IN THE COURT OF SENIOR CIVIL JUDGE PALAMEENER CAMP AT
KUPPAM
HMOP No 2023
Between:
T.Mohan krishana
….Petitioner
And:
S.Nishkrutha …
Respondent
PETITION FILED ON BEHALF OF THE PETITIONER FOR DISSOLUTION
OF MARRIAGE UNDER SECTION 13(1) (ia) OF HINDU MIRRIAGE ACT,
1995
1) PETITIONER:-
Native address: T.Mohan Krishana, Age about 29 years, Hindu, S/o. T.R.
Chalapathi Setty, Gandla by Caste, residing at 1-89, Mattam Village and
Gundusettipalli post, Santhipuram Mandal, Chittoor District, Andhra
Pradesh. Cell.-**************, Aadhar No. 312275806962. Occupation:
supervisor at Bijapur Milk Dairy V.Kota
The address of the petitioner is as stated above and also care of Smt. A.Haritha
advocate, Kuppam Chittoor District. Cell No. 8106457331
2) RESPONDENT:-
Smt. S. Nishkrutha aged 25 years, D/o. S. Venkataramaiah Chetty, Hindu,
Cast by Gandla caste, residing at J K Puram, Near Nayara Petrol Bunk, Raju
Pet Road Kyasamballa Hobli KGR Taluk, Kolar District Karnataka State,
Aadhaar No. 482773816578. Occupation: Accenture company as a Rugular
Contractor at Bangalore BDC9A: Mail Id: nishkrutha.siva@accenture.com,
The address of the respondent is as stated above for service of all notices,
summons, Process etc.
3. The petitioner submits that he married the respondent who is his wife under
the customs prevailed under their religious ceremony. The marriage solemnized on
26.05.2023 at SLV Kalanamandapam Santhipuram in accordance with Hindu
customs. The petitioner parents presented one Mangalyam chain along with
Mangalasutharam weighing approximately 40grams purchased at********shop
and bill no ----------- and, Silk sarees worth about 50000/-(Fifty thousand Rupees
only), to the Respondent. The petitioners parents also presented prior to the
marriage for the Respondent side marriage expenses 1,20,000/- (One lakh twenty
thousand rupees only), was to the Respondent in the presence of MS Subramanyam
S/o Srinivasulu Chetty of Ramakuppam, Madhu S/o Kodhandappa of JK Puram at
Respondents parents residence, and all wedding expenses borne by the Petitioner.
4. The petitioner submits that after the marriage Respondent joined with petitioner
at petitioner house at Mattam village of Santhipuram Mandal, where Petitioner
and respondent lived together about only 3 days, along with petitioner parent’s and
also petitioner’s elder brother and the petitioner working as a supervisor at Bijapur
Milk Dairy at Gandarmakulapalli of K.Kota Mandal and the respondent were
working for Accenture company as a Rugular Contractor at Bangalore as work
from home.
5. The petitioner submits that on 2/6/2023 the Respondent’s mother Namely------
took the respondent to spent some days to the respondent’s parent’s house at J K
Puram, my client further states that absolutely there was no sexual relationship
between the petitioner with respondent, from the beginning of the marriage no
conjugal happiness was provide by the respondent as a wife to the petitioner, and
respondent completely neglected the petitioner, and respondent not interested in
marriage, and during the first night day the respondent was moody, emotionless,
and expressed with the petitioner, that she is in monthly periods, and after she
spent 3 days also she was moody, and abnormally quit, and she does not allow the
petitioner to have sex or even not interested to that if the petitioner is tried to touch,
that without sufficient reason, it was caused mental cruelty, and petitioner was
suffered do to act and behavior of the respondent.
6. The petitioner submits that after the respondent went to her parent’ s house she
never come to her to lead a family life, and the petitioner made a phone call the
respondent did not shown any interest to talk with the petitioner, and on------ to till
now the respondent kept the petitioner’s contact number in block mode, the act of
the respondent show that the respondent not having any short of love and affection
towards the petitioner and she completely neglected the petitioner with out his
fault.
