IN THE COURT OF L.D. J.M.F.C.

, VASHI AT BELAPUR

PWDVA NO. OF 2021

MRS. PRIYADARSHINI NILESH TEMULKAR.

…..APPLICANT

VERSUS

MR. NILESH VIJAYTEMULKAR.

MR. VIJAY TEMULKAR.

MRS. VAISHALI VIJAY TEMULKAR.

…..ACCUSED

REPLY ON BEHALF OF THE

ACCUSED.

MAY IT PLEASE YOUR HONOUR:

The applicant above named most humbly states and

submits as under:

1. That the present application is being filed under

Section 12 of the protection of Women from Domestic
Violence Act, 2005.

2. That the Respondents above named are in domestic

relations with the Applicant i.e. Respondent No.l is her
husband, Respondent No.2 is her father-in-law and
Respondent No.3 is her mother-in-law.

3. The Applicant states that she had married with Mr.

Nilesh Vijay Timulkar on 29th November 2012. The said
marriage is a love and then arranged marriage and was
solemnized at Sanpada, Navi Mumbai in a hotel named
Shikara Hotel. Hereto annexed and marked as Exhibit A
is the copy of Marriage Photograph, Exhibit-B is a copy
of Marriage Certificate and Exhibit-C is the copy of
Aadhar Card. It is strongly denied that the Respondent
No. 1 was working as HR Manager with India Bulls
Pharmaa earning an income of more than Rs. 86,000 per
month as per the last information of Applicant.

4. The Applicant states that the marriage was

consummated and there is one son out of the wedlock.
Their son named Aarav Temulkar is 5 years old, He was
born on 5th March 2016.Hereto annexed and marked as
Exhibit - D is the Aadhar card of Applicant's son Aarav
NileshTemuklar.

5. It is strongly denied that the Applicant states that

she has been compelled to live in the most inhumane
conditions due to ill-treatment, torture, harassment and
cruelty committed by Respondent No.1 i.e. her husband,
Respondent No.2 i.e. her father-in-law and Respondent
No.3 i.e. her mother-in-law.

6. It is strongly denied that the Applicant states that

her matrimonial home is an owned flat in Kharghar
addressed at A4/501,Bhumiraj Woods CHS Sector - 20,
Kharghar, Navi Mumbai, PIN 410 210. That the
respondent states that the said flat is in the joint name
of Respondent no: 1 and Respondent no: 2.

7. It is true that the Applicant and Respondent No. 1

were working together with Wanbury Limited. It is
further true that they started as friends and later got
married in presence of friends, families and relatives.

8. It is strongly denied that initial few days were good

but after that the Respondents started showing their true
colours. It is further denied that the Applicant's mother
in law and father in law were never happy with the fact
since very start that the Applicant was two years elder
than her husband i.e. Respondent No. 1.

9. It is strongly denied that the Applicant was getting

the worst possible treatment by her husband and her in
laws. It is further denied that her ordeal started just after
her engagement with Respondent No. 1. It is denied that
she was insulted and humiliated even at the slightest of
instance by her in laws i.e. Respondent No. 2 and
Respondent No. 3.

10. It is strongly denied that even during Applicant's

pregnancy the Respondents never considered her
condition and kept on forcing her to do all household
chores. It is further denied that even during the
advanced stage of applicant’s pregnancy, the Applicant
was cleaning kitchen, household, washing utensils and
cooking food for everyone when she needed the utmost
care from everyone, especially from her husband and
mother in law. It is further denied that on New Year eve
the Applicant did all the household chores when she was
in her 7th month of pregnancy. It is further denied that
her husband's friends were present and they too felt bad
that the applicant was working so much. It is denied that
those friends of Respondent No. 1 asked him to help the
applicant. It is further denied that the Applicant was
tired and sad. It is further denied that the applicant
states that the Respondent No. 1 asked his mother i.e.
Respondent No. 3 to allow the applicant to rest for some
time as she was tired. It is further denied that the
Respondent No. 3 said “To kyahuathakgayitoh?”. It is
further denied that the Respondent No. 3 used to abuse
and thrash the Applicant on regular basis. It is further
denied that Respondent No. 1 used to hurl the worst
abuses at Applicant and Applicant's mother was a
witness to such incidents.

