Written Statement Draft For Family Suit

IN THE COURT OF _______ AT(City name) (district name)

Family Suit No. ___of 202_

(Applicant name)D/o /S/O (Applicants father name)

(Religion of applicant), Adult, R/o (Residential address of applicant)

(Resident city applicant)--------------------------------------------------- Applicant

Versus

(Respondent name(s))

D/o /S/O (Respondent’s father name)

(Religion of respondent), Adult, R/o (Residential address of Responden)

(Resident city Respondent)------------------------------------------ Respondent(s)

Baby name

D/o-S/O (Respondent/Applicant’s name)

Master Ahmed Mustafa

D/o-S/O (Respondent/Applicant’s name)----------- Minors/ Wards

WRITTEN STATEMENT

It is respectfully submitted by the respondent as follows:-

PRELIMINARY OBJECTIONS:

That the above application is liable to be dismissed on all or any of the following grounds, amongst others, viz:-

That the Applicant have no cause of action to institute and maintain this application.

That the applicant has concealed material and true facts from this Hon'ble Court therefore she is not entitled for equitable and discretionary relief from this Hon'ble Court.

That the applicant has not approached this Hon’ble Court with clean hands and since her action is based on ill will and malice, therefore, she is not entitled for equitable and discretionary relief from this Hon’ble Court.

That the application being frivolous, baseless and vexatious is liable to be dismissed at an initial stage to save the respondent from further harassment and to save the precious time of this Hon'ble Court.

That the allegations contained in the application are baseless and malicious against the respondent in order to pressurize and blackmail him.

That the application has been filed with malafide and ill will and with the objective of engaging the respondent in frivolous litigation in order to harass him and to extract illegitimate financial gains.

Without prejudice to the above, it is further submitted by the respondent as follows: -

That in view of the preliminary legal objections as to the maintainability of the application, the above application being still born is liable to be buried at an initial stage to save t