7. The petitioner submits that on 2/6/2023 to till now the respondent is staying
months together with her parent’s house, and the respondent not showing any
interest to lead married life with the petitioner, the petitioner further submits that
the petitioner and his family members in 3 days of lived by the respondent, they
given the respondent a honored position in the house as woman in half her husband
and completes the petitioner with view to mutual fidelity continue until death as
the petitioner very emotionally attached to the respondent, in other words the
petitioner loves the respondent too much and never uttered any words of abuse or
insult the respondent, and never quarreled with the respondent in order to lead
happy married life. But respondent deprived the conjugal rights of the petitioner
without any justification or reason.
8. The petitioner submits that on-------- 2023 my client visited the respondent’s
house rand requested the respondent to come and join with the petitioner house,
but the respondent have failed to neglected to join the petitioner. In this regard the
petitioner has convened several panchayaths and though the respondent had agreed
to join the matrimonial house, but the respondent have failed to keep up the
respondent promise and whenever the petitioner come and calls the respondent,
and the respondent have intentionally avoiding the petitioner and openly told that
the respondent are not intended to live with the petitioner. The petitioner submits
that the respondent only on the advice of her parent’s, and her relatives, but
respondent not interested to live with the petitioner.
9. The petitioner submits that the petitioner conduct panchayathis more than 19
times at the respondent’s parents house, has not changed his behavior in spite of
advice of the village elders not come for to restitute her conjugal rights, and finally
on 20-9-2023, petitioner and their parents and other caste elders namely Sri.
Vasanth Reddy, Kittappa, Ramu of J.K.Puram Village, M.Nagaraju of
Kanamanayanapalli Village, of V.Kota Mandal, M.S.Subrabmanyam of
Ramakuppam and also the uncle of respondent namely Raju and his Wife
Vanijamma all are came to Respondent’s native village and convened at
Gangamma Temple, all are they called to Respondent and her family members to
the panchayathi, but neither the respondent nor the parent’s of respondent attend or
responded to the said panchathi, then the petitioner return to that palce.
10. The petitioner submits that on 4-10-2023 he issued notice to the respondent to
come and join with the petitioner at matrimonial home in order to lead happy
married life with in a week, but the respondent did not received the notice and
refused to take the notice and with a intention to harass the petitioner and his
parents the respondent and his relatives ON ----10-2023 lodged a complaint before
SHO of -------------PS, and the Police called the petitioner and his family members
for counseling, hence on ----10—2023 petitioner and his family members attended
before SHO of -----Ps, but the respondent and her family members failed attended
before SHO.
11. The petitioner submits that the petitioner tolerating the harassment and torture
made out by the respondent that even the respondent not restitute her conjugal
rights towards the petitioner.
12. The petitioner submits that the petitioner unable to bare the torture casing by
the respondent the petitioner submits that he feels that it is no longer good on his
part to continue the family life with the respondent on account of the harassment
and cruelty caused by the respondent to his and therefore obliged to file this
petition for decree of divorce and for judicial separation with the respondent this
petition. Hence the petitioner is obliged to bring this petition for dissolution of
marriage that took place between the petitioner and the respondent by decree of
divorce.
12. The petitioner submits that there are no proceedings pending before any
court between the parties.
13. The petitioner last residing at Mattam villag of Santhipuam Mandal with
in the jurisdiction of this Hon’able Court. There is no collusion between the
petitioner and respondent to file this petition.
