4.

That the petitioner never remains responsible or in any manner concerned to the respondent the
petitioner after getting pregnant, permanently left the association of the respondent though the
respondent did not leave any stone unturned to bring the petitioner back home the respondent
constantly visited her at her parental home and pleated her and her patents to allow her to go back to
her matrimonial home and join the association and join the petitioner. However, instead the petitioner
parents started cursing the respondent to leave his mother and start staying with them to which the
respondent could not agree and therefore the petitioner parents threaten to implicate the respondent
and his family in false cases.

Sense the petitioner was pregnant the respondent continuously visited her at her parental home and
kept on providing her for all the necessities irrespective of the ill-treatment matted to him. The
respondent had been under grave mental agony and stress and there was a total chaos in the life of the
respondent, respondent has been visiting petitioner regularly. On 13-12-2012 respondent has been
blessed with the baby girl that raised a ray of hope for reunion of respondent and petitioner. However,
they despite all efforts on part of respondent the petitioner deserted the respondent.

The respondent even approaches the elderly persons and the concerned panchayat at seeking their
interventions for brining the petitioner back to matrimonial home. Pursuant thereto a meeting was held
by the concerned Sarpanch of the panchayat Halqa Rahain held a meeting wherein the parents of the
petitioner also participated. In the meeting the petitioner parents’ straight way refuse to send the
petitioner to her matrimonial home and thereafter they took back all STRI DHAN items of the petitioner
from the respondent home and sever all the relation between the petitioner and respondent.

5. That the petitioner has deserted the respondent sans any reason and without any fault on the part of
the respondent. The petitioner did not even spoke to the respondent since, March 2013. The petitioner
cannot take advantage of her own ground and therefore is not entitled for any claim of maintenance.

Para wise Reply:

Para 1 of the petitioner needs no reply.

Para 2 of the petitioner except to the extent that female child i.e., petitioner no. 2 was born out of their
wedlock___________ are twisted and misrepresented. The petitioner cause leave of the learned court to
read the peal in the preliminary submission made here in above as part and parcel of reply to the present
paragraph.

Para 3 under reply is inherently false and patently absurd hence deny in totally. It is denied that the birth
of child was not welcomed in family, it is denied that the petitioner no. 1 was tortured for giving birth to
female child, it is denied that was taunted for bringing less dowry, it is denied that the petitioner no. 1
was mercilessly beaten and turned out of the matrimonial home by the respondent, it is denied that
every time the parents of petitioner no. 1 resolved the matter with the only hope that good sense would
prevail upon respondent. It is submitted that the petitioner herself has deserted the respondent as her
parents does not want her to stay at her matrimonial home. The petitioner never stayed with the
respondent for a consequently period of months, the respondent exhausted all his efforts to bring the
petitioner back to the matrimonial home. However, for the reason inter-alia stated in the preliminary
submission all the efforts of the respondent have failed to achieve any result.
Para 4 the content has been denied that the petitioner no. 1 was time and again pressurized to sign the
document for facilitating the petitioner no. 1 to seek divorce from respondent out of her free will, it is
denied that the petitioner no. 1 and 2 shall have no claim or right in the property of respondent. It has
been denied that the petitioner no 1 was further threatened that respondent no. 1 will arrange second
marriage.

Para 5 the content has been denied that the respondent openly declared that he has performed his
second marriage and petitioner will not be given penny by him.

Para 6 the content of paragraph is matter of record hence need no reply.

Para 7 The content of paragraph are matter of record hence need no reply

Para 8 the content has been denied that on 05-11-2014 the respondent in connivance his family
members mercilessly beaten the petitioner and turned her out from the matrimonial house.

Para 9 the content of paragraph. It is submitted that the petitioner herself deserted respondent without
any fault of the respondent. Respondent has always maintained and taken each and every care of the
petitioner and even today, if the petitioner resides with the respondent the respondent shall take care
and provide all love and affection. The respondent has only a girl child and is dyeing to see her however
the petitioner in order to cause mental agony to the respondent is preventing the girl child to meeting
the respondent.

Para 10 the content is false and manipulative and therefore denied in total. The respondent is source less
and jobless person and is unable to get any employment more particularly because of situation created
by the covid pandemic. The respondent has been dis-inherent by his mother and is wondering here and
there for search of any odd job to make his living and seeking at the mercy of his friends and relatives
the life of respondent is totally shuttered.

Para 11 the content is false and manipulated and therefore denied in total. It is submitted that the
petitioner has deserted since 2012 and has been making her living very well whereas the respondent was
going through vagrancy and is unable to earn any income therefore any amount of maintenance allowed
against the respondent would add insult to the injury and vagrancy of the respondent, if the petitioner
join the company of the respondent the respondent would be able to earn some income for making their
living.

Para 12 the content of paragraph is matter of record hence need no reply.

Therefore, it is most respectfully prayed that keeping in views the facts and circumstances the learned
court is requested here to cancel the petition filed by the petitioner for the relief of the respondent.