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IN THE COURT OF MS.

SHIVANI CHAUHAN,
METROPOLITAN MAGISTRATE SAKET COURTS, NEW
DELHI
IN THE MATTER OF:
SMT. SAVITA DUBEY

...COMPLAINANT
VERSUS

SMT. SUDHA SHARMA

...RESPONDENT

REPLY ON BEHALF OF THE RESPONDENT TO THE


APPLICATION UNDER SECTION 12 OF DOMESTIC
VIOLENCE
ACT
ON
BEHALF
OF
THE
COMPLAINANT
MOST RESPECTFULLY SHOWETH:
PRELIMINARY SUBMISSIONS:
That the above named respondent most respectfully state
and submit as follows:
1. The Application is liable to be dismissed as it is an
abuse of process of law and the Petitioner has not come
before

this

Hon'ble

Court

with

clean

hands.The

Petitioner is not entitled to any relief as she is guilty of


suppression of true and correct facts.
2. That, the Application filed by the complainant is
baseless, meaningless and not at all maintainable in the
eyes of law, as such, the same is liable to be dismissed.
The

entire

application

has

been

based

on

false

allegations

and

general

allegations

without

any

concrete evidence.
3. That the Respondent was married to Satish Sharma
(since deceased) brother of the complainant in the year
1989 and lived a peaceful married life with her husband
and two daughters namely Mannat and Riddhi till the
death of her husband in the year 2012. That it is
pertinent to mention that at the time of the marriage of
the respondent the financial condition of the in laws of
the respondent was not stable, father was retired ,
daughters were not settled either. kiran sharma was in
pvt

job

in

korean

embassy

and

many

times

respondent alongwith her husband went in the middle


of the night to bring her home, complainant was a hard
core alcoholic nd a heavy smoker. when asked what
these people wanted in dowry, reply was we have
everything but slowly and slowly respondent came to
know that they wanted hard cash as the whole family
had bad habits nd there was a huge pending electricity
bill which nobody in the family took initiative to pay nd
when there was a notice to cut connection, it was paid
by us.from the very beginning satish had said that this
is his house and since everybody is living here without
paying rent small bills at least should be paid by them
but all wanted us to bear all the expenditure of the
house and sometimes it used to become so bad that i
used to shiver while eating. That it is further pertinent

to mention that the respondent was in job even before


her marriage which she continued even after her
marriage and she is due to retire in the year 2016.
4. That the complainant is a lady who is a habitual drinker
and smoker and it was not possible to even stand near
her leave apart talk to her as door door tak uski body se
smell aati thee.

As she was involved in various

relationship with other people since her college days.


That it is respectfully submitted that the complainant is
a lady of outdoor character who never bothered to fulfil
her family obligations due to her involvement in
extramarital relationships and her deep involvement in
smoking and drinking. That it is further submitted that
Complainant along with her husband came to the
matrimonial home of the respondent and started living
with the respondent and never went back despite
repeated request from her husband to take her back.

5. That it is pertinenet to mention that at the time of the


marriage of the Respondent the financial postion of the
in laws of the respondent was very bad therefore
respondent who was already in service/job even before
her marriage financially helped her husband to buy
three plots after marriage with her savings , out of
which two plots were sold out by the husband of the
respondent for managing the affairs of the family of her

in laws in intervals. That it is pertinent to mention that


the third plot was sold off in the year 2008 for the well
being of the real sister of the complainant, child of the
complainant and the mother of the complainant.
6. That it is respectfully submitted as the husband of the
respondent sold all the three plots for the well being of
the family members, including the complainant and her
children which made the complainant to think that her
any demand can be fulfilled by the husband of the
respondent. That with the passage of time complainant
started making unreasonable demand of money for the
well being of her child which was denied by the
husband of the respondent as he had already sold all
the three properties which were in the name of the
husband of the complainant for the well being of the
respondent in laws family members. That feeling
aggrieved by the aforesaid conduct of the respondents
husband conduct complainant along with her real sister
Kiran Sharma started torchering and harassing the
respondent as well as her husband and created an
unfavourable environment in the matrimonial household
of the respondent due to which husband of respondent
who

was

already

suffering

from

chronic

calcific

pancreatitis since july 2007, developed stress ulcers


and fell sick to which he never recovered. It is
respectfully submitted that the complainant was not
aware about her brothers (Satish Sharma husband of

the respondent) ill condition as she was always raising


her own problems so as to harass and extract money
from

the

respondent

under

the

guise

of

her

difficulties/problems. and were also pressurising them


to adopt her son as they had only daughters to which
both of them always
said our daughters are our sons.

