IN THE COURT OF MS.

MANU GOEL KHARAB: MM: MAHILA COURT:

DWARKA, NEW DELHI

CC NO. 123/2/2015

IN THE MATTER OF:

Ms. Deepika .. Complainant

Versus

Atul Rana & Ors. .. Respondents

INDEX

S.NO. PARTICULARS PAGES

1. Written statement for and on behalf of the

Respondent No.1 to 4 along with supported
Affidavit

2. List Of Documents along with Documents

NEW DELHI RESPONDENTS

DATED:-

THROUGH

ONKAR ROY & CO.

(ADVOCATES)

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IN THE COURT OF MS. MANU GOEL KHARAB: MM: MAHILA COURT:
DWARKA, NEW DELHI

CC NO. 123/2/2015

IN THE MATTER OF:

Ms. Deepika .. Complainant

Versus

Atul Rana & Ors. .. Respondents

WRITTEN STATEMENT/REPLY ON BEHALF OF THE RESPONDENTS.

MOST RESPECTFULLY SHOWETH:

The answering Respondents most respectfully submits as under:

At the outset the answering Respondents denies all the allegations as have been

made in the complaint save and except which are being specifically admitted

herein below. Without prejudice to what has been stated herein above the

answering Respondents has been advised to raise the following objection by way

of preliminary objections.

PRELIMINARY OBJECTIONS:

1. That the present complaint as has been filed by the Complainant is a

gross abuse of the process of law and has been filed by misleading,

misrepresenting and twisting or suppressing the material facts from this

Hon’ble Court and is liable to be dismissed.

2. That the present complaint as has been filed by the Complainant is

otherwise also not maintainable as the answering Respondent never

treated the Complainant with any kind of cruelty whatsoever and still has

love for her and is trying to persuade her to join the company of the

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 answering Respondents, in that view of the matter the present complaint

is liable to be dismissed out rightly.

3. That the present complaint is liable to be dismissed as the Respondents

has never been guilty of any of the grounds taken by the Complainant

rather it is the Complainant’s family who are guilty of cruelty towards the

answering Respondents and his family members and are forcing the

Complainant to break her happy married life and the present complaint

has been filed only with the view to harass and humiliate the Respondent

by dragging the Respondents into false litigations.

4. That the instant complaint under the provisions of Protection of Women

from Domestic violence Act as has been filed by the Complainant on the

ground of cruelty is not maintainable, as it was always the Complainant’s

family who were against the marriage between the parties, being a love

marriage had never treated the Respondent as their son-in-law, and

therefore the alleged ground taken by the Complainant is false, frivolous

and is liable to be dismissed since the present complaint has been filed on

the instance and behest of her parents. The present complaint is a gross

abuse of the process of law as the respondents are respectful person and

holding good reputation in Kanpur and just to harass and humiliate the

respondent in order to extort money from them, the baseless allegations

are levelled against the respondents in the present complaint..

5. That the complaint has been filed with ulterior motives and the allegations

stated in the complaint are totally false to the knowledge of the

Respondent and the Complainant has filed the false affidavit in support of

her contentions and has filed the present complaint only to harass the

Respondents at the behest and instance of her parents, who were always

against the answering Respondents.

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6. That it is submitted that the attitude of the Respondents towards the

Complainant was always full of love, however her parent’s attitude was

very snooty, arrogant and dominating and her parents had been

unnecessarily interfering in the domestic life of the parties instead of giving

them good sense to lead a happy married life rather have been trying to

break the happy marriage between the parties.

7. That the Complainant has not come to this Hon’ble Court with clean

hands and the instant complaint has been filed on concocted and

fabricated facts and allegations and also by misrepresenting and

misleading this Hon’ble Court and this complaint is liable to be dismissed

on this ground only.

8. That the Complainant has filed false affidavit along with this false and

frivolous complaint with an intent to mislead this Hon’ble Court for which

the Respondents reserves his right to take appropriate action under

Section 340 Cr.P.C.. Hence, the present complaint is liable to be

dismissed on this ground only.

9. That the Complainant is guilty of suppression vari and suggestion falsi,

more particularly the facts stated herein below.

