IN THE HONOURABLE SUPREME COURT OF INDIA

New Delhi

GURUBUX SINGH

PETITIONER

Vs

HARMINDER KAUR

RESPONDENT

ON SUBMISSION TO THE SUPREME COURT OF INDIA

MEMORIAL ON BEHALF OF THE RESPONDENT

HARMINDER KAUR

BATCH-XI

ROLL NO- 169

1 MEMORANDUM FOR THE RESPONDENT

TABLE OF CONTENTS

INDEX OFAUTHORITIEShelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

Bookshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

Dictionarieshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

Statutory and other authorities03

Websiteshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

National judgementhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

STATEMENT OF FACTS04

QUESTIONS PRESENTED05

__________________________________________________________________________________

WRITTEN SUBMISSIONhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip06

___________________________________________________________________________

PRAYER FOR RELIEFhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip08

2 MEMORANDUM FOR THE RESPONDENT

INDEX OF AUTHORITIES

BOOKS

1 MODERN HINDU LAW DR PARAS DIWAN ALLAHABAD LAW AGENCY

DICTIONARIES

1 Blackrsquos Law Dictionary (West Group Publishers 2002)

2 THE LAW LEXICON BAKSHI P M Ashoka Law House New Delhi

STATUTORY AND OTHER AUTHORITIES

1 The Indian Penal Code 1860

WEBSITES

1 wwwmanupatracom

National Judgments

1Samar ghosh vJaya ghosh

2Narayan Ganesh Dastane vs Sucheta Narayan Dastane

3 MEMORANDUM FOR THE RESPONDENT

TABLE OF CONTENTS

INDEX OFAUTHORITIEShelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

Bookshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

Dictionarieshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

Statutory and other authorities03

Websiteshelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

National judgementhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip03

STATEMENT OF FACTS04

QUESTIONS PRESENTED05

__________________________________________________________________________________

WRITTEN SUBMISSIONhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip06

___________________________________________________________________________

PRAYER FOR RELIEFhelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphelliphellip08

2 MEMORANDUM FOR THE RESPONDENT

INDEX OF AUTHORITIES

BOOKS

1 MODERN HINDU LAW DR PARAS DIWAN ALLAHABAD LAW AGENCY

DICTIONARIES

1 Blackrsquos Law Dictionary (West Group Publishers 2002)

2 THE LAW LEXICON BAKSHI P M Ashoka Law House New Delhi

STATUTORY AND OTHER AUTHORITIES

1 The Indian Penal Code 1860

WEBSITES

1 wwwmanupatracom

National Judgments

1Samar ghosh vJaya ghosh

2Narayan Ganesh Dastane vs Sucheta Narayan Dastane

3 MEMORANDUM FOR THE RESPONDENT

INDEX OF AUTHORITIES

BOOKS

1 MODERN HINDU LAW DR PARAS DIWAN ALLAHABAD LAW AGENCY

DICTIONARIES

1 Blackrsquos Law Dictionary (West Group Publishers 2002)

2 THE LAW LEXICON BAKSHI P M Ashoka Law House New Delhi

STATUTORY AND OTHER AUTHORITIES

1 The Indian Penal Code 1860

WEBSITES

1 wwwmanupatracom

National Judgments

1Samar ghosh vJaya ghosh

2Narayan Ganesh Dastane vs Sucheta Narayan Dastane

3 MEMORANDUM FOR THE RESPONDENT

STATEMENT OF FACT

1On 23111997 the appealent got married with the respondent at amritsar according to sikh rites and customs

2From the very beginning the respondent expressed her dislike towards the appealent and his family and gradually started misbehaving with them

3On the first lohri festival after their marriage the respondent being annoyed with the appellant on a trivial issue abused his mother in filthy language in the presence of their relatives and neighbours causing immense pain to the entire family

4Just before the third birthday of their child ie on 10052002 the respondent without any justifiable reason left the matrimonial home leaving the child unattended and went to her parents house and staying there since then The petitioner filed a suit against the respondent on the ground that the respondent abused his mother in filthy language in the presence of their relatives and neighbours on the first lohri festival causing immense pain to the entire family and does mental cruelty to the petitioner

