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Need Advise (def)     30 January 2016

Ws amendment - need advise

My wife filed petition for divorce and I filed a WS after a delay which got granted. Filing of WS was one year back and opposite party filed rejoinder. Now, I see inaccuracies in my WS where specific denials are not therere and submissions have not been adequately made. Also, there are typological errors such as errors in dates. So, my lawyer suggested me to go with amendment in ws. Now i see, all there are too many in numbers around 50. My lawyer says so many amendments may be rejected and count should be brought down drastically.

Some queries for the learned members..


1) Some paras of petition there is no mention of date, time or place of the alleged incidents of cruelty is mentioned - I had denied the para in toto and stated that they are based on false and fabricated facts. Do I need to deny it specifically in the amended ws. Or it is not required as specific date or place is not mentioned.
2) An allegations is put in para A. of petition. say respondent scolded me and said so and so on such date. I have not made the denial there but denied in a more general way in para B of ws that I had never scolded petitioner. Can para B be referred in argument of para A. 
Thanks in advance..



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 1 Replies

Need Advise (def)     30 January 2016

Ma'M, Its not me who filed the divorce petition, its my wife who filed it and I am the respondent here. Thats why I have  filed the written statement.

I have and I need to file WS and I should not be withdrawing it too. However, my old lawyer made mistake in not denying adequately and not putting all the required submissions and filing more than a year back, even the most critical denials and submissions. Now rejoinder has been filed by opposite party and I want to make amendments. Th no of amendments are  way too many in numbers. So, my new lawyer advised to minimise the numbers so that amendment is not rejected. We want to bring it down from 50 nos to below 10. My quesries are based on the same.


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