IN THE COURT OF MRS.

CHARU AGGARWAL, JUDGE FAMILY

COURTS, WEST DISTRICT, TIS HAZARI COURTS, DELHI

PRELIMINARY OBJECTION

1. That the present petition filed by the petitioner is frivolous vexations

and false and has been filed just to cause immense harassment to the

respondent.

2. That there is no cause of action for filing the present petition which is

self evident from the averments made in the petition

3. That the petition filed by the petitioner is nothing but the same has

been filed to pressurize the respondent so as to agree to the whims

and fancies of the petitioner.

4. That it is evident from petition that the same is uncalled for and is

without any basis, therefore the same deserves to be dismissed with

heavy cost.

Reply on Merits

1. That the contents of the para 1 is admitted in toto

2. That the contents of the para 2 is admitted to the extent that as result
of the marriage , a female child, serene gill, was born on 30th july 2018.

that since the birth of , a female child serene gill the petitioner and

respondent no. 1 have acted as parents to her but it is wrong and

vehemently denied that the petitioner share any responsibility towards her

female child.

3. That the contents of the para 3 are admitted and needs no reply.

4. That the content of the para no. 4 is wrong and vehemently denied

that the family member of the petitioner had never caused any kind of

hindrance, obstruction, interference in the matrimonial life of the

petitioner and the respondent at any point of time and had always given

the congenial and favorable environment to the respondent for

establishing the happy and prosperous matrimonial life rather the

petitioner never behaved in right way, used to be very abusive if things

never use to go his way, never respected my parents as he used to abuse

my mother all the time and when he was in Australia he made a video call

on whatsapp to talk to gigi beyond his legal right late in the end while

drinking and started abusing me and my mother on the call and then we

have to disconnect the same. Always had been abusive and aggressive

filthy language towards the respondent no.1 , he is also addictive drinker ,

his family always pressurized or indirect taunting that we want male child
in our family otherwise

5. That the content of the para no. 5 is admitted to the extent that as

result that in the year 2018 the petitioner & respondent no. 1 was residing

in DUBAI- UAE. That the petitioner was working with Belhasa project

LLC-Dubai at Dubai, UAE and in the month of January 2018 and the all

the expenses relating to the delivery of the minor child were solely borne

by the petitioner is the matter of record and needs to be prove in trial. It is

further submitted that on 6th December 2017 went to gynecologist for the

confirmation of pregnancy did all the test and got the confirmation and

inform everyone in my family and petitioner family and than in January

or December we flew back to Dubai for the same and my parents sent the

money for the expenses of the delivery as petitioner did not have any

money to pay for thew hospital bill as insurance company did not cover

all the cost of the treatment as i had a C section and the mother of

respondent no. 1 came to Dubai on her own expenses and the petitioner

did not paid anything for her.

6. That the content of the para no.6 is the matter of record and in starting

while residing in Doha the respondent no.1 used to be in the same room

but of petitioner’s abusive behaviour and alcoholic habits the respondent

no. 1 had to do different room as the petitioner has no help for her child
not during the day or night and the petitioner used to go clubbing and

partying with his male and female friends and used to have extra maritial

affair with numerous girls in Doha as well as in Dubai with all of that the

respondent no.1 have proof which will be attached with the same.

7. That the content of the para no. 7 is wrong and vehemently denied

that the respondent no. 1 took the minor daughter and decided to leave the

petitioner on the basis of meeting family in India, left the matrimonial

home at Doha Qatar and came back to India and started residing with her

parents at the address mentioned in the array of parties. That the

respondent no.1 left Doha because petitioner gave beatings to respondent

no.1 and torn her clothes on 6th June 6:00 am in the morning as the

petitioner was drinkimg all night with his friends and come in the

morning and started abusing and beating the respondent no.1 while she

was crying and taking care of her daughter and for the proof the

respondent no.1 have that piece of clothes with her which the respondent

no.1 can present in the court and that day still horrifies my client as my

client had to run. in the morning to get the help from her friends to take

her away from the petitioner as the petitioner was so dangerous that the

respondent no.1 was sacred for her and her daughter’s life. Therafter , the

petitioner on the various occasions, requested the respondent no. 1 to join

the company of the petitioner but respondent no.1 did not pay any heed
towards the requests of the petitioner

