IN THE COURT OF SH. SANGHMITRA, LD. M.M.

,
DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE :- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus

Shri Gautam Sikka & Ors. …Respondents

D.O.H. 06.08.2022

WRITTEN STATEMENT ON BEHALF OF THE

RESPONDENTS TO THE COMPLAINT UNDER
SECTION 12 READ WITH SECTION 18, 19, 20 AND
22 OF PROTECTION OF WOMEN FROM DOMESTIC
VIOLENCE ACT, 2005 FILED BY THE COMPLAINANT .
---------------------------

MOST RESPECTFULLY SHOWETH :-

PRELIMINARY OBJECTIONS:-

1. That the marriage between the respondent

no.1 and the complainant was solemnized

on 21-02-2018 according to Hindu Customs

and Rites at The Grand Dreams Banquet,

16, Shivaji Marg, Main Najafgarh Road

Industrial Area, Delhi-110015 in a simple

manner without any demand of dowry.

 Hence the application is liable to be

dismissed with heavy costs.

2. That the marriage both the parties resided

together as husband and wife at House No.

3205, 2nd Floor, Sector 57, Gurgaon, where

the marriage was duly consummated

between the parties and one male child

namely Paarth Juneja has been born out

from this wedlock on 13-10-2019. Hence the

application is liable to be dismissed with

heavy costs.

3. That since beginning of the marriage, the

complainant remained under the influence

of her parents and under their influence she

always making the quarrel and abusing with

the respondents and she was also used to go

and back her parental house without giving

any information to the respondents. Hence

the application is liable to be dismissed

with heavy costs.

4. That both the parties living at the said

address, after sometimes the complainant

 started misbehaved, insulted, tortured,

harassed physically and mentally to the

respondents. Hence the application is liable

to be dismissed with heavy costs.

5. That after the marriage the respondents

paid full love and regard to the

complainant, which is expected to a newly

married bride and the respondent no.1 also

following all the instructions of the

complainant but the complainant never

understand the feelings of the respondent

no.1. Hence the application is liable to be

dismissed with heavy costs.

6. That the respondent no.1 has given all love

and affection and respect to the

complainant, since the marriage in the

matrimonial home but the complainant did

not discharged her matrimonial duties and

obligations faithfully and she harassing and

humiliating the respondent no.1. Hence the

application is liable to be dismissed with

heavy costs.
7. That the complainant did not do any

domestic work and the complainant has

been threatening the respondent no.1 to

implicate in false cases as well as dowry

and file false complaint in the police station

against the respondent no.1. Hence the

application is liable to be dismissed with

heavy costs.

8. That the complainant and her family

members used to cruelty with the

respondents and they misguided and

instigated the complainant against the

respondent no.1 before friends and relatives

and the respondent no.1 tried to understand

the complainant and her family members

but they did not listen anything and not

improve their attitude and behaviour

towards the respondents. The complainant

was in habit to search the silly points to

raise and quarrel with the respondent no.1

and the parents of the complainant also

instigated her against the respondents on

 phone. Hence the application is liable to be

dismissed with heavy costs.

9. That during the stay at her matrimonial

house, most of time the complainant used to

talk with her parents on phone. Hence the

application is liable to be dismissed with

heavy costs.

10. That the complainant used to make the

quarrel with the respondents day by day

and threatened to reopen the case by saying

that “Tum Logon Ko Nahi Pata Ki Aaj Main

Jo Bhi Jhoothe Aarop Laga Dungi Aur Police

or Court Bhi Meri Hi Baat Manegi”. The

complainant is also used to give filthy and

abusive language to the respondents by

saying that “Main Chahu To Tumhara

Budapa Jail Me Kata Dungi ” and the

complainant also demanded the money from

the respondents. Hence the application is

liable to be dismissed with heavy costs.

11. That the respondents tolerated all her

atrocities, mental agony, physical agony,

 harassment, cruelties caused by the

complainant since the marriage yet he

tolerated all these atrocities to tie intact

the matrimonial relations but of no avail.

Hence the application is liable to be

dismissed with heavy costs.

12. That the respondent no.1 as well as the

complainant are not having the physical/

sexual relations since ___________ and are

not co-habited with each other since

__________ and lastly resided together in

Gurgaon at the given address. The

respondent no.1 has been ruined forever by

the complainant and his life is being

deserted since 03.06.2020 continuously by

the complainant and there are no

possibilities to live together at any corner

due to the cruel acts of the respondent no.1

and every possibilities has become in end,

so the petition is being filed but now every

possibilities has been ended and the

complainant had threatened to implicate the

 respondents in the criminal cases which is

also the part of cruelties and by the above

said cruelties the respondent no.1 has

received the mental and physical agony and

also have lost the faith of his matrimonial

life and is not able to live together. The life

of the respondent no.1 is being deserted by

the cruel acts of the complainant since 26-

11-2021 continuously. Hence the

application is liable to be dismissed with

heavy costs.

13. That due to constant cruel and callous conduct

on the part of complainant and threat to the

life of the respondent no.1 from the

complainant and her family members it has

become practically impossible for the

respondent no.1 to live in the company of the

complainant. Hence the application is liable

to be dismissed with heavy costs .

14. That the respondent no.1 has not been

afforded with any opportunity to reconcile the

differences with the complainant in any

 manner and that the complainant was hell

bent on sending the respondent no.1 to

judicial custody there is little scope for the

respondent no.1 to condone the acts of

cruelty by the complainant. Hence the

application is liable to be dismissed with

heavy costs

15. That the complainant has suppressed all

true and material facts before this Hon’ble

Court who is liable to be prosecuted for

submitting the wrong facts before this

Hon’ble Court, who has cooked up a wrong

story to get the sympathy from this Hon’ble

Court, hence the application is liable to be

dismissed.

16. That the present application is otherwise,

false, frivolous and vexatious and is without

any cause of action. It is stated that the

allegation and demands as made in the

application are baseless, misconceived,

concoctions, fabrication and product of evil

mind of the complainant. No cause of action

 arose in favour of the complainant and

against the respondents. The case being

without cause of action merits dismissal.

Moreover, the information which has been

provided by the complainant in this

application, which is not based on any

evidence and is a mere concocted story of

the complainant just to falsely implicate the

respondents and to extort money from the

respondents, hence the application is liable

to be rejected.

17. That the complainant has not come to this

Hon’ble Court with the clean hands and she

has suppressed the true facts and

misrepresented before this Hon’ble Court,

thus the complainant is not entitled to any

relief as claimed, hence the application is

liable to be rejected.

18. That the present application is abuse to the

process of law. The complainant is simply

harassing and humiliating the respondents

as the complainant has never been to any

 type of harassment and torture by the

respondents and therefore seeing the

interest of justice, this Hon’ble Court

should take the matter with the intention of

providing justice by the order by

appreciating the evidence and by dismissing

this suit which has been providing by the

above said application, hence the

application is liable to be rejected.

19. That the present application is bundle of

lies, the plaintiff has suppressed all true

and material facts and is liable to be

prosecuted as he has tried to hide her

wrongs and has filed the present application

without any cause and to harass the

respondents to put a pressure to hide her

wrongs, hence the application is liable to be

rejected.

20. That the respondents cannot take advantage

of his own wrongs and the present

application has been filed against the

respondents just to create unnecessary

 pressure to him and wants to extort the

money from the respondents, as such the

application is liable to be dismissed .

REPLY ON MERITS:-

1. That the contents of para no.1 of the

application are matter of record, need no

reply.

2. That the contents of para no.2 (a to f) of the

application are wrong and denied. It is

submitted that the complainant filed the

present case on the basis of totally false

and incorrect facts, therefore the

complainant is not entitled to get any relief.

3(i). That the contents of para no.3(i) of the

application are wrong and denied. It is

submitted that the complainant filed the

present case on the basis of totally false and

incorrect facts, therefore the complainant is

not entitled to get any relief under the

provisions of Section 18 of D.V. Act.

(ii). That the contents of para no.(ii) of the

application are wrong. It is submitted that

 the complainant filed the present case on

the basis of totally false and incorrect facts,

therefore the complainant is not entitled to

get any relief under the provisions of

Section 19 of D.V. Act.

(iii) That the contents of para no.(iii) of the

application are wrong and denied. It is

submitted that the complainant filed the

present case on the basis of totally false

and incorrect facts, therefore the

complainant is not entitled to get any relief

under the provisions of Section 20 of D.V. Act.

(iv) That the contents of para no.(iv) of the

application are wrong and denied. It is

submitted that the complainant filed the

present case on the basis of totally false

and incorrect facts, therefore the

complainant is not entitled to get any relief

under the provisions of Section 22 of D.V. Act.