10. That the present petition is liable to be dismissed as the same is devoid of

merits per se. It is necessary and worthwhile to mention herewith that the

marriage of the petitioner with the respondent no.1 was a love cum

arrange marriage as per the sweet will of their respective parents without

having any demand for the dowry from the respondents side at any point

of time. It is further submitted that the respondents always cared the

petitioner with love and affection by fulfilling all the desires whenever

accrued and facilitating in all possible manner all the times to the

complainant.

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 11. That the family members of the respondent no.1 always discharges their

responsibilities with utmost sincerity towards the petitioner but

unfortunately they becomes the victim of the greediness of the petitioner

as well as her family members. It is further humiliating and embarrassing

that the petitioner at the instance of her family members has dragged the

respondent no.2,3 and 4 in the false and frivolous petition having no iota

of truth. It is necessary and worthwhile to mention herewith that the

respondent no. 2 is working as an Inspector in Anti-Corruption Branch in

CID and was awarded Governor award, President award and number of

bravery award for the services rendered during the services and more

importantly the respondent no.2 is suffering from heart problem and

almost 8 stunts were projected inside his body. It is further submitted that

the during the time when the alleged incident took place he was posted

out of station and was remotely residing and serving the nation and his

name has been falsely implicated in the array of parties for the sake of

tarnishing and hampering the image of the respondent.

12. That the respondents are law abiding citizen of India and has been falsely

dragged to tarnish the image of the respondents and made them to dance

at the tune of the complainant. It is further submitted that the respondents

always treated the complainant with love, affection and always provided

the best as per their ability and endeavors were made so that she will not

feel isolated in her matrimonial house after the marriage. However, it is the

complainant who had made the life of the respondent’s hell by throwing

baseless allegations one after the other to harass and humiliate the

respondents and not only to tarnish the image of the respondents in

Kanpur but to extort money from them under the excessive influence of

her parents in her matrimonial house just repeating the episode of her

sister and subsequently settled all the issues and drawing the hand some

amount from in laws of her sister.

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13. That since the inception of the marriage the behavior of the complainant

was very rude, cruel, and aggressive towards the respondent no. 1 and

his family members as she wanted to live in one separate accommodation

with her husband for which her wishes and desire were declined by the

respondent no.1.

14. The Respondent and his family members on the other hand were very

loving and caring towards the Complainant and always did their best to

keep the Complainant with love and respect.

15. The father of the Complainant likes to control the life of the others and

used his power to break many homes including the home of the elder

sister of the Complainant who divorced his first husband and although got

remarried is still facing marital problems. The elder sister of the

Complainant had lodged complaint with CAW Cell, Nanakpura alleging

serious allegations against her in laws. However, the father of the

complainant compounded the matter by extorting money in the form of

settlement amount from the husband of his elder daughter. It is pertinent

to mention that now it is becoming the modus operendi of the complainant

family at the instance and behest of her father to level false and frivolous

allegations of serious nature and subsequently compounded the same by

getting the hard earned money from in laws and to put pressure and to

gain sympathy and undue favor of the laws which were made exclusively

for the protection of women and to the destitute and vulnerable section of

the society however, there are certain unsocial element in our society who

not only misusing the provisions of such laws but also using women

favorable/protected laws as a dangerous weapon to fulfil their evil designs.

14. The present complaint has been filed by the Complainant only to settle her

personal grudges against the Respondents and to extort money. The

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 allegations are false and concocted and having no leg to stand. Moreover,

the present complaint has been filed with the sole intention to put pressure

upon the Respondent to agree upon the divorce.

15. That the present petition is without having any cause of action and having

no merits in the same and is thus liable to be dismissed out rightly with

heavy cost. It is submitted herewith that even the cause of action para is

not mentioned anywhere in the petition by the petitioner which will give

rise to the present petition, hence the petition is liable to be dismissed on

this sole ground.

16. The Petitioner has intentionally made wrong statements with the sole

motive to seek undue order against Respondents on false and baseless

allegations and accusations. She has committed perjury on the Court

record for which she is liable to be prosecuted and punished in

accordance with law.

17. SSP finding on two occasion

18. Telephonic conversation of Complainant and Respondent No.1 wherein

language used by the complainant was so abusive and filthy which does

not suit to a person belong from a respectful family and the respondent

no.1 in his entire conversation asking for the reason of her changed

behavior .

19. Audio recording of complainant warning the respondent no.1 and his

family members to implicate all of them in false and frivolous cases if the

respondent will not bow down to her feet or to fulfill her unwarranted

demands.