8. That the content of the para no. 8 is wrong and vehemently denied and

due to all that the respondent no.1 have been suffering in this marriage

and the last incident that the respondent no.1 decided to come back to her

parents house and made decision of taking divorce with the petitioner

that’s why the respondent no.1 stopped any contact with the petitioner.

9. That the content of the para no. 9 is wrong and vehemently denied

that respondent no.1 had malafide intention rather the petition itself

beaten or abuse respondent no. 1 on daily basis.

10. That the content of the para no. 10 is wrong and vehemently denied

that since the petitioner and respondent no.1 had not carried out their

matrimonial life together peacefully due to temperamental differences

despite efforts for reunion made by the relatives and well-wishers of their

respective families. That the respondent no. 1 had to make a settlement

for the amicable divorce as the resopndent no.1 never got any help from

the petitioner and his family as the respindent no.1 informed multiple

times to the petitioner’s mother and father about their issues but they kept

on ignoring and took side of the petitioner so the respondent no. 1 had no

help or support on this part. That the content of the para no.10 is admitted
to the extent that the petitioner and respondent no.1 entered into an MOU

dated 02.01.2020 for amicably settling their disputes on the various terms

and conditions,as mentioned in MOU dated 02.01.2020. it is further

submitted that vide said MOU, it was mutually decided and agreed that

the petitioner and respondent no.1 will obtain divorce by mutual consent

by filling petitions U/s 13(B)(1) and 13(B)(2)od HMA,1955.

11. That the content of the para no. 11 are admitted and needs no reply.

12. That the content of the para no. 12 are admitted and needs no reply.

13. That the content of the para no. 13 is wrong and vehemently denied

that during visitations with the minor daughter, the petitioner observed

that she exhibited sign for weight gain and began wearing eyeglasses.

That their daughter started gaining weight gradually which the respondent

no.1 was unable to understand and she consulted her family doctor that

her child is perfectly fine. Consequently, that the content of the para no.13

is wrong and vehemently denied that the petitioner verbally and via email

communications several times requested the respondent no. 1 to arrange

for a medical consultation with a pediatrician for the minor daughter.

however, the respondent no.1 failed to address the legitimate request

made by the petitioner. That the respondent no.1 informed the petitioner
several times which the petitioner never acknowledge and the petitioner

never initiated to take serene (female child) to any pediatrics or any

general practitioner for the same always asking the respondent no.1 to do

the same wherein being a mother the respondent no.1 always use to take

care of her child’s health and nutrition.

14. That the content of the para no. 14 is wrong and vehemently denied

and needs no reply.

15. That the content of the para no. 15 is wrong and vehemently denied

that it is pertinent to highlight herein that since March 2022, the

respondent have denied the petitioner to meet the minor daughter twice in

a week under the guise of the school schedule of the minor daughter. it is

submitted that subsequently, when the petitioner requested compensation

for these missed visitation days and proposed that the minor daughter be

made available during school holidays , the respondent out rightly

rejected the petitioner’s suggestion. That the daughter’s school which is

from Monday to Friday from 9am till 1pm and after school her dance

classes and colouring classes are schedule, as mentioned in the visitation

rights the petitioner was not allowed to take their daughter to his house

but he used to take her to his house and threaten the respondent no.1 by

saying that the petitioner will take their daughter away from the
respondent no.1 due to that pressure the petitioner used to take their

daughter with him to his house and took undue advantage of respondent

no.1 .