4 MEMORANDUM FOR THE RESPONDENT

QUESTIONS PRESENTED

Issues

1Whether their was existence of cruelty or not

2Whether the appellant should get divorce or not

5 MEMORANDUM FOR THE RESPONDENT

________________________________________________________________

WRITTEN SUBMISSIONS

CONTENTION NO-1

1Nothere was no existance of cruelty the married life should be assessed as a whole and a few isolated instances over certain period will not amount to crueltyAs both the appealent and respondent being highly qualified persons an isolated friction on some occasion like festival of lohri even in the presence of others cannot be a valid ground for dissolving the marriageIn Samar ghosh vJaya ghosh 1 the court held that mere trivial irritations quarrels normal wear and tear of married life which happens in day to day life in all families would not be adequate for grant of divorce on the ground of cruelty The married life should be reviewed as a whole and a few isolated instances over a period of years will not amount to cruelty

CONTENTION NO-2

2Nothe appellant should not get divorce as the appealentrsquos husband failed to substantiate the allegations of cruelty In the case of Samar ghosh vJaya ghosh the court held that emotional upset may not be a ground for grant of divorce on the ground of mental crueltyAs according to section 23 of Hindu Marriage Act laid down that the petitioner will not be allowed to take advantage of his or her own wrong or disability this is to say if the guilt of the respondent is in any way the direct or indirect outcome of some wrong or disability of the petitioner the petitioner will not be entitled to the matrimonial relief asked for 2 as in this case the respondent has stated that the appellant is a greedy person and not satisfied with the dowry articles received in marriageShe stated that he always misbehaved and maltreated her and abused on several occasions She also stated that the custody of the child was forcibly taken by the appellant when she returned to matrimonial home and the appellant used to force her to bring cash from her parents as he wanted to purchase a car When she refused to bring cash she was mercilessly beaten by the appellant She stated that in february 4 2000 her parents gave Rs 50000 to the appellant and thereafter the appellant agreed to keep the respondent in her matrimonial home she also stated that the appellant is habitual of taking liquor and under the influence of liquor he used to beat her in the presence of her parents and threaten to kill with poison So all this facts stated by the respondent is sufficient to say that the petitioner treated his wife with both mental and physical cruelty mental cruelty by respondentrsquos act of forcibly taking the custody of the child from respondent and also by harrasing the respondent for dowry and physical cruelty by beating her under influence of liquorSo in direct or indirect way the respondents disliking towards the

1 2007 4 SCC 5112 Modern hindu law DrParas diwan Allahabad law agency

6 MEMORANDUM FOR THE RESPONDENT

appealent and his family members and misbehave with them is the result of petitionerrsquos way of acting with cruelty towards respondent

So doing both physical and mental cruelty is an offence under section 498(i) of Indian Penal Code which says that if the wifersquos husband or relative of the wifersquos husband do cruelty with the wife then the offender will be punished by imprisoned upto 3 yrs in jail and fine so the act of the petitioner of beating the respondent for dowry shows physical cruelty so the petitioner should get punishment under this section and according to Section 4 of Dowry Prohibition Act 1961which says that the act of demanding of dowry by any person directly or indirectly from the parents or guardian of bride or bridegroom is a dowry offence for which the punishment is imprisonment not less than five yrs with fine which shall not be less than Rs 15000 or the amount of the value of such dowry whichever is more so under this act the petitioner is also offender for harassing respondent for dowryIn the case the ground is cruelty or adultery the petitioner is also required to show that he or she did not condone the offence and the petitioner is also required to prove that there is no improper delay in the presentation of the petition3 so according to (b) and (e) of section 23 of Hindu Marriage Act 1955 as it states that ldquowhere the ground of the petition is the ground specified in clause (i) of sub-section (1) of section 13 the petitioner has not in any manner been accessory to or connived at or condoned the act or acts complained of or where the ground of the petition is cruelty the petitioner has not in any manner condoned the cruelty and there is no other legal ground why relief should not be granted then and in such a case but not otherwise the court shall decree such relief accordingly as in this case the appellant filed the petition by highlighting only one instance that the respondent wife abused his parents on the day of festival of lohri in the presence of relatives and neighbours which was happened in 1998 and the petitioner filed suit on the basis of this one act after 2002 when the wife left his home due to his misbehaviour and in 1999 a male child was born so there is sexual intercourse between the parties in the gap before filing the petition and as section 23(b) of Hindu Marriage Act 1955 states that a single act of sexual intercourse between the parties after the act or incident may lead to the condonation of the act and the court gets a legal ground for not granting relief so the petitioner should not get divorce on the ground of cruelty as in the Narayan Ganesh Dastane vs Sucheta Narayan Dastane4 the court held that even a single act of sexual intercourse after the act or incident leads to the condonation of that act

