Rejoinder - Harpreet Kaur

IN THE COURT OF MS. RENU BHATNAGAR, LD.
PJFC
[WEST], TIS HAZARI, DELHI
MT NO.: 598 / 2019
IN THE MATTER OF:
HARPREET KAUR & ANR. ..PETITIONERS
VERSUS
SUKHRAJ ..RESPONDENT
D.O.H.: 09.06.2020
REPLICATION ON BEHALF OF THE

PETITIONERS TO REPLY/WS FILED BY THE
RESPONDENT
MOST RESPECTFULLY SHOWETH:
REPLY TO PRELIMINARY OBJECTIONS:
1. That the contents of para 1 of the preliminary objection
under reply are wrong and denied. It is denied that the
petitioner no.1 has filed the present petition by
concealing material information from this Hon’ble

Court, hence the petition of the petitioner is liable to be
dismissed.
under reply are wrong and denied. It is denied that prior
to filing the present petition, the petitioner has filed
petition which was withdrawn by the petitioner vide
order dated 28.6.11. It is further denied that the present
petition is barred under the principles of resjudicata.
petitioners have not come to the court with clean hands
and has concealed the material information from this
Hon’ble Court.
under reply are wrong and denied. It is denied that it is
the petitioner no.1 who has treated the respondent with
utmost cruelty and now has filed the petition on the basis
of false, fabricated and baseless allegations only with a
view to harass the respondent.

petitioner is not entitled to receive any relief much less
monetary relief against the respondent as she willingly
left the company of the respondent in October 2008 and
has refused to stay with respondent without any cogent
reason. It is further denied that the petitioner no.1 has
deserted the respondent, and has left the company of
respondent without any rhyme or reason. It is further
denied that the petitioner no.1 is running away from all
the responsibilities of matrimonial life but at the same
time, she intends to claim the benefits of a destitute wife
without playing her part.
petitioner no.1 in the present petition has made false
averments and as such the petitioner no.1 is liable to be
prosecuted and punished U/s 195/340 of CrPC.
under reply are wrong and denied. It is denied that there

is no cause of action against the respondents and in
favour of the petitioner no.1 inasmuch as the petitioner
no.1 is not entitled to any relief whatsoever. It is further
denied that there was no dowry demand from the side of
the respondent before or after the wedding and the
wedding was performed without any dowry
present petition is liable to be dismissed on grounds of
willful concealment of facts by the petitioner no.1 from
this Hon’ble Court. It is further denied that the petitioner
no.1 has deliberately concealed her educational
qualifications, her present and past income, her bank
balance/fixed deposits etc. just to gain sympathy from
this Hon’ble Court.
REPLY TO PRELIMINARY SUBMISSIONS:
1. That the contents of para 1 of the preliminary
submissions under reply are wrong and denied. It is
denied that the petitioner no.1 always used to insult and
humiliate the respondent in front of his family members,

friends and relatives. It is further denied that the
petitioner used to boast about her qualification and
earnings. It is further denied that the petitioner never
showed any responsibility towards the respondent and
his mother
denied that the petitioner used to go to her parental home
without even intimating the respondent and his mother
and most of the time she used to stay at her parental
home.
denied that whenever the respondent requested the
petitioner no.1 to atleast inform the respondent prior to
going to her parental home or at any other place, the
petitioner no.1 used to shout on the respondent by saying
that the respondent has no right to interfere in the
personal life of petitioner no.1 and she will do whatever
she likes. It is further denied that the petitioner no.1

mostly used to go to her parental home directly from her
office and used to go to the parental house of petitioner
no.1 to bring her back, but there was no change in the
behavior and habit of the petitioner no.1.
denied that the petitioner no.1 is of dominating nature
and always used to force the respondent to act according
to her wishes. It is further denied that not only this, the
parents and brother of the petitioner no.1 used to extend
threats to the respondent that in case the respondent tried
to interfere in the life of petitioner no.1, they will lodge
false case of dowry demand against the respondent and
his mother.
denied that in October 2008, the petitioner no.1 had gone
to her parents home despite request made by the
respondent and his mother not to go anywhere as she
was at mature stage of pregnancy and travelling was not

good for her, but the petitioner no.1 did not listen to the
request of the respondent and his mother and she went to
her parental house against their wishes.
denied that thereafter when the respondent went to the
parental home of the petitioner no.1 to bring her back to
her matrimonial home, but the petitioner refused to
return back.
denied that the respondent and his mother went to the
hospital and the entire expenses of medicines and
treatment was borne by the respondent, when the
petitioner no.1 was discharged from the hospital, the
respondent called taxi for taking her back to her
matrimonial home, but the petitioner without telling
anything to the respondent had gone to her parental
home by the car of her brother, but the petitioner no.1