11. It is strongly denied that even after her delivery, she

never received any support from her mother in law. It is
further denied that the applicant states that whenever
the Applicant proposed to keep a housemaid for at least
cleaning of house and utensils, her mother used to say,
“Baika paisa mujhedede". It is further denied that the
Applicant had no choice but to overburden herself with
the task of cooking, cleaning, washing utensils, taking
care of her kid and her job. It is further denied that even
before leaving for her office, applicant had to make her
breakfast and clean the floor and then leave for work.

12. It is strongly denied that around November 2016

when her child was approximately just 8 months old,
applicant got to know about an illicit affair of her
husband. It is further denied that the Respondent No. 1
went to Chennai for a tour for 4 days. It is further denied
that the Applicant noticed a change in the behaviour of
Respondent No. 1 after he came back from the tour. It is
further denied that the Respondent No. 1 was behaving
strange. It is further denied that very next morning
Respondent No. 1 said that he wanted to tell something
to the family. It is further denied that Respondent No. 1
said, "Mereko tum log kokuchbatanahai". It is further
denied that then he told about the entire scenario that
happened in Chennai. It is further denied that the
Respondent No. 1 had met a woman much older to him
through online dating app named Tinder and planned to
stay in hotel with her. It is further denied that in
Chennai, the Respondent No. 1 went to a hotel with that
woman. It is further denied that the Respondent No. 1
told about this instance to his family including his wife
because his paramour's (woman's) husband threatened
the Respondent No. 1 by saying that if the Respondent
No. 1 will not tell about this incident to his family, then
he will have to tell it to them - "tubolnahi to main
batatahoon". It is further denied that after this incident
when the Applicant spoke to the husband of that woman
(Paramour of Respondent No. 1), he told her about the
incident of hotel. It is further denied that the Applicant's
husband also thrashed her once because her son was
crying.

13. It is strongly denied that the Applicant was appalled

by knowing about such a disgusting incident about her
husband when the Applicant herself was struggling to
take care of her 8 months old child along with her job
and household chores. It is further denied that the the
Respondent No. 1 didn't want to spend on the medical
expenses and upbringing of their son but he had all the
money to spend on hotel for spending nights and having
illicit sexual relationship with other woman that too in
other state.

14. It is strongly denied that again during the start of

2018 she started feeling strange behaviour of her
husband. It is further denied that the Applicant doubted
due to various incidents that again the Respondent No. 1
was having an affair and again she asked from her
husband whether he was having an affair. It is further
denied that the Applicant also assured her husband i.e.
Respondent No. 1 that in case he was in love with some
other woman, the Applicant will move out of his life very
calmly but the Respondent No. 1 said that there is
nothing like that.

15. It is strongly denied that the Respondent No. 1 went

to Tarkarli with his new girl-friend and two other friends
for picnic while the Applicant was somehow managing
her small child along with her job, kitchen and
household chores without any housemaids.

16. It is further denied that later the Respondent No. 1

went to Alibaug for picnic even when it was raining
heavily. It is further denied that the Applicant requested
him not to go as it was not safe to go for a picnic during
such heavy rain. It is further denied that it was raining
whole night but the Respondent No. 1 left the next
morning very early for picnic. It is further denied that the
Applicant felt very bad because she kept on requesting
the Respondent No. 1 not to go for picnic in such bad
weather conditions and on the top of that her child was
also not well. It is further denied that the Applicant was
unable to understand the urgency of her husband to go
for picnic in such adverse conditions when he might
have chosen to take care of their child or simply rest at
home with family. It is further denied that the same
night the Applicant called the Respondent No. 1 and
asked about his affair with that girl but he took fake
swear upon their child and said that there is nothing like
that -- "Aaravkikasamkuchnahihai".

17. It is strongly denied that one day a friend of

Respondent No. 1 suddenly called her when the
Respondent No. 1 was on tour. It is further denied that
the friend of Respondent No. 1 said to the Applicant,
"Aaj-kal tum logon kakuchtheeknahichalraha”. It is
further denied that the friend of Respondent No. 1 also
said to the Applicant that the Respondent No. 1 was
already dating someone. It is further denied that the
Respondent No. 1 also said to his friend -that his wife
was not giving him the pleasure of physical intercourse
whereas he was getting sexual pleasure and everything
from his girlfriend.

