Hi All,
Today i received summon from SC on stay proceeding for chennai family court divorce case. Pleading for transfer case from chennaii to mumbai from my ex side.
Reason mentioned in their transfer plea, My justifying points in bracket..
1) Her Father and mother are old that she had to take care of them so frequent travel is a problem. (both of them are working till now)
2) She needs to take care of his brother. ( he is 23 years old already completed mariine engineering and worked abroad).
3) She is not financial sound and not working. (She completed MA and B.ED and during 2009 she was doing Mphil and was working at that time)
4) She enrolled new management course in 2011 so she cannot travel.
These are the points she is praying to get transferred.
I have to file counter first and attend ( lawyer or buy person) in jan hearingin SC. My counter points are...
1) They filed cheque bounce case 138 by stealing one of my cheque but when my lawyers asked for genuity of signature. they stopped to attend and didnt pay fine imposed by court, it got dismissed (lack of attendence) in their native mumbai court. which is hardly 2 km from their place.
2) No children out of marriage.
3) Already MC filled by her in chennai is still pending.
4) Current divorce case in chennai is in Pw1 cross and then final judgement. Just 2 hearing to come to a conclusion.
5) They took all my certificates and jewels locking one portion of my mother house till now . Without my orginal i am out of job for three years.
6) Dowry case is still on in chennai and they are not attending reguarly even when we allow them to get divorce and dowry date next day or the other.
There are lot of other good points for me to counter saying they do this just to harrass me by transferring case to mumbai and eventually they wont attend, pointing out wat they did for 138 case.
Will these points help me to get transfer plea dismissed...Pls reply
