Written statement in domestic violence act suit | reply of dv act | Ws 125 Crpc | 

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 herself
left the house of the respondents and has falsely implicated the answering
respondents no. 1 to 5 in the present litigation.  

2.      That the petitioner no. 1 has
not come to this Hon’ble court with clean hands and she has suppressed the true
and material facts from the Hon’ble court 
and as such the present petition of the petitioners is liable to be
dismissed.

3.       That the petitioner no. 1 has
filed the present petition with malafide intention and with the sole motive to
harass the answering respondents as the present petition is based on false and
fabricated facts and as such the petition is liable to be dismissed on this
ground also.

4.       
That the petitioner has got no
cause of action to file the present petition against the answering respondents.

5.       
That the petitioner has got no
locus standi to file the present petition against the answering respondents.

6.       
That the petitioner is
estopped from filing the present petition by her own act and conduct.

7.       
That the facts and
circumstances stated in this petition by the petitioner are totally wrong,
illegal, false, fabricated, vexatious one and hence the petition is liable to
be dismissed with costs.

8.    That the petitioner has
suppressed the actual and material facts before this Hon’ble court as the
petitioner herself left the house of the respondents and she also took away all
the golden and silver ornaments from the house of the respondents. It is also
submitted that the respondent no. 1 several times visited the parental house of
the petitioner no. 1 to bring back her but the she straightly refused to live
with the respondent. It is also submitted that the respondent no. 1 is still
ready and willing to keep the petitioners in her matrimonial home.

Reply parawise:-

1-         
That para no. 1 of the
petition is correct and admitted.

2-         
That the para no. 2 of the
petition is also correct and admitted.

3-         
That the para no. 3 of the
petitioner is wrong and denied and not admitted. It is denied that the father of the petitioner no. 1 and
have spent huge amount in the said marriage. However it is submitted that
the marriage of the petitioner no. 1 with the respondent no. 1 was quite a very
simple marriage because both the families of respondents and petitioner belongs
to a poor class family.

4-         That the para no. 4 of the
petitioner is vehemently wrong and denied as alleged by the petitioner. It is
wrong and denied that the respondents did not satisfied with the dowry given
by the parents to the respondents and just after the marriage the respondent
no. 1 to 5 in collusion with each other started harassing the petitioner no. 1
for bringing less dowry. It is also wrong and denied that they started taunting
that the parents of the petitioner no. 1 have not given sufficient dowry, and
the respondents started giving beatings to the petitioner no. 1 occasionally
from time to time. It is also wrong and denied that the respondents used to
raise the demand of additional dowry from her in the shape of Swift Dezire car
and the respondents said that they will properly keep the petitioner no. 1 if
their said demand will fulfilled by the parents of the petitioner no. 1. The
rest contents of this para are also wrong and denied. It
is submitted that the answering respondents never
beaten up the petitioner for less dowry and they never demand any dowry from
the petitioner no. 1. Moreover the answering defendant no. 2 to 5 were living
separately from the petitioner no. 1 and they have no concern with the present
petition. The all allegations regarding dowry demand are false, fabricated and
concocted one. The petitioner no. 1 has made false allegations against the
answering respondents to implicate them in false case.

5-         That the para no. 5 of the
petition is also wrong and denied. It is denied that the respondent no. 4 tried
to rape with the petitioner no. 1. The rest contents of this para are also
wrong and denied. It is submitted that the respondents belongs to a very
respectable family and to defame the respondents, the petitioner no. 1 imposed
such false allegation of rape against the respondents.

6-        That the para no. 6 of the
petition is wrong and denied. It is denied that the respondent no. 1 has
illegal affair with the respondent no. 5 and when the
petitioner no. 1 requested the respondent no. 1 to not to do such things then
he will not adhere on the request of the petitioner no. 1 and they gave
merciless beatings to the petitioner no. 1 and they have snatched all the
golden and silver ornaments of the petitioner no. 1. It is submitted that the
petitioner no. 1 did not want to join the conjugal company of the respondent
no. 1 and herself left the company of the respondent no. 1 and now in order to
implicate the respondents she made such false allegations against the
respondent no. 1 and his family members.

7-         
That the para no. 7 of the
petition is also wrong and denied. It is denied that at about Two and half year
ago, the respondents in collusion with each other due to non fulfillment of
dowry demands gave merciless beatings to the petitioner no. 1 and they pushed
out the petitioner no.1 from their house and gave threatened to the petitioner
no. 1 that if you will come in house again then we will kill you. It is also
denied that the parents of the petitioner no. 1 came to the house of
respondents and they tried to patch up the matter with the respondents but the
respondent did not listen and they misbehaved with the parents of the
petitioner no. 1 and they pushed out them from their house. It is also denied
that at that time the petitioner no.1 was pregnant. It
is submitted that all the allegations leveled against the answering respondents
are false, fabricated and imaginary one. The petitioner no. 1 left the house of
the respondent No.1 herself without any reasonable cause and rhyme and without
any prior permission and consent of the respondent No.1 in the absence of the
respondent No.1. It is further submitted that the petitioner no. 1 while
leaving the house of respondent no. 1 also took away the entire gold and silver
ornaments with her. And when on next day, the respondent no. 1 went to the
house of the petitioner no. 1 and requested her to join the company of the
respondent No.1 but the petitioner no. 1 clearly refused to join her
matrimonial house. The parents of the petitioner no. 1 also insulted the respondent
No.1 and they told that they would not send back the petitioner no. 1 with the
respondent No.1.