did not allow the respondent and his mother to even take
the new born child.
denied that the respondent and his mother had gone to
the parental house of petitioner no.1 various times and
requested her to come back to her matrimonial home and
to allow them to meet the child, but the petitioner no.1
refused to come back to her matrimonial home and did
not allow respondent and his mother even to see and
meet the child. This caused huge mental trauma for the
respondent and his mother.
denied that ever since the marriage, the petitioner no.1
treated the respondent with utmost cruelty to the extent
that it become difficult for the respondent to pull on
further with petitioner no.1. It is further denied that the
respondent was subjected to mental, physical and
emotional cruelty which made the life of the respondent

a dungeon hell. It is further denied that the petitioner
no.1 by her cruel acts and deeds, has not only made the
respondent suffer miserably, but has even brought the
scared institution of marriage into disrepute.
denied that the petitioner no.1 was unhappy with the
marriage since the very beginning and used to openly
show her resentment by loudly uttering that she never
wanted to marry the respondent. It is further denied that
the petitioner no.1 told the respondent several times that
the respondent has no value in her life.
denied that the petitioner no.1 is a very moody and
unstable lady. It is further denied that the on various
occasions, when the relatives or friends of the
respondent visited him, the petitioner no.1 refused to
even serve water or tea to the guests. It is further denied

that this made the respondent feel embarrassed in front
of the guests.
denied that the petitioner no.1 is lady of short temper
who used to lose her temper and become upset on very
small issued. It is further denied that the she had no
control on her anger and used to pick up fights even on
non issues. It is further denied that the respondent
initially tied to ignore her cruel felt behavior and did not
take it seriously, but felt disturbed and on various
occasions ashamed. It is further denied that the petitioner
no.1 made no efforts to adjust herself in the matrimonial
home. It is further denied that the respondent had been
tolerating the cruel behavior of petitioner no.1 with the
hope that his love and with the passage of time, she may
get adjusted and shall change her behavior after she
feels comfortable and their relation shall improve after
adjustment and with passage of time. It is further denied
that on various occasions, the petitioner no.1 treated the

respondent as if the respondent is even worse than her
servant.
denied that though the respondent treated petitioner no.1
with love and affection, but the petitioner no.1 used to
hate and maltreat the respondent. It is further denied that
all the requests of the respondent made to the petitioner
no.1 to behave properly fell in deaf ears and petitioner
no.1 always showed her apathy to the needs and wants
of the respondent.
denied that even on the pettiest of the altercations, the
petitioner no.1 would behave in an utmost cruel manner.
It is further denied that the petitioner no.1 used to shout
on the respondent and used to use abusive and
intolerable language against the respondent. It is further
denied that the petitioner no.1 would openly threaten the
respondent of dire consequences if he tried to interfere

with the liberty of the petitioner. It is further denied that
the petitioner no.1 even threatened the respondent that
she would implicate the respondent and his family
members in false cases of dowry despite the fact that the
marriage was virtually dowryless and no demand for any
gift, money or dowry articles was ever made by the
respondent or his family members.
denied that on several occasions, the petitioner no.1
would use vile and abusive language against the mother
of the respondent to hurt the sentiments of the
respondent. It is further denied that the petitioner no.1
would seek pleasure dirty words against his mother. It is
further denied that the unbecoming behavior of the
petitioner no.1 towards the respondent and his mother
also brought mental pain and agony to the respondent.
denied that the petitioner no.1 used to force the

respondent to take separate home as the petitioner no.1
was not willing to reside home as the petitioner no.1 was
not willing to reside with the mother of respondent, and
the petitioner no.1 clearly told the respondent that she
cannot take care of the old and aged mother of the
respondent.
denied that the petitioner no.1 used to give threats to the
respondent and his family members that she would file
competitions in police authorities if anyone tries to stop
the petitioner no.1 from doing what she wanted.
denied that the brother of the petitioner no.1 several
times extended threats of dire consequences to the
respondent and his mother, then mother of respondent
lodged competition with PS Hari Nagar Delhi on 25.4.10
& 11.5.10.
denied that due to constant mental tension and torture
extended by the petitioner no.1, her brother and other
family members, the widow mother of respondent has
gone into deep depression and due to that her health
deteriorated day by day and she became bed ridden.
denied that the respondent suffered immense physical
and mental pain and agony apart from harassment and
humiliation at the hands of the petitioner no.1.
denied that the inflexible temperament coupled with the
inhuman behavior of the petitioner no.1 towards the
respondent became a constant menace to the peace and
wellbeing of the household. It is further denied that the
petitioner no.1 always strived to maintain her control

