Objection of the Husband to an Application under Section 125, Cr.P.C.

BEFORE THE HON'BLE COURT OF…………………..
Criminal Application No. ………………… of ………….
(Under Section 125, Cr.P.C.)

District………………
Smt. ……………………….. W/o ………………….. R/o ………………  P. S. ………………. District ……………………….

………….....							…Applicant

Versus

Sri ………………….. S/o ……………….. D/o …………………… P.S. ………………. District …………………….  

………….....  						…Opposite Party

Reply to the application of maintenance filed by the Applicant.

To

The Hon'ble Judge of the aforesaid Court.

The humble opposite party most respectfully showeth as under:

1. That the contents of paras 1 and 2 of the application are admitted.

2. That the contents of para 3 of the application are not admitted.

3. That the contents of para 4 of the application are not admitted.

4. That the contents of para 5 of the application are not admitted.

5. That the contents of para 6 of the application are not admitted.

6. That the contents of para 7 of the application are not admitted.

7. That the contents of paras 8 and 9 of the application are not admitted.

Additional Pleas

8. That the answering opposite party lives in the joint family consisting of the opposite party parents and two younger brothers.

9. That the applicant is bad cultured and still of the worse temper.  She would have strained relations with her-in-laws and shall not miss any opportunity to quarrel with the parents and the brothers of the opposite party in a disreputable manner.

10. That despite request she would not mend her ways.  Instead she insisted upon	the opposite party to severe his relations with the rest of the members of the family.

11. That the opposite party refused to severe his relations with his parents and brothers and consequently the applicant, on her own free will, left the house of the opposite party on …………..with all her bag and baggage and since then she is living with her parents.

12. That the applicant is taking private tuitions of children studying upto class VIII. At present she is having ………….…. students and charging Rs.…../- per month per student.

13. That it is absolutely incorrect to say that the opposite party or his parents/ever demanded any dowry from the applicant or her parents.

14. That the opposite party or his parents have been harassed the applicant for dowry.

15. That the opposite party has never assaulted the applicant nor he ever threw her out of the house on the said date.  The applicant left the house of her own free will.

16. That the opposite party is not the clerk in the …………….. Department.  He is only a peon in ………………. and getting a meagre amount of Rs............. per month, that amount is not even sufficient to support the opposite party himself.

17. That the opposite party has never refused or neglected to maintain the applicant.

18. That the opposite party has always been and still is willing to keep and maintain the applicant with him.

19. That in the aforesaid circumstances, it is just and necessary in the interest of justice that the Hon'ble Court may be pleased to reject the application under Section 125, Cr.P.C.

PRAYER

It is, therefore, prayed that the Hon'ble Court may be pleased to rejected the applicant’s application under Section 125, Cr. P.C. 

Date……………  				     Advocate for the Husband