vaibhav bansal

1) That the contents of para 1 of the application are admitted

being matter of record .however the applicant and the
respondent married on 19.11.2018 as mentioned in the para
under reply. That the marriage was solemnized in a very
lavish manner .It is further pertinent to mention that from
the said wedlock no child was born .

2) That the contents of para 2 are wrong false and denied in

toto .It is denied that the complainant is the victim of
unimaginable cruelty that has been carried out by the above
named respondent upon the complainant by making her life
miserable .It is submitted that the the respondent was a
independent person thoughout , going anywhere at her free
will.It is denied that since inception the respondents have
been treating the complainant with immense cruelty and it is
also denied that the respondent use to treat complainant as a
bounded domestic help.It is submitted that since inception
the respondent never wanted to be physicall with her
husband and the respondent no 1 still tolerated this thinking
that it was the impact of the first marriage and the
respondent never forced her .

3) That the contents of para 3 of the application are denied

that the complainant and her parents at the time of marriage
were made to believe that the respondent are from very well
to do family,and the respondent no 1 is having his own shop
at Chandni Chowk Delhi and doing business of gold bullions
and earning a very good income . It is submitted that the
allegations leveledby the complainant are false and
frivolous ,the complainant may kindly be put to strict proof of
the same .It is denied that he has also purchased the
matrimonial home in his name by his own money .It is denied
that believing the respondents no 1 family ,the marriage was
arranged between the parties .It is submitted that the
complainant said yes for the wedding after respondent
bought a big house .It is admitted that a lavish was held at the
Jehan,G.T.Karnal road bypass New Delhi .It is denied that by
the complainants parents all the demands of the respondents
no 1 family as regards jewellery ,household items and other
items fo then as well as the relatives . It is submitted that
every penny in the marriage was spent by respondent no 1
from both the sides even their fashionae clothes were also
from vaibhav .It is denied that the respondent were not
happy with the jewellery , household items and other items It
is submitted that the respondent has put gold worth rs 40
lakhs in marriage .It is denied that the respondents would
constantly taunts and insult her and her parents for not
getting jewellery ,household items ,and items as per their
standards and name in the society .It is submitted that the
allegation leveled by the complainant are false and frivolous.
The complainant may kindly be put to strict proof of the same
.

4)That the contents of para 4 are false. It is denied that for

few weeks the relation remained cordial between the
complainant and the respondent no 1.It is submitted that the
complainant was living lavish life till the respondent no 1 was
doing well in business the moment he got set back the
complainant started making respondents life hell. It is denied
that after the respondent no 1 started taunting and
commenting the complainant on petty issues and did not did
not allow her to go anywhere outside for any purpose .It is
submitted that the complainant been a independent person
thougout ,going anywhere at her free will. It is denied that
the respondents had also retained all the jewellery of the
complainant with them on the pretext that we will keep all
the jewellery safe with them only. It is submitted that the
complainant has opened a account after the business started
declining and took a locker there In axis bank . the
complainant took the jewellery given by vaibhav and some
few 100 american dollars and also took one diamond set of
her mother in law is kept there .It is denied that till date the
jewellery had not been given back to the complainant even
after making several requests by the complainant to
respondent.It is submitted that the complainant has run
away with all the jewelery given by her in laws .

5)That the contents of para 5 are false. It is denied that after

a few months of the marriage the complainant realized that
the respondent no 1 is a very aggressive ,angry person and
wants to control the complainant in every aspect . It is denied
that the complainant was not given any space or freedom to
do anything in the house and was specifically told that she
can’t do a job or business ,which the complainant found very
difficult to deal with but owing to the values given to her by
her parents . It is submitted that the respondent no 2 sold her
gold jewellery for the business of the complainant and didn’t
even refunded a single rupee. It is denied that she always
made every effort to deal with the miserable situation and
keep quite for the peace of mind of her parents.It is
submitted that the complainant started to treat the
respondents as servents after starting the work .It is denied
that the complainant having no choice gave herself totally to
the respondent no 1 and his family and molded herself
according to their ways , Which was very different from her
side of the family .It is submitted that the complainanat did
not consider the house as her own and used to wake up at
11-12 in the morning .It is submitted that she started living
separate with her husband in paschim vihar , and the
complainant made the respondents do all the packing and if
they denie the complainant use to break the crockery and
shout loudly and to avoid the embaressment in neighborhood
they followed their order .