4. That the contents of para no.4 of the

application need no reply.

5. That the contents of para no.5 of the

application need no reply.

The prayer clause of the complaint is wrong

and denied. It is submitted that the complainant

has not come to this Hon’ble Court with clean

hands and have suppressed all true and

material facts before this Hon’ble Court, who is

liable to be prosecuted and is not entitled for

any relief.

It is, therefore, prayed that the present

complaint may kindly be dismissed with heavy

cost, in favour of the respondents and against

the complainant, in the interest of justice.

Delhi RESPONDENTS
Dated:
Through

(ANURAG SHARMA & GAURAV SRIVASTAVA)

ADVOCATE
M. 8920503527, 9811312468
E. Mail: [email protected]

VERIFICATION
I the above named deponent do hereby

solemnly affirm and declare that the contents of

Para No.1 to 4 of Reply on Merits are true and

correct to my knowledge and the contents of

Paras No.1 to 20 of Preliminary Objections are

true to the information received and believed to

be true. Last Para is Prayer to this Honble

Court.

Verified at Delhi on this ___ Day of August,

2022.

RESPONDENTS

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus
Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
I, Gautam Sikka S/o Shri Ashok Sikka R/o
House No.3205, Second Floor, Sector- 57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 1 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g W r itte n S ta te me n t h as
b e en d ra f te d b y my c o u n s e l u nd e r my in s tr u c tio n s
a nd th e c on te n ts o f th e s a me ar e tr u e an d c o r r e c t
a nd th e sa me ma y k ind ly be r ea d a s p ar t a nd
p ar c e l o f th is a f f ida v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus
Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
I, Rekha Sikka W/o Shri Ashok Sikka R/o
House No.3205, Second Floor, Sector- 57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 2 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g W r itte n S ta te me n t h as
b e en d ra f te d b y my c o u n s e l u nd e r my in s tr u c tio n s
a nd th e c on te n ts o f th e s a me ar e tr u e an d c o r r e c t
a nd th e sa me ma y k ind ly be r ea d a s p ar t a nd
p ar c e l o f th is a f f ida v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus
Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
I, Ashok Sikka S/o Not Known R/o House
No.3205, Second Floor, Sector-57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 3 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g W r itte n S ta te me n t h as
b e en d ra f te d b y my c o u n s e l u nd e r my in s tr u c tio n s
a nd th e c on te n ts o f th e s a me ar e tr u e an d c o r r e c t
a nd th e sa me ma y k ind ly be r ea d a s p ar t a nd
p ar c e l o f th is a f f ida v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus
Shri Gautam Sikka & Ors. …Respondents

D.O.H. 06.08.2022

REPLY ON BEHALF OF THE RESPONDENTS TO

THE DOMESTIC INCIDENT REPORT FILED BY
THE COMPLAINANT.
---------------------------

MOST RESPECTFULLY SHOWETH :-

PRELIMINARY OBJECTIONS:-

1. That the marriage between the respondent

no.1 and the complainant was solemnized

on 21-02-2018 according to Hindu Customs

and Rites at The Grand Dreams Banquet,

16, Shivaji Marg, Main Najafgarh Road

Industrial Area, Delhi-110015 in a simple

manner without any demand of dowry.

Hence the application is liable to be

dismissed with heavy costs.

2. That the marriage both the parties resided

together as husband and wife at House No.

3205, 2nd Floor, Sector – 57, Gurgaon,

Haryana - 122002, where the marriage was

duly consummated between the parties and

 one male child namely Paarth Juneja has

been born out from this wedlock on 13-10-

2019. Hence the application is liable to be

dismissed with heavy costs.

3. That since beginning of the marriage, the

complainant remained under the influence

of her parents and under their influence she

always making the quarrel and abusing with

the respondents and she was also used to go

and back her parental house without giving

any information to the respondents. Hence

the application is liable to be dismissed

with heavy costs.

4. That both the parties living at the said

address, after sometimes the complainant

started misbehaved, insulted, tortured,

harassed physically and mentally to the

respondents. Hence the application is liable

to be dismissed with heavy costs.

5. That after the marriage the respondents

paid full love and regard to the

complainant, which is expected to a newly

 married bride and the respondent no.1 also

following all the instructions of the

complainant but the complainant never

understand the feelings of the respondent

no.1. Hence the application is liable to be

dismissed with heavy costs.

6. That the respondent no.1 has given all love

and affection and respect to the

complainant, since the marriage in the

matrimonial home but the complainant did

not discharged her matrimonial duties and

obligations faithfully and she harassing and

humiliating the respondent no.1. Hence the

application is liable to be dismissed with

heavy costs.

7. That the complainant did not do any

domestic work and the complainant has

been threatening the respondent no.1 to

implicate in false cases as well as dowry

and file false complaint in the police station

against the respondent no.1. Hence the

 application is liable to be dismissed with

heavy costs.

8. That the complainant and her family

members used to cruelty with the

respondents and they misguided and

instigated the complainant against the

respondent no.1 before friends and relatives

and the respondent no.1 tried to understand

the complainant and her family members

but they did not listen anything and not

improve their attitude and behaviour

towards the respondents. The complainant

was in habit to search the silly points to

raise and quarrel with the respondent no.1

and the parents of the complainant also

instigated her against the respondents on

phone. Hence the application is liable to be

dismissed with heavy costs.

9. That during the stay at her matrimonial

house, most of time the complainant used to

talk with her parents on phone. Hence the

 application is liable to be dismissed with

heavy costs.

10. That the complainant used to make the

quarrel with the respondents day by day

and threatened to reopen the case by saying

that “Tum Logon Ko Nahi Pata Ki Aaj Main

Jo Bhi Jhoothe Aarop Laga Dungi Aur Police

or Court Bhi Meri Hi Baat Manegi”. The

complainant is also used to give filthy and

abusive language to the respondents by

saying that “Main Chahu To Tumhara

Budapa Jail Me Kata Dungi” and the

complainant also demanded the money from

the respondents. Hence the application is

liable to be dismissed with heavy costs.

11. That the respondents tolerated all her

atrocities, mental agony, physical agony,

harassment, cruelties caused by the

complainant since the marriage yet he

tolerated all these atrocities to tie intact

the matrimonial relations but of no avail.

 Hence the application is liable to be

dismissed with heavy costs.

12. That the respondent no.1 as well as the

complainant are not having the physical/

sexual relations since ___________ and are

not co-habited with each other since

__________ and lastly resided together in

Gurgaon at the given address. The

respondent no.1 has been ruined forever by

the complainant and his life is being

deserted since __________ continuously by

the complainant and there are no

possibilities to live together at any corner

due to the cruel acts of the respondent no.1

and every possibilities has become in end,

so the petition is being filed but now every

possibilities has been ended and the

complainant had threatened to implicate the

respondents in the criminal cases which is

also the part of cruelties and by the above

said cruelties the respondent no.1 has

received the mental and physical agony and

 also have lost the faith of his matrimonial

life and is not able to live together. The life

of the respondent no.1 is being deserted by

the cruel acts of the complainant since 26-

11-2021 continuously. Hence the

application is liable to be dismissed with

heavy costs.

13. That due to constant cruel and callous conduct

on the part of complainant and threat to the

life of the respondent no.1 from the

complainant and her family members it has

become practically impossible for the

respondent no.1 to live in the company of the

complainant. Hence the application is liable

to be dismissed with heavy costs .

14. That the respondent no.1 has not been

afforded with any opportunity to reconcile the

differences with the complainant in any

manner and that the complainant was hell

bent on sending the respondent no.1 to

judicial custody there is little scope for the

respondent no.1 to condone the acts of

 cruelty by the complainant. Hence the

application is liable to be dismissed with

heavy costs

15. That the complainant has suppressed all

true and material facts before this Hon’ble

Court who is liable to be prosecuted for

submitting the wrong facts before this

Hon’ble Court, who has cooked up a wrong

story to get the sympathy from this Hon’ble

Court, hence the application is liable to be

dismissed.

16. That the present application is otherwise,

false, frivolous and vexatious and is without

any cause of action. It is stated that the

allegation and demands as made in the

application are baseless, misconceived,

concoctions, fabrication and product of evil

mind of the complainant. No cause of action

arose in favour of the complainant and

against the respondents. The case being

without cause of action merits dismissal.

Moreover, the information which has been

 provided by the complainant in this

application, which is not based on any

evidence and is a mere concocted story of

the complainant just to falsely implicate the

respondents and to extort money from the

respondents, hence the application is liable

to be rejected.