13. The cause of action of the petition arose on when the petitioner married the
respondent on 26.05.2023 at SLV Kalanamandapam Santhipuram in accordance
with Hindu customs. When the respondent used to torture and harass the petitioner
mentally by not restitute her conjugal rights towards the petitioner, when and
finally on 20-9-2023 the petitioner conduct panchayath before elders when the
respondent or her family members did not come to panchayathi, --- and that on 4-
10-2023 the petitioner issued notice to the respondent to join and lead happy
married life, when the respondent was refuse to take the notice, and when on-----
2023 lodged a complaint before SHO of PS and the respondent and her family
members neglected to appeared before SHIO, and respondent moths together
staying along with her parents house and when the respondent neglected the
petitioner and when the respondent harassed the petitioner to not restitute her
conjugal rights to words the petitioner and when the respondent not having interest
to lead happy married life and since from 5 months the respondent not came to
petitioner, from the beginning of the marriage the petitioner did no not have any
sexual relationship with the respondent, the petitioner and the respondent last
resided at Kuppam municipality within the jurisdiction of this Honorable Court.
13. The petitioner herewith paid a fixed court fee of Rs.10/- under Article
I (vii) Schedule II of A.P.C.F. and S.V.Act.
14. It therefore prayed that this Hon’ble Court may be pleased to pass
Judgment and decree of divorce:
A) That a decree of divorce be passed in favor of the petitioner and
against the respondent by dissolution of their marriage;
B) That cost of the petition is awarded to the petitioner;
C) That such further and other reliefs may be granted to the petitioner as
may be just;
Advocate for Petitioner Petitioner
I, the above named petitioner do hereby declares that the facts
stated above are true to the best of my knowledge and belief information
and I sing this verification at chittoor on / 9 /2022
Petitioner
List of Documents filed on behalf of the petitioner:-
1. Family photo.
2. Original Wedding card of the petitioner with respondent.
3. Xerox copy of Aadhar card of the petitioner.
4. Xerox copy of Aadhar card of the respondent.
5. Original Jewelry bill -Purchased by the Petitioner for the respondent.
6. Xerox copy of the Respondent’s working details.
7.
IN THE COURT OF SENIOR CIVIL JUDGE PALAMEENER CAMP AT
KUPPAM
HMOP No 2023
Between:
T.Mohan krishana
….Petitioner
And:
S.Nishkrutha …
Respondent
PETITION FILED ON BEHALF OF THE PETITIONER FOR DISSOLUTION
OF MARRIAGE UNDER SECTION 13(1) (ia) OF HINDU MIRRIAGE ACT,
1995
CONTENTS OF THE PETITION:
1 Every petition shall state:
a) The place and date of the marriage 7/2/2013 at petitioner house at
krishnadasanapalli village of
Kuppam town, post and Mandal,
Chittoor District,
b) The name of the parties and their : 1. Smt. A.Haritha D/o. Balappa,
occupation Residing at ----------------------------
Chittoor district. Aadhar No. Andhra
Pradesh. Cell. 8106457331, Aadhar
No. 3313 2498 3661.
2. Sri. M.Vijaya Rami Reddy, aged
50 years, D/o. Late. Madhusudan
Reddy, Hindu, Reddy by caste,
residing at 1-66/A,
Krishanadasanapalli village and post,
Kuppam Mandal, Chittoor District,
Andhra Pradesh. Aadhar No.4599
9989 0206.
c) The place and address where the parties : The petitioner last resided at,
reside or last resided together with the --------------------------nagar, Chittoor
jurisdiction of the court District, Andhra Pradesh
d) The names of the children if any of the : V.Samuel Paul Reddy who born on
marriage together with their date of birth 7/1/2014 now aged 8 years
and age
e) If prior to the date of petition there has : Nil
been any proceedings under the Act
between the parties to the petition, the
full particulars thereof
f) If the petition is for restitution of : Not applicable
conjugal rights, the date from which and
the circumstances under which the
respondent withdraw from the society of
the petitioner
g) If the petition is for judicial separation, The petitioner is filing the petition
the matrimonial offences alleged to other for divorce with respondent. The
grounds upon which the relief is sought petitioner have deserted respondent
together with full particulars thereof so and living separately without any
far as such particulars are known to the connection from since one year 9
petitioner months.
