Gautam Sikka 25-07-2022 WS

IN THE COURT OF SH. SANGHMITRA, LD. M.M.
,
DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI
IN RE :- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant
Versus
Shri Gautam Sikka & Ors. …Respondents
D.O.H. 06.08.2022
WRITTEN STATEMENT ON BEHALF OF THE

RESPONDENTS TO THE COMPLAINT UNDER
SECTION 12 READ WITH SECTION 18, 19, 20 AND
22 OF PROTECTION OF WOMEN FROM DOMESTIC
VIOLENCE ACT, 2005 FILED BY THE COMPLAINANT .
---------------------------
MOST RESPECTFULLY SHOWETH :-
PRELIMINARY OBJECTIONS:-
1. That the marriage between the respondent
no.1 and the complainant was solemnized
on 21-02-2018 according to Hindu Customs
and Rites at The Grand Dreams Banquet,
16, Shivaji Marg, Main Najafgarh Road
Industrial Area, Delhi-110015 in a simple
manner without any demand of dowry.

Hence the application is liable to be
dismissed with heavy costs.
2. That the marriage both the parties resided
together as husband and wife at House No.
3205, 2nd Floor, Sector 57, Gurgaon, where
the marriage was duly consummated
between the parties and one male child
namely Paarth Juneja has been born out
from this wedlock on 13-10-2019. Hence the
application is liable to be dismissed with
heavy costs.
3. That since beginning of the marriage, the
complainant remained under the influence
of her parents and under their influence she
always making the quarrel and abusing with
the respondents and she was also used to go
and back her parental house without giving
any information to the respondents. Hence
the application is liable to be dismissed
with heavy costs.
4. That both the parties living at the said
address, after sometimes the complainant

started misbehaved, insulted, tortured,
harassed physically and mentally to the
respondents. Hence the application is liable
to be dismissed with heavy costs.
5. That after the marriage the respondents
paid full love and regard to the
complainant, which is expected to a newly
married bride and the respondent no.1 also
following all the instructions of the
complainant but the complainant never
understand the feelings of the respondent
no.1. Hence the application is liable to be
6. That the respondent no.1 has given all love
and affection and respect to the
complainant, since the marriage in the
matrimonial home but the complainant did
not discharged her matrimonial duties and
obligations faithfully and she harassing and
humiliating the respondent no.1. Hence the
heavy costs.
7. That the complainant did not do any
domestic work and the complainant has
been threatening the respondent no.1 to
implicate in false cases as well as dowry
and file false complaint in the police station
against the respondent no.1. Hence the
heavy costs.
8. That the complainant and her family
members used to cruelty with the
respondents and they misguided and
instigated the complainant against the
respondent no.1 before friends and relatives
and the respondent no.1 tried to understand
the complainant and her family members
but they did not listen anything and not
improve their attitude and behaviour
towards the respondents. The complainant
was in habit to search the silly points to
raise and quarrel with the respondent no.1
and the parents of the complainant also
instigated her against the respondents on

phone. Hence the application is liable to be
9. That during the stay at her matrimonial
house, most of time the complainant used to
talk with her parents on phone. Hence the
heavy costs.
10. That the complainant used to make the
quarrel with the respondents day by day
and threatened to reopen the case by saying
that “Tum Logon Ko Nahi Pata Ki Aaj Main
Jo Bhi Jhoothe Aarop Laga Dungi Aur Police
or Court Bhi Meri Hi Baat Manegi”. The
complainant is also used to give filthy and
abusive language to the respondents by
saying that “Main Chahu To Tumhara
Budapa Jail Me Kata Dungi ” and the
complainant also demanded the money from
the respondents. Hence the application is
liable to be dismissed with heavy costs.
11. That the respondents tolerated all her
atrocities, mental agony, physical agony,

harassment, cruelties caused by the
complainant since the marriage yet he
tolerated all these atrocities to tie intact
the matrimonial relations but of no avail.
12. That the respondent no.1 as well as the
complainant are not having the physical/
sexual relations since ___________ and are
not co-habited with each other since
__________ and lastly resided together in
Gurgaon at the given address. The
respondent no.1 has been ruined forever by
the complainant and his life is being
deserted since 03.06.2020 continuously by
the complainant and there are no
possibilities to live together at any corner
due to the cruel acts of the respondent no.1
and every possibilities has become in end,
so the petition is being filed but now every
possibilities has been ended and the
complainant had threatened to implicate the

respondents in the criminal cases which is
also the part of cruelties and by the above
said cruelties the respondent no.1 has
received the mental and physical agony and
also have lost the faith of his matrimonial
life and is not able to live together. The life
of the respondent no.1 is being deserted by
the cruel acts of the complainant since 26-
11-2021 continuously. Hence the
heavy costs.
13. That due to constant cruel and callous conduct
on the part of complainant and threat to the
life of the respondent no.1 from the
complainant and her family members it has
become practically impossible for the
respondent no.1 to live in the company of the
complainant. Hence the application is liable
to be dismissed with heavy costs .
14. That the respondent no.1 has not been
afforded with any opportunity to reconcile the
differences with the complainant in any

manner and that the complainant was hell
bent on sending the respondent no.1 to
judicial custody there is little scope for the
respondent no.1 to condone the acts of
cruelty by the complainant. Hence the
heavy costs
15. That the complainant has suppressed all
true and material facts before this Hon’ble
Court who is liable to be prosecuted for
submitting the wrong facts before this
Hon’ble Court, who has cooked up a wrong
story to get the sympathy from this Hon’ble
Court, hence the application is liable to be
dismissed.
16. That the present application is otherwise,
false, frivolous and vexatious and is without
any cause of action. It is stated that the
allegation and demands as made in the
application are baseless, misconceived,
concoctions, fabrication and product of evil
mind of the complainant. No cause of action

arose in favour of the complainant and
against the respondents. The case being
without cause of action merits dismissal.
Moreover, the information which has been
provided by the complainant in this
application, which is not based on any
evidence and is a mere concocted story of
the complainant just to falsely implicate the
respondents and to extort money from the
respondents, hence the application is liable
to be rejected.
17. That the complainant has not come to this
Hon’ble Court with the clean hands and she
has suppressed the true facts and
misrepresented before this Hon’ble Court,
thus the complainant is not entitled to any
relief as claimed, hence the application is
liable to be rejected.
18. That the present application is abuse to the
process of law. The complainant is simply
harassing and humiliating the respondents
as the complainant has never been to any

type of harassment and torture by the
respondents and therefore seeing the
interest of justice, this Hon’ble Court
should take the matter with the intention of
providing justice by the order by
appreciating the evidence and by dismissing
this suit which has been providing by the
above said application, hence the
application is liable to be rejected.
19. That the present application is bundle of
lies, the plaintiff has suppressed all true
and material facts and is liable to be
prosecuted as he has tried to hide her
wrongs and has filed the present application
without any cause and to harass the
respondents to put a pressure to hide her
wrongs, hence the application is liable to be
rejected.
20. That the respondents cannot take advantage
of his own wrongs and the present
application has been filed against the
respondents just to create unnecessary

pressure to him and wants to extort the
money from the respondents, as such the
application is liable to be dismissed .
REPLY ON MERITS:-
1. That the contents of para no.1 of the
application are matter of record, need no
reply.
2. That the contents of para no.2 (a to f) of the
application are wrong and denied. It is
submitted that the complainant filed the
present case on the basis of totally false
and incorrect facts, therefore the
complainant is not entitled to get any relief.
3(i). That the contents of para no.3(i) of the
present case on the basis of totally false and
incorrect facts, therefore the complainant is
not entitled to get any relief under the
provisions of Section 18 of D.V. Act.
(ii). That the contents of para no.(ii) of the
application are wrong. It is submitted that

the complainant filed the present case on
the basis of totally false and incorrect facts,
therefore the complainant is not entitled to
get any relief under the provisions of
Section 19 of D.V. Act.
(iii) That the contents of para no.(iii) of the
complainant is not entitled to get any relief
under the provisions of Section 20 of D.V. Act.
(iv) That the contents of para no.(iv) of the
complainant is not entitled to get any relief
under the provisions of Section 22 of D.V. Act.
application need no reply.

