Aman chawla (DELHI HIGH COURT ADVOCATE) 12 June 2018
You can place preliminary objection in one part and reply on merits on other parts in along with that you can also place some preliminary submission.
In the preliminary objection, you can write how this petition is not maintainable, in reply on merits you can just deny all the allegation para wise and in last (It is optional) in preliminary submission you can write your side story.
TR NIMADE (AM) 12 June 2018
Shri Aman,very good answer and to the point.This is most suitable counter attack pointing out step by step particularly the word "you can write your side story."
I am informiong the latest judgments to my circle.I will happy to update your mail id for the purpose,if u desire.