6)That the contents of para 6 are wrong false and denied in

toto. It is denied that after six months of the marriage the
complainant came to know that the respondent no 1 is a
habitual drinker and a drug addict as he is regularly taking the
alcohol in the day time as well as the night could not live
without it .It is submitted that the complainant was herself a
regular drinker and could’nt live without it . It is denied that
when the complainant raised this issue to respondent no 2
there was no fruitful result came up rather harassment ,
physical and mental trauma was also increased .It is
submitted that she was familiar that respondent no 1 use to
take alcohol ,the complainant married only for her love
towards money and was fine till the business was good ,but
when the respondent was not doing well in business she
started these tauntrams . It is denied that the complainant
was told by the respondent no 2 to compromise to the
circumstances as it’s her duty to take care of respondent no
1.It is submitted that the complainant even before the
marriage took money from respondent no 1 and was a
regular drinker ,she used to stay out of the house till 2o clock
in night . It is denied that the complainant during this stage
of the life felt very disturbed, lonely and sorrowful because
there was no one to hear and provide solution to her life .It is
submitted that the death of the first husband of the
complainant was the complainant was driving the car in the
influence of acohol and had an accident in which his first
husband died .

7)That the contents of para 7 are false .It is denied that the
complainant got no help and support from her mother in law
i.e. respondent no 2 and on the contrary ,she encouraged and
sided with the respondent no 1 and wanted the complainant
to cooperate with this animal behaviour and live with it
without complaining and talking about it to her family .It is
submitted that the complainant herself use to stay out at
night by the permission of her mother and beause of this her
father didn’t like all this ,so so mother’s and daughter antics
made father’s life hell . It is denied that the respondent no 2
always discouraged complainant from telling her parents
about these incidents by saying that this would further annoy
respondent no 1 and disturb the peace of the family . It is
submitted that the allegations leveled by the complainant are
false and frivolous, the complainant may kindly be put to
strict proof of the same. It is denied that the respondent no 2
took respondent no 1 drugs addiction very lightly and did not
bother to speak to the respondent no 1 to change his
behaviour towards the complainant .

8)That the contents of para 8 are wrong false and are denied
in toto .It is denied that the complainant had also taken
respondent no 1 to the doctors many times due to the bad
health issues caused by consuming excessive alcohol and
drugs all the times.It is submitted that the respondents
father was diabetic and his grandfather too and the
complainant knew about it before and the respondent was
was seeing doctor for consultation what was wrong in that .It
is denied that the doctor had also warned the respondent to
immediately stop taking alcohol and drugs , but all in vain as
the respondent no 1 is not willing to give up his bad habits
and remain under intoxication of alcohol and drugs all the
time .It is submitted that the allegations leveled by the
complainant are false and frivolous , the complainant may
kindly be put to strict proof of the same. It is denied that all
the expenses for the medical treatment had been borne by
the complainant as the respondent no 1 used to spend all his
money on consuming alcohol and drugs .The copy of the
medical reports had been annexed herewith as ANNEXURE C-
2.
9)That the contents of the para 9 are wrong false .It is also
denied that the respondent would abuse her on the regular
basis and with most horrendous of expletives and would not
even let her talk to her immediate family members .It is
denied that the situation was so bad that when her family
members would call ,the respondent no.1&2 would get
extremely angry and preceed to criticize her and then start
calling her names and thrash her with anything that they
could lay hands on .it is submitted that the complainant was
so smart and why would anyone bother someone like this .It
is submitted that the complainant is very sharp minded and
used to abuse her mother in law and husband so badly that it
cannot be written.