7. That it is very pertinent to mention that the major


contribution in the current property i.e. 488, Mandakni
Enclave was contributed by the husband of the
respondent as the aforesaid property was initially
booked in the name of the father in law of the
respondent but it was cancelled due to non payment of
the

booking

amount

thereafter

husband

of

the

respondent paid the entire amount and it was revived


back in the name of the father in law of the respondent
in the year 1985. That it is further submitted that
despite the fact that the major share in the current
property was contributed by the husband of the
respondent, complainant herein, is making a baseless
demand that the aforesaid property be allotted in the
name of the complainant.
8. That it is pertinent to mention that the shares were
purchased by the husband of the respondent and his
family in different joint names and as the value of the
shares kept on increasing the greediness of the

complainant and her real sister, Kiran Sharma, also kept


on increasing. That when the prices of the shares
reached zenith complainant and Kirna Sharma kept all
the shares with them and refused to handover the share
of the husband of the respondent and pressurized the
husband of the respondent to sign on the documents of
the property so as to grab the property in their name.
That as all these shares were purchased by the husband
of the respondent in which the name of the husband of
the respondent also appears as the first or second
shareholder, therefore all these shares are liable to be
transferred in the name of the respondent and her
daughters as the two daughters are at vulnerable stage
and still studying and the respondent is due to retire in
Feb. 2016.

9. That the respondent has been harassed by her mother


in law, complainant and her real sister Kiran Sharma for
dowry

and

the

complainant

has

been

constantly

demanding an amount of Rs. 20,00,000 from the


respondent since 2007 for the settelement of her son.
That when the respondent declined to the aforesaid
demand of Rs. 20,00,000, this false case of domestic
violence has been filed against the respondent so as to
extort the money from the respondent.The only time
respondent's mother in law will not curse her was on

karvachauth.

otherwise

constant

harrassment

was

jhonpri se aayi hai etc.


PARA WISE REPLY
1. That the contents of paragraph number 1 of the
application is a matter of record and needs no reply.
2. That

the

contents

of

paragraph

number

are

misconceived, wrong and are denied. It is denied that


respondent has subjected the complainant to any kind
of physical or mental torture and the respondent along
with her husband has always tried to fulfil the demands
of the complainant and her family members. That the
fact of the matter is that the respondent has been
harassed by the complainant and her family members
for the want of dowry and has always pressurised the
respondent to give an amount of Rs. 20 lacs to the
respondent for the settlement of the respondents son.
3. That with reference to the paragrpagh no. 3 of the
application, the respondent does not admit entire
contentions being totally baseless and meaningless and
false allegation. In addition the respondent is admitting
that the designation of the Mr. K.C. Sharma is correct
but the complainant, her mother and her sister Kiran
Sharma has always used the name and designation of
Mr. K.C. Sharma so as to build their status in

the

society. That the last paragrpagh of the para 3 stating

that the property in question i.e. Property No. 488,


Mandakani Enclave, New Delhi- 1100019 was purchased
by Mr. K.C. Sharma is wrong and incorrect and therefore
it is denied. That it is pertinent to mention that the
major share in the property in question was contributed
by the husband of the Respondent.
4. That the contents of the paragrpagh no. 4 are wrong
and hence denied. The fact of the matter is that the
Complainant was neither divorced nor legally separated
from her husband. That it is respectfully submitted that
the complainant left her matrimonial home because of
her extra marital relationship and her addiction towards
smoking and drinking. That the behaviour of the
complainant was very bad towards her husband and her
in laws due to which complainant was never called back
to her matrimonial home not even at the time of the
death of the husband of the complainant.
5.

