IN THE COURT OF MS. NIDHI SINGH, LD.

CMM
SOUTH-EAST, SAKET, NEW DELHI
CT CASES/931/2023

IN THE MATTER OF:

SIMRAN GUPTA …COMPLAINANT
VERSUS
SANTOSH GUPTA …DEFENDANT

WRITTEN STATEMENT/REPLY ON BEHALF OF ALL DEFENDANTS

TO THE PLAINT FILED BY THE COMPLAINANT.

PRELIMINARY OBJECTIONS

1. That the complaint under Section 12 of Protection of

Women from Domestic Violence Act, 2005 filed by the
applicant has not been framed in accordance with
Protection of Women from Domestic Violence Rules 2006
and also has not been framed in accordance with Form I, II
& III of the said rules. In view of this, the present complaint
is not maintainable and the same is liable to be dismissed.
2. That the “Protection of Women from Domestic Violence Act, 2005” is
meant for genuine sufferers and not for misuse thereof. The applicant
is one such misuses of law and thus an abuser of law and process of
the Hon’ble Court and such the applicant is not entitled either to
invoke the provisions of the Act or for any relief(s) claimed therein. In
view of this, the present application is not maintainable and is liable
to be dismissed.
3. That the applicant is not entitled for any relief as claimed in the
present applicant under Section 12, 18, 19, 20 and 22 of Protection of
Women from Domestic Violence Act, 2005. In view of this, the
application is not maintainable and the same is liable to be dismissed.
4. That the applicant has not come before this Hon’ble Court with clean
hands and she has concealed and supressed true and material facts
from this Hon’ble Court. In view of this the complaint is not
maintainable.
5. That the Protection of Women from Domestic Violence Act, 2005 was
enacted with the object of providing remedy under the Civil Law
which was intended to protect the Women being victim of domestic
violence and prevent occurrences of domestic violence in the society.
The present application is not within the definition of Section 3 of the
Protection of Women from Domestic Violence Act, 2005. In view of
this, the application is not maintainable and the same is liable to be
dismissed.
6. That the applicant herself is guilty of her own acts and conduct and as
such she cannot take advantage of her own wrongs. In view of this,
the application is not maintainable and the same is liable to be
dismissed.
7. That the applicant has made vague, false, frivolous, defamatory,
scandalous and concocted allegations in the present application
against the respondents, therefore, the application is not
maintainable and the same is liable to be dismissed.
8. That the application under reply is false, frivolous, baseless and has
been filed with malafide intentions and ulterior motives just to harass
and blackmail the respondents and also with a view to compel the
respondent No.1 to accede to the illegal and unlawful demands of the
applicant. In view of this the application is not maintainable and the
same is liable to be dismissed.
9. That no cause of action has arisen, exists, continues and/or has been
disclosed in the application u/s 12 of Protection of Women from
Domestic Violence Act, 2005 filed by the applicant against the
respondents. The complaint is an abuse and misuse of the process of
law. In view of this, the application is not maintainable and the same
is liable to be dismissed.
10. That the applicant has concealed her income from this Hon’ble
Court, she is not entitled for any maintenance in the present
application. In view of this, the application is not maintainable and
liable to be dismissed.
11. That complainant has failed to give any specific date and month as
and when the alleged incidents have taken place. In fact, no such
alleged occasion ever took place. The petitioner has made false,
 vague, frivolous, baseless and defamatory allegations against the
respondents in present petition. In view of this, the petition is not
maintainable and liable to be dismissed.
12. That all averments/contentions and allegations made against
Respondents in the Complaint filed by the Complainant are
categorically and outrightly denied for being largely based upon
conjectures and surmises. No allegation shall be deemed to be
admitted unless specifically admitted herein below. A bare perusal of
the Complaint unambiguously establish that it is misconceived,
frivolous and vexatious both on facts and in the eyes of law. The
Complainant has resorted to all possible methods with ulterior
motive to extort the money and harass the Respondent No.1 and
other Respondents. It is submitted that the Complaint filed without
any documentary evidence to prove the baseless and concocted
statements is absolutely frivolous and puerile and thus is liable to be
dismissed outrightly with exemplary costs.

PRELIMINARY SUBMISSIONS
1. Save as specifically admitted, the answering respondents denies the
entire allegations and demands as given in the present application in
toto. The respondents further reserves his right to add and amend
any other point that has been stated in this reply.
2. No specific date and time
3. No proof of beating
4. The Respondent No.1 respectfully submits that he is a well-mannered
man and leads his life with clean habits The respondents No.1 is a
tea-totaller man. The respondent no.1 is earning his bread with lots
of efforts and hard work. It is submitted that Complainant and just
because of her illegal demands and lust of money. The Complainant
had left the company of the Respondent No.1 and his family members
and thereafter she was she was creating pressure upon the
Respondent No.1 and his family members for compensation only but
when the Respondent No.1 has shown his inability to fulfil her heavy
demands for money so she has filed the present application after
staying separate from the Respondent No.1 for more than one year.
The Complainant has filed the present complaint just to harass,
humiliate, and pressurise the Respondent No.1 and his family
members to bow down on her illegal demands of heavy
 compensation which is proven fact that she has filed the present
application. The Respondent No.1 provided all comforts and facilities
to the complainant. The complainant continued to misbehave with
the present Respondents in a filthy language. The Respondents have
never mal-treated or caused any kind of torture, harassment and
cruelty to the complainant for the sake of dowry or otherwise and
they have been falsely implicated by the complainant in the aforesaid
Complaint.
PARAWISE REPLY ON MERITS
1. That the contents of Paragraph 1 are the matter of record hence need
no Reply.
