______________ : PETITIONER

---

___________________ : RESPONDENTS

D.O.H.: ………………

REJOINDER / REPLICATION TO THE WS/REPLY FILED BY THE RESPONDENTS NO.2 & 3 TO THE PETITION FILED BY THE PETITIONER.

REJOINDER / REPLICATION TO THE WS/REPLY FILED BY THE RESPONDENTS NO.2 & 3 TO THE PETITION FILED BY THE PETITIONER.

  

REPLY TO THE PRELIMINARY OBJECTION:-

1.   That the contents of para 1 of the preliminary objections are wrong and incorrect, hence denied. It is denied that in the night between \_\_\_\_\_\_\_\_ and \_\_\_\_\_\_ at about \_\_\_\_ petitioner had come at the residence respondent no.2 and 3 an had left minor \_\_\_\_\_\_\_\_\_\_\_ saying that he was being called by his brother and since then minor \_\_\_\_\_\_\_\_\_\_\_ is care and custody of respondents no.2 and 3, since then petitioner had not care for the welfare of minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that petitioner even did not wish minor \_\_\_\_\_\_\_\_\_\_\_ on her birthday and even did not provided any clothes or book or toys to minor  \_\_\_\_\_\_\_\_\_\_\_ since she is in the care and custody of respondents no.2 and 3. It is also denied that petitioner had not care at all regarding the studies and health of minor \_\_\_\_\_\_\_\_\_\_\_ since she is in the care and custody of respondents no.2 and 3, minor \_\_\_\_\_\_\_\_\_\_\_ is at present studying in \_\_\_\_\_\_\_\_\_\_\_, she has been got admitted in the school by Respondents no.2 and 3 regarding the admission of minor \_\_\_\_\_\_\_\_\_\_\_, the expenses have been born by the respondents no.2 and 3. It is denied that minor \_\_\_\_\_\_\_\_\_\_\_ the has great love and affection with the respondent no.2 nad 3, the respondent no.2 and 3 have also great love and affection with minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that petitioner is living alone in \_\_\_\_\_\_ it will not be in the interest and welfare of minor \_\_\_\_\_\_\_\_\_\_\_ to give her custody to petitioner and to change her custody from the respondent no.2 and 3. It is further denied that the welfare of the minor it will be just and proper that this application / petition filed by petitioner is liable to be dismissed with cost.
   

2.  That the contents of para 2 of the preliminary objections are wrong and incorrect, hence denied. It is denied that petitioner is in the habit of telling lies, the statement in oath of petitioner was recorded in the Court of Ld. ASJ on \_\_\_\_\_, in the said statement petitioner stated that he had filed a petition for the custody of his minor daughter in the competent court. It is further denied that petitioner gave intentionally with malafide intention this false statement on oath in the Hon’ble Ld. ASJ that no petition of custody of the minor file by petitioner was pending on \_\_\_\_\_\_ It is further denied that the petition under section 25 of Guardianship Act was filed by petitioner after \_\_\_\_\_. It is correct that petitioner has also filed a divorce petition U/s 13 of HMA Act against the respondent no.1 which is pending in this Hon’ble Court. It is denied that when the divorce petition was filed, petitioner was living in \_\_\_\_. It is correct that this petitioner in the present case has filed the copy of the application addressed to SHO, and which is purported to has been received in the PS \_\_\_\_\_ on \_\_\_\_\_\_\_ and the DD no. is mentioned 49B. It is denied that it will be against the interest and welfare of minor \_\_\_\_\_\_\_\_\_\_\_ to give the custody the petitioner who has no respect for truth. Rest of the contents are denied.
   

3.  That the contents of para 3 of the preliminary objections are wrong and incorrect, hence denied. It is denied that petitioner is in collusion with the police and has got falsely implicated in a false criminal case of murder to his wife respondent no.1 and got arrested her in collusion with the police. It is further denied that the respondent no.1 is innocent and has been falsely implicated in the criminal case. It is also denied that petitioner is a very cunning person and he is very close and friendly with the young lady \_\_\_\_ with whom he wants to marry. It is further denied that petitioner generally talks with \_\_\_ on telephone, petitioner generally exchanges messages on telephone with \_\_\_\_, petitioner generally exchanges greetings on telephone also with \_\_\_. Rest of the contents are matter of record need no reply. It is denied that this petition has been filed by petitioner with mlafide intention and is meritless and is liable to be dismissed.
   

4.  That the contents of para 4 of the preliminary objections are wrong and incorrect, hence denied. It is denied that after consultation and with malafide intention, petitioner has filed this petition after \_\_\_\_\_, by giving false statement on \_\_\_\_\_ petitioner committed perjury and is liable to be prosecuted for intentionally giving false statement on oath before the Ld. ASJ. It is further denied that petitioner is not a fit person to whom the custody of minor be given from the custody of respondents no.2 and 3, for the welfare and minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that it is very necessary that she must remained in the custody of the female, respondent no.3 Mrs. \_\_\_\_\_ is the maternal grandmother of minor \_\_\_\_\_\_\_\_\_\_\_ with whom she is living since \_\_\_\_\_. It is also denied that petitioner is living in \_\_\_\_\_\_\_\_\_\_\_ it will not be in the interest of the minor to change the place of education / study of the minor, when she is already getting education in Delhi.
   