3 Modern hindu law DrParas diwan Allahabad law agency4 1975 AIR 1534

7 MEMORANDUM FOR THE RESPONDENT

_________________________________________________________

PRAYER

Therefore in the light of facts of the case issues raised arguments advanced and authorities

cited this Court may be pleased to adjudge and declare that

a) There is no existance of cruelty on behalf of respondent

b) The petitioner should get punishment under section 498(i) of IPC for treating

respondent with physical cruelty and for taking dowry under dowry prohibition act

1961

All of which is respectfully submittedAll of which is respectfully submitted

Place New Delhi

Date 15-3-2012

Vinay Kumar Sahu

(On behalf of the Respondent)

8 MEMORANDUM FOR THE RESPONDENT

QUESTIONS PRESENTED

Issues

1Whether their was existence of cruelty or not

2Whether the appellant should get divorce or not

5 MEMORANDUM FOR THE RESPONDENT

________________________________________________________________

WRITTEN SUBMISSIONS

CONTENTION NO-1

1Nothere was no existance of cruelty the married life should be assessed as a whole and a few isolated instances over certain period will not amount to crueltyAs both the appealent and respondent being highly qualified persons an isolated friction on some occasion like festival of lohri even in the presence of others cannot be a valid ground for dissolving the marriageIn Samar ghosh vJaya ghosh 1 the court held that mere trivial irritations quarrels normal wear and tear of married life which happens in day to day life in all families would not be adequate for grant of divorce on the ground of cruelty The married life should be reviewed as a whole and a few isolated instances over a period of years will not amount to cruelty

CONTENTION NO-2

2Nothe appellant should not get divorce as the appealentrsquos husband failed to substantiate the allegations of cruelty In the case of Samar ghosh vJaya ghosh the court held that emotional upset may not be a ground for grant of divorce on the ground of mental crueltyAs according to section 23 of Hindu Marriage Act laid down that the petitioner will not be allowed to take advantage of his or her own wrong or disability this is to say if the guilt of the respondent is in any way the direct or indirect outcome of some wrong or disability of the petitioner the petitioner will not be entitled to the matrimonial relief asked for 2 as in this case the respondent has stated that the appellant is a greedy person and not satisfied with the dowry articles received in marriageShe stated that he always misbehaved and maltreated her and abused on several occasions She also stated that the custody of the child was forcibly taken by the appellant when she returned to matrimonial home and the appellant used to force her to bring cash from her parents as he wanted to purchase a car When she refused to bring cash she was mercilessly beaten by the appellant She stated that in february 4 2000 her parents gave Rs 50000 to the appellant and thereafter the appellant agreed to keep the respondent in her matrimonial home she also stated that the appellant is habitual of taking liquor and under the influence of liquor he used to beat her in the presence of her parents and threaten to kill with poison So all this facts stated by the respondent is sufficient to say that the petitioner treated his wife with both mental and physical cruelty mental cruelty by respondentrsquos act of forcibly taking the custody of the child from respondent and also by harrasing the respondent for dowry and physical cruelty by beating her under influence of liquorSo in direct or indirect way the respondents disliking towards the