20. Number of complaints against the complainant transpiring apprehension

against implicated in false and frivolous case.

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21.

Without prejudice to the foregoing preliminary objections as are being

raised herein above, the answering Respondents is giving parawise reply to the

complaint on merits.

REPLY:

1. Complaint filed by the Complainant under the provision of the

Protection of Women from Domestic Violence Act is false. The

Complainant is not an aggrieved person and the present complaint is

another act of cruelty.

2. Denied. The allegations made by the Complainant are false,

frivolous, concocted and fabricated. The complaint deserves to be

dismissed. The Complainant is not entitled for any of the relief sought in

the complaint.

REPLY TO THE BRIEF FACTS

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1. That the contents of para 1 of the complaint under reply are

wrong, false, and are denied. It is emphatically denied that the

marriage between the Complainant and the Respondent was

solemnized according to Hindu rites, customs and ceremonies on

30.11.2007 as alleged in this part of the para under reply. It is

submitted that the Complainant and the Respondent no.1 had

love with each other which was subsequently converted into

arranged marriage with the wishes and desire of their respective

family members. It is specifically denied that the parents of the

complainant spent about Rs.15, 00,000/- including a Innova Car

worth Rs.10, 00,000/- which is in the name of the complainant

and is in the possession of the respondent no.1.

It is submitted herewith that the marriage between the

complainant and respondent no.1 is a dowry less marriage and

the aforesaid car was exclusively purchased by the respondent

no.1 from his own hard earned money by paying a demand draft

to the tune of Rs.4, 00,000/-and rest of the amount through cash

although the same was purchased in the name of the

complainant as she was going to become wife of the respondent

no.1

2. That the contents of para 2 of the complaint under reply needs

no reply as the same is not denied.

3. That the contents of para 3 of the complaint under reply are

wrong, false and frivolous and are denied vehemently in toto.

Submissions made in para 10 may be read as part and parcel and

the same has not been repeated herein for the sake of brevity.

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 4. That the contents of para 4 of the complaint under reply are

wrong, false and frivolous and are denied.

It is submitted herewith that the complainant after few months

of the marriage shows her true color and involved in unnecessary

and unwanted frequent quarrel with the respondent no.1 and his

family members and threatened to lodge false complaint and

implicate the entire family members of respondent no.1.

5 That the contents of para 5 of the complaint under reply are wrong

false frivolous, concocted and are denied in toto. It is vehemently

denied that in February, 2010 the respondents gave so much

physical beatings that the right arm of the complainant got fractured

and did not get her properly treated and the parents of the

complainant brought her in Delhi and got medically treated.

It is submitted herewith that the story planted, concocted by the

complainant is sheer imagination of the complainant as the

allegations made in para under reply cannot be believable as the

same are baseless and never occurred at her matrimonial home.

Had there been any fracture than that was due to the negligence of

complainant at her parental home and specifically not at her

matrimonial home.

6 That the contents of para 6 of the complaint under reply are wrong

false frivolous, concocted and are denied vehemently in toto.

It is submitted herewith that it was the complainant with her

parents who visited the house of the respondents at odd hour and

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 started shouting with abusive and filthy languages against the

respondents and however, the respondents tried their level best to

pacify the matter but to the utter surprise of the respondents, the

complainant and her parents were so heated up that they started

misbehaving with respondent no.1 and caught hold the collar and

extended threats to kill him and his family members. However, when

the respondents left with no other option and in order to save himself

from the clutches of the complainant family members he dialed 100

no. and the P.C.R. van arrived and thereafter the complainant and

her parents left the house of the respondents. It is pertinent and

worthwhile to mention herein that the respondents are still getting

constant threat from the complainant through different modes to

implicate him and his family members in false and frivolous matter

for which the respondent is making timely complaints before various

appropriate authorities.

7. That the contents of para 7 of the complaint under reply are wrong

false, frivolous, concocted and are denied in toto.

It is pertinent to mention herewith that the respondent no.1

always requested the complainant to come back to her matrimonial

house and join the company of respondent no.1 which was

ruthlessly declined as the complainant used to reside most of the

time at her parental house in Delhi and that too without the

knowledge of her husband i.e. Respondent no.1, with the sole

motive to cause and create undue pressure upon the respondent

no.1 so that he will settle down permanently in Delhi as “GHAR

JAMAI” with complainant and his in-laws. It is further submitted that

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 the respondent no.1 always cared, and respected her wife but due to

the excessive interference of the parents of the complainant the

complainant started behaving unorthodoxly with the respondent no.1

and his family members.