application need no reply.
The prayer clause of the complaint is wrong
and denied. It is submitted that the complainant
has not come to this Hon’ble Court with clean
hands and have suppressed all true and
material facts before this Hon’ble Court, who is
liable to be prosecuted and is not entitled for
any relief.
It is, therefore, prayed that the present
complaint may kindly be dismissed with heavy
cost, in favour of the respondents and against
the complainant, in the interest of justice.
Delhi RESPONDENTS
Dated:
Through
(ANURAG SHARMA & GAURAV SRIVASTAVA)

ADVOCATE
M. 8920503527, 9811312468
E. Mail: legalrights0001@gmail.com
VERIFICATION
I the above named deponent do hereby
solemnly affirm and declare that the contents of
Para No.1 to 4 of Reply on Merits are true and

correct to my knowledge and the contents of
Paras No.1 to 20 of Preliminary Objections are
true to the information received and believed to
be true. Last Para is Prayer to this Honble
Court.
Verified at Delhi on this ___ Day of August,
2022.
RESPONDENTS
IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Versus
AFFIDAVIT
I, Gautam Sikka S/o Shri Ashok Sikka R/o
House No.3205, Second Floor, Sector- 57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 1 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g W r itte n S ta te me n t h as
b e en d ra f te d b y my c o u n s e l u nd e r my in s tr u c tio n s
a nd th e c on te n ts o f th e s a me ar e tr u e an d c o r r e c t
a nd th e sa me ma y k ind ly be r ea d a s p ar t a nd
p ar c e l o f th is a f f ida v it.
DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.
DEPONENT


IN THE MATTER OF :-
Versus
AFFIDAVIT
I, Rekha Sikka W/o Shri Ashok Sikka R/o
u nd e r : -
DEPONENT
VERIFICATION
DEPONENT


IN THE MATTER OF :-
Versus
AFFIDAVIT
I, Ashok Sikka S/o Not Known R/o House
No.3205, Second Floor, Sector-57, Gurgaon,
u nd e r : -
DEPONENT
VERIFICATION
DEPONENT


IN THE MATTER OF :-
Versus
D.O.H. 06.08.2022
REPLY ON BEHALF OF THE RESPONDENTS TO

THE DOMESTIC INCIDENT REPORT FILED BY
THE COMPLAINANT.
---------------------------
1. That the marriage between the respondent
no.1 and the complainant was solemnized
on 21-02-2018 according to Hindu Customs
and Rites at The Grand Dreams Banquet,
16, Shivaji Marg, Main Najafgarh Road
Industrial Area, Delhi-110015 in a simple
manner without any demand of dowry.
2. That the marriage both the parties resided
together as husband and wife at House No.
3205, 2nd Floor, Sector – 57, Gurgaon,
Haryana - 122002, where the marriage was
duly consummated between the parties and

one male child namely Paarth Juneja has
been born out from this wedlock on 13-10-
2019. Hence the application is liable to be
3. That since beginning of the marriage, the
complainant remained under the influence
of her parents and under their influence she
always making the quarrel and abusing with
the respondents and she was also used to go
and back her parental house without giving
any information to the respondents. Hence
the application is liable to be dismissed
with heavy costs.
4. That both the parties living at the said
address, after sometimes the complainant
started misbehaved, insulted, tortured,
harassed physically and mentally to the
respondents. Hence the application is liable
to be dismissed with heavy costs.
5. That after the marriage the respondents
paid full love and regard to the
complainant, which is expected to a newly

married bride and the respondent no.1 also
following all the instructions of the
complainant but the complainant never
understand the feelings of the respondent
no.1. Hence the application is liable to be
6. That the respondent no.1 has given all love
and affection and respect to the
complainant, since the marriage in the
matrimonial home but the complainant did
not discharged her matrimonial duties and
obligations faithfully and she harassing and
humiliating the respondent no.1. Hence the
heavy costs.
7. That the complainant did not do any
domestic work and the complainant has
been threatening the respondent no.1 to
implicate in false cases as well as dowry
and file false complaint in the police station
against the respondent no.1. Hence the

heavy costs.
8. That the complainant and her family
members used to cruelty with the
respondents and they misguided and
instigated the complainant against the
respondent no.1 before friends and relatives
and the respondent no.1 tried to understand
the complainant and her family members
but they did not listen anything and not
improve their attitude and behaviour
towards the respondents. The complainant
was in habit to search the silly points to
raise and quarrel with the respondent no.1
and the parents of the complainant also
instigated her against the respondents on
phone. Hence the application is liable to be
9. That during the stay at her matrimonial
house, most of time the complainant used to
talk with her parents on phone. Hence the

heavy costs.
10. That the complainant used to make the
quarrel with the respondents day by day
and threatened to reopen the case by saying
that “Tum Logon Ko Nahi Pata Ki Aaj Main
Jo Bhi Jhoothe Aarop Laga Dungi Aur Police
or Court Bhi Meri Hi Baat Manegi”. The
complainant is also used to give filthy and
abusive language to the respondents by
saying that “Main Chahu To Tumhara
Budapa Jail Me Kata Dungi” and the
complainant also demanded the money from
the respondents. Hence the application is
liable to be dismissed with heavy costs.
11. That the respondents tolerated all her
atrocities, mental agony, physical agony,
harassment, cruelties caused by the
complainant since the marriage yet he
tolerated all these atrocities to tie intact
the matrimonial relations but of no avail.

12. That the respondent no.1 as well as the
complainant are not having the physical/
sexual relations since ___________ and are
not co-habited with each other since
__________ and lastly resided together in
Gurgaon at the given address. The
respondent no.1 has been ruined forever by
the complainant and his life is being
deserted since __________ continuously by
the complainant and there are no
possibilities to live together at any corner
due to the cruel acts of the respondent no.1
and every possibilities has become in end,
so the petition is being filed but now every
possibilities has been ended and the
complainant had threatened to implicate the
respondents in the criminal cases which is
also the part of cruelties and by the above
said cruelties the respondent no.1 has
received the mental and physical agony and

also have lost the faith of his matrimonial
life and is not able to live together. The life
of the respondent no.1 is being deserted by
the cruel acts of the complainant since 26-
11-2021 continuously. Hence the
heavy costs.
13. That due to constant cruel and callous conduct
on the part of complainant and threat to the
life of the respondent no.1 from the
complainant and her family members it has
become practically impossible for the
respondent no.1 to live in the company of the
complainant. Hence the application is liable
to be dismissed with heavy costs .
14. That the respondent no.1 has not been
afforded with any opportunity to reconcile the
differences with the complainant in any
manner and that the complainant was hell
bent on sending the respondent no.1 to
judicial custody there is little scope for the
respondent no.1 to condone the acts of

cruelty by the complainant. Hence the
heavy costs
15. That the complainant has suppressed all
true and material facts before this Hon’ble
Court who is liable to be prosecuted for
submitting the wrong facts before this
Hon’ble Court, who has cooked up a wrong
story to get the sympathy from this Hon’ble
Court, hence the application is liable to be
dismissed.
16. That the present application is otherwise,
false, frivolous and vexatious and is without
any cause of action. It is stated that the
allegation and demands as made in the
application are baseless, misconceived,
concoctions, fabrication and product of evil
mind of the complainant. No cause of action
arose in favour of the complainant and
against the respondents. The case being
without cause of action merits dismissal.
Moreover, the information which has been