1 2007 4 SCC 5112 Modern hindu law DrParas diwan Allahabad law agency

6 MEMORANDUM FOR THE RESPONDENT

appealent and his family members and misbehave with them is the result of petitionerrsquos way of acting with cruelty towards respondent

So doing both physical and mental cruelty is an offence under section 498(i) of Indian Penal Code which says that if the wifersquos husband or relative of the wifersquos husband do cruelty with the wife then the offender will be punished by imprisoned upto 3 yrs in jail and fine so the act of the petitioner of beating the respondent for dowry shows physical cruelty so the petitioner should get punishment under this section and according to Section 4 of Dowry Prohibition Act 1961which says that the act of demanding of dowry by any person directly or indirectly from the parents or guardian of bride or bridegroom is a dowry offence for which the punishment is imprisonment not less than five yrs with fine which shall not be less than Rs 15000 or the amount of the value of such dowry whichever is more so under this act the petitioner is also offender for harassing respondent for dowryIn the case the ground is cruelty or adultery the petitioner is also required to show that he or she did not condone the offence and the petitioner is also required to prove that there is no improper delay in the presentation of the petition3 so according to (b) and (e) of section 23 of Hindu Marriage Act 1955 as it states that ldquowhere the ground of the petition is the ground specified in clause (i) of sub-section (1) of section 13 the petitioner has not in any manner been accessory to or connived at or condoned the act or acts complained of or where the ground of the petition is cruelty the petitioner has not in any manner condoned the cruelty and there is no other legal ground why relief should not be granted then and in such a case but not otherwise the court shall decree such relief accordingly as in this case the appellant filed the petition by highlighting only one instance that the respondent wife abused his parents on the day of festival of lohri in the presence of relatives and neighbours which was happened in 1998 and the petitioner filed suit on the basis of this one act after 2002 when the wife left his home due to his misbehaviour and in 1999 a male child was born so there is sexual intercourse between the parties in the gap before filing the petition and as section 23(b) of Hindu Marriage Act 1955 states that a single act of sexual intercourse between the parties after the act or incident may lead to the condonation of the act and the court gets a legal ground for not granting relief so the petitioner should not get divorce on the ground of cruelty as in the Narayan Ganesh Dastane vs Sucheta Narayan Dastane4 the court held that even a single act of sexual intercourse after the act or incident leads to the condonation of that act

3 Modern hindu law DrParas diwan Allahabad law agency4 1975 AIR 1534

7 MEMORANDUM FOR THE RESPONDENT

_________________________________________________________

PRAYER

Therefore in the light of facts of the case issues raised arguments advanced and authorities

cited this Court may be pleased to adjudge and declare that

a) There is no existance of cruelty on behalf of respondent

b) The petitioner should get punishment under section 498(i) of IPC for treating

respondent with physical cruelty and for taking dowry under dowry prohibition act

1961

All of which is respectfully submittedAll of which is respectfully submitted

Place New Delhi

Date 15-3-2012

Vinay Kumar Sahu

(On behalf of the Respondent)

8 MEMORANDUM FOR THE RESPONDENT

________________________________________________________________

WRITTEN SUBMISSIONS

CONTENTION NO-1

1Nothere was no existance of cruelty the married life should be assessed as a whole and a few isolated instances over certain period will not amount to crueltyAs both the appealent and respondent being highly qualified persons an isolated friction on some occasion like festival of lohri even in the presence of others cannot be a valid ground for dissolving the marriageIn Samar ghosh vJaya ghosh 1 the court held that mere trivial irritations quarrels normal wear and tear of married life which happens in day to day life in all families would not be adequate for grant of divorce on the ground of cruelty The married life should be reviewed as a whole and a few isolated instances over a period of years will not amount to cruelty