and authority over the entire household without any
respect or dignity towards the respondent.
denied that the conduct of the petitioner no.1 is not only
unbecoming of a wife, but of a normal human being as
well. It is further denied that the petitioner no.1 is solely
responsible for making the life of the respondent a
virtual hell. It is further denied that the constant
untoward acts of the petitioner have caused breakdown
of the marriage.
denied that the petitioner no.1 is a well qualified and is
working with Bank of America as team member. It is
further denied that in the year 2010, the petitioner no.1
was getting salary of Rs.93,611/- per month. It is further
denied that the petitioner no.1 concealed these facts from
the Hon’ble Court at the time of filing petition U/s 125
CrPC.
denied that the petitioner no.1 is more qualified and
earning much more than the respondent. It is further
denied that the petitioner no.1 is having more than
sufficient means and is leading a luxurious life.
denied that the respondent is 12th pass and is not having
any professional qualification. It is further denied that
the respondent is residing in a rented house along with
his mother.
denied that the mother of respondent is bed ridden and
the respondent has to remain present at home for taking
care of his mother.

denied that the respondent is having a very small counter
of artificial jewelry at Sadar Bazar Delhi which has been
taken by him on lease/pagri basis. It is further denied
that the respondent has to take care of his mother hence
he is not able to open his counter regularly and whenever
the same is opened, its opened only for a short duration
of time. It is further denied that the respondent is earning
approx. Rs.1,000/- per day and when he opens the
counter. It is further denied that the average monthly
earning of the respondent are not more than Rs.25,000/-
per month.
denied that the respondent has to pay rent of his house of
Rs.10,000/- per month. It is further denied that apart
from this, since the mother of the respondent is bed
ridden, huge amount is spent on medicine and treatment
of the mother of the respondent.

denied that the particulars of educational qualification,
occupation, income etc. of the respondent as alleged by
the petitioners are completely false and baseless and the
only intention of the petitioners is to extract more and
more money from him. It is further denied that the
petitioner no.1 has made vague and unsubstantiated
averments about the alleged income of the respondent
just to mislead this Hon’ble Court.
denied that the respondent no.1 is not sharing the
responsibility of looking after the old and ailing mother
of the respondent. It is further denied that the petitioner
no.1 has filed false and frivolous cases against the
respondent in order to put him into inconvenience.
denied that the petitioner no.1 has already devastated the

lives of the respondent and his mother. It is further
denied that the petitioner herself left the matrimonial
home along with all her jewelry and valuable clothes and
all the Istridhan articles.
denied that the petitioner no.1 has filed the present
petition to satisfy her greed rather than for any bonafide
need. It is further denied that the greed of petitioner no.1
is evident from the fact she has deliberately not revealed
her earnings including salary in the present petition
despite having a handsome earning.
denied that the petitioner no.1 has willfully omitted to
declare her financial status/income in order to induce
this Hon’ble Court to believe that the petitioner has no
source of income. It is further denied that it is a matter of
great surprise that despite having handsome salary and
other income towards interest from investments, coupled

with the siphoning off the assets and valuables from the
house when she stayed with the respondent, the
petitioner no.1 is still claiming monetary reliefs from the
respondent.
denied that the petitioner has not come to the court with
clean hands and remaining contents are matter of judicial
record.
REPLICATION TO REPLY ON MERITS:
1) That the contents of para 1 of petition are denied and the
corresponding para of the petition is reiterated and
reaffirmed to be true and correct.
2) That the contents of para 2 of the petition are denied and the
reaffirmed to be true and correct. It is denied that since the
birth of the child, the petitioner no.2 did not allow the
respondent and his mother even to meet the child.
3) That the contents of para 3 of the petition, need no reply
being matter of record.
4) That the contents of para 4 of the petition are denied and the
reaffirmed to be true and correct. It is denied that the
marriage between the petitioner no.1 and the respondent
performed in a very simple manner and no articles or
jewelry, as alleged given by the parents of petitioner no.1.
5) That the contents of para 5 of petition are wrong and denied
and the corresponding para of the petition is reiterated and