17. That the complainant has not come to this

Hon’ble Court with the clean hands and she

has suppressed the true facts and

misrepresented before this Hon’ble Court,

thus the complainant is not entitled to any

relief as claimed, hence the application is

liable to be rejected.

18. That the present application is abuse to the

process of law. The complainant is simply

harassing and humiliating the respondents

as the complainant has never been to any

type of harassment and torture by the

respondents and therefore seeing the

interest of justice, this Hon’ble Court

should take the matter with the intention of

 providing justice by the order by

appreciating the evidence and by dismissing

this suit which has been providing by the

above said application, hence the

application is liable to be rejected.

19. That the present application is bundle of

lies, the plaintiff has suppressed all true

and material facts and is liable to be

prosecuted as he has tried to hide her

wrongs and has filed the present application

without any cause and to harass the

respondents to put a pressure to hide her

wrongs, hence the application is liable to be

rejected.

20. That the respondents cannot take advantage

of his own wrongs and the present

application has been filed against the

respondents just to create unnecessary

pressure to him and wants to extort the

money from the respondents, as such the

application is liable to be dismissed.

REPLY ON MERITS:-
1. That the contents of para no.1 of the

Domestic Incident Report are matter of

record, need no reply.

2. That the contents of para no.2 of the

Domestic Incident Report are matter of

record, needs no reply.

3. That the contents of para no.3 of the

Domestic Incident Report are partly

admitted and partly denied. It is specifically

denied that the respondent no.1 is working

as Senior Manager (OCC) at Indigo Airlines

and the last salary known to the

complainant was Rs.1,25,000/- per month.

It is submitted that the true and correct

facts have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

4. That the contents of para no.4 of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.1 sister continuously and

persistently followed up and convinced the

complainant and her family member for the

marriage. It is specifically denied that the

respondent further assured and conveyed to

the complainant’s that the respondent

family would ensure at any cost that the

complainant would have no hindrances

whatsoever and she would continue her job

and that to the respondent’s family will help

in the same regards. It is specifically denied

that it was further ensured to the

complainant and her parent that the

respondent no.1 hails from educated and

respected family and they have very good

reputation in the society. It is specifically

denied that it was further conveyed that the

respondents are not money minded and want

the complainant to be their Daughter-in-

law. It is specifically denied that the

complainant very transparently told about

herself to the respondents. It is specifically

denied that the complainant also conveyed

the fact that her parents are dependent on

her and the complainant’s father has

Neurological Problems therefore, a sum of

Rs.5,000/- monthly expenditure in incurred

on account thereof. It is specifically denied

that the respondents assured that they have

no issues at all and further extended

assurance that the complainant is that

liberty to take care of her parents in all the

ways. It is specifically denied that it was

presented by the respondents that their

families are well mannered and respectable

person. It is specifically denied that the

respondent’s family was impressed upon the

complainant’s parents and the complainant.

It is specifically denied that the

respondents eyes was on the complainant’s

salary and her property. It is submitted that

the true and correct facts have already been

mentioned in the preliminary objections and

 the contents of the same may kindly be read

as part and parcel of the reply of para

under reply and the contents of the same

are not repeated herein for the sake of

brevity.

5. That the contents of para no.5 of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

marriage was a very lavish affair for the

complainant’s parents since as per the

direction of the respondent no.1 and his

parents, very large sum of money was spent

beyond the capacity of parents of the

complainant. It is specifically denied that

on demand of the respondent no.1 and his

parents, the complainant’s parents had

spent around Rs.10,00,000/- in the

marriage. It is specifically denied that on

the other hand the complainant parents had

given jewellery to the respondent no.1. It is

submitted that the true and correct facts

have already been mentioned in the

 preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

6. That the contents of para no.6 of the

Domestic Incident Report are wrong and

denied. It is specifically denied that despite

the aforesaid, the respondent no.1 along

with the respondent no.2 to 3 after the

marriage used every opportunity to

complaint that the parents of the

complainant had not solemnized the

marriage as per their status and that a lot

had been left to the desired and spent on

the marriage by the complainant’s parents,

inspite of the fact that the complainant’s

parents had met all the demands of the

respondent no.1 and his family, the greed of

the respondents were never fulfilled. It is

specifically denied that in pursuance

thereof, after the marriage the attitude of

the respondent no.1 and other respondents

towards the complainant and her family

members were not cordial, as the

respondents always dominated the

complainant and her parents. It is

specifically denied that on the other hand,

on account of not bringing dowry, the

complainant had been a victim of extreme

mental abuse, physical assault and

domestic violence at the hand of the

respondent no.1 to 3. It is specifically

denied that the complainant was treated

miserably by her in law despite the fact that

the parents of the complainant had tried to

fulfill all the demands raised by the

respondent no.1 and his family. It is

specifically denied that the respondent no.1

as a matter of routine used to use filthy and

abusive language at home and the

complainant was subjected to verbal abuse

within few days of marriage. It is submitted

that the true and correct facts have already

 been mentioned in the preliminary

objections and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.

7. That the contents of para no.7 of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

matrimonial home is supposed to serve as a

form of support and bring relaxation from

life’s many struggles and agony, whereas in

the present case all the respondents at

matrimonial home had filled the

complainant’s life with fear and trepidation.

It is specifically denied that the

complainant restrained herself from taking

help of law against all the respondents on

account of fear of further violence, fear of

losing home, fear of loneliness and hope

that things would change with time and the

complainant was also compromising with

 the situation so, that with time the

respondent no.1 would accept her as his

wife and the respondent no.2 and 3 will

accept her as their respected daughter-in-

law. It is specifically denied that all the

efforts made by the complainant went in

vain and the complainant continued to face

violence at the hands of all the respondents.

It is specifically denied that the fear of

violence was very imminent and dangerous

that the complainant was all the time living

under extreme stress and anxiety. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

8. That the contents of para no.8 of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

 complainant had been subjected to cruelty,

physical assaults, mental torture, emotion

insult, threats, social abuse, psychological

abuse and economic deprivation at the

hands of all the respondents. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

a. That the contents of para no.a of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant met with the surprise on the

day of marriage when somebody ask the

respondent no.1 that “Kya ye ladki tumhari

choice hai … then respondent no.1 replied

ab kya fark padta hai ab to jo hona tha ho

gaya”. It is submitted that the true and

correct facts have already been mentioned

 in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

b. That the contents of para no.b of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondents being family members were

used to sleep in the same room, however,

just after marriage the respondent no.1

pressurized the complainant and asked the

complainant to sleep with the family. It is

specifically denied that the respondent no.1

asked “apne saath mummy ko bhi bech me

sula le kya … The complainant got surprised

and requested with folded hand that the

same would not be possible as the

complainant will feel very uncomfortable. It

is specifically denied that there were three

bed rooms in the house. It is specifically

denied that the respondent for the ulterior

 purpose tortured the complainant on the

said issues. It is specifically denied that in

the initial days the respondent no.1 does

not consummates the marriage with the

complainant. It is specifically denied that

the respondent no.2 used to sleep on

mattress just outside the bedroom of the

complainant and the respondent no.1. It is

specifically denied that the respondent no.1

restrained the complainant to close the door

of their bedroom. It is submitted that the

true and correct facts have already been

mentioned in the preliminary objections and

the contents of the same may kindly be read

as part and parcel of the reply of para

under reply and the contents of the same

are not repeated herein for the sake of

brevity.

c. That the contents of para no.c of the

Domestic Incident Report are partly

admitted and partly denied. It is specifically

denied that after came back from

 honeymoon the respondent no.1 had again

refused to develop any relationship with the

complainant and used to sleep at the corner

of the bed. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

d. That the contents of para no.d of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.1 is of very aggressive nature

and use to quarrel on very pity issues such

as “why did the complainant, left the towel

on the bed?” “why did she not keep the

glass of water back in the kitchen after

using ? etc.”. It is submitted that the true

and correct facts have already been

mentioned in the preliminary objections and

the contents of the same may kindly be read

 as part and parcel of the reply of para

under reply and the contents of the same

are not repeated herein for the sake of

brevity.

e. That the contents of para no.e of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no1. Is a habitual drinker. It is

specifically denied that the respondent no.1

often used to come late night to home after

drinking. It is specifically denied that 10-

03-2018 the complainant tried to convince

him not to drink regularly. It is specifically

denied that the respondent no.1 turned

around and scolded and abused the

complainant by saying “Behanchod Bass

Apne Kaam Se Matlab Rakh”. It is

specifically denied that the respondent no.1

had clearly told the complainant that “Mai

Piunga Jo Ukhadna Hai Ukad Le” and

further told her that “Tere Baap ka Nahi

Pita”. It is specifically denied that to the

 height of the surprise the respondent no.2

instead of controlling the respondent no.1

was instigating him by saying that “Sab Teri

Galti Hai, Teri Wajah Se Hi Toh Pita Hain,

Bichara Depression Mein Aa Gaya Hain Teri

Jaisi Pagal Aurat Se Shaadi Karke”. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

f. That the contents of para no.f of the

Domestic Incident Report are wrong and

denied. It is specifically denied that on the

very next morning the respondent no.2 was

trying to convince the complainant by

stating that “uske Liye Uske Jaisi Bano Aur

Humare Liye Humare Jaise Bano”. It is

specifically denied that the respondent no.2

further said that “either you live with him

 or leave him but he will not stop drinking”.

