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SHIVANI CHAUHAN,
METROPOLITAN MAGISTRATE SAKET COURTS, NEW
DELHI
IN THE MATTER OF:
SMT. SAVITA DUBEY
...COMPLAINANT
VERSUS
...RESPONDENT
this
Hon'ble
Court
with
clean
hands.The
entire
application
has
been
based
on
false
allegations
and
general
allegations
without
any
concrete evidence.
3. That the Respondent was married to Satish Sharma
(since deceased) brother of the complainant in the year
1989 and lived a peaceful married life with her husband
and two daughters namely Mannat and Riddhi till the
death of her husband in the year 2012. That it is
pertinent to mention that at the time of the marriage of
the respondent the financial condition of the in laws of
the respondent was not stable, father was retired ,
daughters were not settled either. kiran sharma was in
pvt
job
in
korean
embassy
and
many
times
was
already
suffering
from
chronic
calcific
the
respondent
under
the
guise
of
her
booking
amount
thereafter
husband
of
the
and
the
complainant
has
been
constantly
karvachauth.
otherwise
constant
harrassment
was
the
contents
of
paragraph
number
are
the
of
the
respondent
the
family
of
the
so that the
her
sister
and
mother
increased
after
the
except
the
room
of
the
respondent;
the
which
was
being
created
by
the
complainant and the main reason for the same was that
his two daughters aged 30 and 41 were on his head,
finances were
meaningless
mannat
the
child
of
the
respondent
meaningless
of
the
respondent
realised
their
fault
and
the
privacy
of
their
family
but
there
contentions
being
totally
baseless
and
here
that on 08.02.2009
contentions
being
totally
baseless
and
from
the
family
members
of
the
attatched with the house and this was the only asset
made by him for his wife and daughters in the entire
career, he was not able to take this pressure from his
own sister for whom he had done everything as they
were not settled, he fell sick never to recover. in the
hospital, he always asked for his wife's presence despite
her asking him if she can take a break for a day to
which his answer was tu bhi mat aa par in logon ko naa
bhejna. That on 14th January, 2012 husband of the
respondent wanted to go home to take bath as it was
sakranti and respondent took him to his house in her
sisters car as it was very cold at that time but the
behaviour of the complainant her sister and her mother
did not change even at this juncture and the respondent
took her husband back to the hospital as he said to the
respondent sudha mujhe wapis le jaa I am not
able to breathe with these people under this
roof. That the husband of the Respondent also wanted
to take out his Power of Attorney which was given by
the father in law of the respondent in the name of the
Respondents husband but due to his illness he was
unable to take the aforesaid power of attorney in his
possession.
12. That with reference to the contents of the paragraph
number 12 of the application, the respondent deny
entire
contentions
being
totally
baseless
and
of
the
property
in
their
favour
and
contentions
being
totally
baseless
and
and
general
allegations
without
any
concrete evidence.
contentions
being
totally
baseless
and
and
general
allegations
without
any
contentions
being
totally
baseless
and
and
general
allegations
without
any
contentions
being
totally
baseless
and
and
general
allegations
without
any
contentions
being
totally
baseless
and
and
general
allegations
without
any
contentions
being
totally
baseless
and
and
general
allegations
without
any
contentions
being
totally
baseless
and
and
concrete evidence.
general
allegations
without
any
contentions
being
totally
baseless
and
number
and
20
has
general
been
based
allegations
on
without
false
any
in
the
living
room
and
neither
the
contentions
being
totally
baseless
and
entire
contentions
being
totally
baseless
and
and
general
allegations
without
any
concrete evidence.
24. That with reference to the contents of the paragraph
number 23 of the application it is submitted that the
content of para no. 23 is a matter of record and
therefore needs no reply.
RESPONDENT
Through
ANAND DEY
Advocate for the Respondent
Place: Delhi
Dated: __.11.2014
VERIFICATION
Verified at Delhi on this____day of November, 2014 that the
contents of the above reply to the application under section 12
of the Domestic Violence Act, 2005 from paras 1 to 24 are true
and correct to the best of my knowledge and belief and nothing
material has been concealed or suppressed and no part of it is
false.
RESPONDENT
Place: New delhi
Dated:__.11.2014