Grounds to corroborate false allegations on petitioner by respondent:

1.  Because of, the learned court below erred in observing that the respondent has reasonable ground to live separately as on basis that the FIR was registered u/s 498A of IPC, however petitioner produced the evidences which clears that FIR was lodged just after receiving notice of Sec.9 of Hindu Marriage Act and by tempering the police officials wrongly taken complaint and received the complaint from back date. But the learned court by not looking in the matter, wrongly concluded that she has reasonable reason to live separately.

The truth always comes out in the end no matter how hard anyone tries to hide it. 

The petitioner in his original written statement has produced the air ticket on which the respondent travelled on 24.08.2018 .He has shared a path breaking finding that the air ticket on which respondent travelled was booked 39 days in advance. In her original complaint at Mahila Thana she has alleged that she was beaten on account of domestic violence and dowry harassment and driven out of her matrimonial home on 24.08.2018 . She has further alleged that she had a narrow escape on her life .  If all this is supposedly true ,then her ticket should have been purchased on the current date and certainly not 39 days in advance.  She also carried a total of 47 kgs of luggage along with her .The permissible limit by the airlines is a total of 22 kgs (15kgs of checkin baggage and 7kgs of hand baggage). That means she carried an excess baggage of 25kgs for which she has also paid an excess baggage allowance of Rs 2000 visible through her travel certificate and air ticket and icici bank account statement. All these documents have been submitted to the family court. If the respondent was subjected to domestic violence and dowry harassment in the morning of 24.08.2018 (flight timing from Delhi to Jabalpur being 10.10 am), then when did she get the time to pack 47 kgs of luggage. 

The lower court has acknowledged the fact that applicant carried luggage more than the permissible allowance but has chosen to silently ignore the fact the her air ticket was booked 39 days in advance .This is where the lower court has erred. Both these facts taken together-air ticket booked 39 days in advance and luggage more than permissible allowance point out towards applicant's wilful departure and pre-planned exit. Any woman who chooses to sit back at her paternal home out of her own choice, as evident here, is not eligible to claim maintenance on ground of cruelty due to dowry harassment and domestic violence. This is a strong contradiction to the lower court’s acceptance of her reasons to live separately. When the very premise of the complaint has been proven wrong with concrete evidences; the furtherance of the complaint itself loses credibility.

2. Because the learned court has readily believed that there is nothing wrong in Respondent indulging in shopping at the Delhi airport on the unfateful day of 24.08.2018 when she was subjected to domestic violence and dowry harassment and had a narrow escape on her life at her matrimonial home in Faridabad .

a.    Petitioner had duly showcased to the honorable court that respondent megha indulged in shopping at Terminal 1 D of Delhi airport on 24.08.2018. 

b.       An entry dated 24.08.2018 in her ICICI Bank saving account No 140001510406 shows purchase of apparel worth Rs 1799 at the airport

c. Petitioner  argued that this cannot be a normal behavior of a women who has been subjected to torture at her matrimonial home on the very same day and had to run for her life . The learned court has made a note of the same.

d.       In response to this finding of petitioner ,respondent through her learned counsel had filed a reply that she was shivering with cold and was also feeling feverish since she was beaten at her matrimonial home on account of DV and dowry harassment .Hence she had to purchase a sweater to protect herself from cold.

e.       To this response, Petitioner  in his final WS again argued that sweaters are not sold in the month of August 2018 either in Delhi or Jabalpur.

f.        The learned lower court in the absence of evidence found respondent’s explanation valid.

g.    Petitioner started hunting for the receipt of the purchase apparel by respondent at the airport terminal 1 on 24.08.2018. It is the utter surprise to court and Petitioner  that respondent has again been caught red handed once again . She did not purchase a sweater .She purchased Men’s Tshirt in XL size . The receipt from UNITED COLORS OF BENNETON from T1D airport store along with an explanation of email is furnished herewith. Once again respondent Megha has lied on oath

h.       Basis the explanation in point 5 and point 7 stated above ;it appears that respondent  had

•       “Wilful departure + Pre-planned exit + peace of mind to indulge in shopping at the airport”-cumulatively point out that this cannot be the behavior of a married woman who had a narrow escape on her life on the unfateful day of 24.08.2018 at the hands of her husband and inlaws ,on account of dowry harassment and domestic violence.

The learned court has erred to not consider the true fact that not every man is wrong and not every woman is innocent.