Topic – Reply to the Petition

Title- Reply on the behalf of Respondent

Submitted To-

Ms. Navditya Tanwar

Assistant Professor of Law,

H.P. National Law University, Shimla

Submitted By-

Saurav Kataria

B.B.A. LL.B (Hons.); 7th Semester

Enrollment Number – 1120181938

H.P. National Law University, Shimla

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 Declaration

I the author of the assignment declare that the work done in the assignment is my own work and
is original and all the material taken from other sources has been duly acknowledge. I have
adhere to the guidelines of the assignment. Also I am aware of the regulations of the University
of Academic Work and have adhere to those guidelines.

Name – Saurav Kataria

Batch – BBA LLB (7th Semester)

Enrollment no. 1120181938

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 IN THE COURT OF PRINCIPLE JUDGE, FAMILY COURT, JAIPUR

H.M.A. Petition No. …….. Of 2021

In the matter of:

Sh. Ankit Kapoor
H/o Smt Navya Kapoor, r/o Jaipur (Rajasthan) …Petitioner

Versus

Smt. Navya Kapoor

W/o Ankit Kapoor, r/o Jaipur (RAJASTHAN) … Respondent

REAPLY ON BEHALF OF THE PESPONDENT

The Respondent named above most respectfully submits before the Hon’ble Court as under –

1. The Contents of Para 1 of the petition is correct and is admitted.

2. That content of para 2 is admitted and need no reply on this point.

3. The contents of para 3 of the plaint is admitted and no objection.

4. The content of para 4 is admitted.

5. That the contents of para 5 is partially admitted. As she was mentally ill before marriage
and the same was told to the Petitioner and it was also told the now she was fine and if
the petitioner want to confirm then they can meet to the doctor of the Fortis Hospital,
Jaipur.

6. That the contents of para 6 is not admitted because petitioner was clearly informed about
the health condition that respondent was mentally ill for some time due to sunstroke and
cerebral malaria and the same was told and also they meet the doctor that treated the
respondent so there was no fraud.

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7. That content of para 7 is incorrect as the respondent called petitioner’s mother boorish
women but because she use to give some senseless instructions like not talk anyone and
not to do any work with one hand sue to which she was frustrated.

8. That content of para 8 is incorrect as nothing has happened as said by the appellant.

9. That content of para 9 is not admitted because it is partially correct as on that day
petitioner tried to suppress respondent by giving some baseless instructions like she has
to wear this and not to touch vessels without permission and not to serve meal to others
and they had fight and bad words were exchanged.

10. That content of para 10 is incorrect because there was no nagging between them such
arguments are made for the sack of divorce.
11. That the contents of para 11 is not admitted as she never apprehended the petitioner and
his family but the petitioner always use to give baseless inductions and try to dominate
her.

12. That the contents of para 12 is not admitted as the petitioner was trying to get evidence
by making some false allegation.

13. That the contents of para is not correct as petitioner always wanted to dominate and after
having disputes in the material life they had intercourse and has their second daughter
which means petitioner wanted to keep the marriage.

14. That the contents of para 14 is true.

15. That the contents of para 15 is admitted.

16. That the contents of para 16 is correct.

17. That the contents of para is admitted.

18. That the contents of para 18 is correct and needs no reply.

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 PRAYER

It is, therefore, most respectfully prayed that this Hon'ble Court may be pleased to:-

(a) Dismiss the petition of petitioner.

(b) Give custody of both daughters to respondent.

(d) Award the cost to defendant against the petitioner.

(e) Pass such order and further order(s) as may be deemed fit and proper on the facts and
circumstances of this case.

Place: JAIPUR Petitioner: ANKIT KAPOOR

Date: 20 November, 2021 Through
SAURAV KATARIA
(Advocate, District Court, Jaipur)

VERIFICATION

I, the above-named respondent, declare that the contents of the written statement are true within
my personal knowledge and nothing has been concealed therein.

Place: JAIPUR

Dated: 20 November, 2021

NAVYA KAPOOR

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 AFFIDAVIT

IN THE COURT OF PRINCIPLE JUDGE, FAMILY COURT, JAIPUR

H.M.A. Petition No. …….. Of 2021

In the matter of:

Sh. Ankit Kapoor
H/o Smt Navya Kapoor, r/o Jaipur (Rajasthan) …Petitioner

Versus

Smt. Navya Kapoor

W/o Ankit Kapoor, r/o Jaipur (RAJASTHAN) … Respondent

AFFIDAVIT OF NAVYA KAPOOR W/O ANKIT KAPOOR R/O JAIPUR, RAJASTAN

I, MS. NAVYA KAPOOR residing at JAIPUR as on 20 November, 2021 at JAIPUR do hereby

solemnly affirm and declare as under:-

That the accompanying written statement has been drafted by the Counsel as per my instructions
and statement of facts made therein paragraphs 1 to 14 are correct to my knowledge and
statement of law made therein paragraphs 15 to 18 including the prayer of the Written statement
is correct as per legal advice received by me from my counsel and believed to be correct and the
same are not been reproduced herein for the sake of brevity.

NAVYA KAPOOR

DEPONENT

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 VERIFICATION

Verified 25 November, 2021 JAIPUR that the contents of the above affidavit are true to my
knowledge and information received; and nothing material has been concealed therefrom.

Place: Patna

Dated: 25 November, 201

NAVYA KAPOOR

DEPONENT

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