PRIYA SHARMA

ADVOCATE HIGH COURT

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VASTU SHANTI TOWER, PLOT NO. 12, A/403, SEC – 11, NEAR
GURUDWARA, KALAMBOLI, NAVI-MUMBAI- 410218.
TEL- 08097531611 (M)
E-MAIL- priyash907@gmail.com
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th
June, 2017

WITHOUT PREJUDICE

RPAD/SPEED POST/ COURIER

To,

Advocate Munir Ahmad Siddiqui

Office At :- 3/22, Sai Prasad Shopping Centre,
Below Vikroli Court, Kannamwar Nagar – 2,
Vikroli (E), Mumbai – 400 083.
Mobile No. 9322404979.

Subject: - Mental, Physical and Financial Harassment by Mr.

Suresh Shivaji Howale (Husband) and by his Family.
Reference: - Reply to Letter Dated 23/05/2017.

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SIR,
I am concerned for my Client Mrs. Manisha Suresh Howale, Residing
at Sidharth Colony, Gaikwad Nagar, Chembur, Mumbai- 400 071 and upon
seeking the instructions from my client, I have to address you as under:-

1. At the outset my client submits that your client has not provided you
correct facts regarding the matter, he has only lied from his
 imagination mind. He always tried with strong intention only to
malign the character of my client and his family, from the date of
marriage till date. My Client further submits that your client never
respect her or her family specially her mother, your client always use
to say and pressurize my client to stay away from him and his family
at any cost. Certain facts which are not brought to your notice are
herewith the Para wise denials.
2. My Client submits that she got married to Mr. Suresh Shivaji Howale
on 08/03/2000 as per Hindu Rites and Rituals. My Client further
submits that from the date of marriage onwards, my client’s mother -
in – law (Mrs. Lata Shivaji Howale) and Sister – in – law ( Pushpa
Prashant Kandhale) started harassing her without any reason. There
are 2 male children from the said wedlock. It was the Proposal from
your client’s side stating that they are well settled family and has a
good family background and they will consider themselves very lucky
if my client marry to your client. My Client further submits that your
client’s mother lied at each and every stage to fix the marriage she
hide all the information regarding your client, she never stated that
your client handicapped and he is alcoholic addicted and most of the
time use to remain in fully drunken manner and also hide his age
that he is almost younger to marry.
3. My Client submits that from the day when she had a cup of tea till
having food in night your client, your client’s mother and sister they
used to taunt her and use to blame her for dowry, that she had not
brought anything in her marriage. My Client further submits that on
one fine day your client took my client to his sister’s home in
Ambernath and on that night they stayed over there, it was very
terrific night for my client as her sister – in – law’s husband come and
slept beside her and started to touch her with wrong intentions in
order to outrage her modesty when my client shouted loudly on him
 he went away. My Client further submits that on next morning she
complained to your client about all such incident and expected that
he may take some action against him but he fails to do so and replied
my client “he is my sister’s husband, so better you shut your
mouth” and told my client to keep quite. This incident had taken
place continuously 3 – 4 times which my client had always intimated
your client but your client always ignore her and tried to make
understand her only.
4. My Client submits that her parents are poor they cannot afford the
demands of your client’s mother and sister, they both use to torture
my client physically, mentally and financially by stating that “teri
maa ne yeh nai diya, woh nai diya shaadhi mein, teri aukat nai
hai yahan hamare saath rehne ki”. My Client further submits that
they both used to taunt her for dowry, when she use to sit for having
food they use to state that “kabhi apne maa ke ghar pe kuch mila
hai ya nai”. My client looking towards her sons she accepted and
ignored all the wrong doings and things and stayed with your client.
5. My Client submits that if your client used to bring something for my
client at that time her mother – in – law use to feel jealous regarding
their marital relationship. My Client further submits that your client’s
whole family is a liquor addicted uses to drink every day and was
behaving in a very rash and harsh manner with my client without no
reason and started abusing her with a cheap language stating that
“tujhe koi dusra mard chahiye toh bata mujhe”. My Client further
submits that after doing all this nonsense he started abusing her
family members and insulted her in a very rude manner in front of the
whole family members. My Client further submits that your client
never trusted her and never provided her money for expenses of
household.
 6. My Client submits that she has faced all pains which your client has
given her without any reason and that too just to save her marital life
and her children’s future. My Client further submits that your client
never helped her financially for household expenses and children’s
education. Even your client’s mother she has sold all, my client’s and
her son’s jewellery, especially that jewellery which her children’s got
gifts on their birthdays, just to fulfill her unnecessary needs. My
Client further submits that she has to take help of her mother to feed
her children’s. After 4 months of marriage your client’s mother has
sold her mangalsutra without my client’s knowledge.
7. My Client submits that it was all just your client’s showoff and
conspiracy to marry my client, just to trap my client in their vicious
plan. Your client and his family knew all things about my client and
her family background but your client with their malafide intentions
wants to fetch monies from my client.

