IN THE COURT OF _____________
CIVIL JUDGE / JUDGE FAMILY COURT
[City Name]

In Re:
Mst. [Plaintiff’s Full Name]
Versus
[Defendant’s Full Name]

SUIT FOR RECOVERY OF DOWER ARTICLES OR RS. _______/- IN LIEU THEREOF (ALTERNATE CLAIM)

WRITTEN STATEMENT ON BEHALF OF DEFENDANT

RESPECTFULLY SHEWETH:

PRELIMINARY OBJECTIONS

1. That the titled suit is not maintainable in the eyes of law and is liable to be dismissed forthwith.

2. That the Plaintiff has no cause of action against the Defendant. The filing of the present suit is frivolous and a tool of harassment.

In view of the above preliminary objections, the Plaintiff’s suit is liable to be dismissed.

REPLY ON MERITS

1. That the contents of paragraph No. 1 are admitted to the extent that they relate to the record of the case; hence, need no further reply.

2. That the contents of paragraph No. 2 are admitted to the extent of registration of marriage and acknowledgment of dower agreed upon. However, it is denied that the Plaintiff did not receive dower articles. In fact, during the second week of [Month, Year], the Plaintiff left the Defendant’s residence without notice and took away all dower articles, ornaments, and other personal belongings. The Defendant has already initiated legal proceedings against the Plaintiff in this regard before the competent court.

3. That the contents of paragraph No. 3 are formal and require no reply.

4. That the contents of paragraph No. 4 are emphatically denied. The Plaintiff has taken all her belongings with her, including all jewelry and valuables. The Defendant holds no articles belonging to the Plaintiff.

5. That the contents of paragraph No. 5 are denied being baseless. The Plaintiff has no enforceable legal right to file the present suit.

6. That the contents of paragraph No. 6 are denied for being false. No cause of action has accrued to the Plaintiff against the Defendant.

7. That the contents of paragraph No. 8 pertain to legal interpretation and require no specific response.

PRAYER

In view of the above, it is most respectfully prayed that the titled suit may kindly be dismissed with costs being false, frivolous, and vexatious.

Any other relief deemed just and proper in the circumstances may also be granted.

DEFENDANT
Through Counsel

Advocate High Court
Enrollment No. ___________

[Law Firm Name, if any]
[Office Address]

VERIFICATION

Verified on oath at [City] this ___ day of [Month, Year] that the contents of paragraphs No. 1 to 5 are true and correct to the best of my knowledge, and those of paragraphs No. 6 and 7 including the preliminary objections are true and correct to the best of my information and belief.

DEFENDANT
(Signature)