2. That the contents of Paragraph 2 is admitted that petitioner was
married to the Respondent No.1 on 16 July 2021 as per Hindu rites
and ceremonies and thereafter started living in the matrimonial
home along with the Respondents.
3. That the contents of Paragraph 3 is denied that the Petitioner is
suffering mental pain and agony because of the regular abusive
behaviour and foul language used by Respondent No.1 and his family.
Which gives her lot of stress and tension in this younger age. It is
submitted
4. That the contents of Paragraph 4 is only admitted to the extent that
the Respondent No.1 is the husband of the Complainant and working
as an Assistant Engineer in D.D.A. It is evidently denied that the
Respondent No.1 is always demanding the expansive gifts items and
asking for more money in the form of gifts by the complainant and
her mother. It is denied that he is always asking for branded clothes,
watches and other items from the mother of the complainant by
saying that what will his mother-in-law will do with her money.
5. That the contents of Paragraph 5 are denied for being baseless and
puerile. It is completely denied that the other respondents mother-in-
law, father-in-law, brother, brother-in-law, sister-in-law, cousins,
parental uncle and maternal uncle of the Complaianant regularly
provoked the Respondent No.1 to misbehave with his mother-in-law
and wife. It is pertinent to mention herein that it is the complainant
who utter foul language towards the Respondents without any
reason. It is the Complainant who do not want that Respondent No.1
will talk to their family members. It is the Complainant who instigate
the Respondent No.1 and lead him to fight with his own parents.
6. That the contents of Paragraph 6 are denied that the marriage
between the parties was solemnized on 16/07/2021 in Jamshedpur
at Jharkhand according to Hindu rites and ceremony as per the
wishes of the in-laws of the Complainants. It is submitted herein that
the marriage of the parties was solemnized on 16/07/2021 in
Jamshedpur at Jharkhand according to Hindu rites and ceremony as
per the consent of the both parties.
7. The contents of Paragraph 7 are denied for being false and frivolous
and lacking any documentary evidence corroborating the same. It is
denied that the mother of the complainant gave a handsome amount
dowry to the accused person and his family members by exceeding
her financial limits. It is also denied that the dowry articles inter-alia
included lots of gold jewellery, furniture, electronics items and
electrical gadgets/home appliances, costly wearing apparel, and Rs.
11,00,000/- through cheque in different accounts of the family
members of the respondent and Rs. 10,00,000/- via cash other
articles of domestic use. It is submitted that the articles given by the
Complainant’s parents in the marriage as per their choice and
customs. No demand of dowry made by the respondents or their
relatives at any point of time in the marriage. It is pertinent to submit
herein that the Respondent No.1 is sole bread earner in his family
and there 5 family members in the family. Furthermore, the
Complainant always demands the luxurious items from the
Respondent No.1 like luxury bags, luxury sandals etc. It is submitted
that the Complainant coerce the Respondent No.1 to gift her the gold
items on every occasion. It is submitted that the Complainants always
demands to go on luxurious/foreign vacations and threatens the
Respondent No.1 if he will not take her to the luxurious/foreign
vacations she will go to her parental home and never come back.
8. That the contents of Paragraph 8 are denied for being false,
misconceived and misrepresented. It is denied that the Respondent
No.1 provide the different bank accounts details of his family
members for depositing the dowry amount because as a Govt.
employee, he can’t take the amount directly in his own account. It is
pertinent to submit herein that the amount deposited in the said
accounts is not for the dowry. It is the dupery by the Complainant to
implicate the Respondents into the false and frivolous case. The
parents of the Complainant transferred the said amount for the
furniture they want to give to their daughter.
9. The contents of Paragraph 9 are admitted to the extent that the
Complainant completed her MBA through Gautam Budh University,
Greater Noida and she is staying with her widowed mother. It is
vehemently denied that she has no job and having no source of
income. It is submitted herein that the Complainant has done her
MBA from a reputed college and currently she is working at
____________ and getting Rs. _________ salary.
10. That the content of Paragraph 10 is admitted.
11. That the content of Paragraph 11 is vague, wrong and denied. It is
dined that the Respondent no 1. tied the nuptial knot only for the sake
of huge dowry in the marriage. After marriage he turned out to be a
very cruel and reckless and selfish person, who was never inclined to
take care of his wife and never pay respect to his responsibilities and
obligations towards the complainant. It is pertinent to mention
herein that throughout during the Complainant’s stay in the
matrimonial home, her behaviour towards the Respondents was
quarrelsome, non co-operative and indifferent and she made the life
of the Respondent No.1 miserable. The Complainant forced the
Respondent No.1 to live in a separate accommodation. On refusal of
the Respondent No.1, she threatened that she would implicate the
entire family in false and frivolous cases. The Complainant further
threatened not to live in the matrimonial home unless her aforesaid
demands are met.
12. That the content of Paragraph 10 is admitted.
13. That the content of Paragraph 10 is admitted only to the extent that
the both the parties were getting married in Jamshedpur they spent
some time with her in-laws at their residence in Jamshedpur. After
one week they came to Hauz Khas in Delhi in the rented
accommodation of the respondent No. l, which was provided by his
office. They were started the matrimonial life there. After one month,
the Respondent No. 1 invites his friends and some relatives for the
first month's anniversary celebration They all enjoyed the moments
together and also take some pics for the everlasting memory. He also
gifted gold earrings to her at that occasion and ever thing was going
well. It is vehemently denied that after few days the Respondent No. l
started behaving strangely and started abusing and harassing her in
different ways. It is pertinent to mention herein that all the
allegations made by the Complainant are vague just to extort the
money and harass the Respondents. It is specifically submitted herein
 that it is the Complainant who has left the company of the
Respondent No.1 against his wish. It is further submitted that the
Respondent No.1, keeping regard, love and affection for his beloved
wife whom he has always loved with full devotion and loyalty for all
the time and he still have same love and affection for her, and is ready
to live and fulfil all his marital responsibilities towards the
Complainant.