reaffirmed to be true and correct. It is denied that neither the
respondent nor his mother at any point of time demanded
any dowry or cash from the petitioner no.1.
petitioner herself left the matrimonial home along with all
her jewelry and valuable clothes and even after that one
suitcase which was full of her articles was taken away by
her brother and sister from the matrimonial house of
petitioner no.1.
respondent never raised any kind of demand at any point of
time from petitioner no.1 or anyone else.
respondent always treated the petitioner no.1 with utmost

love and care but the petitioner no.1 did not allow the
respondent even to meet his own son and has taken away
child i.e. petitioner no.2 to her parental home directly from
the hospital after his birth. It is further denied that the
respondent and his mother visited the parental house of
petitioner no.1 several times, but all the times the petitioner
no.1 and her family members insulted the respondent and
his mother and did not allow them to even meet the minor
child. It is further denied that it is the petitioner no.1 who
treated the respondent with utmost cruelty and having no
sympathy or emotions towards the respondent.
Istridhan of the petitioner no.1 was always in custody of her
and always in the custody of the petitioner no.1 and was
taken back by the petitioner no.1.
10) That the contents of para 10 of petition are wrong and
denied and the corresponding para of the petition is
reiterated and reaffirmed to be true and correct. It is denied
that it is the petitioner no.1, who treated the respondent and

his mother with cruelty. It is further denied that the
petitioner no.1 is a dominating lady ad always used to
dominate the respondent to act according to his command
and used to force him to live separately from his aged and
ailing mother.
that the petitioner no.1 was not doing any household work
in her matrimonial home and the mother of respondent used
to do the entire household work. It is further denied that the
petitioner no.1 used to tell the respondent that she is doing
job and earning money, hence she will not do any
household work in her matrimonial home.
that it is the petitioner no.1 who was treating the respondent
and his mother with cruelty and always used to force the
respondent to live separately from his mother.

that the respondent and his mother treated the petitioner
no.1 with utmost care and provided her best diet and proper
treatment. It is further denied that even the entire hospital
bills of the delivery of the petitioner no.1 were borne by the
respondent.
that the entire pre and post delivery expenses were borne by
the respondent, but the petitioner no.1 did not allow the
respondent to meet his own child and he has taken away the
child at her parental home directly from hospital.
that the respondent and his mother remained with the
petitioner no.1 in hospital during period, the petitioner no.1
remained in hospital at the time of birth of the child, but the

petitioner no.1 did not allow the respondent and his mother
to meet the child.
that the petitioner no.1 never brought the petitioner no.2 at
the house of the respondents at any point of time and never
allowed the respondent and his mother to see the child, thus
question of confirming the petitioners in a room does not
arise.
that the petitioner no.1 on her own left her matrimonial
home in October 2008. It is further denied that the
respondent and his mother several times went to the
parental house of petitioner no.1 to bring the petitioners
back to their home, but the petitioner no.1 and his family
members insulted the respondent and his mother and did not
allow them to meet the minor child.

that the petitioner no.1 was never treated with cruelty at
any point of time.
that the petitioner no.1 did not allow the respondent to meet
his own child, still the respondent is fulfilling all his
responsibility towards his son.
that the petitioner no.1 is gainfully employed and is earning
handsomely and is not entitled for the relief claimed in the
present petition.

that the mother of the respondent is bed ridden and the
respondent has to remain present at home for taking care of
his mother. It is further denied that the respondent has to
maintain and take care of his mother also.
that the petitioner no.2 is not daughter, but is son of
respondent.
that the respondent is having a very small counter of
artificial jewelry at Sadar Bazar Delhi which has been taken
by him on lease/pagri basis. It is further denied that the
respondent has to take care of his mother hence he is not
able to open his counter regularly and whenever the same is
opened, its opened only for a short duration of time. It is
further denied that the respondent is earning approx.
Rs.1,000/- per day and when he opens the counter. It is

further denied that the average monthly earning of the
respondent are not more than Rs.25,000/- per month.
that the petitioner no.1 on her own left the company of the
respondent without any rhyme or reason and is also earning
handsomely, hence the petitioner no.1 is not entitled for any
maintenance as claimed in the present petition.
that the respondent belongs to lower class.
reiterated and reaffirmed to be true and correct.

