IN THE COURT OF HON’BLE CIVIL JUDGE  _____________ (Name of Place & State) 

CASE NO.______ OF _________

Smt._____________________(Name),

Daughter of________(Father’s Name),

Wife of Shri ______(Husband’s Name),

Aged_____________________(Years),

Residing of _____________(Address),

…………………PETITIONER

 

VERSUS

 

Shri._____________________(Name),

Son of ____________(Father’s Name),

Aged_____________________(Years),

Resident of ______________(Address),

Carrying on_____________ (Business),

………………..RESPONDENT

 

WRITTEN STATEMENT ON BEHALF OF DEFENDANT

Most respectfully submitted-

Preliminary Objections:

1. Admitted the fact of marriage of petitioner and respondent on (__/__/____) in _______________ (name of the place). (If the fact of marriage and date/ place are true)
2. In para. (8), Petitioner’s allegation that the respondent relinquishes his own religion, now this statement made by the petitioner is totally wrongful from the very beginning, as the respondent has not converted or relinquished his own religion, it happened just like- one of the respondent’s friend got fractured in his leg, so he cannot walk properly, so the respondent provided him with the support, so that he can just enter into the holy worship place of his respected religion. It was not more than this.
3. In para. (9), Petitioner’s allegation that the respondent after all formal ceremonies adopted the _________ (name of religion), which has been misunderstand by the petitioner, the respondent was able to help his friend, who was from the other religion, and for his easement he was helping his friend, as the doctor suggested the respondent to be with him, if he is required with anything, or the work which he cannot perform with ease.
4. Under para. (10), (11), the petitioner puts a direct allegation on the respondent stating that he has ceased to be a Hindu by religion, so this fact is totally insignificant, as it can be asked by the other family members in the house of the respondent, that he has not been converted, it is totally a wrongful interpretation from the side of the petitioner against respondent.

 

Even though a Hindu by birth, admires other major religion or if the respondent professes a theoretical allegiance to some such other religion, he cannot be said to have converted to other religion.

 

The Defendant therefore prays and counters claim-

That it may be declared that the said deed of settlement be declared null and void as against her and that the same day by order of this honorable court be cancelled. This suit be dismissed with cost.

Date: __/__/____

(Signature)

Defendant

 

 

 

VERIFICATION

I, defendant, to hereby declares that the facts stated above true and correct to the best of my knowledge, information and belief.

___________________                                                                                         _________________

(Signature)                                                                                                           (Signature)

Advocate of defendant                                                                                  Defendant