h) In case of alleged desertion the date and : The desertion took place one year 9
circumstances under which it began back at Krishnasasanapalli village
kuppam municipality Kuppam
Mandal and since then both the
petitioner and respondent living
separately. And petitioner living
separately at chittoor town.
i) In case of cruelty of sexual intercourse : Not applicable
with any person other than his or her
spouse, the specific acts of cruelty or
sexual intercourse and the occasion when
and the places where such acts were
committed together with the name and
address of the person or persons with,
when the respondent has sexual
intercourse.
j) In case of virulent disease when such : Not applicable
ailment began to manifest itself, the
nature and the period of the curative
steps taken together with the name and
address of the persons who treated for
such ailment and in case of venereal
disease and it was contracted from the
respondent
k) In case of un-soundness of mind, the : Not applicable
time when such unsound began to
manifest itself the nature and period of
any correct steps taken together with the
name and address of the person who
treated for such unsounded of mind
l) If the petition is for divorce matrimonial : The petition is filed for decree
offences alleged for other ground upon divorce petitioner have deserted
which the relief is sought together with respondent since one year 9 months
the full particulars thereof, so far as there is no connection between the
particulars are known to the petitioner petitioner and respondent.
Counsel for the Petitioner Petitioner
IN THE COURT OF SENIOR CIVIL JUDGE PALAMEENER CAMP AT
KUPPAM
HMOP No 2023
Between:
T.Mohan krishana
….Petitioner
And:
S.Nishkrutha …
Respondent
AFFIDAVIT FILED ON BEHALF OF THE PETITINOER
I, A.Haritha, Age about 34 years, Hindu, D/o. A.Balappa, Gandla by Caste,
-----------------------------------------, Chittoor District, Andhra Pradesh. Cell.
8106457331, Aadhar No. 3313 2498 3661. Do hereby solemnly affirm
states as follows:
1. I submits that I married the respondent who is my husband under the customs
prevailed under their religious ceremony. The respondent married me even though
they are different cast and with different formalities married my self at simple
manner with limited family members at my parents house at Krishanadasanapalli
village of Kuppam Town, on 7/2 /2013.
4. I submit that at the time of marriage my parents gave 50 grams of gold
chain, necklace, ear tads, to me and also utensils for domestic life and also my
brother gave one gold ring to respondent, the marriage was celebrated at the
expenses borne by my parents own cost.
5. I submit that after the marriage, my brother asked me to come and live in a
portion at his residence at Krishnadasanapalli, kuppam, the house was rented freely
to us then me and respondent lived happily married life for only about 10 days.
The respondent is addicted to drinking habits much prior to quarrel with my
parent’s for money for his bad habits. But the respondent attitude is not changed
toward myself even after the marriage, and the respondent used to come to home in
the late night by taking alcohol and beat me black and blue without any reason or
fault on myself. The respondent also started to harass me fetch money from my
patent’s house for his bad habits, when I refused to do so, the respondent used to
beat me black and blue and harass me physically and mentally mean while I
conceived and gave birth to a male child name by Samuel Paul Reddy on 7-1-2014
and now the age of child is 8 years. And I lived with the respondent by tolerating
the harassment made out by the respondent as the respondent is habituated for
drinking and other illegal activates but I was tolerating all the harassment caused
by the respondent.
6. I submit that the respondent was not maintaining properly the family life
and not providing any materials for the leading of married life. I submit that due to
heavy torture caused by the respondent I habe not planned for even second child. I
submit that the I left the respondent house along with my child and went to
Dharamapuri of Tamilnadu to my elder sister house and lead a life for some time
and mean while the respondent approached me with a mediators and under took
that he would take care of me properly and asked me to come with him to lead a
married life, trough the belief of the respondent talk I came along with child for
rental house at Kuppam town opp. to Panchayath office, Palace extension road,
Kuppam. After that to lead a life when the respondent not went for work, since I
was started advocate practice at kuppam, and palamaneru court. And mean while
the respondent met with 2 times road accident in the year 2019 and 2020 the
petitioner took the respondent to Krishnagiri, Ravikumar Hospital for treatment
and all the expenses was made by my brother and sister, the surgery cost for two
times around 900000/- was spent by my parent’s. And the respondent was bed
redden my brother and my parents was provided all family necessities to my
family.
