To,

BHAVANA C PRITHWANI
Advocate
6,Sinfonietta Apartments, Model Colony, Lakaki road,
Shivajinagar,
Pune : 411 016

Dear Madam,

On behalf of my clients Miss. Summaiyya Rafiq Shaikh

alias Summaiyya Abubakar Inamdar r/o : 14/16
Chiragunddin Chawl, Chiraj Nagar, Ghatkopar west, Mumbai
400086 and as per the instruction given by her, I address you
as under :-

The notice dated 15/07/24 sent by you on behalf of Mr.

Abubakar Inamdar R/o: Anand Park, lane no.3, Thergaon
Pune- 411033 my client got it on 26/07/24. The reply for this
notice is as under :-

1) The contents of Para 1 of your notice are admitted by my

client

2) The contents of Para 2 of your notice is not admitted by

my client. The contents of the Para 2 of your notice is false
and fabricated by your client. Actually the fact is due to
your client’s 2nd sister’s new marriage and delivery and
 strong oppose from your client’s mother and negative over
involvement of your client’s brother in laws your client
delayed the marriage.

3) The contents of para 3 of your notice is not admitted by

my client. The contents of the para 3 of your …2

Notice is false and fabricated by your client. In the

month of August 2023 your client told my client that his
mother, sisters and both brother in laws are not ready
for this marriage and then your client insisted my client
to do court marriage and he also told my client that his
mother will have to accept them both after the marriage
and your client assured my client that his mother’s
behavior won’t affect our marriage.

4) The contents of Para 4 of your notice is not admitted by

my client. My client states that in the month of October
your client demanded my client and forced her to resign
from her job which was in Mumbai and your client also
threatened my client that if she doesn’t leave her job then
your client will divorce my client before the traditional
marriage. The first divorce threat was given to my client
on date 27/09/23 on next day of the court marriage. My
client request to your client that she has educational loan
on her and many financial constraints because of which
my client could not leave her job. In month of April my
client with her family members went to your clients house
along with Eidi, during the discussion between both family
members your client’s family went into a heated argument
with my client’s family for resignation of my client’s job
 and after that your client threatened my client to divorce
her in month of October.

5) The contents of Para 5 of your notice is not admitted by

my client. The contents of the Para 5 of your notice is false
and fabricated by your client. Your client’s family
members demanded my client’s family members to keep
marriage ceremony in Pune so it would be convenient for
your client’s family members and their relatives. Your
client’s family members demanded big and multiple food
menus for 500-700 people from your client’s side in
nikkah, my client’s family members and my client
explained that they won’t be able to handle 700 capacity
people from groom side because of their financial
condition due to which your client became angry and went
towards my uncle and was about to hit him. In full of
anger he disrespectfully said to my uncle that “ Nikal jaoo
mere ghar se” and he also said “Isko ghar se dhakke marke
bahar nikalo” and your client’s both brother in laws, sister
and mother told my client’s family to leave their house. On
next day your client started to threaten my client to break
this marriage. Inspite all of this my client on behalf of her
family apologized to your client’s family and was ready to
accept all demands of marriage ceremony.

6) The contents of Para 6 of your notice is not admitted by

my client. The contents of the Para 6 of your notice is false
and fabricated by your client. My client had noticed that
there was an extra marital affair of your client with a girl
named Faiza Hassan, your client requested that girl to do
court marriage at that your client was legally married to
me and all the thing stated above were known to your
client’s mother and your client’s mother also stated to my
 client that your client liked Faiza Hassan and the family
members of your client tortured and harassed my client.

7) The contents of Para 7 of your notice is not admitted by

my client. The contents of the Para 7 of your notice is false
and fabricated by your client. After marriage your client’s
mother started staring at my client in an unusual way every
now and then, your client’s mother did not allowed my
client to sit near your client. On 11th December there was a
small reception in which your client was holding my
clients hand and dress after seeing this your client’s
mother insulted my client in front of everyone present in
that hall. My client was always trying to treat her mother
in law like her own mother but your client’s mother was
the one which did not liked my client from the start and
also she demanded utensils, bed, cupboards and washing
machine along with Dowry.