5.   That the contents of para 5 of the preliminary objections are wrong and incorrect, hence denied. It is denied that since the time minor is in the care and custody of the respondent no.2 and 3, this petitioner never made any attempt to look after the welfare and interest of the minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that after giving a false statement on oath on \_\_\_\_ in the Ld. ASJ, after consultation and with malafide intention, this petitioner has filed this petition under consideration. It is also denied that this petitioner has not given any valid and proper reason to change the care and custody of the minor from respondent no.2 and 3 to petitioner. It is denied that the upbringing of minor \_\_\_\_\_\_\_\_\_\_\_ is being properly looked after by respondent no.2 and 3, petitioner who is living alone will not be in the position to given comfortable living for minor child \_\_\_, minor \_\_\_\_ since infancy is living with respondent no.2 and 3 and she has developed emotional bonding with respondents no.2 and 3. It is further denied that petitioner has intention to marry with \_\_\_, respondent no.2 and 3 have sufficient means to look after the welfare of minor \_\_\_\_. It is also denied that the custody of minor \_\_\_ should not be changed until the person in whose custody the minor is found to be unfit to look after the welfare of the minor \_\_\_. It is denied that the petitioner who is in service in \_\_\_\_ and who does not have as a member of his joint family any female member living with him at present, the interest and welfare of minor \_\_\_\_ requires that this petition of petitioner must be dismissed.
   

6.  That the contents of para 6 of the preliminary objections are wrong and incorrect, hence denied. It is denied that after illegal arrest of respondent no.1 on \_\_\_\_\_ the petitioner instead of taking care of the breast feeding child \_\_\_\_\_\_\_\_\_\_\_ came to the house of respondent no.2 and 3 on the night between \_\_\_\_\_\_\_ at about \_\_\_ and left the child (minor \_\_\_\_) with respondent no.2 and 3 on the premise that he (petitioner) was being called by his brother and since then minor child \_\_\_\_ is under the care and custody of respondent no.2 and 3. It is further denied that the stability and consistency in the affairs and routines of the child is also of utmost importance and thus the chil should allow to continue under the care and custody of her maternal grandparents (respondent no.2 and 3) and should not be disturbed and interfered keeping in view of best interest and welfare of the minor child \_\_\_\_ . Rest of the contents are denied.
   

REJOINDER ON MERITS:-

1.   That the contents of para 1 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the petitioner on \_\_\_\_\_ at about 1 am came in the house of respondent no.2 and 3 and left minor \_\_\_\_\_ with respondent no.2 and 3, when the minor child \_\_\_\_\_\_\_\_\_\_\_ was at the stage of breast feeding about 1 pm on the pretext that he was being called by his brother. It is further denied that since \_\_\_\_\_\_\_ the minor child \_\_\_\_\_\_\_\_\_\_\_ is under the care and custody of respondents no.2 and 3 and since then proper care and welfare is being looked after by respondents no.2 and 3 of minor \_\_\_\_\_\_\_\_\_\_\_. It is also denied that now minor \_\_\_\_ has been admitted in a reputed school namely \_\_\_\_\_\_\_, by respondents o.2 and 3 and she is extremely happy in the said school. It is further denied that the girl child is now about 40 months old and her grand maternal mother and her grand maternal father are looking after her interest and welfare. It is further denied that for about 20 months since \_\_\_\_\_\_, the petitioner remained totally indifferent with the welfare and interest of minor \_\_\_\_\_. It is also denied that on \_\_\_\_\_ petitioner intentionally made a false statement in the Court of Sh. V.K. Yadav, ASJ, Delhi that he had filed the petition for the custody of minor \_\_\_\_. It is also denied that infact, on \_\_\_\_ no petition filed by the petitioner  was pending in any court regarding the custody of minor \_\_\_\_\_\_\_\_\_\_\_. It is also denied that after \_\_\_\_\_\_\_ with malafide intention and consultation, petitioner filed the present petition for custody in a well-planned manner after \_\_\_\_\_. It is further denied that on \_\_\_\_ and on \_\_\_\_, minor \_\_\_\_\_ was in the care and custody of respondent no.1 at the residence of her mother. It is further denied that when the petition under Section 25 of Guardian and Wards Act was filed by petitioner, the age of \_\_\_ was about \_\_\_\_ and \_\_\_\_. It is further denied that petitioner has falsely mentioned in this para that the child had attained the age of \_\_\_ and \_\_\_\_.
   

      It is denied that since ____ minor ____ is in the care and custody of respondents no.2 and 3. It is further denied that since then the petitioner has not cared to look after the welfare and interest of minor ___, respondent no.1 is in custody in a false case. It is also denied that petitioner and the police are in collusion and they have in planned way falsely implicated respondent no.1 in the criminal case. It is further denied that petitioner does not have any other family members in his family. Rest of the contents are wrong and denied.

      It is denied that petitioner or his brother or his bhabhi have not attempted to meet and talk with the minor ____ since minor child is in the care and custody of respondent no.2 and 3. It is further denied that petitioner has filed this petition without any legal justification and with malafide intention and ignoring the welfare and interest of the minor. It is also denied that minor ______ is in care and custody of respondent no.2 and 3 since ______ petitioner has approached this Hon’ble Court with malafide intention.

      It is further denied that the petitioner has no respect for truth and oath, the family of the petitioner consists of petitioner and his wife and his minor daughter ____ who is now in the custody of the parents of respondent. It is further denied that petitioner has filed intentionally false affidavit and has committed perjury and has made intentionally also averments on material points in his petition. However, the contents of the para of the petition are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.

