IN THE COURT OF HON’BLE DISTRICT JUDGE, CHANDIGRAH.

PETITION NUMBER _________________

Dr.Mansher Singh s/o Randhir Singh

R/0 House No. 46, Garden Colony, near Juhu Beach Mumbai.

……………Petitioner

VERSUS

Sunidhi w/o Dr.Mansher Singh

House No. 30, New green Park, Model Town Jalandhar.

…………….Respondent

WRITTEN STATEMENT UNDER SECTION 13 OF HINDU MARRIAGE ACT 1955

(XXV OF 1955)

It is respectfully submitted as under:-

1. That the respondent admits the contents of para no.1 of petition.

2. That the respondent admits the contents of para no.2 of petition.

3. That the respondent admits the contents of para no.3 of petition.

4. That the respondent admits the contents of para no.4 of petition.

5. That the respondent clearly denies the contents of para no.5 of petition. It is humbly

submitted that petitioner was indeed working in AIMS New Delhi but his job shift was

only from 9:00 AM to 5:00 PM beyond which he was never called upon. The petitioner

used to spend rest of the time in leisure activities. Petitioner never bothered to take care

of the needs of his family or to give any happiness to his wife. Furthermore the money
 sent by the Petitioner to Sunidhi every month was barely sufficient to meet even the basic

needs of the family. Since the day petitioner has left the house it is the only the

respondent who has been taking care of the whole family.

6. That the respondent admits the contents of para no.6 of petition.

7. That the respondent admits the contents of para no.7 of petition.

8. That the respondent admits the contents of para no.8 of petition.

9. That the respondent admits the contents of para no.9 of petition.

10. That the respondent clearly denies the contents of para no.10 of the petition as the

respondent’s phone was never busy. It is further submitted that petitioner never used to

call the respondent. It was always the respondent who used to call the petitioner to know

about his well- being. Moreover the petitioner never used to talk to the respondent

properly.

11. That the respondent clearly denies the contents of para no. 11 of the petition as

respondent has replied to every once in a blue moon phone call of the petitioner. Further

it is submitted that the petitioner used to doubt respondent even on the slightest things

and never talked to her respectfully. It is further submitted that Balveer is resondent’s

brother and respondent honoured this relation in the limits of its decency.

12. That the respondent clearly denies the contents of para no.12 of the petition as the

respondent had never been careless towards her child as she alone has raised the child.

The grandmother out of her love took care of the child, respondent never denied to

perform her motherly duties.

13. That the respondent clearly denies the contents of para no.13 of the petition as respondent

single handedly took care of child whereas the petitioner never cared about the child. The
 petitioner didn’t bother to take care of the baby even when she got ill and it was

respondent who alone took the baby to the child specialist doctor. Also it was only the

respondent who took care of the regular injections and health checkups of the baby.

Petitioner being the father of the child failed to keep up with the basic necessities of the

baby.

14. That the respondent clearly denies the contents of para 14 of the petition as the

respondent never neglected to take care of the child. Respondent gave her best to take

care of the child as well as the family. In spite of the carefree and careless attitude of the

petitioner, the respondent kept quiet and tried to safeguard the nuptial knot by giving the

petitioner more love and affection as much as she can.

15. That the respondent clearly denies the contents of para no.15 of the petition. It is

submitted that a party was organized by respondent to celebrate the birthday of her child

and on this occasion respondent had specially requested the petitioner to come back home

on time. It is further submitted that petitioner did not pay any heed to the request of the

respondent and even after many calls and messages of the respondent, the petitioner

didn’t come back home on time. Rather petitioner reverted the messages of respondent by

saying that he was busy with his friends.

16. That the respondent clearly denies the contents of para no.16 of the petition. It is humbly

submitted that respondent left the house along with her daughter after the end of the party

and not before. The petitioner by claiming that respondent left the house before party is

putting false allegations on the respondent. Further it is denied that respondent had

already booked the tickets especially for the day beforehand. It is submitted that the
 respondent booked the emergency tickets for the journey only after being so much

mentally harassed by the negligent behaviour of the petitioner.

17. That the respondent clearly denies the contents of para no. 17 of the petition. Petitioner

never tried to call or find the respondent. Respondent till the last moment before

departing on the journey kept calling and messaging petitioner all of which went in vain.

18. That the respondent clearly denies the contents of para no. 18 of the petition. The

petitioner never even once tried to find or contact the respondent. Respondent repeatedly

tried to reach the petitioner through calls and messages on which petitioner switched off

his phone. The intention of the respondent was only to go away for few days but

observing the rude attitude of the petitioner, respondent made a decision to completely

stay away and hence asked the petitioner to transfer the sum of 20,000/- per month for the

daughter’s care and maintenance.

19. That the respondent clearly denies the contents of para no. 19 of the petition. Respondent

had no intention to spoil the assignment of the petitioner. Respondent from the very

initial had always intended for the good of the petitioner and his family and therefore

nothing was done by the respondent purposefully. The decision to leave the house was

taken by the respondent only because she was aggrieved by the behaviour of the

petitioner.

20. That the respondent clearly denies the contents of para no. 20 of the petition. The

petitioner did come to Jalandhar the following day but his motive was only to take his

daughter with him. Petitioner never even once asked the respondent to accompany him

back. He clearly ordered the respondent to pack the things of the child and hand over to

him so that he can take the child back. On this respondent requested the petitioner to
 think with the open mind and sort out the matters with her on which the petitioner bluntly

refused. When respondent stopped the petitioner from taking the child, the petitioner

started arguing which ended up with the quarrel between the two. The petitioner pushed

the respondent away from the baby banging her head on the wall and injuring her.