That with reference to the contents of the paragrpagh


no. 5 the respondent does not admit entire contentions
being totally baseless and meaningless and false
allegations. In this regard it is submitted that the
complainant has attempted to create concocted stories
against the respondent without any concrete evidence.
That the fact of the matter is that at the time of the
marriage

of

the

respondent

the

family

of

the

complainant was undergoing financial problems to


which failure of marriage of the complainant and the

problem of not getting married her real sister Kiran


Sharma was mountimg huge pressure in the family of
the complainat. That it is further submitted that
respondent never used filthy language to any member
of the complainants family. She heard the word Bitch
first time from the complainants mouth and saw that
her photographs were destroyed and torn from her
husbands. That the complainant feeling frustrated with
her matrimonial life constantly tried to create distrust
and problems between

the respondent and her

husband. That it is wrong and denied that there were


any discord between the respondent and her husband.
That it is respectfully submitted that complainant, her
sister and her mother used to harass the respondent
because all of them were extremely dissatisfied with the
respondent due to her failure to fulfil the huge demands
of their dowry. That it is further submitted that as the
family of the complainant was undergoing financial
problem; complainant and her sister Kiran Sharma
started pressurizing the respondent to give money to
them from her saving of last nine years as well as
started eyeing on her provident fund

so that the

pending bills of the electricity as well as other bills can


be cleared, which infact was later on cleared by the
respondent and her husband only. That it is pertinent to
mention that the complainant and her sister Kiran
Sharma have always been fond of gossiping and
spreading false stories in the neighbourhood so as to

lower down the reputation of the respondent in the


society and always tried to create problems between
the respondent and her husband on even the most
trivial issues by telling lies to the husband of the
respondent.
6. That with reference to the contents of the paragraph
number 6 it is submitted that the contents are wrong,
baseless and therefore denied. That the fact of the
matter is that

on 2nd August, 1990 respondent gave

birth to a girl child namely mannat. That it is pertinent


to mention that at this crucial time of the delivery of her
daughter respondent was kept away from her husband
as complainant and her mother has sent the husband of
the respondent to look after his friend who was not
keeping well due to which respondent had to go to
hospital in the neighbours car and the respondents
demand to call her husband was never put into the ears
of her husband so that the respondent can be kept
away from her husband at the crucial time of her
delivery. That the harassment of the complainant along
with

her

sister

and

mother

increased

after

the

respondent gave birth to a girl child and they called it


as the most unfortunate event of their life because
respondent has given birth to a girl child as against
their wishes to a male child. That as the respondent
gave birth to a female child the complainant and her
family members started making discrimination between

the male child of the complainant and the female child


of the respondent and started giving more preference to
the male child of the complainant. That due to the birth
of the girl child complainant and her mother harassed
the respondent to an extent that she was not allowed to
enter into the kitchen and cook food and was asked to
bring food for herself

from outside. That with the

passage of time as the girl child of the respondent


started growing harassment at the hands of the
complainat and her

family members also started

mounting,they used to throw the belongings of the girl


child and the respondent if they used to keep it at any
place

except

the

room

of

the

respondent;

the

respondent used to turn on the television on a very loud


voice only at the time when the female child of the
respondent sit to study. That the complainant and her
mother have tried to dissuade the respondent and her
daughter from using the common area considering the
house to be their wholesome property.
7. That with reference to the contents of paragraph
number 7 it is submitted that the contents are wrong,
baseless and therefore denied. That the fact of the
matter is that the father of the complainant had
developed heart ailment was infact due to the kind of
environment

which

was

being

created

by

the

complainant and the main reason for the same was that
his two daughters aged 30 and 41 were on his head,

creating unres at home and interfering in their sons


family life. That it is denied by the respondent that she
had ever bolted the door of the toilet in the late night
when the father in law of the respondent wanted to use
the washroom situated on his floor. That the aforesaid
allegation on the respondent has been framed by the
complainant without any concrete evidence. That the it
is denied that at the time when the father in law of the
respondent was admitted in the hospital respondent
went for a holiday. That it is further denied that at the
time when the father in law of the respondent was
hospitalised all the expenses were borne out by the
complainants sister. That it is respectfully submitted
that at this juncture as the husband of the respondent
was wholly looking after his father due to his illness
husband of the respondent went out of business and
therefore sold out the second plot located at Jaitpur
which was purchased by the joint contribution of money
from respondent and her husband so as to take care of
the respondents father in law. complainant as the
respondent has seen in al l these years has not even
once looked after her parents , son or brother , never
ever spent a penny on anyone except demanding with
open hands.what was she doing when her father was
sick? drinking to the hilt and lying down wherever she
wished in a not to be seen position.

finances were

managed by us and not her and her real sister.

