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. (9), (10), Petitioner’s allegation that the respondent the petitioner was treated as concubine, and also that the respondent was involved with brother’s wife, so these statements are totally wrong, these statements are falsely presented by the petitioner, as she is not happy with this relation and wanted a divorce, thus when she was not left with any ground, the petitioner started to defame the respondent.
3. In para. (11), (12), Petitioner’s allegation that the respondent humiliated, behaved badly and treated the petitioner, but these things are very wrongful stated by the petitioner, as the petitioner was dissatisfied with the earnings of the respondent, which was clearly known to petitioner before the marriage.
4. Under para. (13), (14), the petitioner puts a direct allegation on the respondent stating that the respondent told the petitioner to leave in a one closed room and also that the respondent only started leaving separately for his study, this statement is very negative and does not happen in any manner as, the petitioner only developed dislike for the respondent as a result of her intimacy with her brother-in-law.
5. Under para. (15), (16), the petitioner puts a direct allegation enormous inaccurate and thereby providing inappropriate statements, as there was no intentional permanent forsaking and abandonment of the respondent from the petitioner.

 

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