To,

Sharad Parmar (Advocate),

M-5, Metro Tower, Ring Road, Surat- 395002.

Sub: Reply to your notice dated 27.04.2022

Respected sir,

With reference to the above cited subject I would like to inform you
that I am in receipt of your notice dated 27.04.2022 delivered to my
address on 04.05.2022 . I have gone through the subject matter of the
notice and therefore I strongly deny and dispute the content of the
notice save and except what are matter of records. In this regard my
observation is as here under :

1) That Para 1 and Para 2 of the Notice are the matter of record .
2) That I have strong objection against the contents of Para 3 of the Notice :

a) You have wrongly stated in the Notice regarding maintenance and

custody of the child . There was no such order passed by Hon’ble
Durgapur Court regarding maintenance and custody of the child .
That the allegation made in Para no.3 is disputed and denied
because as per the Order dated on 30.11.19 passed in subjected Mat
Suit case by Hon’ble Court Of The Additional District Judge, FTC
Durgapur, the marriage tie in between Pawan Bothra and Abhilasha
Bothra was dissolved by a decree of Divorce by mutual consent
which came in effect from 30.11.2019. As per the Decree and Order
of Hon’ble Court Of The Additional District Judge, FTC, Durgapur
there was no direction given to Pawan Bothra for providing
maintenance for his son Yuvraj Bothra @ Yash Bothra. Your client
has labeled a blame which is nothing but to protect herself from
custodian negligence in future because she is not taking proper care
of Yuvraj Bothra.

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Therefore your statement is false and fabricated as your client misrepresented the
order of the Hon’ble Durgapur Court. . Your client is liable under section 107,
191,194 and 196 of Indian Penal Code for willful concealment and
misrepresentation of court order/decree , false information and allegation.

b) You have falsely stated regarding threatening and filthy language to

make me down in the eyes of the society. But your statement is
absolutely false and purposeful. I may request you to mention date
and to submit CCTV footage. Your client is liable under section
191 and 196 of Indian Penal Code for false statement which
affected my honour in the society.

c) Your client is trying to make distance in between me and child.

Therefore raising false and purposeful allegation. There was no
such event or circumstances ever created by me since the birth of
my child. It is very clear from your statement that your client is still
continuing emotional and mental torture since October 2013
which your client had started extremely with expressed words and
submission duly publicized by your client during wedlock as noted
below :
“PATI PAR NIBANDH” : PATI EK GHARELU PRANI HAI, YE
SABHI GHARO MEH ANIWARJYA ROOP SE PAYA JATA
HAI. ISH GHARELU PRANI KO PALNE KA PURA ADHIKAR
PATI NAMAK AUDE SE SAMMANIT MAHILA KO PRAPTH
HOTA HAI.

I. ISKI DO ANKHE HOTI HAI JISSE YEH MUK RAHKAR

MATRO DEKHTA HAI.
II. ISKE DO KAN HOTA HAI JISSE PATNI KI DATT
FATKAR SUNTA HAI.
III. ISKA EK MUKH HOTA HAI JISKE KHULNE PAR
PURNAT PAWANDI HOTI HAI.

IV. ISKI EKLAUTI KATI NAKH MEH ADRISH NAKLE

HOTI HAI.
 Page 2 of 4

V. YEH KAFI KUCH MANUSHYA SE MILTA JHULTA

PRANI HOTA HAI.
VI. AISE PATI HONE SE PURV YE MANUSHYA KI
SHRENI MEH HOTA HAI.

PATI KE PRAKAR :

JORU KA GULAM : YEH PRAJATI HAMARE DESH

MEH BAHUTAYAT ROOP SE PAYE JATI HAI . ISH
PRAJATI KE PATI TIKAO, MEHNATI, SIDHE WOH
WAFADAR HOTA HAI . YEH YUNDA NASAL KE
HOTE HAI. DAT, MARH, GALIYA INPAR PRAVABHIN
HOTI HAI. PALNE KE LEA YEH PATI SABSE ACHE
HOTA HAI .

JORU KA BADHSAHA : YEH PRAJATI DHIRE DHIRE

LUPTH HOTI JA RAHI HAI ISH LEA SARKAR JALD HI
INKE SANRAKSHAN KE LEA “BADHSAHA PATI
SANGRAKSHAN” NAMAK ABHIYAN CHALANE JA
RAHI HAI .

The statement publicized by your client and continuous mental &

emotional torture till date is deadly against the fundamental human
rights and The Constitution Of India as the said expression and
publication is applicable for husband of all women in the world.
Your client is liable for such defaming statement with cost and
consequences.

Apart from that your client has damaged my business after getting
knowledge and experience to operate business from my business
house to start her own business “Abhi Arts Giftland” at my cost .
She is self dependent and financially sound enough which may be
verified from the Income Tax Return for F.Y. 2018-2019, 2019-
 2020 , 2020-2021.

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In spite of financial sufficiency she is not taking care of my child
regarding education and day to day care. This is also for your kind
information that, I am suffering from serious Brain stroke faced on
24th May 2020 only due to continuous mental & emotional torture
made by your client Ablilasha Jain . Your client is continuously
trying to make distance between me and my child by stating false
and fabricated statement since decree of divorce.

I am confident enough that you are misguided by your client who

suppressed the actual fact for labeling allegation against me on the
basis of false and fabricated information and events. Your client
dare to bear the mentality to honour her husband with the statement
“ PATI EK PALTU PRANI HAI” which is enclosed here with for
your ready perusal.

Date: 18.05.2022

Place: Durgapur ……………………..

(Pawan Bothra)

Copy to : Abhilasha Jain D/o Ashok Kumar Borar,

202 Raj Avenue , China Gate Road,
Near to Om Terrace , Surat, Gujrat
PIN: 395017.

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