provided by the complainant in this
application, which is not based on any
evidence and is a mere concocted story of
the complainant just to falsely implicate the
respondents and to extort money from the
respondents, hence the application is liable
to be rejected.
17. That the complainant has not come to this
Hon’ble Court with the clean hands and she
has suppressed the true facts and
misrepresented before this Hon’ble Court,
thus the complainant is not entitled to any
relief as claimed, hence the application is
liable to be rejected.
18. That the present application is abuse to the
process of law. The complainant is simply
harassing and humiliating the respondents
as the complainant has never been to any
type of harassment and torture by the
respondents and therefore seeing the
interest of justice, this Hon’ble Court
should take the matter with the intention of

providing justice by the order by
appreciating the evidence and by dismissing
this suit which has been providing by the
above said application, hence the
application is liable to be rejected.
19. That the present application is bundle of
lies, the plaintiff has suppressed all true
and material facts and is liable to be
prosecuted as he has tried to hide her
wrongs and has filed the present application
without any cause and to harass the
respondents to put a pressure to hide her
wrongs, hence the application is liable to be
rejected.
20. That the respondents cannot take advantage
of his own wrongs and the present
application has been filed against the
respondents just to create unnecessary
pressure to him and wants to extort the
money from the respondents, as such the
application is liable to be dismissed.
REPLY ON MERITS:-
Domestic Incident Report are matter of
record, need no reply.
Domestic Incident Report are matter of
record, needs no reply.
Domestic Incident Report are partly
admitted and partly denied. It is specifically
denied that the respondent no.1 is working
as Senior Manager (OCC) at Indigo Airlines
and the last salary known to the
complainant was Rs.1,25,000/- per month.
It is submitted that the true and correct
facts have already been mentioned in the
preliminary objections and the contents of
the same may kindly be read as part and
parcel of the reply of para under reply and
the contents of the same are not repeated
herein for the sake of brevity.
Domestic Incident Report are wrong and

denied. It is specifically denied that the
respondent no.1 sister continuously and
persistently followed up and convinced the
complainant and her family member for the
marriage. It is specifically denied that the
respondent further assured and conveyed to
the complainant’s that the respondent
family would ensure at any cost that the
complainant would have no hindrances
whatsoever and she would continue her job
and that to the respondent’s family will help
in the same regards. It is specifically denied
that it was further ensured to the
complainant and her parent that the
respondent no.1 hails from educated and
respected family and they have very good
reputation in the society. It is specifically
denied that it was further conveyed that the
respondents are not money minded and want
the complainant to be their Daughter-in-
law. It is specifically denied that the
complainant very transparently told about

herself to the respondents. It is specifically
denied that the complainant also conveyed
the fact that her parents are dependent on
her and the complainant’s father has
Neurological Problems therefore, a sum of
Rs.5,000/- monthly expenditure in incurred
on account thereof. It is specifically denied
that the respondents assured that they have
no issues at all and further extended
assurance that the complainant is that
liberty to take care of her parents in all the
ways. It is specifically denied that it was
presented by the respondents that their
families are well mannered and respectable
person. It is specifically denied that the
respondent’s family was impressed upon the
complainant’s parents and the complainant.
It is specifically denied that the
respondents eyes was on the complainant’s
salary and her property. It is submitted that
the true and correct facts have already been
mentioned in the preliminary objections and

the contents of the same may kindly be read
as part and parcel of the reply of para
under reply and the contents of the same
are not repeated herein for the sake of
brevity.
marriage was a very lavish affair for the
complainant’s parents since as per the
direction of the respondent no.1 and his
parents, very large sum of money was spent
beyond the capacity of parents of the
complainant. It is specifically denied that
on demand of the respondent no.1 and his
parents, the complainant’s parents had
spent around Rs.10,00,000/- in the
marriage. It is specifically denied that on
the other hand the complainant parents had
given jewellery to the respondent no.1. It is
submitted that the true and correct facts
have already been mentioned in the

denied. It is specifically denied that despite
the aforesaid, the respondent no.1 along
with the respondent no.2 to 3 after the
marriage used every opportunity to
complaint that the parents of the
complainant had not solemnized the
marriage as per their status and that a lot
had been left to the desired and spent on
the marriage by the complainant’s parents,
inspite of the fact that the complainant’s
parents had met all the demands of the
respondent no.1 and his family, the greed of
the respondents were never fulfilled. It is
specifically denied that in pursuance
thereof, after the marriage the attitude of

the respondent no.1 and other respondents
towards the complainant and her family
members were not cordial, as the
respondents always dominated the
complainant and her parents. It is
specifically denied that on the other hand,
on account of not bringing dowry, the
complainant had been a victim of extreme
mental abuse, physical assault and
domestic violence at the hand of the
respondent no.1 to 3. It is specifically
denied that the complainant was treated
miserably by her in law despite the fact that
the parents of the complainant had tried to
fulfill all the demands raised by the
respondent no.1 and his family. It is
specifically denied that the respondent no.1
as a matter of routine used to use filthy and
abusive language at home and the
complainant was subjected to verbal abuse
within few days of marriage. It is submitted
that the true and correct facts have already

been mentioned in the preliminary
objections and the contents of the same may
kindly be read as part and parcel of the
reply of para under reply and the contents
of the same are not repeated herein for the
sake of brevity.
matrimonial home is supposed to serve as a
form of support and bring relaxation from
life’s many struggles and agony, whereas in
the present case all the respondents at
matrimonial home had filled the
complainant’s life with fear and trepidation.
complainant restrained herself from taking
help of law against all the respondents on
account of fear of further violence, fear of
losing home, fear of loneliness and hope
that things would change with time and the
complainant was also compromising with

the situation so, that with time the
respondent no.1 would accept her as his
wife and the respondent no.2 and 3 will
accept her as their respected daughter-in-
law. It is specifically denied that all the
efforts made by the complainant went in
vain and the complainant continued to face
violence at the hands of all the respondents.
It is specifically denied that the fear of
violence was very imminent and dangerous
that the complainant was all the time living
under extreme stress and anxiety. It is

complainant had been subjected to cruelty,
physical assaults, mental torture, emotion
insult, threats, social abuse, psychological
abuse and economic deprivation at the
hands of all the respondents. It is
a. That the contents of para no.a of the
complainant met with the surprise on the
day of marriage when somebody ask the
respondent no.1 that “Kya ye ladki tumhari
choice hai … then respondent no.1 replied
ab kya fark padta hai ab to jo hona tha ho
gaya”. It is submitted that the true and
correct facts have already been mentioned

in the preliminary objections and the
contents of the same may kindly be read as
part and parcel of the reply of para under
reply and the contents of the same are not
repeated herein for the sake of brevity.
b. That the contents of para no.b of the
respondents being family members were
used to sleep in the same room, however,
just after marriage the respondent no.1
pressurized the complainant and asked the
complainant to sleep with the family. It is
asked “apne saath mummy ko bhi bech me
sula le kya … The complainant got surprised
and requested with folded hand that the
same would not be possible as the
complainant will feel very uncomfortable. It
is specifically denied that there were three
bed rooms in the house. It is specifically
denied that the respondent for the ulterior

purpose tortured the complainant on the
said issues. It is specifically denied that in
the initial days the respondent no.1 does
not consummates the marriage with the
the respondent no.2 used to sleep on
mattress just outside the bedroom of the
complainant and the respondent no.1. It is
restrained the complainant to close the door
of their bedroom. It is submitted that the
true and correct facts have already been
brevity.
c. That the contents of para no.c of the
Domestic Incident Report are partly
admitted and partly denied. It is specifically
denied that after came back from