PARAWISE DENIALS

PARA 1

With reference to Para 1 my client denies the date of marriage its on

08/03/2000, rest all are the matter of facts.

PARA 2, 3, 4 & 5

With reference to Para 2, 3, 4 & 5 my client denies all the facts and
contentions of Para 2, 3, 4 & 5. My Client submits that your client’s
mother and her younger son has sold a chembur flat in Rs. 5,40,000/-
without informing anyone in home, when my client and her husband
come to know about such big decision, my client started arguing with
them about the decision but they both hit her and her mother – in - law
stated that “tujhe kya karna hai , yeh mera ghar hai main kuch bhi
karu”. At that time your client insisted her to stay away from his family,
 because your client’s mother and sister beated her very badly just
because she argued for her right. My Client further submits that your
client took her away from his family to stay on rent basis. My client never
instigated your client to stay away from the family. Your client never
provided any financial help to my client and used to drink a lot due to
which my client decided to be employed she joined in Kohinoor Hospital
as a security officer, at that time her duty was in morning 6:45 a.m. till 3
p.m. in afternoon but if the staff is limited then her duty used to increase
till 16 hours. My client never let down her responsibility towards her
husband, son and house. But your client never trusted her and used to
allege her as your client’s mother already washed your client’s brain
regarding my client and he used state that “kiske saath soo ke aayi
hai, mujhse maan nai bharta tera dusra mard chahiye”. My Client
further submits that she has given all her efforts to save her marital life
but her mother – in – law and sisters – in – law has created all mess in
her life. Rest all contents and facts are denied in Toto.

PARA 6, 7, 8, 9 & 10

With reference to Para 6, 7, 8, 9 & 10 my client denies all the facts and
contentions of Para 6, 7, 8, 9 & 10. My Client submits that she lodged all
N.C. relating to the cruelty, physically, mentally and financially
harassment which was given by your client and his family. As my client
fails to fulfill your client’s malafide intention, your client always tried to
malign her character and defamed her in all ways. Your client and his
mother tried to kill my client by pressing her neck without any reason
just because she went out to attend DR. Ambedkar’s function at that
time she come home till 12 a.m. at night. She tried to save herself but
there’s no scope as no one was there in home they continued beating her
till 2 a.m. in midnight and threaten her not to utter a word infront of
anyone. Due to which on next day my client went to police station to file
a complaint against your client. My client further submits that your
 client and his mother and sister’s has crossed all their limits of
humanity. They tried to fetch her in between 4 walls of the house and
forced her to leave the job.

8. Under the aforesaid circumstances I, on behalf of my client call upon

you and your client within 7 days from the receipt of this notice, to
send a apologize letter to my client and her family as my client will not
stay separate from her marital home and also compensate her with
Rs. 5,00,000/- to my client with an undertaking in writing that these
kinds of evil tactics you will not do again in future against my client
and his family within 30 days after the receipt of the notice you shall
come, and failing which my clients shall take appropriate legal steps
against you and your parents which shall be totally at you and your
parent’s risk and convenience which please bear in mind. And also
Rs. 15,000/- for the Legal Notice charges which is barred by you and
your client.

Hope wiser counsel prevails

Priya sharma Mrs. Manisha Suresh Howale

Advocate (Client)

Note: my client is ready for amicable solutions.