1.  That the contents of para 2 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the petitioner is working and employed and residing at \_\_\_\_\_ since \_\_\_\_ and no female is living with the petitioner at \_\_\_\_\_. It is further denied that minor \_\_\_\_ is a female / girl child and is about 3 years and 4 months old at present keeping in view the interest and welfare of minor \_\_\_\_\_\_\_\_\_\_\_ it will not be just and proper to give the custody of the minor \_\_\_\_ to the petitioner. It is also denied that in the custody of the petitioner, the upbringing of the minor \_\_\_ will not be proper and in the interest of the minor. Rest of the contents wrong and denied. However, the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

2.  That the contents of para 3 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the contents of para 3 of the petition shows that the intention of the petitioner is that he wants to keep in minor \_\_\_ at \_\_\_\_ where he is employed with \_\_\_\_\_ Company and where the office of \_\_\_\_ company in \_\_\_\_\_ is situated. It is further denied that the welfare of the minor \_\_\_\_ requires that she should continue in care and custody of her maternal grandparents in Delhi. It is further denied that before the order dated \_\_\_\_\_\_ the petitioner had not taken any interest regarding the welfare of the minor and had never made request to the respondents to meet the minor child. The contents of rest of the para are denied.
   

      It is further denied that when minor child is already studying in Delhi it will be against the interest of minor child to shift her for the studies at ___________. It is further denied that it is always desirable that the studies of minor should be in continuation and at the same place. It is also denied that the studies and upbringing are continuing in proper and in congenial atmosphere at Delhi in the care and custody of respondent no.2 and 3. However the contents of the para of the petition are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.

1.  That the contents of para 4 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the respondent no.1 mother of the minor has been falsely implicated in a murder case by the petitioner in collusion with the police in a well-planned manner and she is in judicial custody. It is further denied that the mother of the petitioner was murdered by an unknown criminal on \_\_\_\_ and in that incident, respondent no.1 was also caused injuries who was also medically examined regarding the injuries received by her. It is also denied that the petitioner in the court of SH. V.K. Yadav ASJ on \_\_\_\_\_ has admitted that the relations between respondent and her mother in law were normal.
   

      It is further denied that the minor child is being very well looked after by respondent no.2 and 3 and she is studying in a reputed school and she is living happily with the respondent no.2 and 3. However the contents of the para of the petition are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.

1.   That the contents of para 5 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that respondents had never used abusive language and have never caused violence. It is further denied that the petitioner has intentionally made false and concocted charges with malafide intention. It is also denied that it is in the interest and welfare of the minor that the minor should continue in the care and custody of her maternal grandparents. It is further denied that petitioner is living alone / separately at \_\_\_\_\_. It is further denied that the elder brother of the petitioner with his wife and children are living separate in New Delhi. However, the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

2.  That the contents of para 6 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the petitioner is very close and friendly with one \_\_\_. It is further denied that the petitioner wants to marry said \_\_\_. It is also denied that the divorce has been filed by the petitioner with malafide intention and is meritless. However, the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

3.   That the contents of para 7 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that petitioner has falsely stated regarding his transfer to Delhi. It is further denied that petitioner has not filed nay order of his employer to show his transfer to Delhi, petitioner has not filed nay copy of any request made by him to his employer for his transfer to Delhi. It is also denied that petitioner had left Delhi in \_\_\_\_\_\_\_\_\_\_\_ and had gone to \_\_\_\_\_ and since then he is working there. It is also denied that petitioner has no intention to get him transferred to \_\_\_\_.
   

      It is further denied that the house of the petitioner and his brother’s house are separate and at different places. It is also denied that petitioner does not have any ownership in the house in which his brother is living, his brother does not have any ownership in the house owned by the petitioner in Delhi. It is further denied that the family of the respondents no.2 and 3 is very reputed, it is not in the interest and welfare of the minor that she should be given in the custody of the petitioner. However, the contents of the para of the petition are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.

1.  That the contents of para 8 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the minor is in custody and care of the respondent no.2 and 3, when the minor was left in the care and custody of respondent no.2 and 3 by the petitioner himself. It is further denied that the petitioner feeling deep anguishes, disappointment, frustration due to act and attitude and conduct of the respondents. It is also denied that the petitioner has made false and concocted averments with malafide intention. However, the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

2.  That the contents of para 9 of the WS/reply need are wrong, incorrect, reiterated and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

3. That the contents of para 10 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the respondent no.2 and 3 are fit persons to take care of the minor \_\_\_\_\_\_\_\_\_\_\_ their age about of respondent no.1 is 52 and respondent no.2 is 50 years old. It is further denied that respondent no.2 and 3 are already taking proper care of minor \_\_\_\_\_\_\_\_\_\_\_ since \_\_\_\_\_\_\_\_ the manner in which the averments have been made in this para of the petition it is clear that the petitioner wants to create confusion and that the petitioner has intentionally made false, confusing and vague averments.  However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

4. That the contents of para 11 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that there is no separation of the parties, the petitioner has made false and confusing averments with malafide intention. It is further denied that the petitioner himself had left minor \_\_\_\_\_\_\_\_\_\_\_ at the residence f the respondent no.2 and 3. It is also denied that petitioner wants to marry with \_\_\_\_ who is sister of his Bhabhi and with whom he is very close and friendly. It is further denied that petitioner is regularly in touch with \_\_\_, petitioner is regularly having talk with \_\_\_ on phones also. Rest of the contents are wrong and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

5. That the contents of para 12 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the petitioner is not interested in maintaining the child and to take proper care of the child. It is further denied that petitioner is continuously neglecting the minor \_\_\_\_. It is also denied that minor \_\_\_\_ is already getting proper education and is being properly brought up in good and congenial atmosphere in the care and custody of the respondent no.2 and 3. It is further denied that the petitioner is in the habit of drinking liquor, petitioner is living alone in \_\_\_\_\_ and \_\_\_\_\_\_ is more than 650 kms from Delhi. It is further denied that minor \_\_\_ is already being provided by the respondent no.2 and 3 all the necessary amenities which are required for her proper upbringing and development, she is being brought up in good and congenial atmosphere and in good culture. It is also denied that petitioner does not have any family member living with him at \_\_\_\_\_ where he is working. It is further denied that the petitioner’s elder brother with his wife and two children are living separately since long. It is also denied that the address of the petitioner and his brother and his bhabhi are different, the petitioner has driving license and adhar card and election card on the address which address is not of his brother and Bhabhi. It is also denied that will be against the welfare and interest of minor \_\_\_\_ to hand over her custody to petitioner. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

