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a) That since the Respondent has abandoned on her own she is not entitled for residence

expenses also.
b) That the Respondent further has concealed the fact that she had filed the Petition under
Section 125 of the Code of Criminal Procedure and the same has been withdrawn by her
on account of consented settlement arrived between the parties. Now seeking a relief after
a period of 10 years is not maintainable. As such in terms of settlement the compliance
was made by both the parties after receipt of settlement amount. The fact has been
deliberately concealed by the Respondent before the court which has further resulted in
the passing of the impugned order dated 01.07.2020 by the court below. The fact was
admitted in the Cross Examination conducted on 01.05.2019 and 24.05.2019. The fact
has been deliberately concealed by the Respondent and the order has been passed by the
court below.
c) That the Respondent had taken all the Istridhan and belonging n 22.09.2004 itself when
she had abandoned the Petitioner and the admission has been made before the higher
court in the litigation between the parties. Hence no claim could be made in respect of
Istridhan and the factum proves that the relief claimed is in the nature of vengeance
tactics played upon the Petitioner and to grab money from him and ruin his rest of the
life.
d) That the Respondent had a quarrelsome behaviour and all her demands were fulfilled
when the son Hirdyansh Verma was born. Further it is necessary to state that after
abandoning the father even after the order being passed as visitation right, the
Respondent had not allowed to meet the Petitioner and even the son had not met the
father. Hence since no love and respect being available of the Respondent and son
disentitles from any claim whatsoever.
That the Petitioner and the Respondent had approached the Hon'ble Court seeking Divorce by
mutual consent in and around January 2006. The conditions agreed were fulfilled by the
Petitioner by giving 140gm of gold and Rs 5,00,000/- (Rupees Five Lakhs only) through DD's,
but the Respondent being a greedy lady/woman had refused before the court after filing the
Petition by mutual consent and thereafter she had filed the Complaint before the

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