that the petitioners are not entitled for the relief claimed in
the present petition.
that the petitioner did not allow the respondent and his
mother even to see his own child. It is further denied that
that the respondent has to take care of his old age and ailing
mother who is bed ridden and there is no one in the family
of respondent to take care of his aged and ailing mother also
who is bed ridden and there is no one in the family of
respondent to take care of his mother. It is further denied
that the petitioner no.1 with a view to avoid her
responsibilities towards her matrimonial home has left the
company of the respondent, hence the petitioner no.1 is not
entitled for the relief claimed.
that the respondent has no case at all and the petition of the
petitioners is liable to be dismissed.

reiterated and reaffirmed to be true and correct.
The prayer clauses of the reply / written statement are
also wrong and strongly denied.
PRAYER
In view of the above facts and circumstances, it is most
respectfully humbly prayed that this Hon’ble Court may kindly be
pleased to allow the petition as per prayer clause made therein, in
the interest of justice; and
Pass any other or further order, which this Hon’ble Court
deems fit and proper may also be passed in the interest of justice.
It is prayed accordingly.
Petitioner No.1
Through
Counsel
Delhi
Dated: June-2020
VERIFICATION:
Verified at Delhi on this __ day of June-2020 that the
contents of paras 1 to 8 of preliminary objections & paras 1 to 34
of preliminary submissions are true and correct while as paras 1 to
30 of the replication on merits are correct on the basis of
information received and believed to be true. Last para is prayer
before this Hon’ble Court.
Petitioner No.1
IN THE COURT OF MS. RENU BHATNAGAR, LD. PJFC
[WEST], TIS HAZARI, DELHI
MT NO.: 598 / 2019
IN THE MATTER OF:
HARPREET KAUR & ANR. ..PETITIONERS
VERSUS
SUKHRAJ ..RESPONDENT
D.O.H.: 09.06.2020
REPLICATION ON BEHALF OF THE

PETITIONERS TO REPLY of INTERIM
APPLICATION FILED BY THE RESPONDENT
MOST RESPECTFULLY SHOWETH:
REPLY TO PRELIMINARY OBJECTIONS:
petitioner no.1 has filed the present petition by
concealing material information from this Hon’ble

Court, hence the petition of the petitioner is liable to be
dismissed.
under reply are wrong and denied. It is denied that prior
to filing the present petition, the petitioner has filed
petition which was withdrawn by the petitioner vide
order dated 28.6.11. It is further denied that the present
petition is barred under the principles of resjudicata.
petitioners have not come to the court with clean hands
and has concealed the material information from this
Hon’ble Court.
under reply are wrong and denied. It is denied that it is
the petitioner no.1 who has treated the respondent with
utmost cruelty and now has filed the petition on the basis
of false, fabricated and baseless allegations only with a
view to harass the respondent.

petitioner is not entitled to receive any relief much less
monetary relief against the respondent as she willingly
left the company of the respondent in October 2008 and
has refused to stay with respondent without any cogent
reason. It is further denied that the petitioner no.1 has
deserted the respondent, and has left the company of
respondent without any rhyme or reason. It is further
denied that the petitioner no.1 is running away from all
the responsibilities of matrimonial life but at the same
time, she intends to claim the benefits of a destitute wife
without playing her part.
present application is liable to be dismissed on grounds
of willful concealment of facts by the petitioner no.1
from this Hon’ble Court. It is further denied that the
petitioner no.1 has deliberately concealed her
educational qualifications, her present and past income,

her bank balance/fixed deposits etc. just to gain
sympathy from this Hon’ble Court.
petitioner no.1 is a well qualified and is working with
Bank of America as team member. It is further denied
that in the year 2010, the petitioner no.1 was getting
salary of Rs.93,611/- per month. It is further denied that
the petitioner no.1 concealed these facts from the
Hon’ble Court at the time of filing petition U/s 125
CrPC.
petitioner no.1 is more qualified and earning much more
than the respondent. It is further denied that the
petitioner no.1 is having more than sufficient means and
is leading a luxurious life. It is further denied that at
present the petitioner no.1 is earning a sum of Rs.1.50
lacs per month.