8. That the contents of para 8 of the complaint under reply are wrong

false frivolous, concocted and are denied in toto. It is specifically

denied that the respondent no.1 again in the month of July, 2010

gave physical beatings to the complainant inspite of the fact that the

complainant was in the family way. It is further specifically denied

that the respondent no. 1 and his mother asked the complainant why

she had gone for medical checkup without their consent and the

mother in law/respondent no.3 kicked on her stomach inspite of the

fact that she was in the family way and the respondent no.1 caught

hold of the complainant and complainant fell down on the floor.

It is submitted herewith that the incident alleged by the

complainant are allegations only which were levelled just in order to

create cause of action to file the present complaint and to falsely

implicate, harass and humiliate the respondent no.1 and his family

members. It is further submitted that no such incident purported by

the complainant ever took place at any point of time rather the

respondent no.1 and his family members always cared a lot and

from the day of getting the knowledge that the complainant is in the

family way their care and concern towards the complainant

increases manifold. It is further submitted that during those days of

family way respondent no.1 and his family members not even letting

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 her to do any household work rather all were looking after the

complainant round the clock.

Remaining contents of para under reply are false, wrong, self

contradictory and hence denied. It is submitted herewith that as per

the allegations the physical beatings was given in the month of July,

2010 by the respondent no.3 and the complainant was got medically

examined on 20.8.2010 at Gandhi Nursing Home in Delhi which is a

substantial delay in treatment. Had there been any physical beatings

by the respondent no.3 to the complainant then her parents could

have medically examined the complainant next day instead of a

approximately month delay. It is further submitted that the medical

examination of the complainant was a regular/routine check –up/

treatment as she was knocking the door of becoming a mother and

not due to any physical beating or kick given by respondent no.3.

9. That the contents of para 9 of the complaint under reply are not

denied that on 04.03.2011 a female child namely Misti was born in

Gandhi Nursing Home at Om Vihar, Uttam Nagar, Delhi however, it

is specifically denied that all the expenses of the delivery were also

borne by the parents of the complainant.

It is submitted herewith that the birth of the female child was

from normal delivery and the respondent no. 1 has constantly

requested for the routine check up in Kanpur but his request was

declined by the complainant at the instance and behest of her

parents. Thereafter when the respondent no.1 left with no other

option he started transferring the amount of money to the

complainant as and when required even at the time of the birth of his

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 little daughter, the respondent no.1 had transferred Rs.30,000/-to

the complainant apart from bearing other miscellaneous expenses.

10. That the contents of para 10 of the complaint under reply is wrong

and denied.

It is submitted herewith that it was the respondent no.1 who

visited to his in-laws house and requested to the complainant to

come back with him for the God-Bahari ceremony of his sister,

however the complainant without paying any heed to their request

declined to accompany with respondent no.1 but thereafter with the

repeated request by respondent no.1 and his family members the

complainant agreed to accompany with respondent no.1 with

condition to return back to Delhi i.e. her parental house just after the

God-Bahari ceremony. The respondent no.1 left with no other option

except to bow down to demand of the complainant. It is further

submitted that the complainant most of the time stayed at her

parental house despite of several request to reside with the

respondents at her matrimonial house. Even the pleadings of the

complainant reflect the excessive interference of the complainant

parents in the matrimonial house of their daughter which is the root

cause of the differences between the complainant and the

respondent no.1 .Complainant more often without assigning any

satisfactory reply left to her parental house and whenever

respondent no.1 persuade her to know the reasons behind her

frequent visit to her parental house she rebuked the respondent no.1

and warned him to mind his own business and stay at her parental

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 house as per her own sweet will and without the consent or

intimation to respondent no.1 or any other family members.

11. That the contents of para 11 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto. It is denied that

the complainant was treated well for a period of nine months

approximately thereafter because of the reason that the marriage of

the respondent no.5 was to take place in November, 2011.

It is submitted that the complainant was always treated with

love, care and respect throughout her stay at her matrimonial house

since the inception of the marriage and at no point of time she was

mal-treated or any cruelty was committed upon her.