18. It is strongly denied that the friend of Respondent

No. 1 also told him that he was also complaining about
the Applicant by stating that she does not do any
household work at which his friend asked him not to lie
as she herself has seen the Applicant working so hard
even during advance stage of her pregnancy.

19. It is strongly denied that after being fed up of her

husband's multiple affairs every now and then apart
from his careless nature and bad attitude towards
herself and her child, she decided to finally leave his
home in June 2019. It is further denied that when the
Applicant objected to illicit affairs of her husband i.e.
Respondent No. 1 by stating that he has done affair now
and he will do more affairs in future too, Applicant's
mother in law i.e. Respondent No. 3 said that if a man
does it, it's alright - "to kya, mardkartahai to chalega”. It
is further denied that the Respondent No. 3 started
saying that the Applicant will have to adjust this way.

20. It is strongly denied that right from the start of their

marriage, she was forced to contribute from her salary
and she never refused for that. It is further denied that
every month, without fail, the Applicant used to give Rs.
5,000 to her husband. It is further denied that the most
appalling part was that when she went to her parental
home for her delivery, even during that phase the
Respondent No. 1 went to the parental home (Maayka) of
Applicant to ask for Rs. 5,000 for that month from her.

21. It is strongly denied that the Respondent No. 1

wanted money from her even after being in a good job
and earning more than her but he always hid each and
every information from her about his finances and other
things too. It is further denied that the Applicant felt very
hurt after knowing that the Respondent No. 1 got PF
money which he disclosed to his mother but never told
the Applicant. It is further denied that the Applicant got
to know about it later through some other source.

22. It is strongly denied that in the marriage of 7 years,

she never received a single piece of gold jewellery from
Respondents. It is further denied that the Applicant's
delivery expenses were also borne by her parents and
she was giving Rs. 5000 minimum every month to the
Respondents without fail. It is further denied that the
Applicant states that not only this, only the Applicant
used to spend for her son after his birth.

23. It is true that for reasons better known to applicant

after leaving her home in June 2019, she went to her
parental home, however the respondents do not know till
what day and date the applicant stayed with her parents.
It is further denied that while the Applicant was leaving
her matrimonial home, the Respondent No. 2 and
Respondent No. 3 said that they will end their life by
going under the train. It is further denied that the
Applicant did not want to hurt her in laws and so left her
child with them. It is further denied that the Respondent
No. 2 and respondent No. 3 kept on shouting at the
Applicant by stating that it was her fault. It is further
denied that had she live with her husband well, he would
not have gone to any other woman. It is further denied
that they also asked her to raise her child on her own
without any expenses from Respondents.

24. It is strongly denied that the applicant routine was

very tight. It is further denied that her office timings
were from 9 am to 6 pm. After leaving her matrimonial
home, she went to her parental home in CBD Belapur. It
is further denied that however, the Applicant made sure
not to leave a single chance to be with her son in that
duration of 6 months. It is further denied that the she
used to leave her home by 8 am and return back to
Kharghar at her matrimonial home just for two and a
half hours. It is further denied that after reaching
Kharghar at her Matrimonial home from office at 7 pm,
she used to be there with her son till 9.30 pm. It is
further denied that the Applicant states that in this
duration she used to cook food for her child and made
him have his dinner before leaving. It is further denied
that every Saturday she used to go to her matrimonial
home to pick her child and take him with her to her
parental home at CBD Belapur and every Sunday she
used to go to her matrimonial home again to drop the
child. Only sometimes the Respondent No. 1 used to go
to Applicant's parental home to take the child.

25. It is strongly denied that on one occasion when she

went to her matrimonial place to drop her son, her father
in law i.e. Respondent No. 2 shouted at her for no reason
in the middle of the road. It is further denied that this
happened twice and Applicant's brother was present
there. It is further denied that the Applicant states that
the Applicant then spoke to her husband i.e. Respondent
No. 1 about this incident on which he replied that the
Respondent No. 2 was drunk.