16. That the content of the para no. 16 is wrong and vehemently denied

that in the month of December 2023, during discussions between the

petitioner and respondent no.1 regarding the school admission of the

minor daughter, the respondent no.1 informed the petitioner that she is

unable to get admission of type minor daughter in a prominent / best

school , upon which, the petitioner, being a loving and caring father, took

the said responsibility of school admission upon his shoulder, despite the

agreed terms of MOU dated 02.01.2020 that the petitioner shall not incur

any expenses toward the minor daughter. It is submitted that on

26.12.2023 , the petitioner got admitted his minor daughter in first class

Venkateshwar International School and incurred an amount of Rs 59,148/-

towards the expenses pertaining to the school fees, admission fees,

transportations etc. that the respondent no.1 submitted that the daughter

gave couple of interviews in various schools and thereafter got admission

in GD Goenka, Dwarka but because of petitioners immense pressure thst

the respondent no.1 withdrawn her daughter’s admission from GD

Goenka and afterwards the petitioner forcefully got her admission in

Venkateshwar International School and paid the fees which the petitioner
took from the respondent no.1 and since then the respondent no.1 have

been taking care of her daughter’s fees, daily/monthly expenses to which

the petitioners has no contribution for the same.

17. That the content of the para no. 17 is wrong and vehemently denied

that it is pertinent to note that prior to the admission of the minor

daughter into the school,respondent no.1 regularly communicated with

the petitioner via phone calls and WhatsApp, albeit solely concerning

matters related to the school admission process. That the respondent no.1

submitted that the petitioner use to forcefully contact to respondent no.1

and tried to communicate without any reason which the respondent no.1

never wanted to communicate with the petitioner. It is also wrong

suggested that surprisingly, after completion of the formalities regarding

the admission of the minor daughter, respondent no.1 ceased responding

to the petitioner’s WhatsApp messages or text messages whenever

inquires were made regarding the whereabouts or well-beings of the

minor daughter. That the respondent no.1 also submitted that the

petitioner used to threaten the respondent no.1 to reply to his emails and

messages in which the petitioner stated that he had paid for everything

which he never did.

18. That the content of the para no. 18 is wrong and vehemently denied
that on 20.04.2024, during a visitation of the minor daughter to the

petitioner’s residence, she communicated to the petitioner that “mummy

pata nahi kaha chali gayi hai,ghar nahi aati”. That the respondent no.1

submitted that the respondent no.1 went to meet her brother, and

respondent no.1 informed her daughter about the same. the petitioner used

to force their daughter to say things like this as he used to talk negatively

about respondent no.1 about which the daughter used to inform

respondent no.1 .

19. That the content of the para no. 19 is wrong and vehemently denied

that on 22.04.2024 during a videocall between the petitioner and his minor

daughter, the daughter was showing her school activity to petitioner in

which the class teacher has asked all the students to put picture of their

parents on the notebook but petitioner was shocked to see the picture

provided to the minor daughter had her mother,uncle, aunt , grandmother

(nani),grand father (nanu) and her. daughter told over the video call that

grandmother told your father is a bad person and his photo is not required.

which shows a clear propaganda to fill the minors daughter’s heart with

negative aspects against father and toxic environment for up bring of a

minor child of tender age. that the respondent no.1 submitted that in this it

was just a scrab book that respondent no.1 used to have at home and put

the photo of their family and showed the petitioner which the petitioner
made a point against the respondent no.1 and the respondent no.2 and his

wife that they are feeding their daughter with bad things. That the

respondent no.1 being a mother or her parents have never bad mouthed

about the petitioner because the respondent no.1 never wanted to raise

their daughter with negativity and instead the petitioner and his mother

and father used to bad mouth about the respondent no.1 and respondent

no.2 and his wife which the petitioner never raised voice against it.