It is submitted that the true and correct

facts have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

g. That the contents of para no.g of the

Domestic Incident Report are wrong and

denied. It is specifically denied that after

marriage the parties were invited by the

relative of the respondent for dinner. It is

specifically denied that the relatives had

given some money to the complainant in the

name of Shagun. It is specifically denied

that the complainant had kept the money in

her Almira. It is specifically denied that

after few days, when the complainant was in

dire need of the money, she could not find

the money in the Almira and therefore asked

the respondent no.1. It is specifically

 denied that the respondent no.1 without any

occasion started scolding the complainant

by abusive language like Behenchod, Kuti

etc. teri himmat kaise hui puchane ki. It is

specifically denied that having left with no

other option the complainant had neglected

the complete situation and never discussed

the said issue ever again. It is submitted

that the true and correct facts have already

been mentioned in the preliminary

objections and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.

h. That the contents of para no.h of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant was then getting salary of

Rs.47,000/- in hand. It is specifically

denied that on the other side the

respondent no.1 was then getting

Rs.90,000/- per month. It is specifically

denied that the respondents from the next

day of marriage were making every endeavor

to take the entire salary from the

complainant. It is specifically denied that

the respondent no.1 said “Maine Tujhse Ye

Soch ke Shaadi Ki Thi Ki Tu Mujeh 20000-

25000 Rupaiye Har Mahine Degi, Tere Aane

Se Mere Ghar Ka Kharcha Badh Gaya Hai”.

It is specifically denied that in pursuance

thereof, firstly the respondents pampered

the complainant and when the complainant

denied to hand over the entire salary, the

attitude of the respondents had suddenly

changed. It is specifically denied that

thereafter, they were in one how or the

other hand started to pressurizing the

complainant for her salary. It is specifically

denied that the complainant had submitted

herself completely to the respondents and

for their happiness. It is specifically denied

that the respondent’s eyes are at her

 income. It is specifically denied that on

account thereof the physical and mental

torture had increased since then. It is

specifically denied that the complainant

used to expend her salary in her

matrimonial family. It is specifically denied

that despite the said fact the greed of the

respondents was never satisfied and they

were bound on to take the entire salary in

their hands. It is specifically denied that on

some occasion the respondent no.2 and 3

abused the complainant with dirty language

like “Apne Yaar p urati h etc.”. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

i. That the contents of para no.i of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.1 always used to quarrel on

the said issue and even forced the

complainant to leave the house. It is

specifically denied that in April May 2018

the respondent no.2 told the complainant

that the respondent no.1 never wished to

marry her. It is specifically denied that the

respondent no.2 further stated to the

complainant that “Mera Beta Tujse Shaadi

Nahi Karna Chahta Tha Tab Maine Usko

Dhamki Di Ki Agar Tu Ish Se Shaadi Nahi

Karega Toh Mai Suicide Kar Lungi, Tab Ja

Kar Vo Tumse Shaadi Karne To Tayar Hua”.

It is submitted that the true and correct

facts have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

j. That the contents of para no.j of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

attitude of the respondent no.3 is very

offended for the complainant. It is

specifically denied that the respondent no.3

used to sit in the complainant room until

11:00 P.M. at night. It is specifically denied

that the most unfortunate situation was

when the complainant after coming to the

home form the office could not even get a

movement to rest on account thereof. It is

specifically denied that the complainant

never got any opportunity to have privacy in

her room. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

k. That the contents of para no.k of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.1 use to neglect and insult

the complainant. It is specifically denied

that the complainant after getting off from

her office use to call the respondent no.1 so

that she could accompany him to the home.

It is specifically denied that the respondent

no.1 always used to say that he is busy in

the office work and cannot accompany with

her. It is specifically denied that the

respondent no.1 used to come to the house

at middle of the night after heavy drinking.

It is submitted that the true and correct

facts have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

l. That the contents of para no.l of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.2 & 3 used to sleep in the

complainant’s room whenever the

respondent no.1 had night shift, the reason

given by the respondents was that the AC’s

bill will be saved. It is specifically denied

that the complainant started that she is

comfortable with non-ac room however, the

respondent no.1 used to insist to sleep with

the respondent no.2 & 3. It is specifically

denied that there were many occasions

where the complainant used to find herself

in a very awkward situation. It is submitted

that the true and correct facts have already

been mentioned in the preliminary

objections and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.
m. That the contents of para no.m of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complaint heard the respondent no.2 stating

to the respondent no.1 that “Ek Bacha Paida

Karwa Do Tab Yeh Hath Mai Aa Jaegi”. It is

specifically denied that the respondent no.1

had entered into physical relationship with

the complainant. It is specifically denied

that to the height of surprise there were no

love and emotion during sexual intercourse.

It is specifically denied that the respondent

no.1 only did it that particular which is

required for pregnancy. It is submitted that

the true and correct facts have already been

mentioned in the preliminary objections and

the contents of the same may kindly be read

as part and parcel of the reply of para

under reply and the contents of the same

are not repeated herein for the sake of

brevity.
n. That the contents of para no.n of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant got pregnant in the month of

June, 2018. It is specifically denied that the

complainant had informed about the same

to her parents. It is specifically denied that

the respondent no.1 & 2 started to abuse

the complainant by saying that “pregnancy

humare yaha par teen mahine ke baad batai

jati hai”. It is specifically denied that the

respondent’s never use to take care of the

complainant health during the pregnancy

period and that to they never missed any

occasion to taunt and disgrace the

complainant even in front of the relatives. It

is specifically denied that during the

pregnancy the complainant had health

issues and had to climb two floors to reach

home and after coming back from work,

climbing the stairs was a vey difficult task

for her. It is specifically denied that the

 respondent no.3 used to dictate orders to

the complainant right after she use to enter

the home and whenever she requested for

some rest, they use to taunt and abuse her

by stating things like “Jaise pahad chadh

kar aai hai” “Tu pehli aurat bacha kar rahi

hai duniya ai” “Jara haath hila liya kar,

aise bahu ko log ghar se nikal dete hain ”. It

is submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

o. That the contents of para no.o of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant throughout the pregnancy had

to visit alone to the gynecologist. It is

specifically denied that on one day on

request of the complainant, the respondent

 no.1 agreed to go to the gynecologist along

with the complainant to the heights of the

surprise, the respondent no.2 came along

with them. It is specifically denied that

when the doctor called the complainant

inside the doctor room, the respondent no.1

completely refused stating that ” Mujhe ulti

ah jaegi” and when the complainant insisted

the respondent no.1 had abused the

complainant in front of everybody and the

respondent no.2 instigated was him . It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

p. That the contents of para no.p of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.2 used to tell the

complainants to ask her parents for money

and even grocery such as rice, pulses, ghee,

etc. and to keep everybody happy in the

matrimonial house. It is specifically denied

that the complainant’s parents use to fulfill

all of their demands. It is specifically

denied that the greed of the respondents

was not satisfied and the demands kept on

increasing. It is specifically denied that the

respondent no.3 use to continuously taunt

the complainant and use to compare her

with “Shreya”. It is specifically denied that

the respondent no.3 also told the

complainant to become like Shreya

(Daughter-in-law of his sister) who gets

gifts and foreign fruits for her in-laws. It is

specifically denied that on many instances

the respondent no.3 had given an example

of Brinda (daughter of his sister) who is

being tortured in her matrimonial house. It

is specifically denied that the respondent

no.2 told the complainant to become like

 Brinda who is following all the dictate of

her in-law. It is specifically denied that the

respondent no.3 also told the complainant

that “Bahu Ko Sab Kuch Jhelna Padtha Hai,

Sehna Padtha Hai, Aur Agar Meri Maa Zinda

Hoti Toh Tujhe Batati Ki Bahauo Ko Kaise

Rakha Jata Hai Hamare Ghar Mai”. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

q. That the contents of para no.q of the

Domestic Incident Report are wrong and

denied. It is specifically denied that in

June-July, 2018 the respondent no.3 was

talking to my father over call. It is

specifically denied that the respondent no.3

continuously taunted and also said that

“Apne Apni Bethi Ko Bass Padhai Karai Hai

Aur Kuch Nahi Shikhaya”. It is specifically

denied that in the month of June-July,

2018, the complainant had fruits cravings

during pregnancy therefore, she had

requested the respondent no.1 for the same.