26. It is strongly denied that living at her parental home

was not possible for long duration as her brother and
sister in law too needed privacy in their home. It is
further denied that apart from this, she also wanted her
son to live close to the Respondents for his good overall
development without going through the pain to remain
separated from him. It is further denied that the
Applicant's child's school is in Kharghar and she did not
want any kind of disturbance in his studies too. It is
further denied that with all these objectives in mind, the
Applicant took a flat on rent in Kharghar in the adjacent
building of her matrimonial home. That the respondents
don’t know whether address of her rented apartment was
Kharghar, PIN 410 210, because the said agreement
which is annexed with the application is expired one.
Hereto annexed and marked as Exhibit E Colly are the
copies of rent agreement for her rented apartment in
Kharghar.

27. It is strongly denied that the Applicant states that

she is physically, mentally, emotionally and financially
drained out in this entire episode of domestic violence at
the hands of Respondents. It is further denied that the
Applicant states that to survive with her child since then,
the Applicant had to toil hard day and night.
28. It is strongly denied that the Applicant states that
her life is in mess and she is in acute financial crisis due
to Respondents. It is further denied that the Applicant
states that she bought a scooty in the year 2012 for Rs.
58,000 and the scooty is still with the Respondents. It is
further denied that the Applicant states that she travels
in buses and shared autos for commute. It is further
denied that the Applicant states that still her jewelleries
worth Rs. 20 Lakh are lying with the respondents.

29. It is strongly denied that the Applicant had to shell

out Rs. 1 Lakh and Fifty Thousand for taking loan in the
year 2019. It is further denied that Applicant had to
withdraw 50 % amount of her PF in the year Jan 2020i.e.
Rs. 30,000 before taking loan. Hereto annexed and
marked as Exhibit - F is the copy of loan document.
Hereto annexed and marked as Exhibit - G is the copy of
screenshot depicting 50% withdrawal of her PF amount
by Applicant.

30. It is strongly denied that the Applicant states that

her mother gave Rs. One Lakh to Respondent No. 1 for
buying a second hand Car (Maruti Alto). It is further
denied that the Applicant states that it was purchased
from a shop in Kharghar named 4 Wheels.

31. It is strongly denied that the Applicant states that

she earns Rs. 24,192/- per month. It is further denied
that the Applicant states that out of which she has to
pay Rs. 16,000 for rent. It is further denied that she has
to pay Rs. 3891/- per month EMI for the loan worth Rs.
1.5 Lakh that was taken by her to buy household items
(For 60 months). It is further denied that the Applicant
states that the Applicant pays Rs. 2000 for travel
expense and Rs. 5000 for grocery. Hereto annexed and
marked as Exhibit - H is the copy of Applicant's salary
credit message.

32. It is strongly denied the Applicant states that she

used to have keys for the house but in October 2019 her
father in law i.e. Respondent No. 2 ask her to handover
the house keys to him and she had no option but to do
the same.

33. It is strongly denied that the Applicant states that

her son studies in Jr KG in Vishwajyot High School. It is
further denied that the Applicant states that his annual
fee expenses are Rs. 89,801. Hereto annexed and marked
as Exhibit I is the copy of fee structure of Applicant's
son.

34. It is strongly denied that the Applicant states that

her husband sent her a Mutual Divorce Petition and kept
on forcing her to sign it. It is further denied that the
Applicant states that after this, the Applicant sent a
Legal Notice to him through her advocate and she
received a reply from his advocate. Hereto annexed and
marked as Exhibit – J Colly are the copies of these legal
notices.

35. It is strongly denied that the Applicant was ready to

do anything to be in the marriage but the Respondents
never considered her condition and never supported her.
It is further denied that Applicant states that she was
drained physically, mentally, emotionally and financially.
36. It is strongly denied that the Applicant states that
her husband and in laws are very deceitful persons who
cannot be trusted in any circumstance. It is further
denied that the Applicant states that the Applicant is so
scared due to their nature it has become impossible for
her to trust them for her future.

37. It is strongly denied that the Applicant states that

she thought that the Respondent No.1 will become calm
and responsible towards her and her child but her hopes
shattered and even after putting all her efforts, there was
no change in the behaviour of the Respondent No. 1, 2
and 3. It is further denied that the Applicant states that
the Applicant kept mum in the hope of good future but
the Respondents started humiliating and harassing her
day by day using various tactics.

38. It is strongly denied that the Respondents always

used to behave in arrogant manner and never used to
show any respect to the Applicant. It is further denied
that the Applicant states that the Respondents used to
get angry at the slightest pretext and used to create a
scene, taunting and shouting loudly. It is further denied
that the Applicant states that the Respondents always
used to become violent and aggressive.