honeymoon the respondent no.1 had again
refused to develop any relationship with the
complainant and used to sleep at the corner
of the bed. It is submitted that the true and
d. That the contents of para no.d of the
respondent no.1 is of very aggressive nature
and use to quarrel on very pity issues such
as “why did the complainant, left the towel
on the bed?” “why did she not keep the
glass of water back in the kitchen after
using ? etc.”. It is submitted that the true
and correct facts have already been

brevity.
e. That the contents of para no.e of the
respondent no1. Is a habitual drinker. It is
often used to come late night to home after
drinking. It is specifically denied that 10-
03-2018 the complainant tried to convince
him not to drink regularly. It is specifically
denied that the respondent no.1 turned
around and scolded and abused the
complainant by saying “Behanchod Bass
Apne Kaam Se Matlab Rakh”. It is
had clearly told the complainant that “Mai
Piunga Jo Ukhadna Hai Ukad Le” and
further told her that “Tere Baap ka Nahi
Pita”. It is specifically denied that to the

height of the surprise the respondent no.2
instead of controlling the respondent no.1
was instigating him by saying that “Sab Teri
Galti Hai, Teri Wajah Se Hi Toh Pita Hain,
Bichara Depression Mein Aa Gaya Hain Teri
Jaisi Pagal Aurat Se Shaadi Karke”. It is
f. That the contents of para no.f of the
denied. It is specifically denied that on the
very next morning the respondent no.2 was
trying to convince the complainant by
stating that “uske Liye Uske Jaisi Bano Aur
Humare Liye Humare Jaise Bano”. It is
further said that “either you live with him

or leave him but he will not stop drinking”.
g. That the contents of para no.g of the
denied. It is specifically denied that after
marriage the parties were invited by the
relative of the respondent for dinner. It is
specifically denied that the relatives had
given some money to the complainant in the
name of Shagun. It is specifically denied
that the complainant had kept the money in
her Almira. It is specifically denied that
after few days, when the complainant was in
dire need of the money, she could not find
the money in the Almira and therefore asked
the respondent no.1. It is specifically

denied that the respondent no.1 without any
occasion started scolding the complainant
by abusive language like Behenchod, Kuti
etc. teri himmat kaise hui puchane ki. It is
specifically denied that having left with no
other option the complainant had neglected
the complete situation and never discussed
the said issue ever again. It is submitted
sake of brevity.
h. That the contents of para no.h of the
complainant was then getting salary of
Rs.47,000/- in hand. It is specifically
denied that on the other side the
respondent no.1 was then getting

Rs.90,000/- per month. It is specifically
denied that the respondents from the next
day of marriage were making every endeavor
to take the entire salary from the
the respondent no.1 said “Maine Tujhse Ye
Soch ke Shaadi Ki Thi Ki Tu Mujeh 20000-
25000 Rupaiye Har Mahine Degi, Tere Aane
Se Mere Ghar Ka Kharcha Badh Gaya Hai”.
It is specifically denied that in pursuance
thereof, firstly the respondents pampered
the complainant and when the complainant
denied to hand over the entire salary, the
attitude of the respondents had suddenly
changed. It is specifically denied that
thereafter, they were in one how or the
other hand started to pressurizing the
complainant for her salary. It is specifically
denied that the complainant had submitted
herself completely to the respondents and
for their happiness. It is specifically denied
that the respondent’s eyes are at her

income. It is specifically denied that on
account thereof the physical and mental
torture had increased since then. It is
specifically denied that the complainant
used to expend her salary in her
matrimonial family. It is specifically denied
that despite the said fact the greed of the
respondents was never satisfied and they
were bound on to take the entire salary in
their hands. It is specifically denied that on
some occasion the respondent no.2 and 3
abused the complainant with dirty language
like “Apne Yaar p urati h etc.”. It is
i. That the contents of para no.i of the

respondent no.1 always used to quarrel on
the said issue and even forced the
complainant to leave the house. It is
specifically denied that in April May 2018
the respondent no.2 told the complainant
that the respondent no.1 never wished to
marry her. It is specifically denied that the
respondent no.2 further stated to the
complainant that “Mera Beta Tujse Shaadi
Nahi Karna Chahta Tha Tab Maine Usko
Dhamki Di Ki Agar Tu Ish Se Shaadi Nahi
Karega Toh Mai Suicide Kar Lungi, Tab Ja
Kar Vo Tumse Shaadi Karne To Tayar Hua”.

j. That the contents of para no.j of the
attitude of the respondent no.3 is very
offended for the complainant. It is
used to sit in the complainant room until
11:00 P.M. at night. It is specifically denied
that the most unfortunate situation was
when the complainant after coming to the
home form the office could not even get a
movement to rest on account thereof. It is
never got any opportunity to have privacy in
her room. It is submitted that the true and

k. That the contents of para no.k of the
respondent no.1 use to neglect and insult
the complainant. It is specifically denied
that the complainant after getting off from
her office use to call the respondent no.1 so
that she could accompany him to the home.
It is specifically denied that the respondent
no.1 always used to say that he is busy in
the office work and cannot accompany with
her. It is specifically denied that the
respondent no.1 used to come to the house
at middle of the night after heavy drinking.

l. That the contents of para no.l of the
respondent no.2 & 3 used to sleep in the
complainant’s room whenever the
respondent no.1 had night shift, the reason
given by the respondents was that the AC’s
bill will be saved. It is specifically denied
that the complainant started that she is
comfortable with non-ac room however, the
respondent no.1 used to insist to sleep with
the respondent no.2 & 3. It is specifically
denied that there were many occasions
where the complainant used to find herself
in a very awkward situation. It is submitted
sake of brevity.
m. That the contents of para no.m of the
complaint heard the respondent no.2 stating
to the respondent no.1 that “Ek Bacha Paida
Karwa Do Tab Yeh Hath Mai Aa Jaegi”. It is
had entered into physical relationship with
the complainant. It is specifically denied
that to the height of surprise there were no
love and emotion during sexual intercourse.
It is specifically denied that the respondent
no.1 only did it that particular which is
required for pregnancy. It is submitted that
the true and correct facts have already been
brevity.
n. That the contents of para no.n of the
complainant got pregnant in the month of
June, 2018. It is specifically denied that the
complainant had informed about the same
to her parents. It is specifically denied that
the respondent no.1 & 2 started to abuse
the complainant by saying that “pregnancy
humare yaha par teen mahine ke baad batai
jati hai”. It is specifically denied that the
respondent’s never use to take care of the
complainant health during the pregnancy
period and that to they never missed any
occasion to taunt and disgrace the
complainant even in front of the relatives. It
is specifically denied that during the
pregnancy the complainant had health
issues and had to climb two floors to reach
home and after coming back from work,
climbing the stairs was a vey difficult task
for her. It is specifically denied that the

respondent no.3 used to dictate orders to
the complainant right after she use to enter
the home and whenever she requested for
some rest, they use to taunt and abuse her
by stating things like “Jaise pahad chadh
kar aai hai” “Tu pehli aurat bacha kar rahi
hai duniya ai” “Jara haath hila liya kar,
aise bahu ko log ghar se nikal dete hain ”. It
is submitted that the true and correct facts
o. That the contents of para no.o of the
complainant throughout the pregnancy had
to visit alone to the gynecologist. It is
specifically denied that on one day on
request of the complainant, the respondent

no.1 agreed to go to the gynecologist along
with the complainant to the heights of the
surprise, the respondent no.2 came along
with them. It is specifically denied that
when the doctor called the complainant
inside the doctor room, the respondent no.1
completely refused stating that ” Mujhe ulti
ah jaegi” and when the complainant insisted
the respondent no.1 had abused the
complainant in front of everybody and the
respondent no.2 instigated was him . It is
p. That the contents of para no.p of the
respondent no.2 used to tell the

complainants to ask her parents for money
and even grocery such as rice, pulses, ghee,
etc. and to keep everybody happy in the
matrimonial house. It is specifically denied
that the complainant’s parents use to fulfill
all of their demands. It is specifically
denied that the greed of the respondents
was not satisfied and the demands kept on
increasing. It is specifically denied that the
respondent no.3 use to continuously taunt
the complainant and use to compare her
with “Shreya”. It is specifically denied that
the respondent no.3 also told the
complainant to become like Shreya
(Daughter-in-law of his sister) who gets
gifts and foreign fruits for her in-laws. It is
specifically denied that on many instances
the respondent no.3 had given an example
of Brinda (daughter of his sister) who is
being tortured in her matrimonial house. It
is specifically denied that the respondent
no.2 told the complainant to become like