21. That the respondent clearly denies the contents of para no. 21 of the petition. Observing

the violent behaviour of the petitioner, the respondent gathered the courage to push the

petitioner out of the house and close the door so that petitioner could not harm her further

or take away her daughter. After this the respondent requested the petitioner to send the

money for the well-being of the child and threated him that if he would not send the

money, the respondent would file a case on him for injuring her. The petitioner sent

10,000/- to the respondent only because the petitioner wanted to save himself from the

dire consequences of his act of injuring his wife.

22. That the respondent clearly denies the contents of para no.22 as after returning back to

Mumbai the petitioner never even once called the respondent for the two months. The

petitioner never tried to enquire about the well- being of her daughter or her wife.

Petitioner didn’t pay heed to the health, wellness and the needs of her growing daughter.

The daughter was been taken care of single handedly by the respondent. Respondent on

her own managed the injections, nourishment, medical check-ups, clothing and all other

responsibilities of the child.

23. That the respondent clearly denies the contents of para no.23 of the petition. The

petitioner came to meet the respondent only after the continuous requests of the

respondent for the same. The petitioner intimated the respondent that he will come back

to meet her and take his daughter with him.

24. That the respondent clearly denies the contents of para no.24 of the petition. The

petitioner tried to snatch the daughter from the maid on which the daughter started

crying. Further it is submitted that the daughter was not at all in the untidy or the

unhygienic state.

25. That the respondent clearly denies the contents of para no.25 of the petition. The child

was in the pink of her health. Moreover the daughter was staying in hygienic

environment. Daughter was regularly taken by the respondent for the health check-ups

and there was no fear of any chronic disease.

26. That the respondent admits the contents of para no.26 of petition as the respondent indeed

used to go several times to Phagwara but in the search of the job. It is humbly submitted

that it is clearly accepted by the petitioner that he only sent 10,000/ to the respondent for

three months. This mere amount of money was not sufficient to meet the needs of the

baby as well as of the respondent. Therefore in search of the job, the respondent used to

go out several times to Phagwara.

27. That the respondent admits the contents of para no. 27 of the petition. It is humbly

submitted by the respondent that respondent was being helped by her brother Balveer in

order to find a suitable job for her. Therefore they were being seen together from the past

few months.

28. That the respondent admits the contents of para no. 28 to the extent that Balveer came to

drop the respondent in the car. It is denied that respondent had any affair with Balveer.

Balveer was helping the respondent to find the job only out of his respect for the relation

of brother and sister. And most importantly Balveer singh was like a elder brother for the
 respondent who use to support her whenever she was in need of any kind of moral

support.

29. That the respondent admits the contents of para no. 29 of the petition. The petitioner did

not understand the situation rather with his false assumptions went to ask divorce from

the respondent without knowing the real truth. He further very violently blamed the

respondent for having the affair with her brother Balveer and insulted the respondent very

badly. He very cleverly used the situation for his benefit by blaming the respondent for

having the affair. He asked for the divorce from the respondent stating that I want to

enjoy my freedom without any burden of the relations.

30. That the respondent clearly denies the contents of para no. 30 of the petition. It is

submitted that respondent is a women of good repute and would never use such ill

language as has been alleged by the petitioner. Rather petitioner was the only one who

use to make irrelevant statements about the respondent’s character by calling her

characterless and a gold digger.

31. That the respondent clearly denies the contents of para no. 31 of the petition. It is

submitted that the petitioner has never been treated badly by the respondent. It is further

submitted that the respondent has always loved and cared for the petitioner. Moreover the

scenario is that respondent is being deserted by the petitioner and not vice- versa.

32. That the respondent admits the contents of para no.32 of petition.

33. That the respondent admits the contents of para no.33 of petition.

34. That the respondent admits the contents of para no.34 of petition.

35. That the respondent admits the contents of para no.35 of petition.

36. That the respondent admits the contents of para no.36 of petition.
The petitioner therefore prays:

(a). that the Hon’ble court be pleased to dismiss the petition;

(b) that the Hon’ble Court be pleased to declare that the allegations made by the petitioner

against the respondent are baseless, frivolous and hence, not correct;

(b). that the hon’ble Court be pleased to grant permanent custody of daughter to the respondent;

(c). that the costs of the written statement may be awarded;

(d). that any other relief, which may be proper in the interest of the justice, equity and good

conscience may be provided.

PLACE: CHANDIGRAH

DATE: RESPONDENT

THROUGH COUNSEL

VERIFICATION:

Verified that the contents of the above written statement are true and correct to the best of my

knowledge and nothing has been concealed therein.

Verified at Chandigarh

On _________________ Respondent
 IN THE COURT OF DISTRICT JUDGE, CHANDIGARH

AFFIDAVIT

I, Sunidhi w/o Dr. Mansher Singh, aged about 25 years, occupation household, do hereby

solemnly affirm and declare as under:-

1. That the deponent is the respondent in the captioned suit. I am fully conversant with the

facts of the written statement and competent to swear this affidavit on my behalf.

2. That the present written statement has been drafted by my counsel under my instructions

and guidance and the contents of the same are true and correct and are not being repeated

herein for the sake of brevity and to avoid repetition and prolixity.

3. That the contents of the written statement may kindly be read as part and parcel of this

Affidavit also.

DEPONENT

VERIFICATION

I ……………………………, the respondent, above named do hereby solemnly state and declare

that the contents of para 1 to para 36 are true to my own knowledge and the contents of the

remaining paras are based on the information supplied to me and I believe the same to be true.

DEPONENT