written statement in matrimonial suit

 

 

 

District: North 24 parganas

IN     THE    COURT    OF    THE    LEARNED   DISTRICT   JUDGE     AT    BARASAT

 

                                              Matrimonial suit no.   849  of  2014     

                                                               

                                             Smt. Aditi Sarkar(Roy)

                                            

                                                                    ……………. Petitioner/wife

 

                                                   -Versus-

 

                                             Sri Provas Roy                                                                                                                                              

                                                                   ……………. Respondent/Husband

                                                         

                                                                                                            

WRITTEN STATEMENT ON BEHALF OF THE RESPONDENT/HUSBAND ABOVE NAMED

                                                                        

Most Respectfully Sheweth:-

1.                 That the suit is not maintainable either in law or in facts.

 

2.                 That the suit is false, frivolous, concocted and malafide one.

 

3.                 That saves and except of the statement admitted herein rest of the statements are denied in toto.

 

4.                 That the statements made in Paragraph No. 1 of the Plaint are matter of record.

 

5.                 That the statements made in Paragraph No. 2 of the Plaint is false and as such denied. It is denied that the Respondent refused to live with the petitioner as husband and wife but it is true that the marriage was not consummated due to petitioner’s bad adamentation.

 

 

 

 

6.                 That the statements made in Paragraph No. 3 of the Plaint is false and as such denied. It is denied that the Respondent blamed to the petitioner for her adamant policy but it is true that the petitioner never do her work as a housewife and she always show her non-adjustment mentality.

 

7.                 That the statements made in Paragraph No. 4 of the Plaint is totally false and as such denied. It is denied that the Respondent deliberately has been unwilling to live as husband of the petitioner whereas the Petitioner left her matrimonial house without any reason and never came back.

 

8.                 That the statements made in Paragraph No. 5 and 6 of the Plaint is false and as such denied. It is denied that the Respondent relatives never tried to compromise and solve the matter whereas when the Respondent relatives tried to solve the matter your Petitioner refuse that with filthy language.

 

                                                   It is prayed that your Honour would graciously

                                                   be pleased to allow your Petitioner’s pray as

                                                   per her plaint and the marriage between the

                                                   parties be sat-aside or annulled by a decree of

                                                   nullity or pass such other order/orders as your

                                                   Honour may deem fit and proper for the ends

                                                   of justice.     

 

And for this act of kindness, as your petitioner in duty bound, shall over pray.

 

 

 

                                                              VERIFICATION

I, Sri Provas Roy the Respondent/ husband do hereby declare that the statements made in the foregoing paragraphs are true to my knowledge and belief and I sign this verification this the              day of              , 2014.

 

 

                                                      

                                                                        

 

 

 

 

                                                         AFFIDAVIT

 

      I, Sri Provas Roy son of late Kalipada Roy, aged about     years, by faith- Hindu, by occupation- Service, residing at Narikeltala, P.O.& P.S. Hingalganj,  District- North 24 Parganas ,Pin-743435, do hereby solemnly affirm and declare as follows :-

                                    

 

1.     That I am the Respondent/ husband of this suit and am well conversant with the facts and circumstances of this case.

                                                           

                                                       This is true to my knowledge.

 

2.     That the statements made in the foregoing paragraphs nos. 1 to 8 are all true to my knowledge and belief and the rest thereof are my humble submission before this learned Court.

 

 

 

                                                                  -----------------------------

                                                                           DEPONENT

                                                               Read over, explained in Bengali

                                                               and Identified by me.

 

 

                                                                               Advocate