20. That the content of the para no. 20 is wrong and vehemently denied

that on 23.04.2024, during a video call between the petitioner and his

minor daughter, the daughter displayed evident signs of distress and was

crying and deeply upset rather the petitioner father itself making false,

frivolous and concocted story neither daughter express anything nor she

told that she was upset otherwise she was always got disturbed by the

petitioner when he make random call on inaccurate time. It is also denied

that upon inquiry by the petitioner with the minor daughter regarding the

cause of her distress, the minor daughter expressed a reluctance to engage

in conversation, stating “ mujhe kisi se baat nahi karni hai” before

abruptly terminating the video call rather petitioner itself marked these

false and frivolous statements not her minor daughter. it is also wrong and

vehemently denied that upon observing this concerning behavior, the

petitioner promptly reached out to respondent no. 1 via whatsapp text

message inquiring about the minor daughter’s condition with message

“ why gigi’s mood so upset? Anything happened in the school?”. it is also

denied that the respondent failed to acknowledge or respond to the

aforementioned message of the petitioner. that the respondent not replied

to him because petitioner kept forcing the respondent on call that he will

took her daughter out for his place of residence. that the respondent no.1

submitted that her daughter is a kid and she was very tired that day and

didn't wanted to talk to the petitioner as the respondent no.1 told her

daughter to talk to the petitioner but the daughter said she don’t want to

right now and will talk later as she was very tired from school and just

wanted to relax but the petitioner as usual wants to make an issue out of it

the repondent no.1 told the petitioner the same but the petitioner has to

make his own assumptions for it.

21. That the content of the para no. 21 is wrong and vehemently denied

that on 01.05.2024, a bomb threat incident occurred in schools across

Delhi/NCR. It is also wrongly submitted that the petitioner being concern

for the safety of the minor daughter, the petitioner reached out to the

respondent no.1 via WhatsApp to inquire about the where abouts of the

minor daughter. it is submitted that despite reading the same message of

the petitioner , the respondent no,1 shockingly did not respond towards

the said message, which clearly demonstrated a callous and negligent

attitude of theb respondent no.1 towards the minor daughter, it is

submitted that left with no other alternative, the petitioner promptly

contacted the respondent no.2 and after knowing that the minor daughter

from the school and further proposed the respondent no.2 in case he was

not in a position to bring the minor daughter from the school, then

petition can personally receive the minor daughter from school due to the

alaraming news regarding the bomb threat circulating on various news

channel. That the respondent no.1 submitted that on that day the

respondent no.1 were very well informed about the news and the

respondent no.1 was busy coordinating with her parents and school and

the respondent no.2 took the whole responsibility and replied to the

petitioner for the same.

22. That the content of the para no.22 is wrong and vehemently denied

that the respondent no.1 submitted that DURING PTM class teacher said

that their daughter is an active child and a very bright one just to put her

more activities. The teacher was not aware, respondent no.1 parents did

inform the teacher about their daughter extracurricular activities and

regular visits and cycling to the park which the petitioner is very well

informed of respondent no.1’s parents and the respondent no.1 did

inform the teacher about the absence of respondent no.1, for the

respondent no.1 don't know why the petitioner is trying to take undue
advantage of this time. and in the school paper, it is mentioned that the

respondent no.1 is the legal guardian and the petitioner has no right to

attend such activities at school. the petitioner forces respondent no.1&2

and his wife and intentionally comes to school to attend the same and

tries to show people that the petitioner is being an active parent which the

petitioner is not and even the petitioner called serenes class teacher

multiple times and forced the teacher to add the petitioner in the school

WhatsApp group.

23. That the content of the para no.23 is wrong and vehemently denied

that it is notable that respondent no.2 i.e. the father of respondent

no.1 ,typically spend the entire day spend outside the house with his

friends, returning home only for eating and sleeping. additionally

respondent no.1, being a working women, engaged in night shift ,

resulting in day time sleeping, further more, the mother of respondent

no.1 is old aged ailing lady. it is also wrongly submitted that given this

familial dynamic of the respondents , it is evident that none of the

respondent ,within the residence are adequately positioned to provide

proper care and oversight of the upbringing and education of the minor

daughter. this lack of supervision and attention will significantly hamper

the minor daughter’s physical and mental development. the respondent

no.1 is submitted that the respondent no.2 is retired and stays at home but
what the petitioner wrote is entirely not evitable enough for the reasoning

