PUNJAB AND

TN THE HIGH coURT FOR THE sTATES OF

HARYANA AT CHANDIGARH.

No. 11370 of 2022

C.W.P.

son of Baljit
Jagdeep Singh aged about 52 years

Distt.
Singh, R/o Village Ramgarh, Tehsil Jagraon,
of B-XX-2411/836,
Ludhiana at present resident

Road Ludhiana C/o

Krishna Nagar, Main Ferozepur
Ludhiana. Mobile
Sunder Medical, Near Aarti Chowk,
2973 1909 5853
No. 98154-03053, Aadhaar Card No.
...Petitioner

Versus

1. State of Punjabb through its Secretary,

Home Affairs and Justice, Civil

Department of

Secretariat Building, Chandigarh.

2.
2 Additionall Deputy Commissioner-cum-Appellate

Tribunal Jagraon, Distt. Ludhiana.

3 Kaur aged about 75 yearsS widow of

Kamaljit
Baljit Singh Son of Tarlochan Labh Singh,
resident of village Ramgarh, Tehsil Jagraon,

Distt. Ludhiana
...Respondents

Short Reply by way of affidavit of Major Amit

Sareen Additional Deputy Commissioner -cum

Appellate Tribunal Jagraon, Distt. Ludhiana,

on behalf of the Respondents No. 1 & 2.

I, the above named deponent do hereby solemnly

affirm and declare as under :-

Preliminary Objections:

1. That the writ petition iss not

maintainable
AGainst the Governnent7 Government authorities.
 2
they are presumed to act legally in good

faith. The predecessor COurt of Dr. Nayan

Appellate
Jassal, PCS, Addl. Deputy Cum

order after
Tribunal Jagraon has passed the

summoning thhe and hearing both the

parties
addressed by both the
parties and arguments

Counsels of the parties.

That it was ascertained by the appellate court

2.
that the appellant Smt. Kamaljeet Kaur aged

about 75 years Was not being paid any

maintenance allowance by her son Jagdeep Singh

even after the order dateda
(the respondent)
11/11/2021 of SDM Court. The respondent Sh
Jagdeep Singh could not present any proof of

payment of maintenance allowance t o her mother

Smt Kamaljit Kaur. She was not at all beinng

provided basis amenities and basic physical

needs by her son Sh Jagdeep Singh and was

ousted from her house by her son. Hence the

order under sec 23 of maintenance and welfare

of parents and senior citizens Act, 2007 for

cancellation of vaseeka No. 2221 dated
04/08/2010 has been passed by the appellate

court after affording due opportunity of being

heard to both the parties

3. That the present petitioner failed to prove

the objections raised by him before appellate

court of the predecessor and the court has

rightly passed the order dated 05.04.2022

1under sec 23 of malntenance and welfare of

parents and senior Cltizens Act, 2007

for
cancellation o f vaseeka no. 2221 dated
04/08/2010.
 -3
On Merits :

1. That para No.1 of the writ petition regarding

the residence of the petitioner needs no

reply. But it is
wrong that petitioner is

entitled to invoke the extra ordinary writ

jurisdiction as alleged in this para.

2 That para No.2 of the writ petition is matter

of record.

3 That para No.3 of the writ petition is matter

of record.

That para No.4 of writ petition is not related

4.
to the answering respondents.

That para No.5 of the writ petition is not

related to the answering respondernts.

6. That para No.6 of the Civil Writ petition iss

related with legal question.

7. That para No.7 of the writ petition is not

related to the answering respondents.

8. That para No.8 of the writ petition is not

related to the answering respondents.

9. That para No.9 of the writ petition is not

related to the answering respondents.

10. That para No.10 of the writ petition is not

related to the answering respondents.

11. That as regard para No. 11 of the writ

petition is wrong and denied. The said order

has been passed after hearing the parties as

well as the arguments Irom both the counsels

of the parties.
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12. That as
regard para No. 12 of the writ
petition is wrong and
denied. No
law
question of
ever arisen as mentioned in this para of
the writ petition.

13. That para No. 13 of the writ petition

regardiing previous litigation is a matter of
record.

14. That para No. 14 of the writ petition is

prayer clause, which is also wrong and denied.

It is, therefore, prayed that the

writ petition may please be dismissed with

COsts3.

Place: Jagraon pepenent

Dated :- Majo/AmitSsreenn
ADC Jagraon

Verifi cation
Verified that the contents of para No. 1 to 3 of
preliminary objections and para no. 1 to 13 of

reply to civil writ petition are true and correct

to the best of our knowledge and as per the

official record, nothing has been Concealed. Para
No. 14 relates to prayer.

Place: Jagraon
Dated :-
Deponent
Major Amit Sateen
ADC Jagrao