respondent is 12th pass and is not having any
professional qualification. It is further denied that the
respondent is residing in a rented house alongwith his
mother.
mother of respondent is bed ridden and the respondent
has to remain present at home for taking care of his
mother.
respondent is having a very small counter of artificial
jewelry at Sadar Bazar Delhi which has been taken by
him on lease/pagri basis. It is further denied that the
respondent has to take care of his mother hence he is not
able to open his counter regularly and whenever the
same is opened, it is opened only for a short duration of
time. It is further denied that the respondent is earning

approx. Rs.1,000/- per day and when he opens the
counter. It is further denied that the average monthly
earning of the respondent are not more than Rs.25,000/-
per month.
respondent has to pay rent of his house of Rs.10,000/-
per month. It is further denied that apart from this, since
the mother of the respondent is bed ridden, huge amount
is spent on medicine and treatment of the mother of the
respondent.
Rejoinder to parawise reply on merits:
1. That the contents of para 1 of reply to interim application
need no reply being matter of record. However, it is
submitted that the contents of accompanying replication
may kindly be read as part and parcel as rejoinder to reply
of interim application also as the same are not being
repeated herein for the sake of brevity with a view to avoid
repetition.
are wrong and denied and the corresponding para of the
petition is reiterated and reaffirmed to be true and correct.
are wrong and denied and the corresponding para of the
petition is reiterated and reaffirmed to be true and correct. It
is denied that the petitioner no.1 is a well qualified and is
working with Bank of America as team member. It is
further denied that in the year 2010, the petitioner no.1 was
getting salary of Rs.93,611/- per month. It is further denied
that at present the petitioner no.1 is earning Rs.1.50 lacs per
month and is not entitled for any maintenance.
The prayer clauses of the reply to interim application are
also wrong and strongly denied.
PRAYER
In view of the above facts and circumstances, it is most
respectfully humbly prayed that this Hon’ble Court may kindly be
pleased to allow the interim maintenance application as per prayer
clause made therein, in the interest of justice;

Petitioner No.1
Through
Counsel
Delhi
Dated: June-2020

Rejoinder - Harpreet Kaur

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IN THE COURT OF MS. RENU BHATNAGAR, LD.

MT NO.: 598 / 2019

IN THE MATTER OF:

HARPREET KAUR & ANR. ..PETITIONERS

REPLICATION ON BEHALF OF THE

MOST RESPECTFULLY SHOWETH:

REPLY TO PRELIMINARY OBJECTIONS:

1. That the contents of para 1 of the preliminary objection

under reply are wrong and denied. It is denied that the

petitioner no.1 has filed the present petition by

concealing material information from this Hon’ble

2. That the contents of para 2 of the preliminary objection

under reply are wrong and denied. It is denied that prior

to filing the present petition, the petitioner has filed

petition which was withdrawn by the petitioner vide

order dated 28.6.11. It is further denied that the present

petition is barred under the principles of resjudicata.

3. That the contents of para 3 of the preliminary objection

under reply are wrong and denied. It is denied that the

petitioners have not come to the court with clean hands

and has concealed the material information from this

4. That the contents of para 4 of the preliminary objection

under reply are wrong and denied. It is denied that it is

the petitioner no.1 who has treated the respondent with

of false, fabricated and baseless allegations only with a

view to harass the respondent.

under reply are wrong and denied. It is denied that the

petitioner is not entitled to receive any relief much less

monetary relief against the respondent as she willingly

left the company of the respondent in October 2008 and

has refused to stay with respondent without any cogent

reason. It is further denied that the petitioner no.1 has

deserted the respondent, and has left the company of

respondent without any rhyme or reason. It is further

denied that the petitioner no.1 is running away from all

the responsibilities of matrimonial life but at the same

time, she intends to claim the benefits of a destitute wife

without playing her part.

6. That the contents of para 6 of the preliminary objection

under reply are wrong and denied. It is denied that the

petitioner no.1 in the present petition has made false

averments and as such the petitioner no.1 is liable to be

prosecuted and punished U/s 195/340 of CrPC.

7. That the contents of para 7 of the preliminary objection

under reply are wrong and denied. It is denied that there

favour of the petitioner no.1 inasmuch as the petitioner

no.1 is not entitled to any relief whatsoever. It is further

denied that there was no dowry demand from the side of

the respondent before or after the wedding and the

wedding was performed without any dowry

8. That the contents of para 8 of the preliminary objection

under reply are wrong and denied. It is denied that the

present petition is liable to be dismissed on grounds of

willful concealment of facts by the petitioner no.1 from

this Hon’ble Court. It is further denied that the petitioner

no.1 has deliberately concealed her educational

qualifications, her present and past income, her bank

balance/fixed deposits etc. just to gain sympathy from

this Hon’ble Court.

REPLY TO PRELIMINARY SUBMISSIONS:

1. That the contents of para 1 of the preliminary

submissions under reply are wrong and denied. It is