10)That the contexts of the para 10 are wrong false and are
denied in toto.It is denied that the respondent no 1 always
and frequently mistreated and the complainant tried to stop
the respondent no 1 from consuming alcohol and drugs . It is
submitted that the complainant was a regular drinker and
used to drink too much and could not live without it,and at
the time the house was empty she used to call her friends
and do party at home .The maid told her mother in law but
the respondent no 2 didn’t say anthing for maintaining peace
in house.
11)That the contents of para 11are false and are denied in
toto.It is denied that when the parents of the complainant
had tried to talk to respondent regarding these issues faced
by the complainant ,the respondent started abusing the
parents of the complainant and asked them not to interfere
in their personal life or they will not keep the complainant in
their house .It is submitted that the complainant use to go to
her mothers house daily and she only needed money . It is
denied that the complainant as to save her matrimonial life
stayed nun but all her efforts went in vain as the respondent
no 1 is a very adamant and rude person .It is submitted that
when the respondents go to take her back the complaianant
use to insult them and close the door on their faces . It is
denied that he is very dominating in nature and the
complainant is hard victim in the hands of respondents.

12)That the contents of para 12 are false and are denied in

toto .It is denied that the complainant has made efforts to
plase the respondent no 1 and his family but the respondent
have always torched the complainant as the complainant
played like puppet in their hands ,did what they wanted and
how they wanted her to live .It is submitted that the
complainant did marriage only for supporting her mother and
brother financially ,when the complainant thought I will do
good in business or not she left me and started iving with
someone else for a year and after that the complainant went
to hyderabad with him. It is denied that the complainant did
everthing possible to make her marriage work and in the
manner the respondent no 1 and his family wanted . It is
denied that the respondent never cared for the complainant
and never appreciated the efforts made by the complainant
to keep him and his family happy .It is submitted that the
respondent no 1 use to love the complainant so he handled
the situation peacefully and never said anything to the
complainant

13) That the contents of para 13 are wrong false and are
denied in toto. It is denied that the complainants life has
become miserable due to the aggressive , angry behavior of
the respondent and continuous insults , taunting ,very cold
and indifferent behavior towards her family members. It is
submitted that the complainant never had the capacity to buy
anything for anyone ,the complainant use to take money
from the respondent no 1 and gave it to her mother . It is
denied that the complainant was always taunted by her
mother in law whereas the complainants parent’s tried to
keep them happy in every way at every occation by gifting
complainant’s mother in law with expensive gifts or cash but
they were never satisfied .It is submitted that every peny in
the marriage was givenby vaibhav and gold of 40 lakhs was
given at the time of marriage .

14) That the contents of para 14 are wrong false and are
denied in toto . It is denied that the complainant had always
been economically tortured and pressurized by the
respondents to give them money from her hard earned
income. It is denied that the complainant had been helping
the respondents and was also taking care of the household
expenses due to the drug and alcohol addiction of
respondent no 1 as he used to spend all his money in
consuming alcohol and drugs at all the times. It is denied that
managing the house expenses , illegal demands of money by
the respondents had become a very difficult task for the
complainant .It is denied that whenever the complainant had
requested the respondent no 1 to leave drugs and alcohol
and lead a normal life , she was abused and beaten by the
respondents.It is submitted that the allegations leveled by the
complainant are false and frivolous . The complainant may
kindly be put to strict proof of the same .

15)that the contents of para 15 are false and are denied in

toto. It is denied that the respondent no 1 was never given a
single complainant in any manner and left her with no
options expect to survive with least availability of basic
sources and taking financial help from her parents .It is
denied that whenever she demanded money from
respondents for household expenses , the respondents
started abusing her and passed comments upon her parents
and even many times raised hand on her and turned her into
black and blue. It is submitted that the jewellery of the
mother in law she gave to help start complainant a business
and her office was in gurugram sector 46,after sometime she
started living alone in avi society .The complainant had an
affair there and started living with him and shifted to
Hyderabad with him and her work could be checked on
amazon.