8. That with reference to the contents of the paragraph


number 8 of the application, the respondent deny entire
contentions being totally baseless and

meaningless

and false allegations. In this regard it is submitted that


the complainant has attempted to create concocted
stories against the respondent, without any concrete
evidence. That it is respectfully submitted that mother
in law of the respondent fell in the bathroom as she was
very old and was having some problem in walking and
did not fell at the dining table as no one was ever sitting
and eating at the dining table.That it is pertinent to
mention that complainant fell down while travelling by
an auto and no one else other than the husband of the
respondent took her to the hospital despite the fact that
her real sister was also working and she had a grown up
boy having his car. That it is further submitted that in
the end of year 1996 husband of the respondent
assaulted the respondent as the respondent has asked
for divorce as her frustration level reached at its highest
peak due to the harassment which was being imparted
on the respondent by the complainant along with her
sister and mother in law. That the husband of the
respondent caught hold of the neck of the respondent
and pulled her hair as she has asked for divorce
thereafter

mannat

the

child

of

the

respondent

intervened and asked the respondent to go away from


this place so as to protect herself and in order to protect
herself respondent decided to leave her matrimonial

house and respondent husband and Kiran Sharma took


her to her parents house where again kiran sharma
misbehaved with the family though respondent was in
constant touch with her daughter as the respondent
was not allowed to take her daughter along with herself.
9. That with reference to the contents of the paragraph
number 9 of the application, the respondent deny entire
contentions being totally baseless and

meaningless

and false allegations.That it is submitted that as the


husband of the respondent had sold the plot at Jaitpur
at the time of his fathers illness and some money was
saved from the selling of the aforesaid plot husband of
the complainant decided to construct a garage in the
extra space available in the house for his personal use
as office and at all this time respondent contined to
meet her daughter as she was working in GK-II area only
and after sometime husband of the respondent and in
laws

of

the

respondent

realised

their

fault

and

apologized to the respondent and asked the respondent


to come back as there was some extra space available
for

the

privacy

of

their

family

but

there

also,complainant will come and sit to which many a


times mannat asked her, bua kya kaam hai. even at
such a small age she knew everybody needs privacy
sometime orthe other . That it is pertinent to mention
that at the time when respondent was living at her
parents house husband of the respondent used to visit

the house of the parents of the respondent and made


several request to the respondent to come back to her
matrimonial home.
And again a lot of money was spent by the respondent at
this time to make payment to the labour who were given
notice. this time around riddhi was born in july 1998, and
the only person in inlaws was father in law.

10. That with reference to the contents of the paragraph


number 10 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. That it is pertinent


to mention that the husband of the respondent used to
drink even before her marriage to which respondent
was instrumental in getting him to leave his drinking
habbit. That it is further submitted that the husband of
the respondent has tried on a couple of occasions to put
kerosene on himself just to scare the complainant and
her sister so that the harassment which was being
imparted on the respondent by the complainant and her
sister could be stopped but the complainant and her
sister Kiran Sharma instead of stopping the problems
which was being created by both of them they started
shouting by pointing towards the respondent that yeh
humein maar degi. That after the aforesaid incident
respondent again wanted to leave the matrimonial
house along with her daughters but the husband of the
respondent did not let them go stating that is ghar se
jaan a hai to meri laash se hoke jana hoga after which

respondent did not leave. That it is also submitted that


husband of the respondent never lodged a complaint
but the sister of the complainant Kiran Sharma in order
to take a preventive measure herself went to the police
station and lodged a complaint when the husband of
the respondent repeated the same incident again as the
husband of the respondent was forced by Kiran Sharma
to leave the house. That the husband of the respondent
also warned her sisters not to pressurise him to leave
the house as the property in question was bought with
the hard earned money by the husband of the
respondent and he had the Affidavit stating that father
of the husband of the respondent had left the house for
the husband of the respondent which the husband of
the respondent wanted to give to his children. That it is
further submitted that husband of the respondent never
kicked his sisters to move away from home as the
husband of the respondent was very much attached to
his mother and he did not wanted to hurt his mother in
any manner. That it is further submitted that the
complainant has very little knowledge about the health
of the respondents husband as complainant was
always interested in the property of the respondents
husband and nothing else. That the respondents
husband had already told her that he was having some
problem in digestion as his hole of duodenum was small
and was advised a little operation earlier also.It is
pertinent to mention