7. I submit that when the respondent is bed redden the I again started for went
advocate profession, the respondent use to make hurdles stating that I should not
obeying and contact with male clients and instructed not to talk with any male
clients, and suspect my character and also the respondent did not stop his
harassment such as beating me in a drunken stage the respondent used to beat me
black and blue, hence I has convened number of panchayaths before the village
and family elders and in spite of advice of the village elders the respondent did not
change his behavior and cause severe mental torture to me.
8. I submits that the respondent has no love and affection towards me and my
child the respondent is not taking care of me and child, even respondent has not
changed his attitude and behavior in spite of advice of the elders since from
beginning of marriage and the respondent also made harassment by way of the he
belongs to upper caste and I am belongs to lower caste and also criticize every time
in the name of caste and whenever my relatives visit my house abuse them in the
name of the caste, and instructing me any of the relatives should not visit the my
house. I submits that by this stage I joined my child into Montfort centernary
school of Model colony, kuppam and give in to custody of my grandparents house
at Krishnadasanapalli village and came to Chittoor on January 10 th of 2021 and
living separately at rented house, and practicing as advocate in palamaneru and
chittoor courts as junior advocate.
9. I submits that after that I shifted my house to chittoor the respondent
frequently visiting my house -------------- nagar, chittoor and picking up
unnecessary quarrels and demanding me to and threatening the me that he will kill
me if me and my parents have not provided the property and amount as demanded
by him. I submit that is leading my life with afraid of that the respondent will do
away her life at any moment as he is behaving like psycho, and I give complaint to
the Kuppam police and as well as Chittoor Police and the police officers was
admonished the behavior of respondent but the respondent again continuing his
bad habits, and I am unable to bare the torture casing by the respondent I submits
that I feels that it is no longer good on my part to continue the family life with the
respondent on account of the harassment and cruelty caused by the respondent to
me and therefore obliged to file this petition for decree of divorce and for judicial
separation with the respondent this petition. Hence I is obliged to bring this
petition for dissolution of marriage that took place between me and the respondent
by decree of divorce.
10. I submits that I feels that it is no longer good on my part to continue the
family life with the respondent on account of the harassment and cruelty caused by
the respondent to me and therefore obliged to file this petition for decree of divorce
and for judicial separation with the respondent this petition.
11. I submits that there are no proceedings pending before any court between
the parties.
12. I submits that last residing at Chittoor Town with in the jurisdiction of this
Hon’able Court. There is no collusion between my self and respondent to file this
petition.
13. The cause of action of the petition arose on when the I married the
respondent on 7/2/2013 according to their customs in the Kuppam Town and
Mandal, when the respondent addicted to drinking habits and demanding the
petitioner to arrange amount for his bad habits, when the respondent used to torture
and harass the me physically and mentally by suspect my character, and abusing
in the name of the cast, and when I convened panchayath before the elders of
family, when the respondent has not changed his behavior in spite of advice of the
village elders and continue to harass the petitioner and continues from day to day
at Kuppam municipality where myself and respondent last resided, and where
myself living separately in Chittoor town within the jurisdiction of this Honorable
Court.
Petitioner advocate for petitioner
Solemnly affirm and signed before me at kuppam on 8th day of 2022.
Advocate
IN THE COURT OF SENIOR CIVIL JUDGE PALAMEENER CAMP AT
KUPPAM
HMOP No 2023
Between:
T.Mohan krishana
….Petitioner
And:
S.Nishkrutha …
Respondent
THE ADDRESS OF THE PARTIESFURNISHED UNDER ORDER 7 RULE
14(a) of C.P.C
1) PETITIONER:-
A.Haritha, Age about 34 years, Hindu, D/o. A.Balappa, Gandla by Caste,
-----------------------------Chittoor District, Andhra Pradesh. Cell.