16) That the contents of para 16 are wrong false and are
denied in toto . It is denied that at the time of the marriage ,
it was informed by the respondent no 2 that the respondent
no 1 is having his own shop in chandini chowk ,delhi and he
deals in the business of gold bullions and having a very good
income from the said business . It is denied that in year 2020 ,
the complainant was shoked when she came to know that the
respondent no 1 was not doing any legal business and was
involved in match fixing and cricket betting activite due to
which he had lost all his money in the market and was taking
credits from many people .I is submitted that the allegation
leveled up by the complainant are false and frivolous . The
cpmplainant may kindly be put to strict proof of the same.

17)That the contexts of para 17 are wrong false and are

denied in toto .It is denied that many police complaints has
also been filed against the respondent no 1 by many creditors
from whom he had taken money as he was not doing any
legal business due to which the respondent no 1 was arrested
in FIR no -76/2020,U/S 420/506 IPC,P.S Kotwali
jwalapur ,haridwar and remained in jail since December 2020
for a period of 6 months .It is denied that the contents of the
fir are not repeated and the copy of the FIR and other police
complaints are annexed herewith as annexure c-3(colly).It is
submitted that it was a business dispute and it was settled
amicably , they copied the respondent no 1 sign an proved
him guilty it can be seen clearly in the FIR filed by the
cpmplaianant .

18) That the contents of para 18 are wrong false and are
denied in toto .It is denied that it is pertinent to mention
herein that the respondent no 2 had forced the complainant
to mortgage the jewellery of the complainant for the release
of respondent no 1 and assured that after the bail is granted ,
the respondent will return the jewellery of the complainant
but still the same had not been returned to complainant till
date . It is submitted that no money was given to settle the
dispute and all the jewelery of the house was with the
cpmplainant only and now the complainant is blaming the
respondents for this.

19) That the contents of para 19 are wrong false and are
denied in toto . It is denied that even after getting release
from jail , the respondent no 1 had not left his bad habbits of
consuming alcohol and drugs at regular basis . It is also
denied that within 2days after getting released from the jail
on bail, he started consuming alcohol and drugs and when
the complainant tried to stop respondent no 1 from doing
this ,she was abused , beaten by the respondent no 1 and
respondent no 2 by saying that “all the wrong things
happening in their life was because of you and now
respondent no 1 does not want to stay with you now and
asked the complainant to leave the matrimonial home
immediately or will be thrown by them anytime.It was
submitted that even before when the respondent 1 was in
prison she was living in avi society willingly as it was her
second home where she had an extra maritial affair .She
never wamted to come home .It is submitted that the
complainant didn’t allow respondent no 1 to stay there
because of her affair ,and all the household item were there
like bed ,ac ,kitchen .

20)That the contents of para 20 are wrong false and are

denied in toto. It is denied that the complainant left with no
option had to request her parents to allow her to live with
them at their home at vikaspuri, delhi. It is denied that the
the respondent no 1 after consuming alcohol and drugs in day
time had started visiting at he house of the parents of te
complainant and started abusing In the filthiest language in
front of the parents of the complainant and also threatened
them that if they raise their voice before the police ,he will
kill them and even will not spare the complainant to live
peacefully.It is submitted that the respondent no 1 visited her
home alone to try once more to continue their relationship,as
he didn’t wanted her mother to get insulted .It is denied that
the parents complainant being very humble and peacefull
people had requested many times to respondent no 1 not to
visit their house and create nuisance as it will create bad
image in the society but respondent no 1 being intoxicated
with drugs and alcohol does not bother about any respect of
the parents of the complainant . It is denied that due to these
issues , the complainant parents had shifted to another place
so as to get safeguard their dignity in the society to live
peacefully .It is submitted that the complainant did not allow
him to come inside their house , as the complainant was
already in a relationship with someone .