12. That the contents of para 12 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto. It is specifically

and vehemently denied that the complainant asked her stridhan i.e.

the jewellery given by the parents of the complainant as well as in

laws of the complainant and her other articles but they refused to

give which is in the custody and possession of the respondents.

It is pertinent and necessary to mention herewith that since the

day of marriage all her stridhan in the form of jewellery, articles are

lying with the complainant which she had taken to her parental

house and not even a single article of her stridhan is lying with the

answering respondents. Moreover respondent no.1 and his family

members frequently helped complainant family in rendering financial

assistance as and when required. It is further submitted that just to

extort the money from the respondent no.1 this allegation of stridhan

has been leveled against them to put pressure and extort the money

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 in the same manner as the elder sister of the complainant did with

her in-laws few months back.

13. That the contents of para 13 of the complaint under reply are not

disputed hence admitted as correct except the contents that she was

again kept well for about 6 months.

It is submitted herewith that it was the respondent no.1 who

called the Senior member/relative of the society in form of

Panchayat wherein the complainant verbally agreed to live

peacefully at her matrimonial house and further will not create any

disturbance in her matrimonial house. However after few days the

complainant again back to her old intolerable behavior. It is further

submitted herein till today the respondent no.1 never misbehaved

with the complainant rather it is the complainant who took the vow to

implicate the respondent no.1 and his family members in false and

frivolous cases and the same can be very well understand after

going through the audio clips as well as the telephonic conversation

between the complainant and respondent no.1 Copy of the said

audio and conversation are annexed herewith for the kind

perusal of the Hon’ble court.

14-15. That the contents of para 14-15 of the complaint under reply are

wrong, false, frivolous, concocted and are denied in toto except that

the marriage of the younger sister was to be solemnized on

8.2.2013.

It is submitted herewith that the entire conversation

throughout the pleadings were between the complainant and her

parents to the exclusion of respondent no.1. It is further submitted

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 that it was the respondent no.1 who out of his own sweet will and

understanding took the complainant to Delhi for attending and

participating in the marriage ceremony. Had there been any request

the respondent no.1 could have accompanied with the complainant

to her parental house for the occasion and rather actively

participated as the complainant knows and respect the relations.

It is submitted that neither any invitation nor a single call was made to

the respondent no.1 and his family members to attend the marriage

of the younger sister of the complainant at Delhi. But still out of

courtesy and understanding the respondent no.1 personally took the

complainant to Delhi for attending the marriage ceremony. It is

further pertinent to mention herewith that the parents of the

complainant did not allow him to stay and attend the marriage

ceremony of “SAALI” at Delhi

16. That the contents of para 16 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto. The answering

respondents specifically, vehemently and categorically denied each

and every allegation made in para under reply.

It is submitted herewith that the objections made in preliminary

objection may be referred to as submissions and the same has not

been repeated herein for the sake of brevity.

17. That the contents of para 17 of the complaint under reply are wrong,

false, frivolous and are denied. However it is submitted that the

mother of the respondent no.1 is suffering from multiple joint pain

problem during those periods and is still under medical treatment

and due to constant tension and disturbances at home in Kanpur the

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 respondent no. 1 could not able to come and the same genuine and

bonafide reason had been conveyed to the complainant on the very

same day and respondent no.1 took the complainant back to

matrimonial house.

18. That the contents of para 18 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto.

It is submitted herewith that the respondent no.1 took the

complainant (wrongly written as complainants) on 19.3.14 after the

mother of the respondent no.1 got recovered from her illness and

not due to the reason that C.A.W Cell told that F.I.R. will be

registered in this respect. It is further submitted that the letter dated

19.3.14 pertains not to lodging of F.I.R against the answering

respondent but related to the request being made to S.H.O, C.W.C,

Nanakpura wherein the respondent no.1 stated that he wishes to live

with the complainant and her daughter and has taking them back to

her matrimonial house and urges to restrain the parents of the

complainant from their unnecessary and unwarranted excessive

interference in the happy married life of the respondent no.1 and the

complainant.

19. That the contents of para 19 of the complaint under reply needs no

reply as a matter of record.