6. That the contents of para 13 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that petitioner is living in \_\_\_\_\_ since \_\_\_\_, \_\_\_\_ he never approached to respondents to see or meet minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that minor child aged about 3 year and 4 months it will be against the welfare and interest of minor child to give the custody to petitioner. It is also denied that petitioner has not mentioned even the alleged terms which the respondents wants to dictate to him as claimed by him, it will be against the welfare of minor \_\_\_\_\_\_ to hand over her custody to petitioner. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

7. That the contents of para 14 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that it will be against the interest and welfare of the minor child to give the custody to the petitioner, petitioner is a unfit person to have the custody of minor \_\_\_\_\_\_\_\_\_\_\_. Rest of the contest are wrong and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

8. That the contents of para 15 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that respondent no.1 has been falsely implicated in the case as a result of criminal conspiracy of the petitioner and police officials and she has been falsely implicated in the case due to collusion between petitioner and police officials in a well planned manner. It is further denied that petitioner is a very close and friendly with \_\_\_\_\_\_\_\_\_\_\_. It is also denied that petitioner wants to marry with \_\_\_\_\_\_\_\_\_\_\_, petitioner has strong motive to falsely implicate respondent no.1 in collusion with the police in the criminal case. It is also denied that the petitioner has no legal right in the circumstances of this case to get the custody of minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that the petitioner has not mentioned any provision of law in support of his claim of legal position. It is further denied that petitioner wants to create confusion regarding legal position. It is further denied that it is in the best interest and welfare of minor that the custody should continue with the respondent no.2 and 3 with whom minor is living continuously since \_\_\_\_\_\_\_\_\_\_\_. It is also denied that the interest and welfare of minor child will be adversely affected if the custody will be given to the petitioner. Rest of the contents are wrong and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

9. That the contents of para 16 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that minor child is a girl child of about three years and four months of age she is getting proper education in good atmosphere and proper culture. It is further denied that the conduct of the petitioner is also such that he is unfit person to have custody of minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that the minor \_\_\_\_\_\_\_\_\_\_\_ is getting education in proper atmosphere and under care and affection of the respondent no.2 and 3. It is also denied that the petitioner is unfit person to get the custody of the minor from the custody of respondent no.2 and 3. It is further denied that minor \_\_\_\_\_\_\_\_\_\_\_ is having proper comforts and she is being provided all facilities and amenities for her physical and mental needs by respondent no.2 and 3. It is further denied that minor \_\_\_\_\_\_\_\_\_\_\_ is having a good atmosphere in proper culture at the residence of respondent no.2 and 3, minor \_\_\_\_\_\_\_\_\_\_\_ is very happy and comfortable in the care and custody of respondent no.2 and 3. It is also denied that minor \_\_\_\_\_\_\_\_\_\_\_ is getting proper love and affection in the care and custody of respondent no.2 and 3 minor \_\_\_\_\_\_\_\_\_\_\_ is having love and affection of her maternal grandparents and due to love and affection she has very emotionally attached with the respondent no.2 and 3. It is further denied that the maternal grandparents of minor \_\_\_\_\_\_\_\_\_\_\_ are also very emotionally attached to her and minor \_\_\_\_\_\_\_\_\_\_\_ is having proper education and proper development in the care and custody of respondent no.2 and 3. It is further denied that he maternal grandparents of minor \_\_\_\_\_\_\_\_\_\_\_ are providing all facilities for her all physical needs and for her proper development and welfare. Rest of the contents are wrong and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

10. That the contents of para 17 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that minor \_\_\_\_\_\_\_\_\_\_\_ is living in the care and custody of the respondent no.2 and 3 since \_\_\_\_\_\_\_\_\_\_\_. It is further denied that the petition is meritless and the petitioner is not entitled for the relief claimed and the petition is liable to be dismissed with special cost to respondents. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
    

Reply of prayer clause paras of the reply are absolutely wrong and specifically denied. The respondent is not entitle for any relief claimed for.

Any allegation made in the reply and are not specifically denied herein are absolutely wrong and specifically denied and its non specifical denial shall not be taken as an admission on the part of the petitioner.

P R A Y E R :-

      It is therefore most respectfully prayed that the relief may kindly be granted in favour of the petitioner and against the respondent as prayed in the rejoinder, in the interest of justice, equity and circumstances of the case.

Pass such further order or orders as this Hon’ble Court may deem fit and proper of the facts and circumstances of the case, in the interest of justice.

It is prayed accordingly.

PETITIONER

DELHI THROUGH

DATED

____________

ADVOCATE

___________,

New Delhi-110013.

  

IN THE COURT OF MS. VIJETA SINGH; M.M. MAHILA COURT (SOUTH EAST DISTT.) SAKET COURT, NEW DELHI.

C.C./___/1/2015.

IN THE MATTER OF :-

_________ : COMPLAINANT

---

_______________ : RESPONDENTS

1.   That I am the complainant in the above said case and well conversant with the facts of the case and competent to swear the present affidavit.
   

2.  That the contents of the accompanying rejoinder to reply has been drafted by my counsel as per my instructions and the contents of the same have been duly read and understood by me and after fully understanding the contents of the same, I hereby state that the facts stated therein are all true and correct to my knowledge.
   

