(i) Whether Triple Talaq is unconstitutional on the ground that it violates the

fundamental right of women in general and Muslim women in particular?

The Respondent humbly would like to submit that the contention to the
honourable court that Personal law may connote a different thing but keeping
the changing society in mind, it should be open to interpretation only for
positive changes. That only can help us achieve the objectives of Social Justice
laid down both expressed and implicitly in our Constitution. The counsel
would also state that Section 2 of Muslim Personal Law (Shariat) Application
Act, 1937 was unconstitutional as it violated fundamental rights guaranteed
under Articles 14, 15, 21 and 25 of the Constitution. Further counsel would like
to enumerate that Muslim women are being discriminated through this talaq
system of divorce citing case laws.

(ii) Whether the Muslim womans right to claim maintenance from her husband
under section 125 Cr. P.C. is circumvented by the provisions of Muslim Women
(Protection of Right on Divorce) Act, 1986 and if so, whether it violates any of
the constitutional provisions?
It is most humbly submitted before this honourable court that the petitioner is
entitled to claim maintenance under section 125 CrPC for it is a general law
applicable to all irrespective of any religion enacted to provide speedy and effective
remedy, to needy and vagrant people who are left on the mercy of Almighty without
having any means for their survival. Section 125 being civil nature is purposely
kept in this code to provide strict compliance to the rights of women and for their
welfare and to protect the interests of divorced women who is left at the mercy of
the husband. The apex court in its plethora of judgements has reiterated this aspect
that the Muslim women is equally entitled to claim maintenance under 125 of the
code. Through 3(1)(a) of the Muslim Divorce Act of 1986 means that husband has
to pay for all future expenses and a fair and reasonable claim within the period of
iddat and not that his liability is for the iddat period only. The words Within iddat
 period are purposely kept in the code to ensure speedy and effective claim for the
divorced wife who has no other means for her survival but maintenance. The claim
of maintenance by a divorced Muslim Wife necessarily need not be restricted only
to the iddat period.

(iii) Whether a married woman in general and a married Muslim woman in

particular has a legal right to claim separate residence in the matrimonial
home?
It is humbly submitted that a married women in general and married Muslim
women in particular has a legal right to claim a separate residence in matrimonial
home. The respondent would like to focus on Sec 3 , Sec 3 (b)(1) and Sec.18(2) of
Hindu Adoption and Marriage Ac and Sec 18 and 19 of the Domestic Violence Act.
With reference to the above referred sections, it is the submission of the respondent
that claiming for a separate residence is essential for the Married women and it is
within the scope of the constitution.