8-    That the para no. 8 of the
petition is wrong and denied as alleged by the petitioner no. 1. It is
submitted that since the time of the marriage of the petitioner no. 1, the
petitioner no. 1 many a times left the house of the respondents and she was
usually in the habit of leaving the her matrimonial house. 

9-         
That the para no. 9 of the
petition is also wrong and denied and not admitted. The petitioner no. 1 has no
valid cause of action to file the present petition. It is submitted the
parents of the petitioner no. 1 never conveyed any panchayat at the house of
respondents. It is pertinent to mention here that the petitioner no. 1 herself
do not want to reside with the respondent no. 1 despite of several panchayat
conveyed by the respondents.

10-      
That the para no. 10 of the
petition is also wrong and denied. However if any complaint is moved by the
petitioner no. 1 against the respondents then the same is false and fabricated.

11-      
That the para no. 11 of the
petition is also wrong and denied. It is submitted that the petitioner no. 1 is
not entitled to any such kind of relief as she left the house of respondent no.
1 herself on her own will and wish. The respondent no. 1 is ready to keep and
maintain the petitioner at his house.

12-      
That the para no. 12 of the petition is also
wrong and denied. It is denied the respondent no. 1 works in a transport
company and he has agrl. Land and from these sources the respondent no. 1 is
earning more than Rs. 45,000/- per month. The rest contents of this para are
also wrong and denied. It is submitted that the respondent no. 1 is a daily wage
worker and the respondent no. 1 is ready to keep the petitioners at his house
but the petitioner no. 1 herself is not ready to live with the respondent no.
1, so the petitioner no. 1 is not entitled to get any maintenance from the
respondent no. 1.

13-      
That the para no. 13 of the petition is a legal
para. Hence needs no reply.

14-       That the
para no. 14 of the petition is legal one.

Reply to
prayer :-

                      The prayer clause of the
application is wrong and denied. It is submitted that applicants/petitioners
are not entitled to get any relief sought for U/s 18, 19, 20, 21 & 22 of
the act as the petition is based upon the false, fabricated points and there is
no weight in the petition of the petitioners hence the same is liable to be
dismissed with cost, in the larger interest of justice.

                                                                             Replying Respondents

Through
Counsel         

 

        In the Hon’ble court of Illaqua
Magistrate 

                   Smt. _______ etc.               Vs.         Sh. ______ etc. 

Petition under section 12,18,19,20,21 & 22  of D.V Act.

Reply
to the application U/s 23 of Domestic Violence Act for interim relief on behalf
of the respondents.

R/Madam,

                The answering respondents
submits as under :-

1-   
That the para no. 1 of the
application is formal. However the respondents have filed the written statement
of the petition and the reply of the same may kindly be read as part and parcel
of this reply.

2-   
That the para no. 2 of the
application is correct and admitted.

3-   
That the para no. 3 of the
application is wrong and denied. It is wrong to allege that the respondents
have turned out the petitioner no. 1 along with her minor girl child from the matrimonial
home in wearing clothes only after giving merciless beatings to the
petitioner  no. 1 for not fulfilling
their illegal dowry demands and has treated the petitioner no. 1 with cruelty.
It is also denied that the petitioner no. 1 is unable to maintain herself and
her minor child and she is  residing at
her parental house on their mercy and the father of the petitioner no.1 is a
poor person and is also unable to maintain the petitioners, whereas the
respondent no. 1 works in a transport company and he has agrl. land also and
from these sources he is earning more than Rs. 45,000/- per month and despite
of this he intentionally and willfully fails to maintain the petitioners
despite having good income as such the
respondent no. 1 is legally duty bound to maintain the petitioners.  It is submitted that the answering
respondents never beaten up the petitioner no. 1 for less dowry and the
answering respondents never beaten and never demand dowry from the petitioner
no. 1. The petitioner has made false allegations against the answering
respondents to implicate them in false case. It is submitted that the
respondent no. 1 is a daily wage worker and the respondent no. 1 is ready to
keep the petitioners at his house but the petitioner no. 1 herself is not ready
to live with the respondent no. 1, so the petitioner no. 1 is not entitled to
get any maintenance from the respondent no. 1.

4-   
That the para no. 4 of the
application is wrong and denied. The petitioners are not entitled to get any
maintenance amount from the respondent no. 1 as per the submissions made in
reply of the petition.

               It is therefore prayed that the
petitioner/applicants are not entitled for any kind of maintenance, hence the
same is liable to be dismissed with costs, in the interest of justice.

Dated:
.                                                                                           Respondents                                                                

Through
Counsel                  

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