Brinda who is following all the dictate of
her in-law. It is specifically denied that the
respondent no.3 also told the complainant
that “Bahu Ko Sab Kuch Jhelna Padtha Hai,
Sehna Padtha Hai, Aur Agar Meri Maa Zinda
Hoti Toh Tujhe Batati Ki Bahauo Ko Kaise
Rakha Jata Hai Hamare Ghar Mai”. It is
q. That the contents of para no.q of the
denied. It is specifically denied that in
June-July, 2018 the respondent no.3 was
talking to my father over call. It is
continuously taunted and also said that
“Apne Apni Bethi Ko Bass Padhai Karai Hai

Aur Kuch Nahi Shikhaya”. It is specifically
denied that in the month of June-July,
2018, the complainant had fruits cravings
during pregnancy therefore, she had
requested the respondent no.1 for the same.
It is specifically denied that in replied the
respondent no.1 told her that he does not
have money to fulfill her requests. It is
specifically denied that on the same time he
was drinking and eating non-veg. it is
told the said instance to the respondent
no.2 and 3 expecting them to show some
care and affection, however, instead thereof
their reaction came as a surprise to the
complainant when they told the complainant
that the respondent no.2 did not even get to
see fruits during her pregnancy, its
completely okay if you won’t get some fruit.

r. That the contents of para no.r of the
denied. It is specifically denied that during
the pregnancy the HBA2 level of the
complainant came positive in the test to
which the respondent no.2 told the
complainant that why did not she get this
tested before marriage. It is specifically
denied that she said “Humare Relative Mai
Kisi Ki Bahu Ka Yeh Test Positive Aaya Tha
Usko Unhone Ghar Se Nikal Diya Tha, Log
Toh Aisi Bahu Ko Ghar Se Nikal Dete Hain”.

s. That the contents of para no.s of the
complainant was depressed due to
prevailing situations and thereof, had
requested the respondent no.1 for mental
supports, however, the respondent no.1
ignored all the concerns of the complainant
and created a huge fight over the said issue
in July, 2018. It is specifically denied that
the respondent no.1 again abused the
complainant with dirty languages and said
“Behanchod Tujhe Pata Nahin Hain Log
Bahuon Ko Kaise Rakhte Hain, Hum Toh
Bahut Acche Hain”. It is submitted that the

brevity.
t. That the contents of para no.t of the
denied. It is specifically denied that in such
said situation the complainant could hardly
talk to the respondent no.2 & 3. It is
specifically denied that in the end of July,
2018 the respondent no.1 dragged the
complainant from the car to the restaurant
at Gurgaon. It is specifically denied that at
that time the respondent no.1 got very
drunk and told the complainant that “Aisa
Nahi Chalega Tum Mere Papa Se Friendship
Karo … Unke Shoulder Per Haath Rakh Kar
Baat Kia Karo … Hug kia Karo … Jaise Main
Apni Maa ke Saath Karta Hu”. It is
told the respondent no.1 that though “I
respect him but I cannot get intimate with
him to that extent”. It is specifically denied
that the complainant told the respondent

no.1 that the respondent no.3 used to sleep
in the complainant’s room and also use the
washroom with the doors open while she
was in room itself. It is specifically denied
that in response thereof, the respondent
no.1 could not take it and started abusing
the complainant he said “Waise Tu Bolti Hai
Pain Hota Hai … Khasi Aati Hai .. Ab Tujhe
Pain Nahi Ho Raha Hai… Khasi Nahi Ah
Rahi … Ab Bas Mujhe Tumse Divorce
Chaiye… Mai Tujse Divorce Lunga… Ab Bas
Bohot Ho Gaya.. Agar Tu Pregnant Nahi Hoti
Toh Mai Tujse Khai Mai Gira Kar Mar
Dalta…Bohot Jhasi Ki Rani Bane Ka Shock
Hai Na Tujhe.. Aj Mai Tera Kaam Tamam Kar
Deta Hu”. It is specifically denied that the
respondent no.1 dragged the complainant to
the car and started driving very negligently
and rashly. It is specifically denied that in
the car the respondent no.1 told her that
“Tujse Apne Aap Se Nahi Hota Ki Tu Apne
Pati Ko 20-30 Hazar De De … Ki Yeh Lo

Gautam Yeh Rakh Lo”. It is specifically
denied that the complainant got very
frightened and agreed to abide by his
dictate. It is submitted that the true and
u. That the contents of para no.u of the
respondents during the complainant’s
pregnancy intentionally troubled her. It is
specifically denied that the respondents did
not keep any helper for the household work.
respondents used to order the food from
outside but just to trouble the complainant
they forced her to cook all the meals for
them during her pregnancy. It is specifically

denied that the complainant had to
continuously visit the doctor during the
pregnancy and also had to get herself tested
on regular basis but the respondent no.1 on
regular basis refused to go along with her
for regular check-up nor allowed her to
perform the test which were prescribed by
the doctor. It is submitted that the true and
v. That the contents of para no.v of the
respondent no.1 even denied spending any
penny on the medicine of the complainant.
It is specifically denied that being a
complicated pregnancy the monthly cost of
medicine was around Rs.10,000/- however,

the complainant was getting Rs.5,000/- only
from the CGHS and the remaining medicines
she had to purchase it from her own. It is
had completely refused to bare/deal with
mental, physical & financial support of the
complainant even during the pregnancy. It
is specifically denied that the complainant
had herself afforded all the expenditures of
the pregnancy. It is submitted that the true
brevity.
w. That the contents of para no.w of the
complainant was in complete shock when
she came to know about the respondent no.1

illicit relationship with other girls which
she had found out from the respondent no.1
phone’s photo gallery wherein, she found
him with other girls in a very uncomfortable
position. It is specifically denied that the
respondent no.1 admitted to that effect and
promised not to repeat in future. It is
x. That the contents of para no.x of the
complainant was a Lodhi Colony the
respondent no.1 had also threatened the
complainant that he will abscond to Dubai
and further told her that what would
happen to her because in this society

divorcee and single mother is not accepted
and thereafter, the respondent no.1 started
scolding and abusing the complainant and
stated that “Humare Ghar Mai Aurate Bahar
Ja Kar Nahi Bolti Hai Kuch Bhi … Ghar Mai
Job Hi Hota Hai Who Ghar Mai Hi Rehta
Hain.. Tune Apne Ghar Mai Bhi Yeh Sab Kyu
Bataya, Wahin Aake Tujeh Thappad
Marunga”. It is submitted that the true and
y. That the contents of para no.y of the
denied. It is specifically denied that on 21-
10-2018 the respondent came to Lodhi
Colony, the complainant came upfront and
told them about all complaints/ problems
related to them, to which they did not utter