and has the respondent no. 2 fixed income coming from his rental income

and the respondent no.2 does take care of our agricultural land which the

respondent no.2 gets his regular amount as well and for the respondent

no.2’s wife, she owns an apartment which she gets a regular income from

there as well and for the respondent no.1 have been working since the

respondent no.1 landed in india in 2019 and have been taking care of their

daughter's expenses since than respondent no.1 have enough savings to

prove that they being a whole family is very much capable enough to take

care of their daughters overall well being and all her holistic care as well.

24. That the content of the para no.24 is wrong and vehemently denied

that it is pertinent to mention herein that during video calls and meetings

with the minor daughter specifically after aforesaid parents teacher

meeting of the minor daughter, it came into the knowledge of the

petitioner from his reliable sources that the respondent no.1 is presently

not residing with the minor daughter and has handed over the custody of

the minor daughter completely to her old aged ailing parents.

25. That the content of the para no.25 is wrong and vehemently denied

that vide MOU dated 02.01.2020, the petitioner had given the custody of

the minor daughter to the respondent no.1 only, but since the respondent
no.1 is not residing with the minor daughter which is gravely causing

distress to the mental and physical health to the minor daughter. that the

content of the para no.25 is the matter of trial.

26. That the content of the para no. 26 is wrong and vehemently denied

that it is pertinent to mention herein that the respondent during the stay of

the respondent no.1 with the petitioner , she never showed any respect

towards petitioner’s family and used foul language and always used to

talk in an aggresive tone with them.it is submitted that respondent no.1

had further mischievously with ulterior motives always tried to create a

situation at home where the environment became hostile. further the

respondent no.1 has created a narrative/illusion in the mind of the minor

daughter that everyone in petitioner’s family is bad for her. That the

respondent no.1 submitted that this is not true as the respondent no.1

have been trying her best to maintain a cordial relationship with the

petitioner and his family but being so conservative and demeaning people

and takes the petitioner’s side even the petitioner was so unfaithful,

abusive and alcoholic and there are many incidents that the respondent

no.1 can share the petitioner and his whole family has mistreated the

respondent no.1 and neglected the respondent no.1 and always forced the

respondent no.1 to do things and also force the respondent no.1 for male

child.
27. That the content of the para no. 27 is wrong and vehemently denied

that the petitioner, on various occasions, asked the respondent no.1 for

arranging video calls, visitations with the minor daughter and about the

health conditions of the minor daughter, however, most of the times, the

respondent no.1 never replied and avoided the petitioner in order to

deprive him from the love and whereabouts of the minor daughter. that

the respondent no.1 submitted that all these allegations are totally wrong

and base less as these dates and timing are during covid times and its was

lock down and the respondent no.1& 2 and his wife were scared to leave

the house and for the respondent no.1 and her daughter’s safety is top

priority and by showing these dates the petitioner has shown that he was

not worried about serene health the petitioner just wanted to prove and

forces respondent no.1&2 and his wife to do things the way the petitioner

wants and his queries has always been answered by the respondent no.2 at

all times.