It is specifically denied that in replied the

respondent no.1 told her that he does not

have money to fulfill her requests. It is

specifically denied that on the same time he

was drinking and eating non-veg. it is

specifically denied that the complainant

told the said instance to the respondent

no.2 and 3 expecting them to show some

care and affection, however, instead thereof

their reaction came as a surprise to the

complainant when they told the complainant

that the respondent no.2 did not even get to

see fruits during her pregnancy, its

completely okay if you won’t get some fruit.

It is submitted that the true and correct

facts have already been mentioned in the

preliminary objections and the contents of

 the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

r. That the contents of para no.r of the

Domestic Incident Report are wrong and

denied. It is specifically denied that during

the pregnancy the HBA2 level of the

complainant came positive in the test to

which the respondent no.2 told the

complainant that why did not she get this

tested before marriage. It is specifically

denied that she said “Humare Relative Mai

Kisi Ki Bahu Ka Yeh Test Positive Aaya Tha

Usko Unhone Ghar Se Nikal Diya Tha, Log

Toh Aisi Bahu Ko Ghar Se Nikal Dete Hain”.

It is submitted that the true and correct

facts have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

 the contents of the same are not repeated

herein for the sake of brevity.

s. That the contents of para no.s of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant was depressed due to

prevailing situations and thereof, had

requested the respondent no.1 for mental

supports, however, the respondent no.1

ignored all the concerns of the complainant

and created a huge fight over the said issue

in July, 2018. It is specifically denied that

the respondent no.1 again abused the

complainant with dirty languages and said

“Behanchod Tujhe Pata Nahin Hain Log

Bahuon Ko Kaise Rakhte Hain, Hum Toh

Bahut Acche Hain”. It is submitted that the

true and correct facts have already been

mentioned in the preliminary objections and

the contents of the same may kindly be read

as part and parcel of the reply of para

under reply and the contents of the same

 are not repeated herein for the sake of

brevity.

t. That the contents of para no.t of the

Domestic Incident Report are wrong and

denied. It is specifically denied that in such

said situation the complainant could hardly

talk to the respondent no.2 & 3. It is

specifically denied that in the end of July,

2018 the respondent no.1 dragged the

complainant from the car to the restaurant

at Gurgaon. It is specifically denied that at

that time the respondent no.1 got very

drunk and told the complainant that “Aisa

Nahi Chalega Tum Mere Papa Se Friendship

Karo … Unke Shoulder Per Haath Rakh Kar

Baat Kia Karo … Hug kia Karo … Jaise Main

Apni Maa ke Saath Karta Hu”. It is

specifically denied that the complainant

told the respondent no.1 that though “I

respect him but I cannot get intimate with

him to that extent”. It is specifically denied

that the complainant told the respondent

no.1 that the respondent no.3 used to sleep

in the complainant’s room and also use the

washroom with the doors open while she

was in room itself. It is specifically denied

that in response thereof, the respondent

no.1 could not take it and started abusing

the complainant he said “Waise Tu Bolti Hai

Pain Hota Hai … Khasi Aati Hai .. Ab Tujhe

Pain Nahi Ho Raha Hai… Khasi Nahi Ah

Rahi … Ab Bas Mujhe Tumse Divorce

Chaiye… Mai Tujse Divorce Lunga… Ab Bas

Bohot Ho Gaya.. Agar Tu Pregnant Nahi Hoti

Toh Mai Tujse Khai Mai Gira Kar Mar

Dalta…Bohot Jhasi Ki Rani Bane Ka Shock

Hai Na Tujhe.. Aj Mai Tera Kaam Tamam Kar

Deta Hu”. It is specifically denied that the

respondent no.1 dragged the complainant to

the car and started driving very negligently

and rashly. It is specifically denied that in

the car the respondent no.1 told her that

“Tujse Apne Aap Se Nahi Hota Ki Tu Apne

Pati Ko 20-30 Hazar De De … Ki Yeh Lo

 Gautam Yeh Rakh Lo”. It is specifically

denied that the complainant got very

frightened and agreed to abide by his

dictate. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

u. That the contents of para no.u of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondents during the complainant’s

pregnancy intentionally troubled her. It is

specifically denied that the respondents did

not keep any helper for the household work.

It is specifically denied that the

respondents used to order the food from

outside but just to trouble the complainant

they forced her to cook all the meals for

them during her pregnancy. It is specifically

 denied that the complainant had to

continuously visit the doctor during the

pregnancy and also had to get herself tested

on regular basis but the respondent no.1 on

regular basis refused to go along with her

for regular check-up nor allowed her to

perform the test which were prescribed by

the doctor. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

v. That the contents of para no.v of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.1 even denied spending any

penny on the medicine of the complainant.

It is specifically denied that being a

complicated pregnancy the monthly cost of

medicine was around Rs.10,000/- however,

 the complainant was getting Rs.5,000/- only

from the CGHS and the remaining medicines

she had to purchase it from her own. It is

specifically denied that the respondent no.1

had completely refused to bare/deal with

mental, physical & financial support of the

complainant even during the pregnancy. It

is specifically denied that the complainant

had herself afforded all the expenditures of

the pregnancy. It is submitted that the true

and correct facts have already been

mentioned in the preliminary objections and

the contents of the same may kindly be read

as part and parcel of the reply of para

under reply and the contents of the same

are not repeated herein for the sake of

brevity.

w. That the contents of para no.w of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant was in complete shock when

she came to know about the respondent no.1

 illicit relationship with other girls which

she had found out from the respondent no.1

phone’s photo gallery wherein, she found

him with other girls in a very uncomfortable

position. It is specifically denied that the

respondent no.1 admitted to that effect and

promised not to repeat in future. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

x. That the contents of para no.x of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant was a Lodhi Colony the

respondent no.1 had also threatened the

complainant that he will abscond to Dubai

and further told her that what would

happen to her because in this society

 divorcee and single mother is not accepted

and thereafter, the respondent no.1 started

scolding and abusing the complainant and

stated that “Humare Ghar Mai Aurate Bahar

Ja Kar Nahi Bolti Hai Kuch Bhi … Ghar Mai

Job Hi Hota Hai Who Ghar Mai Hi Rehta

Hain.. Tune Apne Ghar Mai Bhi Yeh Sab Kyu

Bataya, Wahin Aake Tujeh Thappad

Marunga”. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

y. That the contents of para no.y of the

Domestic Incident Report are wrong and

denied. It is specifically denied that on 21-

10-2018 the respondent came to Lodhi

Colony, the complainant came upfront and

told them about all complaints/ problems

related to them, to which they did not utter

a word neither they agreed to the complains

nor did they deny. It is specifically denied

that when the complainant told the

respondent no.2 that the respondent no.1

does not even sleep with her to which she

told her “Haan Kyu Soega Tere Sath… Ek

Bacha Aur Karna Hai Kya Tujhe”. It is

specifically denied that the complainant

further told her that the respondent no.2

goes out to watch movies with girls at late

night to which the respondent no.2 replied

“Haan Kyu Nahi Jaega Bahar Aur Ladkio Ke

Saath… Tu bhi Toh Apne Ghar Mai Ah Kar

Bethi Hui Hai”. It is specifically denied that

the respondent no.2 stated that “Jab Office

Me Mahual Kharab Hota Hai Toh Waha

Bardasht Kar Ke Reh Sakti Ho but Agar

Ghar Me Mahaul Kharab Hota Hai Toh Waha

Bardasht Kar Ke Nahi Reh Sakti”. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

 the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

z. That the contents of para no.z of the

Domestic Incident Report are wrong and

denied. It is specifically denied that after

the delivery of baby, the respondent no.1

insisted the complainant to take back at

matrimonial home. It is specifically denied

that the respondent no.1 further promised

the complainant that he would not do any

kind of physical or mental assault. It is

specifically denied that the complainant

trusting all his promises and for the

betterment & future of her child decided to

go back to the matrimonial house and came

at matrimonial home on 13-03-2019. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

 parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

aa. That the contents of para no.aa of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant after reaching back to the

matrimonial house came to know that on the

ground floor a woman namely Simmi Pahwa

was staying. It is specifically denied that

the complainant finds that there is

something wrong because Simmi Pahwa as

well as her kid would stay in their house

throughout the day and she has huge

influence on the respondent no.1 and 2 to

the height of surprise Simmi Pahwa used to

dictate the complainant. It is specifically

denied that the respondent no.2 would treat

Simmi Pahwa as family members while treat

the complainant like an outsider in her own

house. It is submitted that the true and

correct facts have already been mentioned

 in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

bb. That the contents of para no.bb of the

Domestic Incident Report are wrong and

denied. It is specifically denied that on the

occasion of Holi i.e. 21-03-2019, the Simmi

Pahwa had arranged a small get together at

her house where the respondents and family

of the respondent no.3’s sister were invited.

