The scathing reply, filed as a 65-page affidavit, is the official response of the Ministry of Defence (MoD) to Bhagwat's request for reinstatement and, in turn, makes a plea for his petition being dismissed.

Kumar's affidavit, filed last month, includes confidential documents purported to be evidence of Bhagwat's ``forgery.'' For instance, the affidavit says that the Directorate of Naval Law has found that Bhagwat ``commanded'' the Naval Advisor in London to prepare ante-dated documents against the present Deputy Chief of Naval Staff, Vice Admiral Harinder Singh, and prepared his Annual Confidential Reports (ACRs) on the basis of these fabricated documents.

Bhagwat had filed his petition in July this year after the High Courts in Delhi and Mumbai had dismissedthree PILs on the subject of his dismissal. In response, his successor has called him a ``genetic liar'' and a ``compulsive litigant who is in the habit of making wild, reckless, motivated and unsubstantiated allegations against one and all.''

Kumar claims that a pointer toward the former Naval Chief being a ``security risk'' (one of the grounds of his dismissal) was the fact that he attached classified MoD records along with his petition. But he ``cleverly'' did so six months after his dismissal so he could escape disciplinary action under Section 80 of the Navy Act. Bhagwat is expected to shortly reply to these counter-allegations, after which his petition will either be admitted or dismissed in court.

Kumar has alleged that the dismissed Chief ``habitually'' spoiled ACRs of subordinate officers and that the dossiers of two officers--Captain Contractor and Commander Bandopadhya--could be produced in court to prove this.

Kumar has also tried to rebut some of Bhagwat's claims prior to his dismissal. Healleges that Bhagwat lied when he said the Director of Naval Intelligence unilaterally lodged a protest with the Pakistan High Commission regarding over-flying of Pak planes over Naval ships. The decision to lodge a protest, according to the the affidavit, was taken jointly by the top brass of the Navy in Bhagwat's presence. These records, the Mumbai High Court has been told, can also be produced as and when required.

The reply to courts gives an indication as to how vitiated the relationship between Kumar and Bhagwat had been. Kumar had said that while he had given a copy of his official representation (on the subject of seniority in command) to Bhagwat in August 1998, he had not forwarded it to Defence Minister George Fernandes.

When reminded on telephone, Bhagwat threatened him and Kumar took the extreme step of officially informing the Defence Minister about the episode.

Sushil Kumar's December 2, 1998 letter is annexed with the affidavit for the Mumbai High Court. It states: ``I received a shorttelephone call from CNS, Admiral Vishnu Bhagwat. He shouted at me in an angry and belligerent tone and threatened me ...during this unprovoked hysterical outburst he became practically incoherent. I pleaded with him that he was speaking to me on an open Naval telephone circuit and that it was not fair to treat his C-in-C so shabbily and in such a threatening and intimidating manner. All this fell on deaf ears...''