a word neither they agreed to the complains
nor did they deny. It is specifically denied
that when the complainant told the
respondent no.2 that the respondent no.1
does not even sleep with her to which she
told her “Haan Kyu Soega Tere Sath… Ek
Bacha Aur Karna Hai Kya Tujhe”. It is
further told her that the respondent no.2
goes out to watch movies with girls at late
night to which the respondent no.2 replied
“Haan Kyu Nahi Jaega Bahar Aur Ladkio Ke
Saath… Tu bhi Toh Apne Ghar Mai Ah Kar
Bethi Hui Hai”. It is specifically denied that
the respondent no.2 stated that “Jab Office
Me Mahual Kharab Hota Hai Toh Waha
Bardasht Kar Ke Reh Sakti Ho but Agar
Ghar Me Mahaul Kharab Hota Hai Toh Waha
Bardasht Kar Ke Nahi Reh Sakti”. It is

z. That the contents of para no.z of the
denied. It is specifically denied that after
the delivery of baby, the respondent no.1
insisted the complainant to take back at
matrimonial home. It is specifically denied
that the respondent no.1 further promised
the complainant that he would not do any
kind of physical or mental assault. It is
trusting all his promises and for the
betterment & future of her child decided to
go back to the matrimonial house and came
at matrimonial home on 13-03-2019. It is

aa. That the contents of para no.aa of the
complainant after reaching back to the
matrimonial house came to know that on the
ground floor a woman namely Simmi Pahwa
was staying. It is specifically denied that
the complainant finds that there is
something wrong because Simmi Pahwa as
well as her kid would stay in their house
throughout the day and she has huge
influence on the respondent no.1 and 2 to
the height of surprise Simmi Pahwa used to
dictate the complainant. It is specifically
denied that the respondent no.2 would treat
Simmi Pahwa as family members while treat
the complainant like an outsider in her own
house. It is submitted that the true and

bb. That the contents of para no.bb of the
occasion of Holi i.e. 21-03-2019, the Simmi
Pahwa had arranged a small get together at
her house where the respondents and family
of the respondent no.3’s sister were invited.
complainant was surprised looking at the
behaviour of the respondent no.1 towards
Simmi Pahwa. It is specifically denied that
the respondent no.1 and Simmi Pahwa were
playing Holi in an appropriate manner and
unusual manner like touching each other. It
is submitted that the true and correct facts

cc. That the contents of para no.cc of the
complainant also finds that Simmi Pahwa
used to call the respondent no.1 approx. 30-
40 times in a day to which the respondent
no.1 had answered few of the calls and most
of the calls were rejected by the respondent
no.1. It is specifically denied that the
complainant found out a mail from Simmi
Pahwa wherein it was written on the
occasion of the respondent no.1 birthday
that “Mujhe Pata Nahi Ki Cooking Karke
Time Tumhe Muj Me Kya Acha Laga … Mujhe
Tumhare Se Baat Karni Hai… Tumhare
Saath Time Spend Karna Bohot Acha Lagta
Hai… Mai Tumhara Birthday Apne Tareke Se
Celebrate Karna Chahti Thi… But Tumhe

Pata Hai Ish Life Mai Yeh Possible Nahi
Hai”. It is submitted that the true and
dd. That the contents of para no.dd of the
03-2019 the complainant became furious
and at the same movement woke up the
respondent no.1. It is specifically denied
that the complainant politely asked about
his and Simmi Pahwa relationship. It is
also told him that she already knows about
everything but she could still give their
marriage a chance only if he tells her the
truth. It is specifically denied that the
marriage a chance, only if he tells her the

truth. It is specifically denied that the
respondent no.1 accepted all his mistakes
and told everything to the complainant that
he is in relationship with her. It is
ee. That the contents of para no.ee of the
denied. It is specifically denied that very
next morning the complainant discussed
everything with the respondent no.2,
however, the reaction of the respondent
no.2 was very surprising for the
the respondent no.2 told on the face of the
complainant that “Jab Mere Bete Ko Ghar Pe
Kuch Nahin Milega Toh Who Bahar Hi Toh

Muh Marega”. It is specifically denied that
on the same day i.e. 27-03-2019 the
complainant’s family came to her
matrimonial house to resolve the problem. It
is specifically denied that the complainant’s
parents made all the efforts to explain the
respondent no.1 not to repeat the same
mistake again but unfortunately, the
respondent no.2 never wanted to resolve the
issues. It is submitted that the true and
ff. That the contents of para no.ff of the
respondent no.2 and 3 already know about
the illicit relationship of the respondent
no.1 and in fact they used to support the

that on 28-03-2019 the complainant
requested the respondent no.2 & 3 to call
Simmi Pahwa. It is specifically denied that
the complainant was surprised looking at
her behaviour with the respondent no.2. It
is specifically denied that Simmi Pahwa was
sitting with the respondent no.2 and her
elbows were on respondent no2. Shoulder. It
is specifically denied that their relationship
is very strong. It is specifically denied that
Simmi Pahwa refused everything about the
relationship before the complainant and on
the other hand the respondent no.2 & 3
made it look like completely complainants
fault. It is specifically denied that after
persistent effort of the complainant Simmi
Pahwa accepted that she is in relationship
with respondent no.1 and promised the
complainant that she would maintain
distance from the respondent no.1. It is

gg. That the contents of para no.gg of the
denied. It is specifically denied that soon,
after the incident the respondent no.2 & 3
started to quarrel with the complainant on
small matters and would start abusing her.
It is specifically denied that after the
aforesaid incident the respondent no.2 & 3
started telling the complainant and the
respondent no1. To leave the house and to
go stay somewhere else. It is specifically
denied that the respondent no.1 in
frustration had packed all his bags and
asked the complainant to go to her parental
house wherein, the complainant refused
stating that “Yeh Log Aged Hai.. Kuch

Urgency Hui Toh Koi Bhi Nahi Hoga Saath
mai… Aise Nahi Kar Sakte Hai Hum Log Inhe
Akele Chor Kar Nahi Ja Sakte Hai”. It is
specifically denied that the complainant was
always concern and worried about the
respondent no.2 & 3 health & wellbeing but
unfortunately, she was never accepted as a
daughter-in-law in the house. It is
hh. That the contents of para no.hh of the
other hand the complainant was never in
peace because of the unfortunate behaviour
of the respondent no.2 towards her. It is

had made the life of the complainant
miserable. It is specifically denied that the
respondent no.2 had tried all the means to
trouble the complainant in some or the
other manner. It is specifically denied that
the domestic servant that was called for the
complainant’s help was purposely always
kept occupied by the respondent no.2 so
that the complainant had to do everything
by herself. It is specifically denied that it
was an unfortunate situation for the
complainant because even after the delivery,
the respondent no.2 never gave the love and
affection to the complainant. It is
very weak after the delivery but the
respondents had never cared about their
health. It is specifically denied that the
complainant was never considered as part of
the family. It is specifically denied that the
respondent no.2 never wanted the
respondent no.1 to develop healthy

relationship with complainant therefore, she
would pin-point on pity issues to the
respondent no.1 against the complainant so,
that there was always a disputed
atmosphere around them. It is specifically
denied that the respondent no.2 had created
a huge fight in the house having left with no
other option the complainant’s parents &
sister had to come home to resolve the
problem. It is specifically denied that on 25-
07-2019 when the complainant’s sister was
making a point, the respondent no.3 stated
“Nikal Ja Yaha Se Behnchood, Tujhe Yaha
Kisne Bulaya Hai, Apni Behen Ko Bhi Le Ja
Yaha Se”. It is submitted that the true and