8106457331, Aadhar No. 3313 2498 3661.
The address of the petitioner is as stated above and also care of Sri. Vijay
kumar advocate, Chittoor District. B.Com., LL.B., Advocate, Cell No.
for the purpose of summons, notices, process etc.
2)RESPONDENT:-
Sri. M.Vijaya Rami Reddy aged 50 years, D/o. Late. Madhusudan Reddy,
Hindu, Reddy by caste, residing at 1-66/A, Krishanadasanapalli village and
post, Kuppam Mandal, Chittoor District, Andhra Pradesh. Aadhar No.4599
9989 0206.
The address of the respondent is as stated above for service of all notices,
summons, Process etc.
Advocate for Petitioner
IN THE COURT OF SENIOR CIVIL JUDGE PALAMEENER CAMP AT
KUPPAM
HMOP No 2023
Between:
T.Mohan krishana
….Petitioner
And:
S.Nishkrutha …
Respondent
PHOTOGRAPHS OF THE PARTIES
IN THE COURT OF THE SENIOR
CIVIL JUDGE PALAMNER CAMP
AT KUPPAM
H.M.O.P.No. Of 2023
PETITION FILED ON BEHALF OF
THE PETITIONER BY MUTUAL
CONSENT UNDER SECTION 13B OF
HINDU MARRIAGE ACT, 1955
Date of fling :
Filed by:A.Haritha.,BA.,LL.B.
Advocate
Kuppam
8106457331
IN THE
H.M.O.P.No. Of 2022
DUPLICATE COPY
PETITION FILED ON BEHALF OF
THE PETITIONER BY MUTUAL
CONSENT UNDER SECTION 13B OF
HINDU MARRIAGE ACT, 1955
Date of fling :
Filed by:
A.Haritha
Advocate
Kuppam
8106457331
IN THE COURT OF THE SENIOR CIVIL JUDGE, PALAMANER
CAMP AT KUPPAM
H.M.O.P.No. of 2022
Between:
S.Venkatasubbaiah
…….Petitioner
And:
Malathi …… Respondent
THE ADDRESS OF THE PARTIESFURNISHED UNDER ORDER 7 RULE
14(a) of C.P.C
1) PETITIONER:-
Venkatasubbaiah S/o. Subbaiah, Age about 24 years, Hindu, Vadde by
Caste, residing at Govindapalli village, PES post, Gudipalli Mandal,
Chittoor District, Aadhar No. 248943753033. Do hereby solemnly affirm
states as follows:
The address of the petitioner is as stated above and also care of Smt. A. Haritha,
B.A., LL.B., Advocate, Kuppam Cell No. 8106457331.
1) RESPONDENT:-
Smt. Malathi aged 21 years, D/o. Sudhakar, Hindu, Vadde by caste,
residing at near MTB water tank, Omshakthi Layout, Kaverinagar,
Mahadevapuram Poat, Banglore, Karnataka State. Aadhar No.
956615847012.
The address of the respondent is as stated above for service of all notices,
summons, Process etc.
Advocate for Petitioner
IN THE COURT OF THE SENIOR
H.M.O.P.No. Of 2022
PETITION FILED ON BEHALF OF
THE PETITIONER UNDER SECTION
13 (1) ia OF HINDU MARRIAGE
ACT, 1955
Date of fling :
Filed by:
IN THE COURT OF THE
H.M.O.P.No. Of 2022
DUPLICATE COPY
PETITION FILED ON BEHALF OF
THE PETITIONER UNDER SECTION
13 (1) ia OF HINDU MARRIAGE
ACT, 1955
Date of failing :
Filed by:
IN THE COURT OF THE SENIOR CIVIL
H.M.O.P. No. 2022
Document no:
Nature of Document:
Date of Document:
Description of Document:
Filed on: / /2022
Filed by :