It is specifically denied that the

complainant was surprised looking at the

behaviour of the respondent no.1 towards

Simmi Pahwa. It is specifically denied that

the respondent no.1 and Simmi Pahwa were

playing Holi in an appropriate manner and

unusual manner like touching each other. It

is submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

 the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

cc. That the contents of para no.cc of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant also finds that Simmi Pahwa

used to call the respondent no.1 approx. 30-

40 times in a day to which the respondent

no.1 had answered few of the calls and most

of the calls were rejected by the respondent

no.1. It is specifically denied that the

complainant found out a mail from Simmi

Pahwa wherein it was written on the

occasion of the respondent no.1 birthday

that “Mujhe Pata Nahi Ki Cooking Karke

Time Tumhe Muj Me Kya Acha Laga … Mujhe

Tumhare Se Baat Karni Hai… Tumhare

Saath Time Spend Karna Bohot Acha Lagta

Hai… Mai Tumhara Birthday Apne Tareke Se

Celebrate Karna Chahti Thi… But Tumhe

 Pata Hai Ish Life Mai Yeh Possible Nahi

Hai”. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

dd. That the contents of para no.dd of the

Domestic Incident Report are wrong and

denied. It is specifically denied that on 26-

03-2019 the complainant became furious

and at the same movement woke up the

respondent no.1. It is specifically denied

that the complainant politely asked about

his and Simmi Pahwa relationship. It is

specifically denied that the complainant

also told him that she already knows about

everything but she could still give their

marriage a chance only if he tells her the

truth. It is specifically denied that the

marriage a chance, only if he tells her the

 truth. It is specifically denied that the

respondent no.1 accepted all his mistakes

and told everything to the complainant that

he is in relationship with her. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

ee. That the contents of para no.ee of the

Domestic Incident Report are wrong and

denied. It is specifically denied that very

next morning the complainant discussed

everything with the respondent no.2,

however, the reaction of the respondent

no.2 was very surprising for the

complainant. It is specifically denied that

the respondent no.2 told on the face of the

complainant that “Jab Mere Bete Ko Ghar Pe

Kuch Nahin Milega Toh Who Bahar Hi Toh

 Muh Marega”. It is specifically denied that

on the same day i.e. 27-03-2019 the

complainant’s family came to her

matrimonial house to resolve the problem. It

is specifically denied that the complainant’s

parents made all the efforts to explain the

respondent no.1 not to repeat the same

mistake again but unfortunately, the

respondent no.2 never wanted to resolve the

issues. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

ff. That the contents of para no.ff of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.2 and 3 already know about

the illicit relationship of the respondent

no.1 and in fact they used to support the

respondent no.1. It is specifically denied

that on 28-03-2019 the complainant

requested the respondent no.2 & 3 to call

Simmi Pahwa. It is specifically denied that

the complainant was surprised looking at

her behaviour with the respondent no.2. It

is specifically denied that Simmi Pahwa was

sitting with the respondent no.2 and her

elbows were on respondent no2. Shoulder. It

is specifically denied that their relationship

is very strong. It is specifically denied that

Simmi Pahwa refused everything about the

relationship before the complainant and on

the other hand the respondent no.2 & 3

made it look like completely complainants

fault. It is specifically denied that after

persistent effort of the complainant Simmi

Pahwa accepted that she is in relationship

with respondent no.1 and promised the

complainant that she would maintain

distance from the respondent no.1. It is

submitted that the true and correct facts

 have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

gg. That the contents of para no.gg of the

Domestic Incident Report are wrong and

denied. It is specifically denied that soon,

after the incident the respondent no.2 & 3

started to quarrel with the complainant on

small matters and would start abusing her.

It is specifically denied that after the

aforesaid incident the respondent no.2 & 3

started telling the complainant and the

respondent no1. To leave the house and to

go stay somewhere else. It is specifically

denied that the respondent no.1 in

frustration had packed all his bags and

asked the complainant to go to her parental

house wherein, the complainant refused

stating that “Yeh Log Aged Hai.. Kuch

 Urgency Hui Toh Koi Bhi Nahi Hoga Saath

mai… Aise Nahi Kar Sakte Hai Hum Log Inhe

Akele Chor Kar Nahi Ja Sakte Hai”. It is

specifically denied that the complainant was

always concern and worried about the

respondent no.2 & 3 health & wellbeing but

unfortunately, she was never accepted as a

daughter-in-law in the house. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

hh. That the contents of para no.hh of the

Domestic Incident Report are wrong and

denied. It is specifically denied that on the

other hand the complainant was never in

peace because of the unfortunate behaviour

of the respondent no.2 towards her. It is

specifically denied that the respondent no.2

had made the life of the complainant

miserable. It is specifically denied that the

respondent no.2 had tried all the means to

trouble the complainant in some or the

other manner. It is specifically denied that

the domestic servant that was called for the

complainant’s help was purposely always

kept occupied by the respondent no.2 so

that the complainant had to do everything

by herself. It is specifically denied that it

was an unfortunate situation for the

complainant because even after the delivery,

the respondent no.2 never gave the love and

affection to the complainant. It is

specifically denied that the complainant was

very weak after the delivery but the

respondents had never cared about their

health. It is specifically denied that the

complainant was never considered as part of

the family. It is specifically denied that the

respondent no.2 never wanted the

respondent no.1 to develop healthy

relationship with complainant therefore, she

would pin-point on pity issues to the

respondent no.1 against the complainant so,

that there was always a disputed

atmosphere around them. It is specifically

denied that the respondent no.2 had created

a huge fight in the house having left with no

other option the complainant’s parents &

sister had to come home to resolve the

problem. It is specifically denied that on 25-

07-2019 when the complainant’s sister was

making a point, the respondent no.3 stated

“Nikal Ja Yaha Se Behnchood, Tujhe Yaha

Kisne Bulaya Hai, Apni Behen Ko Bhi Le Ja

Yaha Se”. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

ii. That the contents of para no.ii of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant was treated worst then a

servant in the house. It is specifically

denied that the whole purpose of the

respondent no.2 was to let down the

reputation of the complainant in front of

servant, neighbours, relatives. It is

specifically denied that in the house they

had treated & respected the servants better

than the complainant. It is specifically

denied that the servants would get proper

food in comparison of the complainant. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

jj. That the contents of para no.jj of the

Domestic Incident Report are wrong and

denied. It is specifically denied that in the

month of August, 2019 on a trifle issue the

respondent no.3 grab the hand of the

complainant pushed and slapped her. It is

specifically denied that the respondent no.3

also abused the complainant by saying

Behanchod, chinar etc. It is specifically

denied that apart thereof the respondent

no.3 used to insult the complainant in front

of the relatives stating that the complainant

knows nothing and is a dumb & worthless

woman and that she can never satisfy

anyone of the family members. It is

specifically denied that again in last week of

august, the respondent no.3 at one occasion

had mishandled the complainant and had

also used slangs against her. It is submitted

that the true and correct facts have already

been mentioned in the preliminary

objections and the contents of the same may

 kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.

kk. That the contents of para no.kk of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondents have always had eyes over the

property of the complainant’s parents. It is

specifically denied that the respondent no.1

had always told her to sell the parental

house (Bareilly) and get him a shop and

further asked the complainant to put his

name in the property papers along with the

complainant. It is specifically denied that

the complainant had always refused/

neglected the said demand of the respondent

no.1 due to which a huge quarrel was

always created in the house. It is

specifically denied that the respondents

no.2 & 3 had always instigated the

respondent no.1. It is submitted that the

 true and correct facts have already been

mentioned in the preliminary objections and

the contents of the same may kindly be read

as part and parcel of the reply of para

under reply and the contents of the same

are not repeated herein for the sake of

brevity.