21)That the contents of para 21 are wrong false and are

denied in toto. It is denied that due to the constant threats by
the respondent no 1 and to safe guard the dignity of her
parents , the complainant had finally decided to leave the city
and shifted to Hyderabad in the month of October ,2021 so
hat she can stay away from the respondents and can live a
peaceful life .

22) That he contents of para 22 are wrong false and are

denied in toto. It is denied that till date , even after shifting
from one city to another city for her survival , the
complainant is still faing the mental abuse and verbal abuse
at the hands of the respondent no 1 as he have been calling
her on her phone number after consuming alcohol and drugs
on daily basis . it is submitted that .It is submitted that the the
respondent came out of prison in September and she left for
Hyderabad in October because the complainant was already
in a relationship with a boy from that society and he was
from hyderabad. The complainant had also filed a complaint
with he local police station ,Hyderabad on 05.05.2022
regarding the allegation leveled and threats given by he
respondent no 1 after consuming alcohol and drugs over the
whats app messages and video calls done to the
complainant . It is denied that the complainant has suffered
immense pain and hurt from the respondents.It is submitted
that the complainant and her mother was greedy they
snatched the house from her father and they both could do
anything for money . It is denied that the complainant has
not slept one night in peace for as long as she can
remember . It is denied that the complainant is
mentally ,physically and emotionally scared and she is unable
to carry on anymore like this .It Is submitted that the
complainant was playing sympathy card and harassing decent
people . The copy of the said complaint dated 05.05.2022 and
copy of the screenshots of the said whatsapp messages are
annexed herewith as annexure C-4(colly).

23) That the contents of para 23 are wrong false and are
denied in toto . It is denied that the complainant was facing
all these atrocities of the respondents with the ray of hope
that one day better sense would prevail upon them and
respondent no 1 would understand his responsibility but his
careless attitude has not changed towards the complainant
till present.It is submitted that the allegation leveled by the
complainant are false and frivolous. The complainant may
kindly be put to strict proof of the same.

24) That the contents of para 24 are wrong false and are
denied in toto . It is denied that the complainant being a lady
have made all the best possible efforts and tolerated all sort
of torture , humiliation & embarrassment to the bearable
extent to save her matrimonial life,but allwent in vain.It is
submitted that the allegation leveled by the complainant are
false and frivolous . The complainant kindly be put to strict
proof of the same

25)That the contents of para 25 are wrong false and are

denied in toto .It is denied tat the complainant ealier did not
initiated any legal action against the respondent with the
hope that good sense will prevail upon the respondents . It is
denied that the complainant tolerated all these with the
hope of saving her matrimonial life and better future ,but of
no avail.It is submitted that the respondent no 1 was in love
with the complainant so he was seeing all these tauntrams by
her and they went abroad for a trip but after that the
business started collapsing and wanted to travel many places
with her and felt bad about this that he could not give such
things to her wife.It is submitted that the respondent no 2
also treated the complainant like her own daughter and what
if she said somethings she is also my daughter It is submitted
that she only married for the money .
26)That the contents of the para 26 are wrong false and are
denied in toto .It is denied that the complainant had only the
experience of unhappy ,miserable life full of
humiliation,accusation,and mental agony of the whimsical ,
arrogant and non cooperative attitude of the respondent no 1
and 2 . It is denied that the amount f humiliation and cruelty
poured into the life a living/veritablehell which she could
never imagine in her wildest dreams . It is submitted that the
allegation leveled by he complainant are false and frivolous .
The complainant may kindly be put to strict proof of the same
.

27) That the contents of para 27 are wrong false and are
denied in toto . It is denied that the respondent have
commited the offence of threatening ,physical
assault ,domestic violence including verbal and emotional
abuse and mental torture ,insults which prima –facia shows
respondent has comitted offences punishable under this
act .It is submitted that the she started a business from the
respondents house only and was earning ood by her online
business amazon ,the respondent did all this to make her
wife’s work settle . she never gave money in the house and
was earning good it can be checked by her amazon account .