My wife filed petition for divorce and I filed a WS after a delay which got granted. Opposite party filed rejoinder. Now, I see inaccuracies in my WS where specific denials are not therere and submissions have not been adequately made. Also, there are typological errors such as errors in dates. So, my lawyer suggested me to go with amendment in ws. Now i see, all there are too many in numbers around 50. My lawyer says so many amendments may be rejected and count should be brought down drastically.
Some queries for the learned members..
1) Some paras there is no mention of date, time or place of the alleged incidents of cruelty is mentioned - I had denied the para in toto and stated that they are based on false and fabricated facts. Do I need to deny it specifically in the amended ws. Or it is not required as specific date or place is not mentioned.
2) There are sub-sections in a para which I have mentioned that this part is denied since it is fabricated but not specifically denied exactly what has been alleged.
3) Specific allegations is put in para A.. say respondent scolded me and said so and so on such date. I have not made the denial there but denied in a more general way in para B that I had never scolded petitioner. Can para B be referred in argument of para A.
3) If allegation is spercific, can a general denial work.. say allegation is respondent beat petitioner and scolded so and so and stared at her.. Will it be sufficient to say in the reply to the para.., respondent never beat petitioner and never harassed her.
I am asking this because my lawyer is saying that we should have minimal changes in our amendment. I had around 50 changes including typological errors, new and amended submissions, new and amended denials.
Thanks, in advance.