ll. That the contents of para no.ll of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.1 has always been an

irresponsible husband and father. It is

specifically denied that the respondent no.1

had never helped the complainant financial,

physical and mentally to raise the kid. It is

specifically denied that the respondent no.1

and 2 would avoid getting the kid

vaccinated. It is submitted that the true

and correct facts have already been

mentioned in the preliminary objections and

the contents of the same may kindly be read

as part and parcel of the reply of para

 under reply and the contents of the same

are not repeated herein for the sake of

brevity.

mm. That the contents of para no.mm of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant was under impression that

after the birth of baby the behaviour of the

respondent no1. Would change, however, no

such miracle had happened. It is

specifically denied that the respondent no.1

was very formal with the new born baby and

the complainant had never seen that the

respondent no.1 is pampering and loving the

baby as normal human being do so. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

nn. That the contents of para no.nn of the

Domestic Incident Report are wrong and

denied. It is specifically denied that at some

occasion, the respondent no.1 used to

brought daily needs items for the New Born

Baby, however, thereafter, whenever the

complainant asked for Daily Needs items of

Baby the respondent no.1 ignored and at

some occasion scold the complainant that I

am not your servant who supposed to do all

the stuff. It is specifically denied that the

complainant had to beg for the basic need

for the new born baby. It is specifically

denied that the complainant miserably

failed to understand the ulterior purpose

behind such violence and trauma. It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

 the contents of the same are not repeated

herein for the sake of brevity.

oo. That the contents of para no.oo of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.1 never used to make love

with the New Born and away used to run

away from the responsibility. It is

specifically denied that the complainant was

very surprised with the behaviour of the

respondent no.1. It is specifically denied

that the respondent no.1 never use to take

care of the child. It is specifically denied

that the respondent no.1 denied to get the

baby vaccine. It is submitted that the true

and correct facts have already been

mentioned in the preliminary objections and

the contents of the same may kindly be read

as part and parcel of the reply of para

under reply and the contents of the same

are not repeated herein for the sake of

brevity.
pp. That the contents of para no.pp of the

Domestic Incident Report are wrong and

denied. It is specifically denied that on 28-

02-2020 the complainant got injury in her

spine. It is specifically denied that one day

she was out of medicine and it was very late

therefore, she had requested the respondent

no.1 to get her the pain killer medicine as it

was a necessity. It is specifically denied

that the respondent no.1 did not took her

pain seriously, instead he told her that he

will place an order for the medicine vide

online because they were getting discount

on the said medicine. It is specifically

denied that the complainant was surprised

looking at his behaviour when she had

specifically told him that it was an urgent

requirement and she could not wait for the

medicine to arrive next week. It is

specifically denied that having left with no

other option she had requested her sister to

get her the medicine who had arranged the

 medicines from somewhere. It is submitted

that the true and correct facts have already

been mentioned in the preliminary

objections and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.

qq. That the contents of para no.qq of the

Domestic Incident Report are wrong and

denied. It is specifically denied that during

end of May, 2020 the respondent no.1 was

very drunk on one night and he had called

the complainant to the balcony. It is

specifically denied that the respondent no.1

told her that she needs to go back to her

home as she was not helping the respondent

no.1 financially. It is specifically denied

that the respondent no.1 could not keep her

in the house if she cannot contribute in the

house financially. It is specifically denied

that the complainant did not find it right to

 speak anything to the respondent no.1 on

that spot, therefore the complainant decided

to keep quiet however, the respondent no.1

without any occasion became furious

slapped and pushed the complainant

outside the house and had locked the door

from inside of the house. It is specifically

denied that the complainant kept on

requesting the respondents to let her in but

nobody came to help her nor did anybody

open the door till late night. It is submitted

that the true and correct facts have already

been mentioned in the preliminary

objections and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.

rr. That the contents of para no.rr of the

Domestic Incident Report are wrong and

denied. It is specifically denied that on 03-

06-2020, the situation got out of control

when the respondent no.1 started a huge

fight over the trifle issues. It is specifically

denied that the respondent no.1 started that

“Ghar Mai RO Kharab Hai Tu Teek Nahi

Karwa Sakti … Tere Ghar Walon Sagan Mai

Dete Hi Kya Hai, Jitna Tere Ghar Wale Dete

Hain Uthna Toh Hum … Apni Behn Ke

Naukaro Ko Sagan De Dete Hai … Tujhe

Saving Karni Hai Toh Behnchood Apne Ghar

Ja Ke Kar .. Yaha Par Kyu Reh Rahi Hai…

Behenchod Panauti Hain Tu … Meri Maa Ka

Right Hai Relatives Ko Batana Ki Unpe Kya

Hui Hai … Tujhe Baat Karni Nahin Aati

Isliye Hum Tujhe Relatives SE Nahin

Milatei”. It is specifically denied that the

respondent no.1 became more furious and

had started slapping the complainant. It is

specifically denied that the respondent no.2

and 3 did not even try to stop the

respondent no1. Instead they had locked

themselves inside the room It is specifically

denied that the respondent no.1 had

physically assaulted the complainant for

about more than an hour but nobody had

tried to save her. It is specifically denied

that the complainant called her parents and

even then the complainant’s parent had

tried to resolve the dispute between the

respondent no.1 and the complainant but

unfortunately nobody was ready to listen. It

is specifically denied that on that occasion

the respondent no.3 had abused the

complainant’s family and told them to get

out of his house. It is specifically denied

that the respondent no.3 told the

complainant’s parents that “Madharchod

Bhag Ja Yaha SE Nahi To Jaan Se Mar

Denge”. It is submitted that the true and

correct facts have already been mentioned

in the preliminary objections and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

ss. That the contents of para no.ss of the

Domestic Incident Report are wrong and

denied. It is specifically denied that on 03-

06-2020 the respondents have thrown the

complainant and her son from their house

during the COVID-19 lockdown period. It is

specifically denied that the complainant

having no other option left came to Lodhi

Colony with her baby. It is specifically

denied that the complainant and her parent

tried to reconcile the situation, however,

the respondent instead upon divorce. It is

specifically denied that the respondent by

one way or other threatening the

complainant to give divorce. It is submitted

that the true and correct facts have already

been mentioned in the preliminary

objections and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.
tt. That the contents of para no.tt of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

condition of the complainant has become

worse than an animal and has been forced

to lead a miserable life. It is specifically

denied that the complainant left in lurch by

the respondents It is specifically denied

that the complainant expressed her every

feeling of love and emotion however, the

respondent no.1 never turned up. It is

specifically denied that the respondent no.1

has started threatening the complainant to

give divorce or he will not let her live. It is

specifically denied that the respondent no.1

through various modes threatened the

complainant and asked her to give divorce

so that he could marry with the other girl.

It is specifically denied that on 01-11-2020

the respondent no.3 said “Chahein Mujeh

Kitne Paise Kharch Karne Pade Main In Logo

Ko Sabak Sikha Ke Rahunga”. It is

 submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

uu. That the contents of para no.uu of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondents may physically harm the

complainant and her child and may try to

eliminate her to achieve their ulterior

designs. It is specifically denied that there

is a security threat to the complainant and

her child, which is leading to huge mental

torture and insecurity to the complainant. It

is specifically denied that because of the

assault, cruelty, mental, physical, financial

and emotional torture on the hands of the

respondents, the complainant has been

suffering from mental trauma. It is

 submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

vv. That the contents of para no.vv of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

respondent no.1 has not only caused

physical injury to the complainant but all

the respondents also undermined the social,

economic, psychological and emotional well

being of the complainant. It is specifically

denied that the complainant has been

rendered destitute by the respondent no.1.

it is specifically denied that on account of

the domestic violence the complainant’s

health is deteriorating day by day and the

complainant is living under threat. It is

submitted that the true and correct facts

 have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

ww. That the contents of para no.ww of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant came to know that the

respondent are trying to sell the property of

the Gurgaon House No.3205, Second Floor,

Sector-57, Gurgaon, Haryana i.e. the shared

house hold of the complainant . It is

submitted that the true and correct facts

have already been mentioned in the

preliminary objections and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

xx. That the contents of para no.xx of the

Domestic Incident Report are wrong and

denied. It is specifically denied that the

complainant’s Diamond Ring and the Gold

Chain (given by the nani) are in possession

of the respondent and despite request the

respondent have not given the same.

It is specifically denied that apart

thereof, the furniture’s and Home

Appliances i.e. AC, Bed with Mattress,

Almira, Aashing Machine and Cloth stand

which were given by the parents of the

complainant to the complainant at the time

of marriage are still lying with the

respondent and despite request the

respondent not return the same. It is

specifically denied that the complainant

have the Video Footage, Audio Recording,

Emails, What’s app Message etc. and the

complainant seek leave of the court to file

the same at the time of evidence.