CONTENTION NO-2

2Nothe appellant should not get divorce as the appealentrsquos husband failed to substantiate the allegations of cruelty In the case of Samar ghosh vJaya ghosh the court held that emotional upset may not be a ground for grant of divorce on the ground of mental crueltyAs according to section 23 of Hindu Marriage Act laid down that the petitioner will not be allowed to take advantage of his or her own wrong or disability this is to say if the guilt of the respondent is in any way the direct or indirect outcome of some wrong or disability of the petitioner the petitioner will not be entitled to the matrimonial relief asked for 2 as in this case the respondent has stated that the appellant is a greedy person and not satisfied with the dowry articles received in marriageShe stated that he always misbehaved and maltreated her and abused on several occasions She also stated that the custody of the child was forcibly taken by the appellant when she returned to matrimonial home and the appellant used to force her to bring cash from her parents as he wanted to purchase a car When she refused to bring cash she was mercilessly beaten by the appellant She stated that in february 4 2000 her parents gave Rs 50000 to the appellant and thereafter the appellant agreed to keep the respondent in her matrimonial home she also stated that the appellant is habitual of taking liquor and under the influence of liquor he used to beat her in the presence of her parents and threaten to kill with poison So all this facts stated by the respondent is sufficient to say that the petitioner treated his wife with both mental and physical cruelty mental cruelty by respondentrsquos act of forcibly taking the custody of the child from respondent and also by harrasing the respondent for dowry and physical cruelty by beating her under influence of liquorSo in direct or indirect way the respondents disliking towards the

1 2007 4 SCC 5112 Modern hindu law DrParas diwan Allahabad law agency

6 MEMORANDUM FOR THE RESPONDENT

appealent and his family members and misbehave with them is the result of petitionerrsquos way of acting with cruelty towards respondent

So doing both physical and mental cruelty is an offence under section 498(i) of Indian Penal Code which says that if the wifersquos husband or relative of the wifersquos husband do cruelty with the wife then the offender will be punished by imprisoned upto 3 yrs in jail and fine so the act of the petitioner of beating the respondent for dowry shows physical cruelty so the petitioner should get punishment under this section and according to Section 4 of Dowry Prohibition Act 1961which says that the act of demanding of dowry by any person directly or indirectly from the parents or guardian of bride or bridegroom is a dowry offence for which the punishment is imprisonment not less than five yrs with fine which shall not be less than Rs 15000 or the amount of the value of such dowry whichever is more so under this act the petitioner is also offender for harassing respondent for dowryIn the case the ground is cruelty or adultery the petitioner is also required to show that he or she did not condone the offence and the petitioner is also required to prove that there is no improper delay in the presentation of the petition3 so according to (b) and (e) of section 23 of Hindu Marriage Act 1955 as it states that ldquowhere the ground of the petition is the ground specified in clause (i) of sub-section (1) of section 13 the petitioner has not in any manner been accessory to or connived at or condoned the act or acts complained of or where the ground of the petition is cruelty the petitioner has not in any manner condoned the cruelty and there is no other legal ground why relief should not be granted then and in such a case but not otherwise the court shall decree such relief accordingly as in this case the appellant filed the petition by highlighting only one instance that the respondent wife abused his parents on the day of festival of lohri in the presence of relatives and neighbours which was happened in 1998 and the petitioner filed suit on the basis of this one act after 2002 when the wife left his home due to his misbehaviour and in 1999 a male child was born so there is sexual intercourse between the parties in the gap before filing the petition and as section 23(b) of Hindu Marriage Act 1955 states that a single act of sexual intercourse between the parties after the act or incident may lead to the condonation of the act and the court gets a legal ground for not granting relief so the petitioner should not get divorce on the ground of cruelty as in the Narayan Ganesh Dastane vs Sucheta Narayan Dastane4 the court held that even a single act of sexual intercourse after the act or incident leads to the condonation of that act

3 Modern hindu law DrParas diwan Allahabad law agency4 1975 AIR 1534

7 MEMORANDUM FOR THE RESPONDENT

_________________________________________________________

PRAYER

Therefore in the light of facts of the case issues raised arguments advanced and authorities

cited this Court may be pleased to adjudge and declare that

a) There is no existance of cruelty on behalf of respondent

b) The petitioner should get punishment under section 498(i) of IPC for treating

respondent with physical cruelty and for taking dowry under dowry prohibition act