14. The contents of Paragraph 14 are denied for being false and lacking
any evidentiary proof corroborating the false and frivolous
statements made. It is denied that suddenly complainant was
subjected to extreme physical, sexual, verbal, emotional and
economic cruelty by Respondent no. 1 and his family. It is denied that
the complainant tried to bear with that to save her marriage but
finally when she was harassed by the Respondents beyond the human
limit of tolerance the complainant was mothers forced to shift to her
widowed house and the mother of the complainant's mother also
tried sort out the differences by way of requesting the Respondent
No. 1 and his family members but to no avail. It is pertinent to
mention herein that the Complainant and her mother are cooking a
false and frivolous story just to harass and extort more and more
money from the Respondent No.1. It is specifically submitted herein
that the Complainant always asks for money from the Respondent
No.1 by making false stories that her mother is not well and she
needs some monetary help, that she will return the money soon.
Respondent No.1 being a gentle man always helped her mother-in-
law and the Complainant.
15. That the contents of Paragraph 15 are wrong and denied. It is denied
that the Respondent No 1 along with his mother and other family
members are still reluctant and outrightly refused to take
complainant back and ask for a new car and house. It is admitted only
to the extent that the Complainant had to lodge criminal complaint
against Respondent No. 1 and his family members with the Station
House Officer, Police Station Govind Puri dated 22/02/23 and
another complaint in C.A.W Cell on 29/02/23 the same is pending. It
is pertinent to mention herein that the On __________, the Complainant
went to her parental house without any reason. The Respondent No.1
requested her to come back to the house, but she outrightly refused.
The Complainant went to her parent’s house against the wishes of the
Respondent No.1 and his family. While leaving the house, she
 threatened that she would implicate the Respondents in a false
dowry demand case. Subsequently the aforesaid threat was carried
out by the Complainant by lodging a false complaint to the Station
House Officer, Police Station Govind Puri dated 22/02/23 and
another complaint in C.A.W Cell on 29/02/23.
16. The contents of Paragraph 16 are denied for being baseless and
puerile. It is denied that the Respondent no 1, his parents, brother,
sister and two cousins always used complainant as a scapegoat and
tried to squeeze money from her old mother on some or the other
pretext.
17. The contents of Paragraph 17 are denied for being false and
frivolous and lacking any documentary evidence corroborating the
same. It is denied that before the marriage at the time of Ring
ceremony, Respondent no. 3 handed over a lengthy list of articles that
she was looking forward to getting in this marriage from the family of
the complainant as dowry. It is also denied that the mother of the
complainant expressed her inability to meet with expectations of the
accused family. Still, the mother of the complainant confirmed that
she would provide the necessary articles in this marriage according
to her capacity. It is pertinent to mention herein that the Complainant
was never subjected to demand of dowry but now to harass and
pressurize all the Respondents, she has framed such concocted
allegations against the Respondents for which the Complainant be
put to produce strict proof in support of her vague contents of this
para.
18. That the contents of Paragraph 18 are wrong and denied. It is denied
that during the engagement ceremony, the complainant's family
offered Respondent no. 1 some gold ornaments, Rs. 10,000 Cash. It is
admitted to the extent that the few sets of clothes, a make-up kit for
mother- in -Law, fruits, dry fruits and silver coconut etc were given. It
is pertinent to mention herein that the marriage between the
Complainant and the Respondent No.1 is solemnized as per the
Hindu writes and ceremonies and giving few sets of clothes, a make-
up kit for mother- in -Law, fruits, dry fruits and silver coconut. All
these are the rituals which were followed by the Hindu families and
no one is forced in the Complainant’s family to do any of the rituals.
19. The contents of Paragraph 19 are denied for being false and
frivolous and lacking any documentary evidence corroborating the
same. It is denied that after the engagement again the mother-in-law
 gave a list of items demanded by Complainant's father- in -law. They
demanded AC, Refrigerator, LED TV, Washing Machine, Double Bed,
Dressing Table Sofa Set, Car, Diamond Ring, Diamond earing for
mother -in -law, and a gold chain for Respondent No.1/Santosh with
Ten Lakh cash and Eleven lakhs via cheque and said that when people
will come in our marriage, they will see what had been given in the
marriage. It is pertinent to mention herein that the Complainant was
never subjected to demand of dowry but now to harass and
pressurize all the Respondents, she has framed such concocted
allegations against the Respondents for which the Complainant be
put to produce strict proof in support of her vague contents of this
para.
20. That the contents of Paragraph 20 are denied for being false and
frivolous. It is denied that after hearing all the demands
complainant's mother said no to the marriage with the Respondent
No.1. It is denied after listening no from our side, the Badi Mami ji of
Respondent no. 1 called my mother on phone and said that there
must be some misunderstanding or maybe they are misguided by
some people so please don't refuse this relation and then she also
assured my mother on behalf of the respondents that it will not
happen again. It is specifically submitted the content of this para is
false and intended to support the frivolous story fabricated by the
complainant.
21. That the contents of Paragraph 21 are wrong and denied. It is denied
that After getting assurance from the Respondent's side my mother
got ready for this relationship. It is denied that they said that we are
only demanding the pleasure & easy life of your daughter Simran so
when she comes to our place then she would be using all these
articles after her marriage & the gifts will improve the status of
Simran in society. After hearing all this my mother felt happy and
started preparations for marriage. It is also denied that "she also
transferred eleven lakh rupees through different accounts in the
accounts of Complainant’s mother -in- law and brother -in- law as per
the directions of Respondent no. 1." It is also denied that she also
gave Ten Lakh Rupees Via cash by selling her gold for the sake of her
daughter's marriage. It is pertinent to mention herein that the
amount deposited in the said accounts is not for the dowry. It is the
dupery by the Complainant to implicate the Respondents into the
 false and frivolous case. The parents of the Complainant transferred
the said amount for the furniture they want to give to their daughter.