 It is specifically denied that succinctly

speaking the complainant is repeatedly

subjected to physical, mental and emotional

violence including repeated acts of physical

assault, incessant insults and tyrannies,

verbal abuse, harassment and deprivation of

physical, financial and personal resources

at the hand of all the respondents.

It is submitted that the true and correct

facts have already been mentioned in the

preliminary objections and the contents of the

same may kindly be read as part and parcel of

the reply of para under reply and the contents of

the same are not repeated herein for the sake of

brevity.

It is, therefore, prayed that the Domestic

Incident Report may kindly be dismissed with

heavy cost, in favour of the respondents and

against the complainant, in the interest of

justice.

Delhi RESPONDENTS
Dated:
 Through

(ANURAG SHARMA & GAURAV SRIVASTAVA)

ADVOCATE
M. 8920503527, 9811312468
E. Mail: [email protected]

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus

Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
 I, Gautam Sikka S/o Shri Ashok Sikka R/o
House No.3205, Second Floor, Sector- 57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 1 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g r ep ly h as b e en d ra f te d b y
my counsel u nd e r my in s tr u c tio n s a nd th e
c o n te n ts o f th e sa me a r e tr u e a nd c o r r e c t a nd th e
s a me may k in d ly b e r e ad as pa r t an d pa r c e l o f
th is af f id a v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus

Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
 I, Rekha Sikka W/o Shri Ashok Sikka R/o
House No.3205, Second Floor, Sector- 57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 2 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g r ep ly h as b e en d ra f te d b y
my counsel u nd e r my in s tr u c tio n s a nd th e
c o n te n ts o f th e sa me a r e tr u e a nd c o r r e c t a nd th e
s a me may k in d ly b e r e ad as pa r t an d pa r c e l o f
th is af f id a v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus

Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
 I, Ashok Sikka S/o Not Known R/o House
No.3205, Second Floor, Sector-57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 3 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g r ep ly h as b e en d ra f te d b y
my counsel u nd e r my in s tr u c tio n s a nd th e
c o n te n ts o f th e sa me a r e tr u e a nd c o r r e c t a nd th e
s a me may k in d ly b e r e ad as pa r t an d pa r c e l o f
th is af f id a v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus

Shri Gautam Sikka & Ors. …Respondents

D.O.H. 06.08.2022
REPLY ON BEHALF OF THE RESPONDENTS TO THE
APPLICATION UNDER SECTION 23 (2) OF
PROTECTION OF WOMEN FROM DOMESTIC
VIOLENCE ACT, 2008 FOR EX-PARTE INTERIM
ORDER FILED BY THE COMPLAINANT .
---------------------------

MOST RESPECTFULLY SHOWETH :-

PRELIMINARY OBJECTIONS:-

1. That the answering respondents have filed

t heir written statement alongwith the

prelim inary objections, the contents of the

prelim inary objections may be read as the part

and parcel of the prelimina ry objections to the

reply of the applicat ion the same have not

been reproduced here for the sake of brevity.

REPLY ON MERITS:-

1. That the contents of para no.1 of the

application are matter of record, need no

reply.

2. That the contents of para no.2 of the

applicat ion, needs no reply, it is the matter of

record. However, it is submitted that the

 answer ing respondents have filed their written

statement alongwith the prelim inary

objections, the contents of the written

statement may be read as the part and parcel

of the reply to the applicat ion, the same have

not been reproduced here for the sake of

brevity.

3. That the contents of para no.3 of the

application are wrong and denied. It is

specifically denied that the complainant was

leading a standard life at her matrimonial

home before marriage. It is specifically

denied that the respondents are also rich

people and own various moveable and

immovable properties and bank balances. It

is specifically denied that the respondent

no.1 and his family members are man of

means. It is submitted that the true and

correct facts have already been mentioned

in the written statement and the contents of

the same may kindly be read as part and

 parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

4. That the contents of para no.4 of the

application are wrong and denied. It is

specifically denied that the respondent no.1

is working at Indigo Airlines and to the best

knowledge of the complainant the last have

annual income of Rs.15,00,000/- per

annum. It is specifically denied that inspite

of having very high yearly income of the

respondent no.1 the complainant was

performed to lead a miserable life. It is

submitted that the true and correct facts

have already been mentioned in the written

statement and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.
5. That the contents of para no.5 of the

application are wrong and denied. It is

specifically denied that the respondents had

committed various acts of Domestic Violence

and cruelty upon the complainant and that

further have not maintaining the

complainant and the child and made their

life miserable. It is submitted that the true

and correct facts have already been

mentioned in the written statement and the

contents of the same may kindly be read as

part and parcel of the reply of para under

reply and the contents of the same are not

repeated herein for the sake of brevity.

6. That the contents of para no.6 of the

application are wrong and denied. It is

specifically denied that the respondent no.1

continues threatening the complainant and

asking for divorce and if she denies the will

ruin her life. It is specifically denied that

the threat is imminent and constant. It is

 submitted that the true and correct facts

have already been mentioned in the written

statement and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.

7. That the contents of para no.7 of the

application are wrong and denied. It is

specifically denied that the complainant

requires Rs.50,000/- per month for

maintenance of herself and the new born

child. It is submitted that the true and

correct facts have already been mentioned

in the written statement and the contents of

the same may kindly be read as part and

parcel of the reply of para under reply and

the contents of the same are not repeated

herein for the sake of brevity.

8. That the contents of para no.8 of the

application are wrong and denied. It is

 specifically denied that the application is

bonafide and in the interest of justice. It is

submitted that the true and correct facts

have already been mentioned in the written

statement and the contents of the same may

kindly be read as part and parcel of the

reply of para under reply and the contents

of the same are not repeated herein for the

sake of brevity.

The prayer clause of the application is

wrong and denied. It is submitted that the

complainant has not come to this Hon’ble Court

with clean hands and have suppressed all true

and material facts before this Hon’ble Court,

who is liable to be prosecuted and is not

entitled for any relief.

It is, therefore, prayed that the present

application may kindly be dismissed with heavy

cost, in favour of the respondents and against

the complainant, in the interest of justice.

Delhi RESPONDENTS
Dated:

Through

(ANURAG SHARMA & GAURAV SRIVASTAVA)

ADVOCATE
M. 8920503527, 9811312468
E. Mail: [email protected]

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus

Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
 I, Gautam Sikka S/o Shri Ashok Sikka R/o
House No.3205, Second Floor, Sector- 57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 1 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g r ep ly h as b e en d ra f te d b y
my counsel u nd e r my in s tr u c tio n s a nd th e
c o n te n ts o f th e sa me a r e tr u e a nd c o r r e c t a nd th e
s a me may k in d ly b e r e ad as pa r t an d pa r c e l o f
th is af f id a v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus

Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
 I, Rekha Sikka W/o Shri Ashok Sikka R/o
House No.3205, Second Floor, Sector- 57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 2 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g r ep ly h as b e en d ra f te d b y
my counsel u nd e r my in s tr u c tio n s a nd th e
c o n te n ts o f th e sa me a r e tr u e a nd c o r r e c t a nd th e
s a me may k in d ly b e r e ad as pa r t an d pa r c e l o f
th is af f id a v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT

IN THE COURT OF SH. SANGHMITRA, LD. M.M.,

DISTT. SOUTH EAST, SAKET COURTS, NEW DELHI

IN RE:- COMPLAINT CASE NO. 457 OF 2021

IN THE MATTER OF :-
Smt. Nidhi Juneja …Complainant

Versus

Shri Gautam Sikka & Ors. …Respondents

AFFIDAVIT
 I, Ashok Sikka S/o Not Known R/o House
No.3205, Second Floor, Sector-57, Gurgaon,
Haryana , d o h e r eb y s o le mn ly a f f ir m a nd d e c la r e a s
u nd e r : -
1. T ha t I a m th e r e sp o nd e n t no . 3 in th e a bo v e no te d
c a s e a nd b e ing f u lly c on v e r s an t with th e f a c ts o f
th e c a s e an d is ab le to s we a r th is a f f ida v it.
2. T ha t th e a c c o mpa ny in g r ep ly h as b e en d ra f te d b y
my counsel u nd e r my in s tr u c tio n s a nd th e
c o n te n ts o f th e sa me a r e tr u e a nd c o r r e c t a nd th e
s a me may k in d ly b e r e ad as pa r t an d pa r c e l o f
th is af f id a v it.

DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of A u g u s t ,
2 0 2 2 , that the contents of the above said affidavit
are true and correct to my knowledge and nothing
material has been concealed therefrom.

DEPONENT