ii. That the contents of para no.ii of the
complainant was treated worst then a
servant in the house. It is specifically
denied that the whole purpose of the
respondent no.2 was to let down the
reputation of the complainant in front of
servant, neighbours, relatives. It is
specifically denied that in the house they
had treated & respected the servants better
than the complainant. It is specifically
denied that the servants would get proper
food in comparison of the complainant. It is

jj. That the contents of para no.jj of the
denied. It is specifically denied that in the
month of August, 2019 on a trifle issue the
respondent no.3 grab the hand of the
complainant pushed and slapped her. It is
also abused the complainant by saying
Behanchod, chinar etc. It is specifically
denied that apart thereof the respondent
no.3 used to insult the complainant in front
of the relatives stating that the complainant
knows nothing and is a dumb & worthless
woman and that she can never satisfy
anyone of the family members. It is
specifically denied that again in last week of
august, the respondent no.3 at one occasion
had mishandled the complainant and had
also used slangs against her. It is submitted

sake of brevity.
kk. That the contents of para no.kk of the
respondents have always had eyes over the
property of the complainant’s parents. It is
had always told her to sell the parental
house (Bareilly) and get him a shop and
further asked the complainant to put his
name in the property papers along with the
the complainant had always refused/
neglected the said demand of the respondent
no.1 due to which a huge quarrel was
always created in the house. It is
specifically denied that the respondents
no.2 & 3 had always instigated the
respondent no.1. It is submitted that the

brevity.
ll. That the contents of para no.ll of the
respondent no.1 has always been an
irresponsible husband and father. It is
had never helped the complainant financial,
physical and mentally to raise the kid. It is
and 2 would avoid getting the kid
vaccinated. It is submitted that the true

brevity.
mm. That the contents of para no.mm of the
complainant was under impression that
after the birth of baby the behaviour of the
respondent no1. Would change, however, no
such miracle had happened. It is
was very formal with the new born baby and
the complainant had never seen that the
respondent no.1 is pampering and loving the
baby as normal human being do so. It is

nn. That the contents of para no.nn of the
denied. It is specifically denied that at some
occasion, the respondent no.1 used to
brought daily needs items for the New Born
Baby, however, thereafter, whenever the
complainant asked for Daily Needs items of
Baby the respondent no.1 ignored and at
some occasion scold the complainant that I
am not your servant who supposed to do all
the stuff. It is specifically denied that the
complainant had to beg for the basic need
for the new born baby. It is specifically
denied that the complainant miserably
failed to understand the ulterior purpose
behind such violence and trauma. It is

oo. That the contents of para no.oo of the
respondent no.1 never used to make love
with the New Born and away used to run
away from the responsibility. It is
very surprised with the behaviour of the
that the respondent no.1 never use to take
care of the child. It is specifically denied
that the respondent no.1 denied to get the
baby vaccine. It is submitted that the true
brevity.
pp. That the contents of para no.pp of the
02-2020 the complainant got injury in her
spine. It is specifically denied that one day
she was out of medicine and it was very late
therefore, she had requested the respondent
no.1 to get her the pain killer medicine as it
was a necessity. It is specifically denied
that the respondent no.1 did not took her
pain seriously, instead he told her that he
will place an order for the medicine vide
online because they were getting discount
on the said medicine. It is specifically
denied that the complainant was surprised
looking at his behaviour when she had
specifically told him that it was an urgent
requirement and she could not wait for the
medicine to arrive next week. It is
specifically denied that having left with no
other option she had requested her sister to
get her the medicine who had arranged the

medicines from somewhere. It is submitted
sake of brevity.
qq. That the contents of para no.qq of the
denied. It is specifically denied that during
end of May, 2020 the respondent no.1 was
very drunk on one night and he had called
the complainant to the balcony. It is
told her that she needs to go back to her
home as she was not helping the respondent
no.1 financially. It is specifically denied
that the respondent no.1 could not keep her
in the house if she cannot contribute in the
house financially. It is specifically denied
that the complainant did not find it right to

speak anything to the respondent no.1 on
that spot, therefore the complainant decided
to keep quiet however, the respondent no.1
without any occasion became furious
slapped and pushed the complainant
outside the house and had locked the door
from inside of the house. It is specifically
denied that the complainant kept on
requesting the respondents to let her in but
nobody came to help her nor did anybody
open the door till late night. It is submitted
sake of brevity.
rr. That the contents of para no.rr of the
06-2020, the situation got out of control

when the respondent no.1 started a huge
fight over the trifle issues. It is specifically
denied that the respondent no.1 started that
“Ghar Mai RO Kharab Hai Tu Teek Nahi
Karwa Sakti … Tere Ghar Walon Sagan Mai
Dete Hi Kya Hai, Jitna Tere Ghar Wale Dete
Hain Uthna Toh Hum … Apni Behn Ke
Naukaro Ko Sagan De Dete Hai … Tujhe
Saving Karni Hai Toh Behnchood Apne Ghar
Ja Ke Kar .. Yaha Par Kyu Reh Rahi Hai…
Behenchod Panauti Hain Tu … Meri Maa Ka
Right Hai Relatives Ko Batana Ki Unpe Kya
Hui Hai … Tujhe Baat Karni Nahin Aati
Isliye Hum Tujhe Relatives SE Nahin
Milatei”. It is specifically denied that the
respondent no.1 became more furious and
had started slapping the complainant. It is
and 3 did not even try to stop the
respondent no1. Instead they had locked
themselves inside the room It is specifically
denied that the respondent no.1 had

physically assaulted the complainant for
about more than an hour but nobody had
tried to save her. It is specifically denied
that the complainant called her parents and
even then the complainant’s parent had
tried to resolve the dispute between the
respondent no.1 and the complainant but
unfortunately nobody was ready to listen. It
is specifically denied that on that occasion
the respondent no.3 had abused the
complainant’s family and told them to get
out of his house. It is specifically denied
that the respondent no.3 told the
complainant’s parents that “Madharchod
Bhag Ja Yaha SE Nahi To Jaan Se Mar
Denge”. It is submitted that the true and

ss. That the contents of para no.ss of the
06-2020 the respondents have thrown the
complainant and her son from their house
during the COVID-19 lockdown period. It is
having no other option left came to Lodhi
Colony with her baby. It is specifically
denied that the complainant and her parent
tried to reconcile the situation, however,
the respondent instead upon divorce. It is
specifically denied that the respondent by
one way or other threatening the
complainant to give divorce. It is submitted
sake of brevity.
tt. That the contents of para no.tt of the
condition of the complainant has become
worse than an animal and has been forced
to lead a miserable life. It is specifically
denied that the complainant left in lurch by
the respondents It is specifically denied
that the complainant expressed her every
feeling of love and emotion however, the
respondent no.1 never turned up. It is
has started threatening the complainant to
give divorce or he will not let her live. It is
through various modes threatened the
complainant and asked her to give divorce
so that he could marry with the other girl.
It is specifically denied that on 01-11-2020
the respondent no.3 said “Chahein Mujeh
Kitne Paise Kharch Karne Pade Main In Logo
Ko Sabak Sikha Ke Rahunga”. It is

uu. That the contents of para no.uu of the
respondents may physically harm the
complainant and her child and may try to
eliminate her to achieve their ulterior
designs. It is specifically denied that there
is a security threat to the complainant and
her child, which is leading to huge mental
torture and insecurity to the complainant. It
is specifically denied that because of the
assault, cruelty, mental, physical, financial
and emotional torture on the hands of the
respondents, the complainant has been
suffering from mental trauma. It is

vv. That the contents of para no.vv of the
respondent no.1 has not only caused
physical injury to the complainant but all
the respondents also undermined the social,
economic, psychological and emotional well
being of the complainant. It is specifically
denied that the complainant has been
rendered destitute by the respondent no.1.
it is specifically denied that on account of
the domestic violence the complainant’s
health is deteriorating day by day and the
complainant is living under threat. It is

ww. That the contents of para no.ww of the
complainant came to know that the
respondent are trying to sell the property of
the Gurgaon House No.3205, Second Floor,
Sector-57, Gurgaon, Haryana i.e. the shared
house hold of the complainant . It is

xx. That the contents of para no.xx of the
complainant’s Diamond Ring and the Gold
Chain (given by the nani) are in possession
of the respondent and despite request the
respondent have not given the same.
It is specifically denied that apart
thereof, the furniture’s and Home
Appliances i.e. AC, Bed with Mattress,
Almira, Aashing Machine and Cloth stand
which were given by the parents of the
complainant to the complainant at the time
of marriage are still lying with the
respondent and despite request the
respondent not return the same. It is
have the Video Footage, Audio Recording,
Emails, What’s app Message etc. and the
complainant seek leave of the court to file
the same at the time of evidence.