here

that on 08.02.2009

respondents husband was admitted in private wards of


AIIMS for operation regarding pancreatitis but by gods
grace he was discharged with a warning to quit
smoking. That it is respectfully submitted that the
husband of the Respondent was suffering from the
digestive problems and used to take strong pain killers
even thrice in a day at times since the beginning of the
year 1989.
11. That with reference to the contents of the paragraph
number 11 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. That it is submitted


that husband of the respondent was admitted in the
AIIMS in year 2012 for a period pof 40 days i.e. from
16th Decemeber-26th January 2012, i.e. till the day of
the demise of the respondents husband. That it is
pertinent to mention that in all these 40 days of
suffering respondent was looking her husband alone
without any kind of support neither financially nor
emotionally

from

the

family

members

of

the

complainant and the bill for the medical treatment of


the respondents husband was borne alone by the
respondent only.respondent alongwith her daughters
mannat and riddhi fought for the life of satish but he
was left with no WIll to live as he was being pressurised
by kiran sharma to sign off the property papers to get
the house transferred in her name. since he was

attatched with the house and this was the only asset
made by him for his wife and daughters in the entire
career, he was not able to take this pressure from his
own sister for whom he had done everything as they
were not settled, he fell sick never to recover. in the
hospital, he always asked for his wife's presence despite
her asking him if she can take a break for a day to
which his answer was tu bhi mat aa par in logon ko naa
bhejna. That on 14th January, 2012 husband of the
respondent wanted to go home to take bath as it was
sakranti and respondent took him to his house in her
sisters car as it was very cold at that time but the
behaviour of the complainant her sister and her mother
did not change even at this juncture and the respondent
took her husband back to the hospital as he said to the
respondent sudha mujhe wapis le jaa I am not
able to breathe with these people under this
roof. That the husband of the Respondent also wanted
to take out his Power of Attorney which was given by
the father in law of the respondent in the name of the
Respondents husband but due to his illness he was
unable to take the aforesaid power of attorney in his
possession.
12. That with reference to the contents of the paragraph
number 12 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. That the fact of the

matter is that neither the complainant nor her sister


ever bothered to change their attitude even after the
death of the husband of the respondent and always
used to taunt the complainant that her husband had
died without signing the papers of the property as all of
them since inception wanted to grab the property,
therefore complainanat along with her sister and in
collusion with her mother made a forged will dated
14.06.2012

of

the

property

in

their

favour

and

thereafter started harassing the complainant and her


daughters to move away from the house. That it is
further submitted that complainant and her sister Kiran
Sharma always encouraged their maids to speak in a
foul language and against the respondent which made
it difficult for the respondent to enter into the kitchen;
that against the behaviour of the maids respondent has
made complaint to police even but everytime when
police asked the complainant and her sister to change
their maid they used to reply that wont change their
maid. maid has this liberty to throw the respondents
utensils etc and break them to which kiran sharma
bucks her up with the words very good, she deserves
it.After filing a case with malafide intentions, there
behaviour has become worse thinking they have the
licence now to torture and harrass the respondent as
under.

13. hamare pair parti to kuch de bhi dete, husband ko


maar kar bhi datii hui hai. maa baap bhi nahin le jaate
aisi larki ko. yahan pare hain. jashan mana rahe hain.
14. That with reference to the contents of the paragraph
number 13 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire contents


of paragraph number 13 has been based on false
allegations

and

general

allegations

without

any

concrete evidence.

15. That with reference to the contents of the paragraph


number 14 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire contents


of paragraph number 14 has been based on false
allegations

and

general

allegations

without

any

concrete evidence. That it is also pertinent to mention


that as the complainanat and her family members since
inception wanted to grab the property, therefore
complainanat along with her sister and in collusion with
her mother made a forged will dated 14.06.2012 of the
property in their favour and that the complainant has
made a baseless allegations against the respondent
without specifying the date and number of complaint if
any.

16. That with reference to the contents of the paragraph


number 15 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire contents


of paragraph number 15 has been based on false
allegations

and

general

allegations

without

any

concrete evidence. That the contents of paragraph


number 15 does not say that when various complaints
was made against the respondent.