1961

All of which is respectfully submittedAll of which is respectfully submitted

Place New Delhi

Date 15-3-2012

Vinay Kumar Sahu

(On behalf of the Respondent)

8 MEMORANDUM FOR THE RESPONDENT

appealent and his family members and misbehave with them is the result of petitionerrsquos way of acting with cruelty towards respondent

So doing both physical and mental cruelty is an offence under section 498(i) of Indian Penal Code which says that if the wifersquos husband or relative of the wifersquos husband do cruelty with the wife then the offender will be punished by imprisoned upto 3 yrs in jail and fine so the act of the petitioner of beating the respondent for dowry shows physical cruelty so the petitioner should get punishment under this section and according to Section 4 of Dowry Prohibition Act 1961which says that the act of demanding of dowry by any person directly or indirectly from the parents or guardian of bride or bridegroom is a dowry offence for which the punishment is imprisonment not less than five yrs with fine which shall not be less than Rs 15000 or the amount of the value of such dowry whichever is more so under this act the petitioner is also offender for harassing respondent for dowryIn the case the ground is cruelty or adultery the petitioner is also required to show that he or she did not condone the offence and the petitioner is also required to prove that there is no improper delay in the presentation of the petition3 so according to (b) and (e) of section 23 of Hindu Marriage Act 1955 as it states that ldquowhere the ground of the petition is the ground specified in clause (i) of sub-section (1) of section 13 the petitioner has not in any manner been accessory to or connived at or condoned the act or acts complained of or where the ground of the petition is cruelty the petitioner has not in any manner condoned the cruelty and there is no other legal ground why relief should not be granted then and in such a case but not otherwise the court shall decree such relief accordingly as in this case the appellant filed the petition by highlighting only one instance that the respondent wife abused his parents on the day of festival of lohri in the presence of relatives and neighbours which was happened in 1998 and the petitioner filed suit on the basis of this one act after 2002 when the wife left his home due to his misbehaviour and in 1999 a male child was born so there is sexual intercourse between the parties in the gap before filing the petition and as section 23(b) of Hindu Marriage Act 1955 states that a single act of sexual intercourse between the parties after the act or incident may lead to the condonation of the act and the court gets a legal ground for not granting relief so the petitioner should not get divorce on the ground of cruelty as in the Narayan Ganesh Dastane vs Sucheta Narayan Dastane4 the court held that even a single act of sexual intercourse after the act or incident leads to the condonation of that act

3 Modern hindu law DrParas diwan Allahabad law agency4 1975 AIR 1534

7 MEMORANDUM FOR THE RESPONDENT

_________________________________________________________

PRAYER

Therefore in the light of facts of the case issues raised arguments advanced and authorities

cited this Court may be pleased to adjudge and declare that

a) There is no existance of cruelty on behalf of respondent

b) The petitioner should get punishment under section 498(i) of IPC for treating

respondent with physical cruelty and for taking dowry under dowry prohibition act

1961

All of which is respectfully submittedAll of which is respectfully submitted

Place New Delhi

Date 15-3-2012

Vinay Kumar Sahu

(On behalf of the Respondent)

8 MEMORANDUM FOR THE RESPONDENT

_________________________________________________________

PRAYER

Therefore in the light of facts of the case issues raised arguments advanced and authorities

cited this Court may be pleased to adjudge and declare that

a) There is no existance of cruelty on behalf of respondent

b) The petitioner should get punishment under section 498(i) of IPC for treating

respondent with physical cruelty and for taking dowry under dowry prohibition act

1961

All of which is respectfully submittedAll of which is respectfully submitted

Place New Delhi

Date 15-3-2012

Vinay Kumar Sahu

(On behalf of the Respondent)

8 MEMORANDUM FOR THE RESPONDENT