Divorce exparte

Dear Client,

In your counter affidavit, you should clearly state that you are employed as a physical labourer in the Gulf, where your work involves standing for 10–12 hours a day, climbing approximately 1,000 staircase steps daily, lifting and carrying heavy loads, and performing other strenuous physical activities. Explain that despite suffering from persistent knee pain, you continue to work only to meet your financial obligations, medical expenses, and future savings, and not because you are physically fit.

You should also state that you have consulted an orthopaedic doctor, who has advised conservative treatment consisting of rest, physiotherapy/exercises, a proper diet, and periodic review over the next few months before determining whether you are medically fit to continue such physically demanding employment. If possible, annex a written medical certificate or opinion along with your medical reports and bills, as documentary medical evidence carries greater weight than an oral opinion.

These facts are relevant for the Court to fairly assess your present earning capacity, medical condition, and ability to pay maintenance.