Short answer. Under Rule 42, Section 5, your comment must be filed in seven legible copies with certified true copies of the record portions relied on and supporting papers, stating whether you accept the statement of matters involved, pointing out any insufficiencies without repeating them, and explaining why the petition should not be given due course.
What the law says
The comment of the respondent shall be filed in seven legible copies, accompanied by certified true copies of such material portions of the record referred to therein together with other supporting papers and shall (a) state whether or not he accepts the statement of matters involved in the petition; (b) point out such insufficiencies or inaccuracies as he believes exist in petitioner's statement of matters involved but without repetition; and (c) state the reasons why the petition should not be given due course.
Rule 42, Section 5 — Contents of comment. Read the full provision →
What the law says
A copy thereof shall be served on the petitioner.
Rule 42, Section 5 — Contents of comment. Read the full provision →
The filing requirements before you even get to content
Section 5 sets out concrete formal requirements: the comment must be filed in seven legible copies, accompanied by certified true copies of such material portions of the record referred to therein together with other supporting papers. That means you need to identify which parts of the record your comment actually relies on and attach certified true copies of those specific portions, not simply the whole record indiscriminately.
Requirement (a): accepting or disputing the petitioner's statement
The comment must first state whether or not he accepts the statement of matters involved in the petition. This is where you tell the court, up front, whether the petitioner's own framing of the facts and issues is one you agree with, or one you intend to contest — it sets the stage for everything that follows in your comment.
Requirement (b): pointing out inaccuracies without repeating them
If you do not accept the petitioner's statement, Section 5 requires you to point out such insufficiencies or inaccuracies as he believes exist in petitioner's statement of matters involved but without repetition. The "without repetition" instruction matters — the rule expects you to identify the errors or gaps directly, rather than simply restating the entire matter in your own words as a workaround.
Requirement (c): arguing against due course
The comment's substantive core is the third requirement — it must state the reasons why the petition should not be given due course. This is where you actually make your case to the appellate court for why the petition should not proceed further, and it is the part of the comment most directly aimed at the outcome you want.
Serving the petitioner
Finally, the rule closes with a straightforward service requirement: a copy thereof shall be served on the petitioner. Filing the comment with the court is not the end of the obligation — the petitioner needs their own copy as well, so they know exactly what you have argued and can respond to it in whatever further proceedings follow, rather than learning about your position only once the court rules.