17. That with reference to the contents of the paragraph


number 16 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire contents


of paragraph number 14 has been based on false
allegations

and

general

allegations

without

any

concrete evidence. In this regard it is submitted that the


complainant has attempted to create concocted stories
against the respondent, without any concrete evidence
and is only repeating the content in a general way in all
the preceeding paragraphs.
18. That with reference to the contents of the paragraph
number 17 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire contents

of paragraph number 14 has been based on false


allegations

and

general

allegations

without

any

concrete evidence. That it is submitted that respondent


has never bolted the door of the kitchen from outside as
most of the time respondent is out of the house and
only time when the respondent is in kitchen is the time
of cooking foof for herself and her daughter and even
that time respondent is harassed by the complainant
and her maids.
19. That with reference to the contents of the paragraph
number 18 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire contents


of paragraph number 18 has been based on false
allegations

and

general

allegations

without

any

concrete evidence. That it is pertinent to mention that


complainant by mentioning the name of the daughters
of the respondent is trying to impute false allegations
against them without their any role in anything.
20. That with reference to the contents of the paragraph
number 18 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire contents


of paragraph number 18 has been based on false
allegations

and

concrete evidence.

general

allegations

without

any

21. That with reference to the contents of the paragraph


number 20 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire content of


paragraph
allegations

number
and

20

has

general

been

based

allegations

on

without

false
any

concrete evidence. That it is pertinent to mention that


respondent does not keep any kind of personal
belongings

in

the

living

room

and

neither

the

respondent nor her daughters used to visit the living


room because of the fact complainant and his son
Hunnar Dubey has put a camera in the living room and
common room as well and started taking videos of the
respondent and her 16 year old daughter and they
mock the respondent and her daughter by saying that
we are recording you. Here respondent is under
constant fear of complainant , kiran sharma,shivani and
hunar dubey who can anyday poison the food which is
made by resp. in the morning for her daughter and is
left on the table, which is fiddled with afterwards when
she leaves for office and nobody from her side is in the
house. HEr things are lying in open and resp. had
already lost many expensive things including jewellery.It
is pertinent to mention
here that resp. whenever wanted to buy furniture, her
inlaws will not allow her but will use the money for their

luxurious living like 24 hours heater in all the rooms of


theirs was one of many luxuries , enjoyed by them.
22. That with reference to the contents of the paragraph
number 21 of the application, the respondent deny
entire

contentions

being

totally

baseless

and

meaningless and false allegations. That it is respectfully


submitted that as the relatives of the respondent are
well settled and are in very good financial condition due
to which complainant started mounting pressure on the
respondent to ask for 20 lakhs from the relatives of the
respondent as complainant would be needing it to settle
his 32 year old son Hunnar against whom a police
complaint had already been registered for misconduct.
That when respondent denied for the same complainant
threatened the respondent that if she would not ask for
the money from her relatives then complainat would
lodge a false case of attempt to kill the son of the
complainant and her sister.

That it further submitted

that son of the complainant has acted violently on


multiple occasions by banging doors at late midnight,
throwing things and has tried to establish dominance by
violent physical gestures and by shouting at the
respondent and on her daughter. That it is also
submitted that son of the complainant does not have
any respect for the complainant and is of extremely
irresponsible nature.
23. That with reference to the contents of the paragraph
number 22 of the application, the respondent deny

entire

contentions

being

totally

baseless

and

meaningless and false allegations. The entire contents


of paragraph number 22 has been based on false
allegations

and

general

allegations

without

any

concrete evidence.
24. That with reference to the contents of the paragraph
number 23 of the application it is submitted that the
content of para no. 23 is a matter of record and
therefore needs no reply.

25. That with reference to the contents of the paragraph


number 24 of the application it is submitted that the
content of para no. 24 is a matter of record and
therefore needs no reply.
PRAYER
It is, therefore, most respectfully prayed that this Honble
Court may be pleased to order:
(a)

That the application under reply made be dismissed

with heavy cost;


(b)

Any other order as this Hon'ble Court may deem fit

and proper in the facts and circumstance of the present


case.

RESPONDENT
Through
ANAND DEY
Advocate for the Respondent
Place: Delhi
Dated: __.11.2014
VERIFICATION
Verified at Delhi on this____day of November, 2014 that the
contents of the above reply to the application under section 12
of the Domestic Violence Act, 2005 from paras 1 to 24 are true
and correct to the best of my knowledge and belief and nothing
material has been concealed or suppressed and no part of it is
false.

RESPONDENT
Place: New delhi
Dated:__.11.2014