39. It is strongly denied that the Applicant states that

the Respondents became violent day by day and
domestic violence against the Applicant has increased
day by day. Respondent No. 1 has been sending various
legal documents to the Applicant in order to harass her.

40. It is strongly denied that the Applicant states that

that on 16th Feb 2021 Applicant's son Aarav was having
high fever. The Applicant informed the Respondent No. 1
the very same day by sending message to her husband
that the child is not well and hence he will not attend the
Online class. It is further denied that the Applicant
states that even after knowing the child had high fever,
Respondents didn't come to meet the child even when
the Applicant was living in the adjacent building of the
Respondents. Hereto annexed and marked as Exhibit-K
is the screenshot of this message chat between Petitioner
and Respondent No. 1.

41. It is strongly denied that the Applicant states that

in the duration of three months in the year 2021, the
Respondents have met the child Aarav hardly 5-6 times.
Respondents force the Applicant to travel most of the
times with child in order to make them meet the child.

42. It is strongly denied that the Applicant states that

Respondent No. 1 called Applicant's friend Jhanvi
Mandhare and started admonishing her. It is further
denied that the Applicant states that he also called
another common friend and told him details about
Applicant and about their relationship status. It is
further denied that the Applicant states that the
Applicant feels humiliated by listening to her personal
details from others.

43. It is strongly denied that the Applicant states that it

was 5th birthday of her son on 5th March 2021.
Respondents didn't come on 5th March to celebrate the
child's birthday. It is further denied that the Applicant
states the Respondent No. 1 and 2 met the child in Little
World Mall and gave him gift and moved away from
there.
44. It is strongly denied that the Applicant states that
she tried her level best to convince the Respondents but
due to adamant, greedy and irresponsible behaviour of
the Respondents her efforts became futile. It is further
denied that the Applicant states that thus complainant
controlled herself by keeping calm and quiet and hoped
that in future all this will become alright and normal but
now she has lost all the hopes. It is further denied that
the Applicant states that the Respondents do all wrong
doings against her. It is further denied that the Applicant
states that the Applicant has come on cross roads. It is
further denied that the Applicant states that she
absolutely has no idea about her future. It is further
denied that the Applicant states that she is left insulted
and humiliated everywhere in front of the society.

45. It is strongly denied that the Applicant states that

now the domestic violence on the hands of the
Respondents has become uncontrollable. It is further
denied that the Applicant states that the Respondents
have stopped all communication with Applicant and her
family. It is further denied that the Applicant states that
the Respondents have forced the Applicant to go out of
her matrimonial house and live a miserable life with her
small income. It is further denied that the Applicant
states that the Applicant is somehow managing the rent
and expenses of her rented apartment which she is
vacating for the time being as she is not being able to
cope up with the huge expenses, job and child. It is
further denied that the Applicant states that currently
she is residing with her parents apart from paying the
rent of her flat in Kharghar. It is further denied that the
Applicant states that she will not be able to live for longer
duration with her parents as they have their personal life
too and hence she will have to again shift to a rented
apartment.

46. It is strongly denied that the Applicant submits that

the respondents have harassed, injured and endangered
her life as well as the life of her child. It is further denied
that the Applicant states that the Applicant states that
injuries cause harm physically as well as mentally to her.
It is further denied that the Applicant states that they
also caused bodily pain, harm, danger to her life and
health.

47. The Applicant states that she is residing within the

jurisdiction of this Hon'ble Court. The Respondent is also
staying within the jurisdiction of this Hon'ble Court.
Therefore this Hon'ble Court is having jurisdiction to try
this petition. Hereto annexed and marked as Exhibit-L is
the electricity bill of parental home of Applicant.