3.  The facts stated therein may kindly be read as part and parcel of the present Affidavit also as the contents of the same have not been reproduced herein for the sake of brevity.
   

DEPONENT

      Verified at Delhi on this ___, day of August, 2016 that the contents of the above Affidavit are true and correct to my knowledge, nothing material has been concealed there from.

DEPONENT

  

**RESPONDENT NO.1
**

IN THE COURT OF MS. POONAM A. BAMBA; PRINCIPAL JUDGE; SOUTH DISTRICT, FAMILY COURT, NEW DELHI.

G. PETITION NO. __/2015.

IN THE MATTER OF :-

________________ : PETITIONER

---

_________________ : RESPONDENTS

D.O.H.: ………………

REJOINDER / REPLICATION TO THE WS/REPLY FILED BY THE RESPONDENT NO.1 TO THE PETITION FILED BY THE PETITIONER.

REPLY TO THE PRELIMINARY OBJECTION:-

1.   That the contents of para 1 of the preliminary objections are wrong and incorrect, hence denied. It is denied that it will not be in the welfare and interest of minor \_\_\_\_\_\_\_\_\_\_\_ to give her in the custody of petitioner. It is further denied that petitioner is living alone in \_\_\_\_\_\_\_\_\_\_\_ (AP) for the last more than two years and no female is living with him. It is also denied that if she will be given in the custody of petitioner it will be cause dislocation of her studies and it will not be in the interest and welfare of minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that minor \_\_\_\_\_\_\_\_\_\_\_ it growing up in good surrounding and proper and good culture while in the care and custody of her maternal parents. It is further denied that on \_\_\_\_\_\_\_\_\_\_\_ Kumari \_\_\_\_\_\_\_\_\_\_\_ was about one year old and since then she is continuously in the care and custody of her maternal grandparents with whom she has emotional bonding. It is also denied that petitioner has intention to marry with \_\_\_\_\_\_\_\_\_\_\_ with whom he has close relation and friendship and is continuously having talks and conversation on telephone also.
   

      It is further denied that in case care and custody of minor ___________ will be changed as prayed by petitioner, it will be against the interest and welfare of the minor ___________ who is comfortably and happily living and studying in the care and custody of her maternal grandparents.

1.  That the contents of para 2 of the preliminary objections are wrong and incorrect, hence denied. It is denied that petitioner is in collusion with the police and has got falsely implicated in a false criminal case of murder to respondent no.1 and got arrested her in collusion with the police. It is further denied that the respondent no.1 is innocent and has been falsely implicated in the criminal case. It is also denied that petitioner is a very cunning person and he is very close and friendly with the young lady \_\_\_\_\_\_\_\_\_\_\_ with whom he wants to marry. It is further denied that petitioner generally talks with \_\_\_\_\_\_\_\_\_\_\_ on telephone, petitioner generally exchanges messages on telephone with \_\_\_\_\_\_\_\_\_\_\_, petitioner generally exchanges greetings on telephone also with \_\_\_\_\_\_\_\_\_\_\_. Rest of the contents are matter of record need no reply. It is denied that this petition has been filed by petitioner with mlafide intention and is meritless and is liable to be dismissed.
   

REJOINDER ON MERITS:-

1.   That the contents of para 1 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the petitioner on \_\_\_\_\_\_\_\_\_\_\_ at about 1 am came in the house of respondent no.2 and 3 and left minor \_\_\_\_\_\_\_\_\_\_\_ with respondent no.2 and 3, when the minor child \_\_\_\_\_\_\_\_\_\_\_ was at the stage of breast feeding about 1 pm on the pretext that he was being called by his brother. It is further denied that since \_\_\_\_\_\_\_\_\_\_\_ the minor child \_\_\_\_\_\_\_\_\_\_\_ is under the care and custody of respondents no.2 and 3 and since then proper care and welfare is being looked after by respondents no.2 and 3 of minor \_\_\_\_\_\_\_\_\_\_\_. It is also denied that now minor \_\_\_\_\_\_\_\_\_\_\_ has been admitted in a reputed school namely \_\_\_\_\_\_\_\_\_\_\_, by respondents o.2 and 3 and she is extremely happy in the said school. It is further denied that the girl child is now about 40 months old and her grand maternal mother and her grand maternal father are looking after her interest and welfare. It is further denied that for about 20 months since \_\_\_\_\_\_\_\_\_\_\_, the petitioner remained totally indifferent with the welfare and interest of minor \_\_\_\_\_\_\_\_\_\_\_. It is also denied that on \_\_\_\_\_\_\_ petitioner intentionally made a false statement in the Court of Sh. V.K. Yadav, ASJ, Delhi that he had filed the petition for the custody of minor \_\_\_\_\_\_\_\_\_\_\_. It is also denied that infact, on \_\_\_\_ no petition filed by the petitioner  was pending in any court regarding the custody of minor \_\_\_\_\_\_\_\_\_\_\_. It is also denied that after \_\_\_\_ with malafide intention and consultation, petitioner filed the present petition for custody in a well planned manner after \_\_\_\_. It is further denied that on \_\_\_\_ and on \_\_\_, minor \_\_\_\_\_\_\_\_\_\_\_ was in the care and custody of respondent no.1 at the residence of her mother. It is further denied that when the petition under Section 25 of Guardian and Wards Act was filed by petitioner, the age of \_\_\_\_\_\_\_\_\_\_\_ was about 2 years and 9 months. It is further denied that petitioner has falsely mentioned in this para that the child had attained the age of two years and six months, when this petition was filed in \_\_\_\_\_.
   