22. That the contents of Paragraph 22 are admitted.
23. That the content of Paragraph 23 is vague, wrong and denied. It is
denied that the Complainant was happy to see Respondent No.1’s
parents. It is denied that one day when her mother fall sick she went
to meet her at her place and stayed there for one night and came back
the next day. When she reached back, she found that her almirah was
opened and her clothes and other things were scattered at the floor.
When the complainant reacted to this and asked them that why they
opened her almirah and scattered everything, they ignored her and
did not reply anything. It is denied that when she asked again then
her mother-in-law humiliated her and shouted on her and confined
her that the accused would leave her anytime for a second marriage
because she didn't bring sufficient dowry in her marriage and now,
he is getting better options for marriage. It is pertinent to mention
herein that the Complainant was never been happy to see the parents
of the Respondent No.1. She always compels the Respondent No.1 to
send them back to their hometown, threatening to leave if they
stayed. Complainant used to say that “I feel suffocated when your
parents are around”. On that day also Complainant picked an
unnecessary quarrel with her mother-in-law and warned that “I
cannot live with you under the same roof, I am going to my mother’s
house and will be back tomorrow until then leave this house”.
24. That the contents of Paragraph 24 are wrong and denied. It is denied
that with the passage of time complainant was subjected to more
cruelty by the Respondents, his mother, his father, his brother, his
younger sister, brother-in-law. It is denied that they left no chance to
hurt her whether they were staying there or not. It is denied that they
regularly provoked Respondent no.1 for less dowry whenever it is
possible for them via phone calls or in meetings. It is specifically
submitted the content of this para is false and intended to support
the frivolous story fabricated by the complainant.
25. That the contents of Paragraph 25 are wrong and denied. It is denied
that the cousin named Ritu Raj always provoked him against the
Complainant, he always remains in touch with him. It is denied that
his cousin Ritu Raj who is working as a St. manager in Tata Steel, at
Ranchi ,Jharkand always provoked him for marrying a girl who is not
bringing sufficient dowry and always provoked him to leave the
 Complainant for that. It is denied that he called him day to day basis
and advised him to live alone like him. He is also living alone after
fetching a handsome dowry and left his wife at her parents’ home. It
is submitted herein that it is the Complainant who left the house
because the Respondent No.1 is not fulfilling her luxurious wants like
luxury bags and sandals, gold jewellery on every occasion and
luxury/foreign trips etc. It is specifically submitted herein that at the
time of leaving the house Complainant threatened the Respondent
No.1 that she will implicate every member of his family into the false
and frivolous case and by these vague statements she is trying to fulfil
the purpose.
26. That the contents of Paragraph 26 are wrong and denied. It is denied
that the other cousin Supriya has some affair with Santosh according
to his family. It is denied that the next day of our marriage the whole
family of Santosh warmed the Complainant by saying that keep him
away from Supriya. He liked her so much so always keep an eye on
him. Don't allow him to meet Supriya anymore because he already
spent lot of money on her by giving her gold jewellery many times. It
is denied that the Respondent No.1 likes to stay at Patna where
Supriya stays and always take her for fancy lunch and dinner at
different restaurants. It is denied that whenever he left the
complainant, he went to Patna to spend some time with his cousin
Supriya. It is submitted herein that the Supriya is the sister of the
Respondent No.1 and the Complainant in the feeling of envy
concocted the false and frivolous story to implicate her into this case.
27. That the contents of Paragraph 27 are wrong and denied. It is denied
that the Respondent No. 1 was in habit of chain smoking and drinking
alcohol. It is denied that the Respondent No.1 pressurize her and
wanted unnatural sex with the Complainant. It is denied that the
Respondent No.1 is in habit of fighting with everyone. It is further
denied that when his parents were staying with them, he also fought
with his father and his father leave the house in a fit of anger and
went to his relative’s house who is staying at Palla in Faridabad. It is
denied that he mentioned there about his bad behaviour and said
that Santosh is ill mannered so now it is not easy for anyone to stay
with him.
28. That the content of Paragraph 28 is vague, wrong and denied. It is
denied that after that incident Santosh didn't regret anything and he
continued his bad habits without any shame. It is denied that he
 asked the complainant to get ready like a call girl and every night he
wants to entertain himself by watching porn videos and asking the
complainant to behave like a call girl. It is denied that one day he
ordered the Complainant that now whenever they are alone in the
house at that time the Complainant should not wear anything and she
should do all household chores without wearing any clothes. It is
denied that the Complainant refused his demand but hearing her no
he slapped the complainant and asked her to follow his commands. It
is denied that the Complainant follows his commands and she felt
very uncomfortable and awkward. It is denied that as per his
directions when the complainant was making tea for him, he
deliberately left the main door open and called his friend when his
friend entered into the house, he saw the complainant without any
clothes which was seriously an embarrassing and humiliating
situation for the complainant. It is denied that after this incident the
complainant cried a lot and felt cheated, humiliated and disrespected.
The complainant was very disappointed and regret about that
incidence but respondent No. l who is a shameless fellow didn't
improve himself.