8) The contents of Para 8 of your notice is not admitted by

my client. The contents of the Para 8 of your notice is false
and fabricated by your client. Your client’s family member
opposed us for going on Honeymoon, when my client and
your client went on Honeymoon to Ooty your client threw
telephone on my client and also threatened my client that
your client will marry another doctor in front of my client.
Your client’s mother told my client that she would tell her
son to divorce my client and also demanded for
honeymoon expenses.

9) The contents of Para 9 of your notice is not admitted by

my client. The contents of the Para 9 of your notice is false
and fabricated by your client. After returning from
 honeymoon your client joined his job and then your
client’s family members started to pressurize and torturing
my client to leave the job and sit at home. On 26/12/23
when your client was at office his mother threatened my
client to leave house and your client, and also tell to my
client at your client will easily get convince to give talak to
my client. When your client came from the office all
things was told by my client to him but instead of
supporting he became angry and threw helmet on my
client in parking area and also beated my client in the
bedroom at 2:00AM at night, due to which my client was
mentally as well as physically broken, due to this she
leaved your client house.

10) The contents of Para 10 of your notice is not admitted

by my client. The contents of the Para 10 of your notice is
false and fabricated by your client. On 18 th Jan your client
came to my client hospital campus and forced her to take
her home and apologized for the behavior of all his family
member’s, but my client requested your client to bring his
mother and father at my client’s house for purpose of
clearing the disputes, but after listening to the said things
your client got aggressive and told that I will not bring his
mother and father. On 30 June your client’s brother in laws
Faiyaz Baba and mohammad inamdar at my client’s house
and threatened my client not to communicate with your
client.

11) The contents of Para 11 of your notice is not admitted

by my client. The contents of the Para 11 of your notice is
false and fabricated by your client. Your client’s father
assured to keep the meeting at Nana’s house while leaving
from Mumbai, my client assured your client that after last
 date of duty in Mumbai, and my client will go your
client’s house in Pune, without keeping the meeting of
negotiation your client decided to give divorce to my
client.

12) The contents of Para 12 of your notice is not admitted

by my client. The contents of the Para 12 of your notice is
false and fabricated by your client. On 11/03/24 Fayaz
baba threatened my client to leave her job and to do all
house hold work including serving his parents, Fayaz baba
also told me that if you want to come to our house you will
have to do all the house hold work and no maid will be
hired, and Mohammad Inamdar told my client to leave the
job.Your client’s family members claimed that they will
decide whether your client will continue this marriage or
give you talak. On night of nikkah your client’s sister
fought with my client and in influence of his sister your
client raised hand on me and threatened my client that he
will throw my client out of the house. Your client claimed
that his mother is not happy with the marriage so he will
give my client triple talakh any time.

13) The contents of Para 13 of your notice is not admitted

by my client. The contents of the Para 13 of your notice is
false and fabricated by your client. On 30/04/24 your
client called my client and he threatened and abused my
client. On 01/05/24 your client called my client at late
night and started threatening and abusing my client.

14) The contents of Para 14 of your notice is not admitted

by my client. The contents of the Para 14 of your notice is
false and fabricated by your client. What happen is on
30/06/24 your client along with both of his brother in laws
 and father came to my client’s house and they threatened
my client and they told her not to communicate with your
client and they also said that they will decide what your
client will do with my client.

15) My client is ready to cohabit with your client and she is

ready to reside with your client by forgetting all things
done by your client and his family members in past. Only
one condition that assurance shall be given by your client
and his family members that they will treat my client with
good manners. She is not ready to give divorce to your
client.You are here by charged with its costs of Rs.
25,000/- for this notice reply which please further note.

Regards,

(Adv. Bilal Shaikh) (Mrs. Summaiyya Rafiq Shaikh)