1. Have you not engaged a lawyer? If you have engaged one then it is his job to draft your reply which has to be done after perusal of the petition. We have not read her draft, so cannot tell you how to draft your reply.

2. The onus to prove her income is on you. File your reply to her application. An application has to be filed to seek court's direction to the employer to appear in the court with her record. The court may in its discretion summon any person or any document.

3. For a woman to state that she is unemployed, in order to create cause of action for maintenance, is not lying on oath.

1) file application under section 91 cr pc calling upon wife to produce her income tax returns for last 3 years , her bank statement

2) in your reply mention that wife has suppressed material fact form court is not entitled to any maintenance

3)file application for perjury under section 340 cr pc read with section 191 , 193 of IPC

Adduce all the evidence before the Court to establish your claim that your wife is not jobless. Also, because she has misrepresented actual facts before the Court, file an application under s. 340 for perjury together with your objection.

Anyone giving false affidavit under sec 296 CrPC can be held liable for offence against public justice. Besides, in the next hearing you should counter her affidavit giving evidence of her employment and therefore any claim of her for maintenance .

You can frame the objection accordingly and produce before the court all the documents which shews otherwise to what she has claimed in her petition, it is advised that you consult a local lawyer who will help you in drafting an appropriate reply. Please annex all the prove that you have against her.

Regards

Since making lieon oath is a criminaloffenceyou cna criminally prosecute her for telling this lie.

So you can file a petition u/s340 crpc so she can be prosecuted for perjury and punished fir this.

First of all establish her employment details through the cross examination, if she denies then you may summon the employer to furnish the details through court by filing a petition under section 91 cr.p.c.