Without prejudicing the merits of my denial Respondent

state as under:

1. The respondent No.1 states that their marriage was

solemnized on 29th November 2012. The said marriage
was a love marriage with consent of both the parents.
2. The respondent states that the Applicant was working
as Receptionist and the Respondent No.1 was working
as an HR Executive with Rs.25000 salary.
3. The Respondent states that he was staying in Vikhroli
in 1 RK (250 per sq feet area). The Applicant had
 stated that she wants to stay near by her parents i.e.
Belapur and she insisted Respondent No.1 to buy a
flat near i.e. Belapur. The Respondent No.1 states
that the Respondent No.1 convinced his parents and
sold out his father’s flat and took a loan of Rs. 10
lakh which is still going on and purchased a flat in
Kharghar which is in the name of Nilesh Temulkar
and Vijay Temulkar. The Respondent No.1 states that
this was all done for the comfort of the Applicant.
4. The Respondent No.1 states that his parents were
very happy with the marriage and things were going
smoothly. The Respondent No.1 states that they
always treated the Applicant like a daughter. The
Respondent No.1 states that his parents were never
orthodox and always provided the best of best
freedom and comfort to the Applicant.
5. The Respondent No.1 states that even the Respondent
himself was never orthodox or conservative and
provided the best love and freedom to the Applicant.
The Respondent No.1 states that the Respondent
No.3 always use to cook and pack tiffin for the
applicant so that she doesn’t face much hectic
schedule for her office. The Respondent No.1 states
that also the Respondent No.3 used to make sure that
in evening, dinner is also cooked so that the Applicant
doesn’t face any hectic schedule.
6. The Respondent No.1 states that many times
Respondent No.2 use to pick the Applicant from
Kharghar station so that she doesn’t have to use
public transport and reaches back home comfortably
and safely. The Respondent No.1 states that inspite of
all these above efforts, the Applicant always had few
concerns.
7. The Respondent No.1 states that the Applicant used
to insist the Respondent to buy gold jewellery as
during their marriage he had not given much gold to
her. The Respondent No.1 states that the Respondent
already had loan and household expenses so that was
not possible for him.
8. The Respondent No.1 states that the Applicant
always use to convey very small things such as food
not being made of her choice, which was not at all
true. The Respondent No.1 states that the Respondent
always used to insist the Respondent that they should
stay separately, but being the only son the
Respondent never agreed to it. The Respondent No.1
states that the Respondent No.3 always made sure
that the Applicant gets all the things and food of her
choice.
9. The Respondent No.1 states that the Applicant was
willing to buy a new car so for her comfort, the
Respondent took a car loan and also bought a new
car. The Respondent No.1 states that the Respondent
and his family did all the possible things that could
make her happy, but still the Applicant always
showed her unhappiness.
10. The Respondent No.1 states that in 2015, the
Applicant and Respondent No.2 and Respondent No.3
suggested the Respondent No.1 to buy a flat in
Badlapur. The Respondent No.1 states that there was
a problem of cash flow but still the Respondent No.1
thought of taking one more loan and purchasing the
flat. The Respondent No.1 states that the parents of
Respondent No.1 had only Rs. 3,50,000/- in their
account which they invested for buying the flat. The
Respondent No.1 states that the Respondent No.1
 used his own savings including PF and invested
Rs.3,90,000/- in the flat. The Respondent No.1 states
that the Applicant invested Rs.1,58,000/- in the flat
which is 13% of overall cost. The Respondent No.1
states that remaining, the Respondent had to take
one more house loan.
11. The Respondent No.1 states that the Respondent
No.1 and his family were so much in good faith with
the Applicant that they suggested that they should
include the Applicant’s name also with a good
gesture.
12. The Respondent No.1 states that from the first day
of their marriage the Respondent No.1 and his
parents were happy. The Respondent No.1 states that
it’s just the expectations of the Applicant went on
increasing which they still tried to fulfil.
13. The Respondent No.1 states that if there would
have been any conflict during these many years or
that the Applicant would have been in any wrong
treatment, she would have approached any legal
authorities i.e. police complaint. The Respondent No.1
states that she was getting such a good treatment
from her inlaws and husband that there wasn’t any
need of the same.
14. The Respondent No.1 states that also the things
would have been bad then the parents wouldn’t have
suggested to put her name in Badlapur flat.
15. The Respondent No.1 states that in 2016, they were
blessed with a son named Aarav Temulkar. The
Respondent No.1 states that during the Applicant’s
