131402 (experience letter is annexed herewith)

after that she was working in Central Library as a

Data Entry operator from 16.12.2016.(Experience

letter is annexed herewith). Thereafter she was

working in Lady Harding Medical College & Sucheta

Kripalani Hospital, New Delhi-110001 as a Assistant

Warden and was earning Rs.31,244/- per months till

20.05.2020 after that she resigned from the

hospital(appointment letter, attendance sheet, copy

of the salary cheque, copy of the payment of salary

through electronic clearing system, copy of e-

payment, resignation letter are annexed herewith)

and stated to work in a company and is earning

Rs.35,000/- per month. It is also pertinent to

mention herein the decree holder having PAN Card

 bearing No.BAXPR3679C and the decree holder is also

filing Income Tax Return (copy of ITR is annexed

herewith). The decree holder is/was residing at her

parental home. The decree holder is also having two

FDRs and also having three bank accounts, one is a

joint account with the judgment debtor another

account number is in State Bank India, Branch Badli

and one more account bearing no. 34799257080 in

State Bank of India, Branch Sector-18, Rohini,

Delhi (related documents are enclosed herewith) in

this way the decree holder is earning a handsome

amount and living a luxury life on the other hands,

the judgment debtor is a patient, mentally

depressed and getting treatment from IHBAS

Hospital. With a great difficulty he is earning

Rs.9,530/- per month in the Pankaj Book Depot &

Sports Center.

6. That the objection no 1 of the execution is that

there is no cause of action arose in favour of the

Decree Holder and against the parents of the

Judgment Debtor.
 PRAYER

In view of the objection mentioned above it is

therefore most respectfully prayed that the execution

of the decree holder may kindly be dismissed, in the

interest of justice.

Delhi
Dated:-
DECREE HOLDER
Through

VANDANA RUHELLA
&
Abhishek Ruhela
Advocate
Off- 1972 Gali No 3
Kailash Nagar Delhi-31
 IN THE COURT OF SH. SANJAY JINDAL, PRINCIPAL

JUDGE, NORTH DISTRICT, FAMILY COURT, ROHINI,

DELHI

Ex-………../2023.

IN THE MATTER OF:-

RITU …DECREE HOLDER

THROUGH

SH. AMIT …JUDGMENT DEBTOR

AFFIDAVIT

I, Amit Kumar Malik S/o Sh. Yogender Pal Singh R/o E-

191, Gali No. 10 Khajuri Khas, Karawal Nagar, North

East District-110094, do hereby solemnly affirm and

declare as under:-

1. That the deponent is the judgment debtor in the

above noted execution petition and I am fully

conversant with the facts of the case and competent

to swear this affidavit.

2. That all content of my accompanying objection of

the execution has been drafted by my counsel under

 my instruction and the contents of the same has not

been repeated herein for the sake of brevity and

have been read over and explained to me in

vernacular and are true and correct to my knowledge

and belief.

Deponent

Verification:-

Verified at Delhi on this…… day of Feb, 2023 that

the contents of my above affidavit are true and correct

to my knowledge, no part of it is false and nothing

material has been concealed therefrom.

Deponent