28. That the content of the para no. 28 is wrong and vehemently denied

that the petitioner whereas meets the minor daughter, had provided her

dresses,gifts, toys, electronic gadgets etc., which shows how the

petitioner is attached to his minor daughter and is a caring and loving

father, rather it is submitted that petitioner is an addictive drinker and

abusive person, he always while on phone call says derogatory statements

to the respondent no. 1 and kept telling to her that “ mae tumhari beti ko

lekar jaunga tumse dur bhot jald fir dekhna tum”. it is also wrong

and denied that the petitioner is capable of and is willing to provide to his

minor child the best parenting for the best interest and welfare of the

child if the petitioner is given the custody of the daughter. It is submitted

that the respondent No. 1 and her family is well capable for taking care of

her child since after separation but the petitioner always try to make her

life full of trouble by doing foolish act like by taking daughter at his place

and not dropping her on time even not attending calls while daughter with

him, also put all bad and against statement in mind of the minor daughter

“ nanu apko bhot dattae hai na or nani bhi or mummy unhae kuch kehti

bhi nhi”. that the respondent no.1 submitted that by showing such bills

and statements doesn't prove what the petitioner is capable of the

respondent no.1 have thousands of bills and receipts of expenses that the

respondent no.1 have been taking care of thier daughter and how much

the respondent no.1 love their daughter with thousands of photos in her

phone which the respondent no.1 can also attach and present as well. and

which will also prove that the respondent no.1 being the legal guardian

and single mother can take care of their daughter over all well being.

29. That the content of the para no. 29 is wrong and vehemently denied
that this is an established of fact that the child should be allowed to grow

in an atmosphere with the customs of his family i.e. as per the family

traditions of an Indian family, which shall be best secured by the

petitioner-herein . the respondent no.1 has always been giving priority to

her own personal interest than that of the child, whereas the petitioner has

in the past and in future willing to sacrifice his own personal needs and

requirements in preference to the needs and requirement of his child and

her upbringing. that the child is very happy in the custody of the

petitioner and love to spend time with him. that the respondent no.1

submitted that keeping it forward as explained in above point serene is

very well known about her culture and traditions being enjoyed and

followed the same starting from greeting to praying to her favorite god

Ganesh Ji. Again can show many things showing enjoying outings gifts

and many moments of her life which can proof very well that the

respondent no.1 and her family is very much capable of taking care of

serene in every way possible

30. That the content of the para no. 30 is wrong and vehemently denied

that in the case, the respondent no.1 is the custodian parent , however the

respondent no.1 has left the child in the sole custody of respondent no.2

and his wife. it is pertinent to note that the environment, then it will be

detrimental to her mental faculties and wellbeing and her character will
be shaped badly. the respondent no.2 and his family always leave the

child alone and to pacify the child give her unlimited and unsupervised

access to electronic gadgets like mobile phone and television. that the

respondent no.1 submitted that this such a blunt lie that the respondent

no.1 & 2 and his wife don't take care of their daughter and leave her

unsupervised that is no way possible he only use to see for few minutes of

when the petitioner use to call their daughter as we use to leave their

daughter alone in room while the petitioner used to call their daughter to

talk to their daughter and moreover the petitioner used to call every odd

hours beyond his visitation and calls rights and always used to force and

abuse respondent no.1 & 2 and his wife for the same and threaten

respondent no.1 & 2 and his wife that the petitioner will kill respondent

no.1 and her family.

31. That the content of para 31 is wrong and vehemently denied that

further it is beyond doubt that the role of the petitioner in the

development of a child’s personality and their ability to do so can never

be doubted . In fact, the child can get the best protection and education

only through the petitioner . neither the mother nor any other person can

endow the same kind of love, affection, care and sympathies to the child

that as of a father. further the company of a petitioner may be in fact

much more valuable particularly to a growing up of child in their tender

age. that the respondent no.1 submitted that the respondent no.1 totally

disagrees that the petitioner is fit enough and capable enough to take care

of their daughter as the petitioner has temperamental issues, short

tempered and abusive, and alcoholic beyond their imagination where in

not used to remember what the petitioner did last night as the petitioner is

being remarried again. That the respondent no.1 don't trust the petitioner

and his wife can take care of their daughter .

32. That the contents of the para no.32 is wrong and vehemently denied

that the interest and welfare of the minor child lies with the Petitioner in

this case as in the absence of the Respondent No.1, the Petitioner is the

best person to provide necessities and comforts which would ensure that

the child grows up improper atmosphere so that in the course of time the

child will stand on their own legs and will be a useful addition to the

society and the family. It is pertinent to mention here that besides meeting

the basic needs, the child must be brought up in proper atmosphere and

the conditions in the house must be conductive to their ever-growing

personality. That the respondent no.1 submitted that the petitioner is not

mentally stable enough as the petitioner and his whole family is being

abusive and toxic enough that the respondent no.1 dont belive that the

petitioner can provide a good and stable environment for their daughter.

