She submitted before Justice Rajiv Sahai Endlaw that unlike the External Affairs Ministry's contention that her conduct raised questions about her "trustworthiness and integrity", in her 16 years of service she was "routinely adjudicated" as 'outstanding' or a very good officer with the highest degree of credibility and integrity.
In her response to the ministry's contention that she violated Indian Passports Act and Citizenship Act, Khobragade has said "it is respectfully stated that mother of the petitioners (Khobragade's daughters) never applied, nor allowed her spouse or dependants to apply for a foreign nationality or an immigrant visa nor is such a thing alleged by the respondents (Centre).
Khobragade has also said in her rejoinder affidavit that she has "served the country for 16 years with outstanding service records."
"The confidential notes written by the persons who have had the occasion to observe the conduct of the officer closely, routinely adjudicated the officer as 'outstanding' or a very good officer with the highest degree of credibility and integrity...," the rejoinder added.
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She has also said that her daughters were entitled to have Indian diplomatic passports.
"Hence this court is requested to quash all the actions which result from bias and vengeance," she has said.