20. That the contents of para 20 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto.

It is submitted herewith that the complainant at the instance

and behest of her parents more particularly her father wrote number

of false and frivolous applications before different authorities, had

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 misrepresented and suppressed the material facts from the

authorities wherein the entire family members of the respondent

no.1 has been falsely implicated including the old age ill mother and

the studying younger brother who were even not at home at the time

of alleged incident arose and accrue on different dates and events. It

is pertinent to mention herewith that even the top police official

committee of Kanpur, found the allegations against the respondent

no.1 and his family members are baseless and given clean chit to

the respondents. Not only this, second enquiry was also conducted

in this regard in Kanpur and the said higher official also found the

allegations as baseless.

It is not denied that the respondent no.1 on 23.6.2013 made a

statement before the C.O., Govind nagar, Kanpur but it is submitted

that the complainant subsequently failed to fulfill the promises and

assurances made at the time of settling the issues between the

complainant and respondent no.1

21. That the contents of para 21 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto. It is specifically

denied that after 19.3.2014 the respondent no. 1 and his family

members including his married sister again started giving physical

and mental torture to the complainant and started demanding dowry

in the sum of Rs.5,00,000/-(Rupees Five Lacs).

22. That the contents of para 22 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto. It is submitted that

the entire allegations are baseless for the want of knowledge to the

answering respondents.

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23. That the contents of para 23 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto. It is specifically

and vehemently denied that on 7.2.2015 the miscarriage took place

because of other physical and mental torture given by the

respondent no.1, 3 and 4.

It is pertinent and necessary to mention herewith that the

miscarriage was without the consent of the respondent no.1 and his

family members as they were remotely residing in Kanpur and the

same was at the instance and behest of her parents and that too at

her parental house vicinity hospital in Delhi.

24. That the contents of para 24 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto for want of

knowledge.

25. That the contents of para 25 of the complaint under reply are wrong,

false, frivolous, concocted and are denied in toto.

26. That the contents of para 26 of the complaint under reply are wrong,

false, frivolous, concocted and are denied.

It is denied that after some time the respondent again started

giving physical beatings and mental torture to the complainant and

on her complaint the mother of the complainant reached at Kanpur

in July,2015 and on 17.7.2015, the respondents gave physical

beatings with fist and kicks and even torn her clothes and tried to

commit rape .It is very much necessary to mention herewith that on

the one hand the complainant alleges that the respondents gave

physical beatings with fist and kicks and on the other hand she

alleges that they tried to commit rape. These allegations reveals the

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 determination of the complainant to send the entire family members

behind the bar by levelling the allegations of one of the heinous

crime i.e. rape and particularly against her husband and her in- laws.

It is specifically denied that the respondents threatened that

she will not be allowed to live here and made a demand of dowry of

Rs.10, 00,000/-(Rupees Ten Lacs) .It is submitted herewith that in

preceding paras the allegations qua demand of dowry is for Rs.5,

00,000/- and in the para under reply the same is now Rs.10,

00,000/- which clearly depicts the contradictory stands of the

complainant and further expose the falsity of the story of the

complainant. Hence, the self-contradictory allegations completely

bring to the fore that the present false and frivolous complaint has

been filed by the Complainant on the instigation and instance of her

parents based upon false and frivolous grounds

Rest of the contents of para under reply are denied except lodging

of FIR against the respondent no.2. It is submitted herewith that the

complainant finally succeeded in her illegal designs of implicating

the respondent no.1 and his family members in false and frivolous

cases by getting an FIR registered against the father of the

respondent no.1 by hook and crook. It is further submitted that the

father of the respondent no.1 become the victim of the apprehension

of the respondent no.1 and his family members.

27. That the contents of para 27 of the complaint under reply are denied.

It is denied that any reminder was sent to the Senior Superintendent

of Police, Kanpur on 20.7.2015. Till date no action has been made

21
 against the Respondent which proves that the reminder if any filed

was false.

28. That the contents of para 28 of the complaint under reply are denied.

It is submitted that till date no action has been made against the

Respondent which proves that the complaint if any filed by the

Complainant was false.

29. That the contents of para 29 of the complaint under reply needs no

reply as matter of record.

30. *That the contents of para 30 of the complaint under reply needs no

reply as matter of record. The complainant is self-sufficient and is

capable of maintaining herself.

31. *That the contents of para 31 of the complaint under reply needs no

reply as matter of record.

32. That the contents of para 32 of the complaint under reply are wrong,

false, frivolous, concocted and are denied. It is denied that the

respondent no. 1 has also purchased a plot from Kanpur

Development authority measuring 400 sq. yards, for a sum of more

than Rs.50,00,000/- (Rupees Fifty Lacs) in an Industrial Area in

December,2014.