29. That the contents of Paragraph 29 are wrong and denied. It is denied
that few days after this incident, Respondent No.1 again started to
put indecent demands in front of the complainant. It is denied that
every time he asked her to wear small and sexy clothes. It is denied
that he took the complainant to the market and purchased some
small and sexy clothes for her. It is denied that one day he took her
into a market with him on his bike and showed some girls and tell the
complainant that he knows the price of every girl and he also knows
what any particular girl can do to give physical pleasure to please a
man. It was shocking and uncomfortable for a simple girl who always
remain in the vicinity of her friends and family. It is denied that the
Complainant always tried to save her marriage through every way
and means but the Respondent no.1 never pay any respect to her
efforts and he regularly use abusive language. It is denied that he
always place indecent remarks in front of the complainant and turns
all her efforts to maintain peace and harmony in the matrimonial
house in vain.
30. That the contents of Paragraph 30 are wrong and denied. It is denied
that the situation was getting worse by day to day because
Respondent No.1 was creating a ruckus in day-to-day life without any
 shame. It is denied that he always use filthy and abusive language for
the parents of the Complainant which was intolerable for the
complainant. It is denied that he called her a prostitute. It is denied
that he repeatedly talks rubbish about the mother of the complainant.
It is denied that when she complainant about this to her father-in-
law, he doesn't pay any heed to her words. It is denied that father-in-
law always provoked Respondent no. l and said the Complainant that
"AB SHAADI KI HAI TOH NIBHANA TOH PADEGA HI, ABHI TOH
BAHUT KUCH DEKHNA HOGA ISS LADKI KO" And he also said to his
son that "HAME TO KANGLEY PALLEY PAD GAYE". It is denied that
father-in-law also provoked his son that if she doesn't obey you then
you can beat her.
31. That the contents of Paragraph 31 are wrong and denied. It is denied
that she called her mother- in- law and brother- in- law, they came to
Delhi. It is denied that she was very happy to see them that maybe
she will get some help from them. It is denied that they had other
plans, after reaching there they started behaving strangely with her
on every big and small issue. It is denied that they said that now we
don't want you in this house. It is denied that there is no place for you
in our life, we can get a better girl and a much wealthier family for
our son, who is in a good job.
32. That the contents of Paragraph 32 are wrong and denied. It is denied
that she has no option so she had been listening all these things and
cry a lot during that period. It is denied that she suffered a lot of
mental and physical pain due to the unnecessary behaviour of the
respondents. It is denied that on 06/09/2021 when she find some
irregularity in her periods, she told respondent no.1 about this then
her husband took her along with her mother-in-law to Rainbow
Children's Hospital for an ultrasound. It is denied that there she got to
know that she was pregnant for five weeks and two days. After
hearing this news, she was very happy and excited due to pregnancy
she was not feeling well so the doctor suggested her bed rest for
some-time.
33. That the contents of Paragraph 33 are wrong and denied. It is denied
that one day when she was sitting on a chair in her bedroom
suddenly her mother-in-law came into her bedroom and pulled up
her clothes forcefully and saw her private parts. It is denied that she
was in utter shock and asked her Husband that why she did this to
me, but he didn't give any reply to her. It is denied that the next day
 he sends his mother and his brother to Mossa ji's house in Palla at
Faridabad. She tried to stop them but they hit her hand and went to
Mossa ji house, when they left the house Respondent no. 1 came
outside of the house and shouted at her in front of the neighbours. It
is denied that he alleged that she fights with my mother and brother,
she sent them away from this house. It is denied that he said that I
can't live with her and I will file divorce and get rid from her. It is
denied that he deliberately created a scene in front of the neighbours
and created negative image of the complainant in the eyes of society
members and tried to win the sympathy of all people in his favors.
34. That the contents of Paragraph 34 are wrong and denied. It is denied
that incident created a gap in our relationship. It is denied that on 2
October 2021, Respondent No.1 left the house by saying that I have
some urgent work in the office and I will be back in few hours. I
waited for him for the whole day but he did not turn up, then the
complainant tried his phone no. but it was switched off. It is denied
that she also called his family members and all relatives but she did
not get any information. It is denied that then after next day, she filed
a missing complaint at the area Police Station (complaint attach) on
03/10/2022. Then the complainant returned back to their Hauz Khas
flat, she was worried about him and again she called their common
relatives to know about him. But she didn't receive any information
about him. It is denied that she got to knew from one of his friends
that last night he dropped him at the airport. It is denied that after
long hours of waiting, she received a call from him, he said that he is
in Patna at his maternal grandmother's house where Supriya resides.
It is denied that while she was talking to him suddenly his brother
snatch the phone from him and said don't dare to call him again
otherwise I will not spare you and your mother, and I will not leave
you, if you try to reach here at Patna to meet my brother. It is denied
that he warned her and said you and your mother are helpless and
you don't have any other option, you both have to follow our orders.
It is pertinent to mention herein that all these allegations are nothing
but the awful attempt of the Complainant to implicate the
Respondent into false and frivolous complaint. The Complainant was
fully aware that the Respondent No.1 went to the Patna for a family
function. It is submitted herein that the Respondent No.1 was never
aware about the said complaint nor there was any investigation
happened to find the Respondent No.1 that the said complaint was
 nothing but a preplanned gimmick of the Complainant to extort some
money and harass the Respondent and their family members.
35. That the contents of Paragraph 35 are wrong and denied. It is denied
that she felt lonely and helpless due to the strange behaviour of the
respondents and continued to reach out to him through phone calls
but all in vain because he blocked her number. It is denied that she
called other relatives who were involved in their marriage but didn't
get any positive response from any of them. It is denied that they said
that Santosh is getting some pyschological treatment for his
abnormal and unexpected behavior in Patna. It is denied that she was
surprised by hearing all about this and requested them to share the
prescription of the Doctor for further advice from any other Doctor in
Delhi but they refused to share the details with her.