      It is denied that since ___________ minor ___________ is in the care and custody of respondents no.2 and 3. It is further denied that since then the petitioner has not cared to look after the welfare and interest of minor ___________, respondent no.1 is in custody in a false case. It is also denied that petitioner and the police are in collusion and they have in planned way falsely implicated respondent no.1 in the criminal case. It is further denied that petitioner does not have any other family members in his family except the respondent no.1 against whom the petitioner has filed a petition for divorce which is pending. Rest of the contents are wrong and denied.

      It is denied that petitioner or his brother or his bhabhi have not attempted to meet and talk with the minor ___________ since minor child is in the care and custody of respondent no.2 and 3. It is further denied that petitioner has filed this petition without any legal justification and with malafide intention and ignoring the welfare nadi nterest of the minor. It is also denied that minor ___________ is in care and custody of respondent no.2 and 3 since ___________ petitioner has approached this Hon’ble Court with malafide intention.

      It is further denied that the petitioner has no respect for truth and oath, the family of the petitioner consists of petitioner and his wife and his minor daughter ___________ who is now in the custody of the parents of respondent. It is further denied that petitioner has filed intentionally false affidavit and has committed perjury and has made intentionally also averments on material points in his petition. However the contents of the para of the petition are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.

1.  That the contents of para 2 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the petitioner is working and employed and residing at \_\_\_\_\_\_\_\_\_\_\_ since \_\_\_\_\_\_\_ and no female is living with the petitioner at \_\_\_\_\_\_\_\_\_\_\_. It is further denied that minor \_\_\_\_\_\_\_\_\_\_\_ is a female / girl child and is about 3 years and 4 months old at present keeping in view the interest and welfare of minor \_\_\_\_\_\_\_\_\_\_\_ it will not be just and proper to give the custody of the minor \_\_\_\_\_\_\_\_\_\_\_ to the petitioner. It is also denied that in the custody of the petitioner, the upbringing of the minor \_\_\_\_\_\_\_\_\_\_\_ will not be proper and in the interest of the minor. Rest of the contents wrong and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

2.  That the contents of para 3 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the contents of para 3 of the petition shows that the intention of the petitioner is that he wants to keep in minor \_\_\_\_\_\_\_\_\_\_\_t at \_\_\_\_\_\_\_\_\_\_\_ where he is employed with \_\_\_\_\_\_\_\_\_\_ and where the office of Genpact company in \_\_\_\_\_\_\_\_\_\_\_ is situated. It is further denied that the welfare of the minor \_\_\_\_\_\_\_\_\_\_\_ requires that she should continue in care and custody of her maternal grandparents in Delhi. It is further denied that before the order dated \_\_\_\_ the petitioner had not taken any interest regarding the welfare of the minor and had never made request to the respondents to meet the minor child. The contents of rest of the para are denied.
   

      It is further denied that when minor child is already studying in _____ it will be against the interest of minor child to shift her for the studies at ___________. It is further denied that it is always desirable that the studies of minor should be in continuation and at the same place. It is also denied that the studies and upbringing are continuing in proper and in congenial atmosphere at ____ in the care and custody of respondent no.2 and 3. However the contents of the para of the petition are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.

1.  That the contents of para 4 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the respondent no.1 mother of the minor has been falsely implicated in a murder case by the petitioner in collusion with the police in a well-planned manner and she is in judicial custody. It is further denied that the mother of the petitioner was murdered by a unknown criminal on \_\_\_\_ and in that incident, respondent no.1 was also caused injuries who was also medically examined regarding the injuries received by her. It is also denied that the petitioner in the court of SH. V.K. Yadav ASJ on \_\_\_\_ has admitted that the relations between respondent and her mother in law were normal.
   

      It is further denied that the minor child is being very well looked after by respondent no.2 and 3 and she is studying in a reputed school and she is living happily with the respondent no.2 and 3. However the contents of the para of the petition are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.

1.   That the contents of para 5 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that respondents had never used abusive language and have never caused violence. It is further denied that the petitioner has intentionally made false and concocted charges with malafide intention. It is also denied that it is in the interest and welfare of the minor that the minor should continue in the care and custody of her maternal grandparents. It is further denied that petitioner is living alone / separately at \_\_\_\_\_\_\_\_\_\_\_. It is further denied that the elder brother of the petitioner with his wife and children are living separate in \_\_\_\_. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

2.  That the contents of para 6 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the petitioner is very close and friendly with one \_\_\_\_\_\_\_\_\_\_\_. It is further denied that the petitioner wants to marry said \_\_\_\_\_\_\_\_\_\_\_. It is also denied that the divorce has been filed by the petitioner with malafide intention and is meritless. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

3.   That the contents of para 7 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that petitioner has falsely stated regarding his transfer to Delhi. It is further denied that petitioner has not filed nay order of his employer to show his transfer to \_\_\_\_\_, petitioner has not filed nay copy of any request made by him to his employer for his transfer to Delhi. It is also denied that petitioner had left \_\_\_ in \_\_\_\_\_\_\_\_ and had gone to \_\_\_\_\_\_\_\_\_\_\_ and since then he is working there. It is also denied that petitioner has no intention to get him transferred to Delhi.
   

      It is further denied that the house of the petitioner and his brother’s house are separate and at different places. It is also denied that petitioner does not have any ownership in the house in which his brother is living, his brother does not have any ownership in the house owned by the petitioner in Delhi. It is further denied that the family of the respondents no.2 and 3 is very reputed, it is not in the interest and welfare of the minor that she should be given in the custody of the petitioner. However the contents of the para of the petition are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.

