Legal drafting

Written statement in a civil suit for declaration and permanent injunction  The written statement on behalf of the defendant, Smt. Shahijan, was submitted in response to a suit for declaration and permanent injunction filed against her by Mubin. The defendant raised preliminary objections, including that the plaintiff's suit was not maintainable against her, the plaintiff had no cause of action, and the plaintiff had no locus standi to file the suit. The defendant's reply includes admitting the marriage between the parties but denying several other allegations made by the plaintiff. The defendant claims that the plaintiff harassed her over dowry and demanded a Maruti car from her, and that her family members gave her merciless beatings, snatched her jewelry, and turned her out of the matrimonial home. IN THE COURT OF SH. ____________ACJ, SR. DIV. __________ Mubin Vs. Smt. Shahijan SUIT FOR DECLARATION & FOR PERMANENT INJUNCTIO...

 Reply of election petition for Gram Panchayat  IN THE HON’BLE COURT OF ADDITIONAL CIVIL JUDGE (SR. DIV) Smt. ____             V/s             Smt.____and others Reply to the Election Petition U/s 176 of Haryana panchayati Raj Act 1994 on behalf of respondent no. 1. Respected Sir,                                                         The answering respondent no. 1 most respectfully submits as under:- Preliminary Objections:- 1-     That the petition of the petitioner is not maintainable in the present form against the answering respondent. 2-     That the petitioner has no locus-stan...

 IN THE HON’BLE COURT OF SH. PAWAN KUMAR A.C.J. SR. DIV. .......    Smt. Dulari etc.  Vs     M.C. Ha.....     Suit for Declaration and Permanent Injunction.                Written statement on behalf of the defendant no. 2.   Sir,  The defendant no. 2 humbly submits as under:- Preliminary objections:- That the suit of the plaintiffs is not maintainable in the present form.  That the plaintiffs have no locus standi to file the present suit.  That the plaintiffs are estopped by their own act, conduct and acquiescence from filing the present suit.  That the plaintiffs have not come with clean hands before the hon’ble court and have suppressed the true and material facts from the hon’ble court. That the suit of the plaintiffs is false, frivolous, vexatious and hence is liable to be dismissed with special costs.   Reply Parawise:- That the para no. 1 of the plai...

        IN THE COURT OF HON’BLE CIVIL JUDGE, _________   V                          Versus                    R SUIT FOR PERMANENT INJUNCTION WRITTEN STATEMENT  ON BEHALF OF DEFENDANT RESPECTFULLY SHOWETH:- PRELIMINARY OBJECTIONS:- 1-             That the instant suit filed by the plaintiff is not maintainable in the eyes of law against the answering defendant. 2-             That the plaintiff has no cause of action for filing the present suit against the answering defendant, if any, mentioned in plaint then is false & made-up. 3-             That the plaintiff has no locus-standie for filing the suit as the plaintiff had entered into an agreeme...

Written statement in domestic violence act suit | reply of dv act | Ws 125 Crpc |                In the Hon’ble court of Illaqua Magistrate _____________                    Smt. ________                Vs.          Sh. ________ Petition under section 12,18,19,20,21 & 22   of D.V Act. Reply to the petition on behalf of the respondents. R/Madam,           The answering respondents respectfully submits as under :- Preliminary objections : 1.     That the present petition of the petitioner is not maintainable against the answering respondents because petitioner no. 1 did not want to join the conjugal company of the respondent no. 1 without any sufficicent reason and rhyme and the petitioner no. 1...