33. That the contents of para 33 of the complaint under reply are wrong,

false, frivolous, concocted and are denied. It is denied that the

respondent o.1 is also having agricultural land more than 40 Bigha in

Village Nourtha, P.O. Sikandrarau, Distt.Hathras (U.P.).It is further

denied that the house no.128/1040, Y Block, kidwai Nagar, P.S.

Naubasta, Kanpur, City (U.P.) is also in the name of the respondent

22
 no.1 which has been constructed upto two storied in an area of more

than 200 sq.yrds, the value of the said house is rs.1,50,00,000/-

34. That the contents of para 34 of the complaint under reply are wrong,

false, frivolous, concocted and are denied. It is submitted herewith

that the respondent no.1 is having one licensed gun and the same is

for the protection purpose as father of the respondent no.1 is

working as Inspector in Anti-Crime Branch.

35. That the contents of para 35 of the complaint under reply are matter

of record except that the complainant who is aggrieved in this case.

Lastly, Prayer para of the complaint is wrong hence denied.

The complainant is not entitled to any directions /protection or other relief

from this Hon’ble Court. The Complainant has no reason to fear about her

life or limb or of her parents and children from the Respondents. Since no

cause of action arose, no orders are required to be passed in the matter. f.

It is submitted herewith that the Respondents had always discharged his

matrimonial duties and obligations towards the Complainant and the

children and treated them nicely with all love and care. The Respondent

never committed any kind of cruelty against the Complainant and the

allegation of committing abuses is false. The Complainant is not entitle for

any relief prayed in the complaint.

A. Denied. The Respondents has not committed any domestic

violence upon the complainant so no order preventing the

Respondent is required to be passed.

23
B. Denied. The complainant had left the matrimonial home and

started living with her parents and also took away the minor child

to cause agony and harassment to the Respondent. It is

submitted that the Respondent had been approaching the

complainant to bring her back along with her minor daughter

requesting her to live peacefully and not to spoil the relationship

and think of the future of child also.

C. Denied. It is submitted that all the jewellry and dowry articles of

the complainant are in the custody and possession of the

complainant at the time of leaving the matrimonial house and

nothing remains with the respondents.

D. Denied. No protection orders are required to be passed in the

matter. The complainant is residing at Najafgarh, Delhi at her

parental house along with the minor daughter as per her own

sweet will and the Respondents is residing at Kanpur and had not

visited her place of residence.

E. Denied. It is submitted herewith that the respondent no.1 does

not possess any properties in his name till today so no order for

restraining the respondent no.1 from selling, transferring or

disposing off is required to be passed.

F. Denied. It is submitted herewith that the Innova car having

registration no. DL-4C-AE-9068 was purchased exclusively by

the respondent no.1 from his own savings and from financial

assistance of friends and since the complainant was about to

become the legally wedded wife of the respondent no.1, so the

24
 respondent no.1 did not hesitate by getting it registered in the

name of the complainant.

G. Denied. It is submitted herewith that the complainant wilfully and

out of her own sweet will left the company of respondent no.1 to

harass and humiliate and to cause financial hardship.

Considering the financial status of the parties, no order for grant

of any maintenance are required to be passed.

H. Denied. It is denied that the complainant is entitled for any

compensation. The complaint is false and is liable to be

dismissed. Since the Respondents has never caused any mental

torture to the Complainant so the question of seeking any amount

in this regard is baseless. The Complainant is not entitled to claim

Rs. 10 Lacs or any part thereof from the Respondents on any

count.

. PRAYER

It is, therefore most respectfully prayed that the Hon’ble Court

may graciously be pleased to dismiss the present complaint as the

same is false and frivolous and is bundle of lies. The complaint is

without any cause of action and is frivolous and is liable to be

dismissed out rightly with costs.

Prayed accordingly.