1.  That the contents of para 8 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the minor is in custody and care of the respondent no.2 and 3, when the minor was left in the care and custody of respondent no.2 and 3 by the petitioner himself. It is further denied that the petitioner feeling deep anguishes, disappointment, frustration due to act and attitude and conduct of the respondents. It is also denied that the petitioner has made false and concocted averments with malafide intention. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

2.  That the contents of para 9 of the WS/reply need are wrong, incorrect, reiterated and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

3. That the contents of para 10 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the respondent no.2 and 3 are fit persons to take care of the minor \_\_\_\_\_\_\_\_\_\_\_ their age about of respondent no.1 is 52 and respondent no.2 is 50 years old. It is further denied that respondent no.2 and 3 are already taking proper care of minor \_\_\_\_\_\_\_\_\_\_\_ since \_\_\_\_\_\_\_\_\_\_\_ the manner in which the averments have been made in this para of the petition it is clear that the petitioner wants to create confusion and that the petitioner has intentionally made false, confusing and vague averments.  However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

4. That the contents of para 11 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that there is no separation of the parties, the petitioner has made false and confusing averments with malafide intention. It is further denied that the petitioner himself had left minor \_\_\_\_\_\_\_\_\_\_\_ at the residence f the respondent no.2 and 3. It is also denied that petitioner wants to marry with \_\_\_\_\_\_\_\_\_\_\_ who is sister of his Bhabhi and with whom he is very close and friendly. It is further denied that petitioner is regularly in touch with \_\_\_\_\_\_\_\_\_\_\_, petitioner is regularly having talk with \_\_\_ on phones also. Rest of the contents are wrong and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

5. That the contents of para 12 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that the petitioner is not interested in maintaining the child and to take proper care of the child. It is further denied that petitioner is continuously neglecting the minor \_\_\_\_\_\_\_\_\_\_\_. It is also denied that minor \_\_\_\_\_\_\_\_\_\_\_ is already getting proper education and is being properly brought up in good and congenial atmosphere in the care and custody of the respondent no.2 and 3. It is further denied that the petitioner is in the habit of drinking liquor, petitioner is living alone in \_\_\_\_\_\_\_\_\_\_\_ and \_\_\_\_\_\_\_\_\_\_\_ is more than 650 kms from Delhi. It is further denied that minor \_\_\_\_\_\_\_\_\_\_\_ is already being provided by the respondent no.2 and 3 all the necessary amenities which are required for her proper upbringing and development, she is being brought up in good and congenial atmosphere and in good culture. It is also denied that petitioner does not have any family member living with him at \_\_\_\_\_\_\_\_\_\_\_ where he is working. It is further denied that the petitioner’s elder brother with his wife and two children are living separately since long. It is also denied that the address of the petitioner and his brother and his bhabhi are different, the petitioner has driving license and adhar card and election card on the address which address is not of his brother and Bhabhi. It is also denied that will be against the welfare and interest of minor \_\_\_\_\_\_\_\_\_\_\_ to hand over her custody to petitioner. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

6. That the contents of para 13 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that petitioner is living in \_\_\_\_\_\_\_\_\_\_\_ since \_\_\_\_\_\_\_\_ he never approached to respondents to see or meet minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that minor child aged about 3 year and 4 months it will be against the welfare and interest of minor child to give the custody to petitioner. It is also denied that petitioner has not mentioned even the alleged terms which the respondents want to dictate to him as claimed by him, it will be against the welfare of minor \_\_\_\_\_\_\_\_\_\_\_ to hand over her custody to petitioner. However, the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

7. That the contents of para 14 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that it will be against the interest and welfare of the minor child to give the custody to the petitioner, petitioner is a unfit person to have the custody of minor \_\_\_\_\_\_\_\_\_\_\_. Rest of the contest are wrong and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

8. That the contents of para 15 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that respondent no.1 has been falsely implicated in the case as a result of criminal conspiracy of the petitioner and police officials and she has been falsely implicated in the case due to collusion between petitioner and police officials in a well-planned manner. It is further denied that petitioner is a very close and friendly with \_\_\_\_\_\_\_\_\_\_\_. It is also denied that petitioner wants to marry with \_\_\_\_\_\_\_\_\_\_\_, petitioner has strong motive to falsely implicate respondent no.1 in collusion with the police in the criminal case. It is also denied that the petitioner has no legal right in the circumstances of this case to get the custody of minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that the petitioner has not mentioned any provision of law in support of his claim of legal position. It is further denied that petitioner wants to create confusion regarding legal position. It is further denied that it is in the best interest and welfare of minor that the custody should continue with the respondent no.2 and 3 with whom minor is living continuously since \_\_\_\_\_\_\_\_\_\_\_. It is also denied that the interest and welfare of minor child will be adversely affected if the custody will be given to the petitioner. Rest of the contents are wrong and denied. However, the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

9. That the contents of para 16 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that minor child is a girl child of about three years and four months of age she is getting proper education in good atmosphere and proper culture. It is further denied that the conduct of the petitioner is also such that he is unfit person to have custody of minor \_\_\_\_\_\_\_\_\_\_\_. It is further denied that the minor \_\_\_\_\_\_\_\_\_\_\_ is getting education in proper atmosphere and under care and affection of the respondent no.2 and 3. It is also denied that the petitioner is unfit person to get the custody of the minor from the custody of respondent no.2 and 3. It is further denied that minor \_\_\_\_\_\_\_\_\_\_\_ is having proper comforts and she is being provided all facilities and amenities for her physical and mental needs by respondent no.2 and 3. It is further denied that minor \_\_\_\_\_\_\_\_\_\_\_ is having a good atmosphere in proper culture at the residence of respondent no.2 and 3, minor \_\_\_\_\_\_\_\_\_\_\_ is very happy and comfortable in the care and custody of respondent no.2 and 3. It is also denied that minor \_\_\_\_\_\_\_\_\_\_\_ is getting proper love and affection in the care and custody of respondent no.2 and 3 minor \_\_\_\_\_\_\_\_\_\_\_ is having love and affection of her maternal grandparents and due to love and affection she has very emotionally attached with the respondent no.2 and 3. It is further denied that the maternal grandparents of minor \_\_\_\_\_\_\_\_\_\_\_ are also very emotionally attached to her and minor \_\_\_\_\_\_\_\_\_\_\_ is having proper education and proper development in the care and custody of respondent no.2 and 3. It is further denied that he maternal grandparents of minor \_\_\_\_\_\_\_\_\_\_\_ are providing all facilities for her all physical needs and for her proper development and welfare. Rest of the contents are wrong and denied. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
   