pregnancy, the Respondent No.1 and his parents gave
the best possible environment to her. The Respondent
No.1 states that the Respondent No.3 always made
 sure that the Applicant’s health is the top priority.
The Respondent No.1 states that the Respondent No.3
has taken care of her grandson Aarav in a very
amazing manner. The Respondent No.1 states that
from his childhood she made sure that he is well
nourished and well behaved. The Respondent No.1
states that even in primary school she use to drop
him and pick him up apart from household work.
16. The Respondent No.1 states that the
Applicant always insisted Respondent No.1 to put
Aarav in day care. The Respondent No.1 states that
Respondent No.3 wasn’t in that favour of putting
Aarav in day care. Like any other grandparent she
was very well attached with grandson Aarav. The
Respondent No.1 states that even the same goes with
Respondent No.2 and Respondent No.1. The
Respondent No.1 states that even Aarav was
very very happy.(Photographs attached)
17. The Respondent No.1 states that during this period
there was always a doubt in the mind of Respondent
No.1 that the Applicant is hiding some things with
him. The Respondent No.1 states that she use to chat
with a so called friend of her but she always use to
clear the chats on whatspp. The Respondent No.1
states that on cross questioning she never gave a
convincing reply to Respondent No.1.
18. The Respondent No.1 states that in June 2019, The
Respondent No.1 states that the Applicant bought a
new phone. The Respondent No.1 states that she kept
her old phone hided in her wardrobe. The Respondent
No.1 states that Respondent No.1  went through that
phone and he got evidence of the Applicant having an
affair. The Respondent No.1 states that in that phone
 there were several adultery pics of her with third
person and further cross questioning she confessed
that she was having an affair .
19. The Respondent No.1 states that the Applicant left
her home and went to mothers place stating that she
doesn’t want to stay with Respondent No.1 . She was
taking Aarav Temulkar with her but we insisted that
do not take child with her.
20. My client and Respondent No.1 and his parents
were deeply hurted and shattered by her behaviour.
The Respondent No.1 states that they all are
disappointed that inspite of giving so much of love
,respect, freedom and care, the Applicant did this.
21. The Respondent No.1 states that on 31st July 2020
The Respondent No.1 states that got a notice from the
Applicant via Adv. Madhuri Kohli  saying that the
Applicant wants to get separated and she has asked
for mutual divorce . The Respondent No.1 states that
as Alimony she had asked for Badlapur flat on her
name and fixed alimony.
22. The Respondent No.1 states that during this period
son Aarav was in custody of Respondent No.1.
Son wasmorethan happy.Photographs attached. The
Respondent No.1 states that the Applicant use to visit
Respondent No.1  for meeting son Aarav and use to
leave back home.
23. The Respondent No.1 states that now the time came
wherein the Applicant wanted to take son Aarav
completely in her custody.She called the Respondent
No.1 in the month of Jan 2021 and informed him that
she is taking Aarav to Belapur for some days. The
Respondent No.1 states that the Respondent No.1
never ever objected on this also. The Respondent No.1
 states that post Jan 2021, the Applicant never
brought Aarav at his fathers place. The Respondent
No.1 states that infact when they visit to meet him
son cries which clearly signifies that the
Applicant gives her son wrong understanding about
his father to the son. The Respondent No.1 states that
as a father also, the Respondnet No.1 took complete
responsibility of the child. The Respondent No.1
states that his entire education expenses are been
carried out still by the Respondent No.1
only.Fees receipt attached. Last payment done chq
dated 07th Dec 2021.
24. The Respondent No.1 states that on 20st March
2021, the Applicant  called and informed that she is
taking to collect all gold ornaments on which the
Respondent No.1 informed that it should be done in
front of lawyers on which she didn’t agree saying
that it’s my gold and I won’t come to third party to
collect the same.(Call Recording available)
25. The Respondent No.1 states that the
Applicant along with her  friend Ms
Sharda Rawat came at my clients place to collect all
her gold ornaments. The Respondent No.1 states that
she accepted all the gold items (photographs
attached),with acceptance letter.
26. The Respondent No.1 states that in the DV dated
01st April 2021, the Applicant has mentioned that gold
jewellery worth Rs 20 Lakh are lying with the
Respondent No.1 which is completely false. The
Respondent No.1 states that in this manner, the
Applicant has completely disturbed the mental and
physical peace of Respondent No.1,Respondent No.2
and Respondent No.3. The Respondent No.1 states
 that as the Applicant is having an affair and she
wants to get married to the third person her plans are
to use DV as tool for alimony by making all false
allegations.