It is specifically denied that succinctly
speaking the complainant is repeatedly
subjected to physical, mental and emotional
violence including repeated acts of physical
assault, incessant insults and tyrannies,
verbal abuse, harassment and deprivation of
physical, financial and personal resources
at the hand of all the respondents.
preliminary objections and the contents of the
same may kindly be read as part and parcel of
the reply of para under reply and the contents of
the same are not repeated herein for the sake of
brevity.
It is, therefore, prayed that the Domestic
Incident Report may kindly be dismissed with
heavy cost, in favour of the respondents and
against the complainant, in the interest of
justice.
Delhi RESPONDENTS
Dated:
Through

ADVOCATE
M. 8920503527, 9811312468


IN THE MATTER OF :-
Versus
AFFIDAVIT
u nd e r : -
2. T ha t th e a c c o mpa ny in g r ep ly h as b e en d ra f te d b y
my counsel u nd e r my in s tr u c tio n s a nd th e
c o n te n ts o f th e sa me a r e tr u e a nd c o r r e c t a nd th e
s a me may k in d ly b e r e ad as pa r t an d pa r c e l o f
th is af f id a v it.
DEPONENT
VERIFICATION
DEPONENT


IN THE MATTER OF :-
Versus
AFFIDAVIT
u nd e r : -
DEPONENT
VERIFICATION
DEPONENT


IN THE MATTER OF :-
Versus
AFFIDAVIT
u nd e r : -
DEPONENT
VERIFICATION
DEPONENT


IN THE MATTER OF :-
Versus
D.O.H. 06.08.2022
REPLY ON BEHALF OF THE RESPONDENTS TO THE
APPLICATION UNDER SECTION 23 (2) OF
PROTECTION OF WOMEN FROM DOMESTIC
VIOLENCE ACT, 2008 FOR EX-PARTE INTERIM
ORDER FILED BY THE COMPLAINANT .
---------------------------
1. That the answering respondents have filed
t heir written statement alongwith the
prelim inary objections, the contents of the
prelim inary objections may be read as the part
and parcel of the prelimina ry objections to the
reply of the applicat ion the same have not
been reproduced here for the sake of brevity.
REPLY ON MERITS:-
application are matter of record, need no
reply.
applicat ion, needs no reply, it is the matter of
record. However, it is submitted that the

answer ing respondents have filed their written
statement alongwith the prelim inary
objections, the contents of the written
statement may be read as the part and parcel
of the reply to the applicat ion, the same have
not been reproduced here for the sake of
brevity.
leading a standard life at her matrimonial
home before marriage. It is specifically
denied that the respondents are also rich
people and own various moveable and
immovable properties and bank balances. It
is specifically denied that the respondent
no.1 and his family members are man of
means. It is submitted that the true and
in the written statement and the contents of

is working at Indigo Airlines and to the best
knowledge of the complainant the last have
annual income of Rs.15,00,000/- per
annum. It is specifically denied that inspite
of having very high yearly income of the
respondent no.1 the complainant was
performed to lead a miserable life. It is
have already been mentioned in the written
statement and the contents of the same may
sake of brevity.
specifically denied that the respondents had
committed various acts of Domestic Violence
and cruelty upon the complainant and that
further have not maintaining the
complainant and the child and made their
life miserable. It is submitted that the true
mentioned in the written statement and the
continues threatening the complainant and
asking for divorce and if she denies the will
ruin her life. It is specifically denied that
the threat is imminent and constant. It is

sake of brevity.
requires Rs.50,000/- per month for
maintenance of herself and the new born
child. It is submitted that the true and
in the written statement and the contents of

specifically denied that the application is
bonafide and in the interest of justice. It is
sake of brevity.
The prayer clause of the application is
wrong and denied. It is submitted that the
complainant has not come to this Hon’ble Court
with clean hands and have suppressed all true
and material facts before this Hon’ble Court,
who is liable to be prosecuted and is not
entitled for any relief.
It is, therefore, prayed that the present
application may kindly be dismissed with heavy
cost, in favour of the respondents and against
the complainant, in the interest of justice.

Delhi RESPONDENTS
Dated:
Through

ADVOCATE
M. 8920503527, 9811312468


IN THE MATTER OF :-
Versus
AFFIDAVIT
u nd e r : -
DEPONENT
VERIFICATION
DEPONENT


IN THE MATTER OF :-
Versus
AFFIDAVIT
u nd e r : -
DEPONENT
VERIFICATION
DEPONENT


IN THE MATTER OF :-
Versus
AFFIDAVIT
u nd e r : -
DEPONENT
VERIFICATION
DEPONENT

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Gautam Sikka 25-07-2022 WS

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IN THE COURT OF SH. SANGHMITRA, LD. M.M.

IN RE :- COMPLAINT CASE NO. 457 OF 2021

Shri Gautam Sikka & Ors. …Respondents

WRITTEN STATEMENT ON BEHALF OF THE

MOST RESPECTFULLY SHOWETH :-

1. That the marriage between the respondent

no.1 and the complainant was solemnized

on 21-02-2018 according to Hindu Customs

and Rites at The Grand Dreams Banquet,

16, Shivaji Marg, Main Najafgarh Road

Industrial Area, Delhi-110015 in a simple

manner without any demand of dowry.

dismissed with heavy costs.

2. That the marriage both the parties resided

together as husband and wife at House No.

3205, 2nd Floor, Sector 57, Gurgaon, where

the marriage was duly consummated

between the parties and one male child

namely Paarth Juneja has been born out

from this wedlock on 13-10-2019. Hence the

application is liable to be dismissed with

3. That since beginning of the marriage, the

complainant remained under the influence

of her parents and under their influence she

always making the quarrel and abusing with

the respondents and she was also used to go

and back her parental house without giving

any information to the respondents. Hence

the application is liable to be dismissed

with heavy costs.

4. That both the parties living at the said

address, after sometimes the complainant

harassed physically and mentally to the

respondents. Hence the application is liable

to be dismissed with heavy costs.

5. That after the marriage the respondents

paid full love and regard to the

complainant, which is expected to a newly

married bride and the respondent no.1 also

following all the instructions of the

complainant but the complainant never

understand the feelings of the respondent

no.1. Hence the application is liable to be

dismissed with heavy costs.

6. That the respondent no.1 has given all love

and affection and respect to the

complainant, since the marriage in the

matrimonial home but the complainant did

not discharged her matrimonial duties and

obligations faithfully and she harassing and

humiliating the respondent no.1. Hence the

application is liable to be dismissed with

domestic work and the complainant has

been threatening the respondent no.1 to

implicate in false cases as well as dowry

and file false complaint in the police station

against the respondent no.1. Hence the

application is liable to be dismissed with

8. That the complainant and her family

members used to cruelty with the

respondents and they misguided and

instigated the complainant against the

respondent no.1 before friends and relatives