36. That the contents of Paragraph 36 are wrong and denied. It is denied
that meanwhile all this situation she gets a notice from her college to
attend regular classes of MBA. It is denied that when she joined
regular classes and staying in the hostel, she had no one to look after
her. It is denied that she regularly tried to coordinate with Santosh
but all in vain. It is denied that due to the stress, she didn't take care
of herself and she lost her baby in the earlier time of pregnancy. Due
to miscarriage, she fell into depression and found herself in a
miserable condition. It is denied that still she was worried about
respondent no.1. It is pertinent to mention herein that one day
Respondent No.1 caught her talking with another man and when he
asked her about that man, she refused to say anything. It is further
submitted herein that the Complainant always wants to abandon the
Respondent No.1 and went to her hostel to pursue MBA without the
wish and consent of the Respondent No.1. It
37. That the contents of Paragraph 37 are wrong and denied. It is denied
that when her mother knows about her condition, she informed the
respondent about the miscarriage of their daughter-in-law but they
did not respond back and they never show any serious concern about
her well- being. It is denied that they said that “Marti hai toh mar jaye
.humen koi matlab nahi hai”. It is denied that they said that "Let us
know when she dies". It is denied that the Complainant pursued the
accused to take her back in order to save her matrimonial life. It is
denied that the accused was of the view that neither he nor his family
was ever happy with her since she could not fetch sufficient dowry
from her home.
38. That the contents of Paragraph 38 are wrong and denied. It is denied
that the complainant tried to reach him through, all means but she
got no response. It is denied that the complainant all alone facing the
harsh realities of this world She was waiting to get a response from
their side.
39. That the contents of Paragraph 39 are accepted to the extent that
one day Respondent No.1 called her and asked her to meet at
restaurant at Nehru Place in Delhi, and thereafter they decided to
forget about the past incidents and the Respondent No.1 invited her
for a Pooja in his native town and she reached there. It is denied that
she got to know from their relatives that spreading rumours about
her that the baby which she conceived earlier was not belonged to
him and she cheated him. It is pertinent to mention herein that the
Respondent No.1 always wants to live peacefully with the
Complainant and always tries to resolve the issues but the
Complainant always picked unnecessary quarrels. It is the
Respondent No.1 who called her and tried to resolve the matter but
thereafter when the Complainant reached to their native place for
pooja she again picked a quarrel and said that “you have invited me at
pooja and never thought of gifting me something special like gold ring
or earrings etc”.
40. That the contents of Paragraph 40 are wrong and denied. It is denied
that hearing all these false allegations she was getting very sad and
hurt by the statements of the Respondent no.1. It is admitted to the
extent that the complainant who was pursuing MBA was not staying
in Delhi regularly and sometime she stayed at the Hostel for the
completion of the course. Every weekend she came to Delhi and stay
with him. It pertinent to mention herein that the Complainant always
prefer to stay at her hostel and never appeared happy when she came
to her house in Delhi. Furthermore, it is submitted that Respondent
No. 1 attempted to contact her to inquire about her classes, but the
complainant rarely answered her phone. When she did answer, she
was often out with friends and would say, "I'm very busy right now,
and I'll call you later tonight," but the call would never come.
Consequently, Respondent No. 1 had to call her again to ask if she had
eaten, to which she would reply curtly, "Don't worry about me, I have
my friends to take care of me. Worry about yourself instead."
41. That the contents of Paragraph 41 are admitted to the extent that
when the complainant was in her last semester then the Respondent
 No.1 pays her fees because she was not doing any job. It is
vehemently denied that her mother already spent her whole income
in the marriage of the complainant. It is denied that the complainant
knows the fact that how her mother has left with minimum
resources. It is denied that then only she requested Respondent no. 1
to fill the fees from the amount he got through cash or via cheque in
the marriage. It is submitted herein that the Respondent No.1 never
refused to pay for the Complainant’s expenses and also pays for her
fee every time after the marriage. It is specifically submitted herein
that the Respondent No.1 had to even took a personnel loan of Rs.
1,05,000/- to pay her fee.
42. That the contents of Paragraph 42 are wrong and denied. It is denied
that She promised him to return the amount when she will get a
decent job. It is denied that despite of having sufficient dowry and
sufficient bank balance deliberately took a personal loan of Rs.
1,05,000/- for the payment of fees to create a serious impact. It is
denied that when her in law got to know about the fees they shouted
on him and asked him to create pressure on her mother to pay the
amount. It is pertinent to mention herein that the Respondent No.1
and his parents was very happy that she is pursuing her further
studies and implied pressure on her to do household chores because
of her studies. It is further submitted that Respondent No.1 and his
parents was in favour that the fee was paid by the Respondent No.1
as he is the husband of the Complainant.
43. That the contents of Paragraph 43 are wrong and denied. It is denied
that when the complainant was in Jamshedpur and asked about the
marriage album the Respondent no. 2 hide the marriage album and
when she accidentally recovered that from some place the
Respondent no. 2 snatch it from her hands and ran away in the street.
44. That the contents of Paragraph 44 are wrong and denied. It is denied
that when he came back into the house he created a scene by
breaking LED T.V. and called the police. When the police personnel
came they saw the whole situation. It is denied that they tried to
console her by saying that don't worry within time everything will be
alright, so don't worry and keep patience. It is also denied that they
also warmed her In- Laws for creating false evidences. It is pertinent
to mention herein that the Respondent took the Complainant
Jamshedpur on _______ for a __________ and there she also picked
unnecessary quarrel with the Respondent No.2. It is further
 submitted that the Complainant started persuading the Respondent
No.2 to told Respondent No.1 to take her back to her hostel as I do
not feel comfortable with your family and feeling suffocated and if he
did not bring her back, she will call her boyfriend. Respondent No.2
was in shock after hearing that he said I am going to tell Santosh
about what you said about your boyfriend. Subsequently, the
Complainant started breaking the appliances. Thereafter, the
Respondent No.2 called the police.