As the petitioner has a very lewd lifestyle wherein it proves the petitioner
is not capable enough and provide a good example for serene upbringing.

33. That the content of the para no. 33 is wrong and vehemently denied

that the Respondent no. 1 from the very beginning has not been able to

effectively manage the affairs of the minor child. The child is growing

and indispensably requires the care and custody of Petitioner at this

juncture. The minor child needs the care, custody and patronage of her

father i.e. Petitioner the most and apart from the Petitioner there cannot

be any other person more competent to keep the custody of the child. On

the other hand, the Respondent had never taken care of the child and has

only been a visitor to the child on occasion. The Petitioner can effectively

supervise the development and welfare of the child in her best interests.

34. That the contents of para no. 34 is wrong and vehemently denied that

for the Kind consideration of this Hon'ble Court, the Petitioner is

enumerating the grounds on the basis of which custody of the child may

be given to him:-

a. Education of Child: Will be taken care by the Petitioner/father along

with his parents i.e. grandmother and grandfather of the minor

daughter. The Petitioner's family is well educated who understands

the importance and need of education being the foundation of one's

life and can provide high quality education to the child.

b. Health: The health and hygiene of the child is of utmost importance

 to the Petitioner. The Petitioner always had been taking care of the

health of the child including regular checkups and vaccination and

will continue to take care of his daughter.

c. The Physical/mental development of the child: Apart from knowing

the importance of studies and education, the Petitioner is well aware

of all round development of child. The Petitioner and the child shares

special bond and the Applicant had always spent quality time with his

daughter. Also, the minor daughter will have the company of his

grandmother and grandfather and the nurtured family values in the

said atmosphere.

d. Love and affection: the minor daughter always will be the

Petitioner/father's first priority. The Petitioner /father himself comes

from a highly educated family and has always received best care, love

and affection from his own parents. The Applicant/ father wishes the

same for his daughter and will make sure his child gets the best in life

and will like to fulfill all legitimate wishes of the child to the best of

his capacity.

e. Financial Support: The Petitioner is an individual who is more than

capable of providing financial support to his daughter.

35. That the content of para no. 35 is wrong and vehemently denied that

the respondents, their associates are creating the continuous hindrance,

obstructions interference on the way of the petitioner and his parents to

have the custody and company of the minor child and they want to retain

the custody of the minor child with illegal and unlawful motive only to

satisfy their personal financial interest and they are not interested in the

wellbeing of the minor child and wellbeing of the minor child demands

that minor should have the company of the petitioner and his parents, so

the petitioner is invoking the jurisdiction of this Hon'ble Court.

36. That the content of para no.36 is wrong and vehemently denied that

the petitioner is having the strong apprehension and reason to believe that

the respondent no. 1 with sole dishonest and fraudulent intention to keep

away the minor child from the company of the Petitioner may remove the

minor child from the jurisdiction of Delhi without the prior permission,

consent of the petitioner and if the respondent no. 1 succeeds in her illegal

design and motive then it will cause grave prejudice to the interest of the

minor child and it will cause grave irreparable loss and injury.

37. That the content of para no. 37 is wrong and vehemently denied that

the Hon'ble Court has jurisdiction to entertain the present petition since

the child is residing at WZ-1247, Nagal Raya, New Delhi-110046 with the

Respondent No. 2 which is within the jurisdictional territory of this

Hon'ble court.
The prayer clause of the petition is wrong and denied

PRAYER

It is therefore prayed that in view of the above mentioned facts and legal

submission made therein above, the petition of the petitioner may kindly

be dismissed with cost.

` RESPONDENT

THROUGH

COUNCIL