IN THE HIGH COURT OF <state> AT <city>

IN THE COURT OF <judge name> Ld. <position in full>

(<type of jurisdiction, if LC/HC)

<case type> NO. <xx/year>

IN THE MATTER OF/BETWEEN/In Re:

If person, <Name> aged <xx>,

s/o OR w/o <name>,
Residing at <address>

If minor, suing through guardian ...Plaintiffs

If company/trust/partnership,
duly incorporated under the <> Act,
having registered office at <address>
through its <authorized rep/director/trustee>
Versus
Same for …Defendants

SUIT FOR DECLARATION, DAMAGES, RECOVERY,

SPECIFIC PERFORMANCE, MANDATORY INJUNCTION,
ETC.
PETITION FOR DIVORCE MADE UNDER SECTION 13(1)(A)
OF THE HINDU MARRIAGE ACT, 1955
PETITION U/ SECTION 9 OF THE HINDU MARRIAGE ACT,
1955, FOR THE RESTITUTION OF CONJUGAL RIGHTS
ADD “REPLY TO” BEFORE THE TITLE
WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

SIR/MA’AM, THE PLAINTIFF MOST RESPECTFULLY SHOWETH: -

Preliminary Objections
A. That the plaintiff has no cause of action.

B. That the suit plaintiff is is barred by limitation.

C. That the plaint is bad for non-joinder of necessary parties.

D. That the plaintiffs are estopped from filing such suit by way of their conduct,
admission, omission.
E. That the plaintiff has suppressed material facts, i.e. approached the court with
laches and unclean hands.

F. That the suit is not maintainable in its current form as the plaintiff does not have
the necessary locus standi to file this suit.

G. That the plaintiff has grossly undervalued the suit and that the court does not have
pecuniary jurisdiction to judge this suit.

H. That the suit is barred for want of notice under Section 80 of the Code of Civil
Procedure Code.

I. That the suit has been filed with the sole purpose of harassing and causing mental
agony to the defendant, and hence it ought to be rejected at the very outset.

Para-wise reply
1. That para no.1 is true and accordingly admitted.

2. That para no.2 are a matter of record require not admission.

3. That para no.3 is wrong and denied completely.

4. That para no.4 is admitted to the extent of the factum of marriage; and everything
else is not admitted for want of knowledge.

5. That para no.5 is wrong and denied.

6. That para no.6 needs no reply.

7. That the para no.7 is not admitted.

PRAYER

In the facts and circumstances of the present case, the plaintiffs most respectfully pray
that this Hon’ble Court may be pleased to pass in favor of the plaintiffs and:-

a) Dismiss the present suit filed by the Plaintiff with exemplary costs; and

b) Pass any and such further order(s) that this Hon’ble Court deems fit in the facts
and circumstances of the present case.

DEFENDANTS

THROUGH

<ADVOCATE NAME>
ADVOCATES FOR DEFENDANTS
<ADVOCATE’S ADDRESS, IN FULL>

PLACE: <place>
DATED: <date>
AFFIDAVIT

I, <defendant’s name>, s/o w/o <name>, aged about <age> years r/o <address> solemnly
affirm and declare as under

1. That the reply has been drafted by my counsel as per my instructions and directions,
after which it has been read over and explained to me in Hindi. I have heard and
understood the contents of the reply which are true and correct and the same may be
treated as part of this affidavit and the same are not being reproduced to avoid
repetition of same facts.

2. That, to the best of my knowledge, the documents attached with the reply are
genuine documents/true copies, which are not forged or fabricated documents in any
manner.

VERIFICATION:

Verified at <place> on <date> that the facts stated in the preceding paras _ to _ of the
above plaint are true and correct to our knowledge and also based on the official
records; and that the contents of paras __ to __ thereof are based upon legal advice
bonafide received from counsel and believed by us to be true and correct.

PLAINTIFFS