45. That the contents of Paragraph 45 are only submitted to the extent
that the Complainant is the only child of her parents. It is vehemently
denied that the regular abusive behaviour of the respondents turned
her life into misery. It is denied that she has no support System. It is
denied that she was silently tolerating all this humiliation and
disrespect. It is also denied that the respondents always use this
situation as an advantage and they never paid any attention towards
the need of the complainant.
46. That the contents of Paragraph 46 are wrong and denied. It is denied
that whenever Respondent no. 1 talked to his paternal uncle and
maternal uncle, he suddenly started speaking abusive language for
the Complainant and her mother. It is denied that he asked the
complainant to call her mother and demands the ownership of the
flat and the registry of the flat in his own name, where she is living
alone. It is denied that he also wants to grab the rent of another flat of
the complainant's mother which is only source of living of her
mother. It is also denied that the paternal uncle and maternal uncle
always provoked him to beat the complainant and always tried hard
to break this marriage by creating misunderstandings because now
they have some better marriage proposals for him.
47. That the contents of Paragraph 47 are wrong and denied. It is denied
that when her mother denied the transfer of property in his name he
got agitated and used filthy language for her mother and her other
relatives. It is denied that he called her mother a widow and
whenever he ate the home cooked meal prepared by her mother
when she invited them, he complains that what a widow kind of taste
is there in the food. It is denied that he always insulted her by saying
that there is no taste in the food which was cooked by her mother and
it is so blend like a widow. It is also denied that he also commented
about the relationship for her parents that they must be used some
medicine for the enjoyment in their married life which hurts the
 complainant a lot. It is denied that when she opposed the nature and
way of talking about her parents, he scolded her while degrading her
family members & slapped her and many times he pressed her mouth
too.
48. That the contents of Paragraph 48 are wrong and denied. It is denied
that when complainant's mother went for a pilgrimage in a bus, he
said by turning his hand that the bus will turn like this and no one
will survive in the bus and you will leave alone in this world. It is
denied that he always talks rubbish about her mother and her family.
49. That the contents of Paragraph 49 are wrong and denied. It is denied
that the mother of the accused procured all the cash, jewellery, and
other articles from the complainant by saying that she kept it safely. It
is also denied that when she asked to keep the jewellery she was not
allowed to keep them with her for what so reason.
50. That the contents of Paragraph 50 are wrong and denied. It is denied
that the accused used to come very late every night after consuming
alcohol with his friends, he talked to other girls on the phone in very
hussy voice. It is denied that when the complainant used to raise her
voice against this the accused used to shout and beat her mercilessly.
It is denied that the mother of the respondent never stopped her son
for doing the same rather she used to instigate respondent to beat the
complainant further.
51. That the contents of Paragraph 51 are wrong and denied. It is denied
that the Complainant was not allowed to use the dustbin at her
matrimonial home and she was forced to go out in the lane to throw
the garbage of the home. It is denied that the complainant was also
not having the liberty to use sufficient water. It is denied that the
complainant was feeling restless when the Respondent no. 1 trying to
frighten her by saying that a witch is also staying with them in their
house at Hauz Khas and there is another ghost is living in their
neighbour. It is denied that he always insisted her to stay at her
mother's place because then only he can bring another girl in their
house and entertain himself. It is also denied that he always wants
that the complainant has to stay away from him and she never ask
any question about his whereabouts.
52. That the contents of Paragraph 52 are wrong and denied. It is denied
that whenever the complainant tried to appraise the accused of the
same, he was duly instigated by his father, mother and younger sister
and other family members. It is denied that in the dead night when
 the accused used to come in a drunken state he used to beat the
complainant mercilessly with shoes and sandals and he pressed her
mouth. Sometimes, the accused used to hit the complainant with the
steel glass as well. It is denied that on several occasions he pressed
her mouth by his hands and tried to kill her. It is denied that he also
said that you and your mother are two bodies but one soul and if will
kill you then she will automatically die". It is denied that he always
demanded luxury items from my mother he never takes care of his
liabilities. It is denied that there were several occasions when
Complainant was left with no money arid her mother provided the
grocery items for the house. It is denied that he was always stays
reluctant towards his duties. It is denied that he said to her that you
are living on my mercy and you married me for my salary, soon I will
get divorce from you because I know how to handle all this. It is
denied that he always said that I know most of the laws are very strict
in matrimonial matters and mostly favors the girls but don't worry I
know how to tackle the law.
53. That the contents of Paragraph 53 are wrong and denied. It is denied
that the younger sister of the accused used to ridicule the
complainant for not bringing sufficient dowry in her marriage and
warned her for a number of times not to raise any voice against the
accused and his family as her complaint wouldn't be entertained any-
where because they have nexus with some top brass of the police
authority. It is denied that the Respondent no. 1 purchased liquor in
market and asked her to drink the same, but when she refused, he
broke the bottle of liquor & the slapped her tightly. It is denied that
her mother-in-law also thrown out to her, said my daughter & son in
law are not happy with you so go to your home and come with gifts
for them. It is denied that the Respondent no.1 usually came late
drunken and beaten her for no reason. It is denied that one day they
forced her and send her back to her house into Auto & said " JA AUR
CAR LEKAR HI AAEYO". It is denied that she stayed for 16 days at her
parents’ house but could not arrange for car because her mother can't
afford a car, she already invested all the money in her marriage.