Respondents

Through

25
 Onkar Roy & Ankit Jain

Advocates
Ch-602, Lawyers Chamber Block,
Dwarka Court Complex, Sector-10 Dwarka
Delhi
Dated:

26
IN THE COURT OF MS. MANU GOEL KHARAB: MM: MAHILA COURT:
DWARKA, NEW DELHI

CC NO. 123/2/2015

IN THE MATTER OF:

Ms. Deepika .. Complainant

Versus

Atul Rana & Ors. .. Respondents

AFFIDAVIT

I, Atul Kumar Rana, S/o Sh.Raja Ram Singh Rana, aged about 41
years, R/o 1104, 128/1040, YBlock, Kidwai Nagar, P.S. Naubasta, Kanpur
City(U.P.) do hereby solemnly affirm and state as under:

1. I am Respondent No.1 in the above Complaint. I am conversant with

the facts and circumstances of the case and am able to depose about
them.

2. I say that the accompanying Written Statement to the complaint

under the provisions of Protection of Women from Domestic Violence Act
has been drafted on my instructions and the facts stated therein are true to
my knowledge while the legal submissions are information received and
believed to be correct.

DEPONENT

VERIFICATION:
Verified at Delhi on this day of December, 2015 that the contents of
pares 1 and 2 of my above affidavit are true to my knowledge.

DEPONENT

27
IN THE COURT OF MS. MANU GOEL KHARAB: MM: MAHILA COURT:
DWARKA, NEW DELHI

CC NO. 123/2/2015

IN THE MATTER OF:

Ms. Deepika .. Complainant

Versus

Atul Rana & Ors. .. Respondents

AFFIDAVIT

I,.Raja Ram Singh Rana, S/o aged about 41 years, R/o 1104,
128/1040, YBlock, Kidwai Nagar, P.S. Naubasta, Kanpur City(U.P.) do
hereby solemnly affirm and state as under:

1. I am Respondent No.2 in the above Complaint. I am conversant with

the facts and circumstances of the case and am able to depose about
them.

2. I say that the accompanying Written Statement to the complaint

under the provisions of Protection of Women from Domestic Violence Act
has been drafted on my instructions and the facts stated therein are true to
my knowledge while the legal submissions are information received and
believed to be correct.

DEPONENT

VERIFICATION:
Verified at Delhi on this day of December, 2015 that the contents of
pares 1 and 2 of my above affidavit are true to my knowledge.

DEPONENT

28
IN THE COURT OF MS. MANU GOEL KHARAB: MM: MAHILA COURT:
DWARKA, NEW DELHI

CC NO. 123/2/2015

IN THE MATTER OF:

Ms. Deepika .. Complainant

Versus

Atul Rana & Ors. .. Respondents

AFFIDAVIT

I, Vimla Devi, W/o Sh.Raja Ram Singh Rana, aged about 41 years,
R/o 1104, 128/1040, YBlock, Kidwai Nagar, P.S. Naubasta, Kanpur
City(U.P.) do hereby solemnly affirm and state as under:

1. I am Respondent No.3 in the above Complaint. I am conversant with

the facts and circumstances of the case and am able to depose about
them.

2. I say that the accompanying Written Statement to the complaint

under the provisions of Protection of Women from Domestic Violence Act
has been drafted on my instructions and the facts stated therein are true to
my knowledge while the legal submissions are information received and
believed to be correct.

DEPONENT

VERIFICATION:
Verified at Delhi on this day of December, 2015 that the contents of
pares 1 and 2 of my above affidavit are true to my knowledge.

DEPONENT

29
IN THE COURT OF MS. MANU GOEL KHARAB: MM: MAHILA COURT:
DWARKA, NEW DELHI

CC NO. 123/2/2015

IN THE MATTER OF:

Ms. Deepika .. Complainant

Versus

Atul Rana & Ors. .. Respondents

AFFIDAVIT

I, Prasant Kumar, S/o Sh.Raja Ram Singh Rana, aged about 41

years, R/o 1104, 128/1040, YBlock, Kidwai Nagar, P.S. Naubasta, Kanpur
City(U.P.) do hereby solemnly affirm and state as under:

1. I am Respondent No.4 in the above Complaint. I am conversant with

the facts and circumstances of the case and am able to depose about
them.

2. I say that the accompanying Written Statement to the complaint

under the provisions of Protection of Women from Domestic Violence Act
has been drafted on my instructions and the facts stated therein are true to
my knowledge while the legal submissions are information received and
believed to be correct.

DEPONENT

VERIFICATION:
Verified at Delhi on this day of December, 2015 that the contents of
pares 1 and 2 of my above affidavit are true to my knowledge.

DEPONENT

30
31