IN THE COURT OF PRINCIPAL JUDGE,FAMILY COURT-II
KAMRUP AT GUWAHATI
Crl) Case No. 369/2021
Piku Dey
. Petitioner
-Versus-
Anup Dey
+ Respondent
The humble Written Statement on
behalf of the above named
Respondent.
MOST RESPECTFULLY SHEWETH
1. That, the present petition is not maintainable as per
provision of law.
2. That, the present petition is not maintainable in the
present facts and circumstances of the case and as such
liable to be dismissed in limine.
3. That the Respondent has received a copy of the
petition filed under Section 125 of the Code of Criminal
Procedure,1973. The Respondent had the privilege of going
through the contents thereof. That, the Respondent denies
all the statements as stated therein except those what has
been specifically admitted herein.407
hat, with regard to the statements made in
Paragr:
DemumosWendi2i the nespeacennte st not want to
give any comment,
5. That, with regard to the statement made in Paragraph
no. 3, the Respondent begs to state that the statements
Made therein are absolutely false and misleading. The
Respondent does Not have shop in his name and he runs a
shop which belongs to his father.
4. That, with regard to the statements made in
Paragraph no. 4 and 5, the Respondent begs to state that
The Respondent's mother never opposed the marriage with
the petitioner but instead was very supportive and it is true
that the Petitioner was working but it is absolutely false that
the Respondent or his family had an objection to it nor asked
her to leave the job after marriage.
5. That, with regard to the statements made in
Paragraph no. 6 and 7, the Respondent begs to state that
the statements petitioner made there in is absolutely false,
fabricated, concocted and hence denied. The Petitioner was
never asked to do any household works as there was already
a servant to do household chores and the Respondent's
mother nerver asked the Petitioner for any jeweleries orValua|
bles, The respong
le
ls out
her daily need
without a que:
al
|Ways asked the petitioner a0
'S and al.
SO pr
stion, Provided everything she demanded
& 7
"That, wit
’ With regard to the statement made in paragraph
no. 8 a
nd 9
statements ma the Respondent begs to state that te
mistead Made therein are totally false, fabricated,
'Ng and hence denied. The Respondent never asked
the Paetiti
Petitioner to stop contacts with her family members OF
jo any
an
one else nor the petitioner was asked t0 d
nstead
household or other works during her pregnancy i
asked her to rest well.
7. That, with regards to the statement made in
paragraph no. 10,11,12 and 13, the Respondent begs to
state that the allegations labelled therein are totally false
and misleading and hence denied. The Respondent never
asked the Petitioner to not consume protein nor the question
of eating non veg as protein ever arose. The Respondent
always wanted to have a girl child and when the girl child
namely “Patishree” was born the respondent celebrated it
as she was his only and first child and tried his best to fulfill
all the needs of the petitioner and the new baby with utmost
love and care and at times stayed with them without going
to shop and thinking of the business.some verb
anything happened on Jun
evel
alee T asked the Respondents to go
a allowing the penn Celebrate rakhi so the question of
ae Petitioner to go to her maternal home does
nor ;
pains any argument or anything happened in the
september,2015. The respondents
about the pers i ane are
onal savings of the petitioner nor enquired
about it.
to her mate
9. That, with regard to the statements made in
paragraph no. 16 and 17, the Respondent does not want to
give any comment.
12. That, with regard to the statements made in
the Respondent begs to state
paragraph no. 18,19 and 20,
in the matter of
that the petitioner was interfering
0. 4 and when the respondent no. 4
tioner started to shout at him saying
s to listen to him and had
Respondent ni
not to interfere, the Peti
she is elder than him and he need
al arguments and nothing else
e,2020, the allegations made are
completely false and baseless.
asked her
happened nor13 :
+ That:
7 IN re 9)
°: 21, the Resp i Statements mag
maa 6 as to ade in Paragraph
y tl ttioner : state that the the allegations
totally fy) SNE Was physically assaulted is
and Misleading instead the
14. That, wi
t, with regard to the statement made in paragraph
No. 22
and 23 the Respondent does not want to give any
comment.
15: That, with regard to the statements made in
Paragraph no. 24, the Respondent begs to state that he is
running a small accessories shop which belongs to his father
and has no other source of income and is running the family
with whatever small amount he is earning and the
Respondent is already paying an amount of Rs 5000/- as
monthly maintenance to the Petitioner vide Misc Case no.
123/2021 which is pending in the court of JMFC-4, Kamrup
(M), Guwahati.
16. That, with regard to the statements made in Paragraph
no. 25 to 41, the Respondent does not want to give any
comment.ly
ie That, i
” tone aaene allegations levelled by the
spondent are absol
fabricated, motivated and stoutly denied by the mos
The petitioner is not entitled to claim any maintenance ee
the purview of section 125 of Cr.PC. That the petition is
devoid of any merit and as such liable to be dismissed in
limine.
Under the above premises it is
therefore prayed that Your Honour
would be pleased to dismiss this
instant case and / or pass such other
order/ orders as Your Honour may
deem fit and proper.
And for the act of kindness the humble opposite party
as in duty bound shall ever pray.VERIFICATION
aged about 42 years,,
R/o Moriani Kenedy Park, Ware
P.S- Moriani, District-
I, Anup Dey, S/o Sri Karnal
Ranjan Dey, dno. 1,P.0%
Jorhat, Assam, do hereby verify that
the statements made in
Paragraphs
are the
matter of records and those made in paragraphs
Ve if
+. are true
to the best of my knowledge and information derived and
the rest are my humble submission before this Hon’ble
Court,
And I sign this verification on this 17" day of
Februrary’ 2024 at Guwahati.
Jue 2 +
SIGNATURE\
» Any
ip
SV. Ro a OW ag
istrict.
AFFIDAVIT
aa IDAVIT
Sani Ke,
abou
ut 42 years., S/o Sri Kamal Ranjan
Jor
Nedy Pp;
ee ata 'Y Park, Ward no, 1, P.O & P.S- Moriani:
Mow ssam do he it
Sie reby solemnly affirm and declare
1
~ That
1 Tam
tt
&™ fully conve ‘he respondent in the instant Petition and I
rsant i i
Case and as rel t with the facts and circumstances of the
1am competent to swear this affidavit.
2.
‘That,
, the statements made in this affidavit and those
Made in
Paragraphs
are the matter of records and those made in
paragraphs
are true to the best
of my knowledge and information
derived and the res'
are my humble submission before this
Hon'ble Court.
OATH
1 swear that th
‘is my declaration is true, that it conceals
nothing and that no part of it Is false, $0 help me God.
And 1 sign this affidavit on this
of.....-+ : vase 2024 at Guwahati.
day