54. That the contents of Paragraph 54 are wrong and denied. It is denied
that the accused was once again callous to her and she was subjected
to more cruelty and violence. It is denied that the complainant still
tried to save her marriage and tried to adjust herself to all the odds of
her matrimonial home, however, the accused and his family members
 were hell went to drive her out from there. It is denied that the
accused came home late after drinking from outside. It is denied that
after coming home he again started drinking when the mother of the
accused started cursing the complainant for not bringing sufficient
dowry.
55. That the contents of Paragraph 55 are wrong and denied. It is denied
that the demand were never ending from in laws house and their
cruelties increasing day by day. It is denied that one day when
complainant was at her mother's house, Respondent no. 1 came in
the evening in drunken position & asked about his share in the
property. It is denied that when my mother objected him, he use
abusive language & beat the complainant in front of her mother. It is
denied that when her mother tried to stop him, he said that ki “Dono
Maa Beti ko jaan se maar dunga". It is denied that in next morning
when he came back into his sense, he feels sorry for his behaviour
which also melts her heart. He promised to not repeat the same
incidence.
56. That the contents of Paragraph 56 are admitted to the extent that on
7h September, 2022 we went to Manali for a short trip of three days.
When he asked me about this trip, I felt that may be this trip will give
a new start to our relationship and maybe we will get a fresh start. It
is vehemently denied that there we spent some quality time together
but after reaching back from Manali that peace was remain for only
few days. It is pertinent to mention herein that the Respondent No.1
took the Complainant to the Manali trip because he wants to see her
happy. Subsequently, on the same day when we reached to the Manali
she started demanding to drink alcohol. Respondent No.1 was in
shock to see that the Complainant is habitual drinker because the
Complainant said you know nothing about my college life. Thereafter,
the Respondent said NO to the alcohol and the Complainant started
abusing the Respondent No.1 at the Mall Road and went away to the
hotel without the Respondent No.1.
57. That the contents of Paragraph 57 are wrong and denied. It is denied
that on 16h Oct 2022 he again ran away from the house and when the
complainant called him, he did not answer the call. It is denied that
after waiting for him for more than fifteen days the complainant came
back to her mother's place and till that time she is residing there.
58. That the contents of Paragraph 58 are wrong and denied. It is denied
that after coming back from her matrimonial home the complainant
 tried to talk to the accused so many times, who is adamant to leave
her and has threatened her with dire consequences in case she
prefers to come back to her matrimonial home without his
permission. It is denied that the complainant is helpless and staying
with her old and widow mother. It is pertinent to mention herein that
the Complainant left the Matrimonial house without any reason and
abandon the Respondent No.1 for months. It is further submitted that
the Complainant hardly lives in her matrimonial house, she mostly
refers to live at her parental home or at the hostel so that she can
easily talk to his boyfriend and spend nights in the clubs with his
boyfriend.
59. That the contents of Paragraph 59 are wrong and denied. It is denied
that the stridhan of the complainant are still lying in the illegal
custody of the accused and his family members. It is denied that the
accused is intentionally and deliberately avoiding the maintenance to
the Complainant.
60. That the contents of Paragraph 60 are wrong and denied. It is denied
that presently the Complainant is residing at her parental house and
fully depend upon the mercy of her mother. It is denied that the
Complainant has been suffering from financial crises. It is denied that
the mental pain and agony by the act of the respondent No.1 and his
family is not bearable any-more. It is denied that the Respondent no.1
and his family members illegally withheld complainant who is
helpless is staying with her old and widow mother. It is denied that
the stridhan of the Complainant is still lying in their possession. It is
denied that the Complainant anyhow adjusted themselves in short
accommodation with her old and ailing mother of the Complainant,
whereas the Accused has been avoiding to provide her shelter in
matrimonial house and he wants to grab the property of the
complainant's mother in his name.
61. That the contents of Paragraph 61 are wrong and denied. It is
denied that the Respondents are harassing and torturing the
petitioner by illegal act of violence in order to throw her from the
matrimonial house. It is denied that the respondents are always
trying to fight with the complainant over petty issues and threaten to
throw her away from the matrimonial place. It is denied that the
sister -in-law with other respondents always fighting with the
petitioner and abusing her through different ways and means.
62. That the contents of Paragraph 62 are matter of record hence needs
no Reply.
63. That the contents of Paragraph 63 are wrong and denied. It is denied
that under the above said facts and circumstances, the Complainant
has been suffering from domestic violence and same is still
continuing. It is denied that, it has become practically impossible for
the petitioner to make her both ends meet in the absence of any
funds. It is also denied that it is also difficult to manage the divorce
case in Jharkhand, which is deliberately filed out of delhi by
Respondent no. 1 who is staying in delhi and working as an a.e. in
dd.a". It is denied that her bare survival is at stake because due to
paucity of funds the petitioner is almost on the verge of starvation It's
easy for the respondent no.1 to appear on every date in Jharkhand
but it's not easy for the complainant to appear on every date because
she has not sufficient funds in her hands.
64. That the contents of Paragraph 64 are wrong and denied. The
Complainant is not entitled for any relief as prayed in this para under
Reply.
65. That the contents of Paragraph 65 are wrong and denied. It is
denied. That the petition filed by the Complainant is not maintainable
and liable to be dismissed.

Prayer Clause is denied

PRAYER
It is prayed before this hon’ble court in view of the preliminary
objections and submissions, the applicant is not entitled for any relief
as prayed in the application and the application under section 12 of
DV Act, 2005 may kindly be dismissed.

DELHI.
DATED:
THROUGH;

TLI
ATTORNEYS
Chamber No.- 311, Western
 Wing Tis Hazari Court,
Delhi-110054 Mob-
9958429420, 9711933400
Email:- attorney.tli@gmail.com