Ground beyond written statement of defendent

Prakash (Querist) 30 May 2012 This query is : Resolved
Ld Counsels,

Wife filed divorce on self-contradictory allegations, husband in his counter has not specifically stated that the allegations are self contradictory and mutually destructive. Though all the allegations were specifically denied.

Further husband has not stated specifically that wife approached the court with unclean hands in the written statement.

Will this preclude the husband from taking these grounds in his cross examination, evidence and arguments. In other words should all points/question of law be raised in the written statement before evidence and arguments.

Thanks.

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