10. That the contents of para 17 of the WS/reply need are wrong, incorrect, reiterated and denied. It is denied that minor \_\_\_\_\_\_\_\_\_\_\_ is living in the care and custody of the respondent no.2 and 3 since \_\_\_\_\_\_\_\_\_\_\_. It is further denied that the petition is meritless and the petitioner is not entitled for the relief claimed and the petition is liable to be dismissed with special cost to respondents. However   the   contents   of   the   para   of   the   petition   are reiterated as true and correct, may kindly be read as part and parcel of the para under reply as the same are not being reproduced herein for the sake of brevity.
    

Reply of prayer clause paras of the reply are absolutely wrong and specifically denied. The respondent is not entitle for any relief claimed for.

Any allegation made in the reply and are not specifically denied herein are absolutely wrong and specifically denied and its non specifical denial shall not be taken as an admission on the part of the petitioner.

P R A Y E R :-

      It is therefore most respectfully prayed that the relief may kindly be granted in favour of the petitioner and against the respondent as prayed in the rejoinder, in the interest of justice, equity and circumstances of the case.

Pass such further order or orders as this Hon’ble Court may deem fit and proper of the facts and circumstances of the case, in the interest of justice.

It is prayed accordingly.

PETITIONER

DELHI THROUGH

DATED

___________

ADVOCATE

____________,

New Delhi-110013.

  

IN THE COURT OF MS. VIJETA SINGH; M.M. MAHILA COURT (SOUTH EAST DISTT.) SAKET COURT, NEW DELHI.

C.C./___/__/2015.

IN THE MATTER OF :-

______________ : COMPLAINANT

---

______________________ : RESPONDENTS

1.   That I am the complainant in the above said case and well conversant with the facts of the case and competent to swear the present affidavit.
   

2.  That the contents of the accompanying rejoinder to reply has been drafted by my counsel as per my instructions and the contents of the same have been duly read and understood by me and after fully understanding the contents of the same, I hereby state that the facts stated therein are all true and correct to my knowledge.
   

3.  The facts stated therein may kindly be read as part and parcel of the present Affidavit also as the contents of the same have not been reproduced herein for the sake of brevity.
   

DEPONENT

      Verified at Delhi on this ___, day of May, __ that the contents of the above Affidavit are true and correct to my knowledge, nothing material has been concealed there from.

DEPONENT

  

IN THE COURT OF MS. VIJETA SINGH; M.M. MAHILA COURT (SOUTH EAST DISTT.) SAKET COURT, NEW DELHI.

C.C./__/__/2015.

IN THE MATTER OF :-

__________ : COMPLAINANT

---

___________ : RESPONDENTS

D.O.H.: _______

REJOINDER ON BEHALF OF THE COMPLAINANT TO THE REPLY FILED BY THE RESPONDENTS.

REJOINDER ON MERITS : -

1. That the contents of para 1 of the reply to the application is reiterated. However, the contents of the complaint may be read as integral part of this replication on the same is no repeated for the sake of brevity.
   

2. That the contents of para 2 of the reply are reiterated, hence denied. However, the contents of the complaint may be read as integral part of this replication on the same is no repeated for the sake of brevity.
   

3-8. That the contents of paras 3-8 of the reply to the application is wrong and denied. However, the contents of the plaint may be read as integral part of this replication on the same is no repeated for the sake of brevity.

Prayer clause of the reply to the application is absolutely wrong and specifically denied. The respondents are not entitled to the relief claimed for.

Any allegation made in the reply of the application and are not specifically denied herein are absolutely wrong and specifically denied and its non specifical denial shall not be taken as an admission on the part of the complainant.

P R A Y E R :-

      It is therefore most respectfully prayed that the relief may kindly be granted in favour of the complainant and against the respondents as prayed in the replication, in the interest of justice, equity and circumstances of the case.

      It is prayed accordingly,

DELHI COMPLAINANT

THROUGH

DATED

_____________

ADVOCATES

____________,

New Delhi-110013.

IN THE COURT OF MS. POONAM A. BAMBA; PRINCIPAL JUDGE; SOUTH DISTRICT, FAMILY COURT, NEW DELHI.

G. PETITION NO. __/2015.

IN THE MATTER OF :-

_______________ : PETITIONER

---

_________________ : RESPONDENTS

1.   That I am the petitioner in the above noted matter and am well conversant with the facts of the case and am also competent to swear the present affidavit.
   

2.  That the contents of the accompanying rejoinder to reply to the application have been drafted by my counsel as per my instructions and the contents of the same have been duly read over and understood by my vernacular language and after fully understanding the contents of the therein are all true and correct to my knowledge.
   

DEPONENT

      Verified at Delhi on this _____, day of July, 2016 that the contents of my above affidavit are true and correct to my knowledge, no part of it is false and nothing material has been concealed therefrom.

DEPONENT