Her 125 crpc petition points
1. That the petitioner was earlier married with one Ramandeep Singh who died and she got remarried with the respondent, whose wife had also expired and this is the second marriage of both parties. That now the petitioner No.1 is the wife of the respondent and the marriage was performed on 22.11.2015 as per Hindu rights and traditions and at the time of marriage, parental relations of petitioner had given a substantial dowry more than their status in the shape of stri dhan to the Respondent.
Answer: That the contents of pargraph no. 1 concocted stories against the respondent without any concrete evidence. She never show the death certificate and marriage certificate of her died husband (Ramandeep Singh). As per Hindu marriage Act no Saptapadi is done and marriage is no register in D.C. office. We never demand any type of dowry or article. That the petitioner has suppressed the material facts and has not approached this Hon’ble Court with clean hands, hence the present application is liable to be dismissed
2. That it is very unfortunate for petitioner no.1 that since the inception of marriage, respondent and his parental relations started to harass her and demanded Rs. 2 lac in cash and other dowry and also started giving beating to her.
Answer: That the contents of the paragrpagh no. 2 are wrong and hence denied.
3. That the petitioner kept on tolerating all his high handed ness of the respondent and his family members with a hope that one day or the other the behaviour of the Respondent and his family members will improve towards the petitioner but that day as expected by the petitioner never saw the Light of the day.
Answer: That the contents of the paragrpagh no. 3 are wrong and hence denied.
4. That though the petitioner and the respondent are living in the same house but the respondent is not paying a single penny to the petitioner for last one year. Even the petitioner have been deprived from the basic amenties of life. The petitioner is totally dependent on the mercy of her parents. Answer: She is living in respondent parents home in first floor with all facilities (accomodation,electricity,water,food,gas cylinder etc...). She also filed permanent injunction and her section 39 application is allowed in due course of law.
5. That the petitioner is earning a very meagree salary of Rs. 10,000 by which she cannot even fulfil her daily needs. At the same time, the petitioner is having no moveable or immovable property on her name. On the other hand hand, the respondent is employed in some IT company and is getting a salary around Rs. 80,000 per month. Moreover the respondent is having rental income of Rs. 5000 per month from the second floor of the house given on rent to different tenants. As such the respondent is earning Rs. 85,000 per month without any kind of liability.
Answer: She earns 60,000 and did not spend any single coin in home expenses and daily needs. Response is jobless. Petitioner is the owner of disputed land in Ranjit Bagh Gurdaspur, if she claims she get 2 acre land of her own hissa.
6. That on account of afore said reasons the petitioner is facing the stage of starvation.
Answer: That the contents of the paragrpagh no. 3 are wrong and hence denied.
7. That since the respondent has neglected and refused to maintain the petitioner, therefore the petitioner is left with no other alternative except to file the present petition and against the respondent in this hon’ble court.
Answer: The motive behind the filing of the petition is that the petitioner and her relatives want to put undue pressure upon the respondent to extort money from him with malafide intention.
8. That considering the earning capacity of the respondent and considering the cost of living these days, the respondent is liable to be directed to pay at least a sum of Rs. 20,000 per month to the petitioner from the date of filing this petition, and the respondent can easily afford to pay the aforesaid amount of the petitioner.
Answer: She is already getting (food, clothing and shelter) based on 125 crpc barret. That no cause of action ever accrued in the favor of the petitioner and against the Respondent, hence the present petition/application is not maintainable and is liable to be dismissed with cost.
9. That furthermore the respondent is also liable to be directed to pay litigation expenses amounting to Rs. 11,000 to the petitioner which she has incurred and are further likely to be incurred in connection with the present petition.
Answer: That the contents of paragraph number 1 of the application is a matter of record and needs no reply.
10. That the prescribed court fee as per law has been affixed on the petition.
Answer: The petition has been drafted by taking false and frivolous pleas and as such the petition is liable to be dismissed.
11. That in case the present prayer of the petitioner is not allowed by this hon’ble court, then the petitioner will suffer serious prejudice and huge irreparable loss and injury in the time to come. Answer: The cruel treatment meted out to the respondent adverse impact by on the petitioner respondent’s brought health and the respondent lost his working strength and positive thinking petitioner is due to trying depression. The undue advantages of her own wrongs and as such the petition is liable to be dismissed
12. That there are sufficient ground for allowing the present prayer of the petitioner.
Answer:
13. That the detailed affidavit of the petitioner in support of the contents of the present petition also filed here with for the kind perusal of this hon’ble court.
Answer:
Under the circumstances detailed above it its most respectfully prayed that by way of acceptance of present prayer of the petitioner, the respondent may kindly be directed to pay a sum of Rs. 20,000 per month to the petitioner from the date of filing of the petition as her monthly maintainance expenses. The respondent may also be directed to pay a sum of Rs. 11,000 as litigation expenses to petitioner immediately. Complete costs of petition be also awarded to the petitioner. Any other relief to which the petitioner may be found entitled the law, equity and justice be also awarded to her
please help me to find the good one reply or whatsapp me at mobile no. Nine nine eight eight seven 077 three three
