written statment

IN THE COURT OF CIVIL/FAMILY JUDGE & JUDICIAL MAGISTRATE-VII HYDERABAD
Family Suit No. 18 of 2007


MST. AISHA        -----------------------             Plaintiff

Versus

MUHAMMAD SUHAIL    ------------------              Defendant



WRITTEN STATEMENT.
        The plaintiff above named very respectfully begs to submit his written statement as under:-
        That, contents of Para-1 of the suit are admitted.
        That, contents of Para-2 of the suit are denied. It is submitted dower amount has been paid by the defendant on first night of marriage on demand by the plaintiff.
        That, contents of Para-3 of the suit are  denied being false and concocted. It is submitted that plaintiff was given very nominal dowry articles worth Rs.50,000/- and at the time of leaving the house of defendant, the plaintiff has taken away all the gold ornaments and valuable clothes including gold ornaments and valuable clothes given by the side of defendant worth Rs.30,000/-. It is also denied that Television, Deep-Freezer and Washing Machine were given to the plaintiff in dowry, but only bad room set was given to her which is lying in the house of defendant.
        That, contents of Para-4 of the suit are denied in toto. It is submitted defendant has an adequate source of income and he properly maintained the plaintiff in all respects within his means, but it is the plaintiff who proved herself a disobedient, unfaithful and unwilling wife as she used to leave the house of defendant in his absent without prior permission always stayed in the house of her parents several days and being a loving husband defendant bear her such attitude.
        That, contents of Para-5 of the suit are false, fabricated, concocted and baseless hence denied vehemently. On the contrary it is the defendant who tolerate the attitude of the plaintiff being loving husband but plaintiff did not care.
        That, contents of Para-6 of the suit are denied vehemently being false and concocted. It is submitted that plaintiff was a disobedient and unwilling wife and on several occasions he left the house of defendant without his prior permission and used to stay in the house of her parents for couple of days but on 26-2-2007 she left the house of defendant in his absent without his prior permission and taken away all the gold ornaments and valuable clothes including the gold ornaments and clothes given by the side of defendant and since then she is residing in the house of her parents. The defendant number of times approached himself and through the elders of the family to resolve the matter amicably and to bring the plaintiff to his home, but due to the ill behaviour of the plaintiff and her disinterest the matter has not been resolved.
        That, contents of Para-7 of the suit are false, fabricated and concocted as such denied vehemently.  It is further submitted that plaintiff is residing in the house of her parents without any cause and reason and without prior permission of the defendant, despite several approaches made by the defendant and his elders she did not turn up to the house of defendant. However during her stay with the defendant she was properly maintained by the defendant in all respects.
        That, contents of Para-8 of the suit are groundless and baseless hence denied vehemently. It is further submitted that in this para plaintiff has not defined clearly that what kind of cruelty and maltreatment has been committed by the defendant and this para does not prove any cruelty, misbehave, maltreatment and non-maintenance,