BEFORE THE DISTRICT JUDGE OF FAMILY COURT,

MADURAI

H.M.O.P.No. 725/2023

G.Maragathapriya …Petitioner

-vs-

R.Mohan …Respondent

COUNTER FILED BY THE RESPONDENT

The Respondent above named begs to submit as follows.

The address for service of all notices and processes on the

side of respondent is that of his counsel, M/s. M.S. Parthiban,
having office at 4/229 Harini Arumuga Nagar, Narasingam Road,
Kadachanendhal, Madurai—625107.

1. It is submitted that each and every paragraph in this petition

is denied as false, unless it is admitted deliberately,

2. The respondent is hereby admitting the marriage but

disputing the jewels and the value of the sridhana
properties. As the same has to be proved by the
petitioner.
3. It is submitted that at the time of marriage, the
petitioner brought a steel bero and a few utensils as
sridhana properties and after she came to Chennai, she
lived with the respondent, where she purchased a cot,
fridge, and Mixer grinder, hence as a total sridhana
property would come around rupees 50,000 (Fifty
thousand rupees). It is pertinent to mention here that,
at the demand of the petitioner the respondent has
 returned all the sridhana properties which were there in
Chennai to the petitioner who was residing at Madurai.
4. It is submitted that the respondent is hereby denying all
allegations in para no.5. The petitioner is hereby
denying the allegation of the petitioner that the
respondent had promised the petitioner and her
parents that his salary would increase. The fact remains
that there was no conversation with respect to the
salary increment of the respondent. The respondent is
hereby denying the allegations with regard to spending
money of both Petitioner and respondent and also
denying the allegation that the respondent came home
in a drunken state and scolded her and her parents with
obscene language. The facts remain that it is the
respondent’s salary which was used for household
expenses and also it is the fact that the respondent is
not having a habit of drinking alcohol as alleged by the
petitioner. It is pertinent to mention here that it is the
petitioner who requested the respondent to buy a wine
in the month of _______2019, the respondent who was
shellshocked on hearing the request from the
petitioner, took the same in a lighter way for the
welfare of the family. The respondent is further denying
the very allegation that he never showed any happiness
during the pregnancy of the petitioner which is nothing
but a highly concocted imaginary statement. The
respondent is hereby denying the very allegation that
on the 2nd week of July 2019, the respondent doubted
the petitioner’s chastity and scolded her with obscene
words, the respondent is further denying that the
respondent used to illtreat the petitioner on a daily
basis. It is pertinent to mention here that it is the
respondent who had taken care of the petitioner by
taking her to the hospital and scan centres at regular
intervals. The respondent is further denying the very
 allegation that the respondent was planning to go
abroad and on such pretext scolded the petitioner by
doubting her chastity and integrity and behaved like a
mental patient. The facts remain that it is the petitioner
who behaved as such whereas now she is playing topsy
turvy, and it is the respondent who tolerated all the
unusual behaviour of the petitioner, epically it is the
petitioner who always doubted the respondent and
unnecessarily concocted narrations with the
respondent’s officemates. The respondent chewed
everything for the welfare of the family thinking that
the petitioner was behaving as such in view of her
pregnancy and prepartum depression. It is pertinent to
mention here that it is the respondent who had cooked,
washed, and took care of the petitioner on those
pregnancy time. The respondent never doubted the
petitioner’s chastity or self-discipline and never taunted
or scolded her with obscene words rather the
respondent transported the sridhana properties at the
whims of the petitioner.
5. It is submitted that the respondent is hereby denying all
allegations in para no.6. The respondent is denying the
allegation that he never came to see the child. The fact
remains that the petitioner informed the respondent on
2nd January 2020 evening at around 7 pm hearing the
same the respondent boarded the train by taking a
general class ticket and went to Madurai. Since the
petitioner felt the pain suddenly due to the loss of
amniotic fluid C-section was planned all of a sudden
and hence the birth took place as unplanned. When the
respondent was travelling in a train, he received a call
from the petitioner’s uncle who told him that the
petitioner had given birth to two male children. The
very next day the respondent reached Madurai the
respondent went to hospital and directly stayed with
the petitioner and his children. It is pertinent to mention
here that the respondent’s mother who was at
Tharapuram went to the hospital on the very same day
(i.e) on 02.01.2020. it is further a fact that, it is the
respondent who spent and arranged the name
ceremony for his children and hence respondent is
denying the allegation concerning the same and also
denying the narration as if there was a conciliation and
the respondent accepted to pay Rs. 5,000/- for monthly
and promises which were nothing but a pure concocted
story. It is pertinent to mention here that the
respondent transported the above-mentioned things
after the birth of the children for the needs of the
petitioner and children and that too at the request of
the petitioner. It is further a fact that it is the petitioner
who wanted to reside in her parent’s home and stated
the reason that she felt comfortable only while residing
at her parental home in view of the twin toddlers.
Though the respondent requested the petitioner to
come to Chennai and to live with him the petitioner
used the twin toddles as bait to keep herself as
comfortable in her parental home and the same got
continued in view of the Covid-19 pandemic. The
respondent is hereby denying the allegation that the
petitioner abstained herself from reaching the
petitioner’s parental home in order to meet her and his
renren for 2 months and further denying the allegation
that the respondent scolded the petitioner with obscene
words and questioned her self-discipline when she
questioned reasons. The fact remains that the
petitioner knew verywell that it was a complete
lockdown at Covid-19 pandemic and hence the
transportation was limited by the government. It is
pertinent to mention here that at one instance on June
2020 due to lack of adequate transportation the
 respondent come all the way from Chennai to Madurai
in his bike out of love he had with the petitioner and his
children. It is further a fact that the respondent
celebrated the Tonsure function of his children in the
month of 2020 in his native temple in Coimbatore for
which the petitioner and her relative came in a van and
celebrated happily suppressing all these facts the
petitioner is narrating entirely a concocted story which
is completely false.
6. It is submitted that the respondent is hereby denying all
allegations in para no.7. especially the respondent
hereby denying the allegation that the petitioner is
living without any sexual pleasure in the marital life and
further denying the fact that the respondent has not
maintained their children. The facts remain that the
respondent has taken care of the petitioner and his
children. It is submitted that at the instances, the
petitioner is denying the respondent’s request to shift
herself to Chennai or to his native Tharapuram. Further,
the petitioner used to point out her job being working
from home and pointed out the children refused to
travel to Chennai and pointed out the internet
connection to travel Tharapuram.
7. It is submitted that since the respondent lost his
earnings due to the terminate project in Month of Nov
2021 got new job in the month of June 2022 and as
such interregnum period the respondent managed to
earn parttime job earnings to the petitioner whenever
he met her.
8. It is submitted that on 26.01.2022 the petitioner and
her parents attend the “Panchasamaskaram” function
at Srirangam, Thiruchy.
9. It is submitted that the petitioner’s parents who are
influencing the petitioner not to live with the
respondent for the reason best known to them. Since
 the petitioner’s parents who are taking care of them
may be the reason for such intention to keep the
petitioner with them. It is further submitted that despite
repeated demands from the respondent it was the
petitioner’s parents who were on the front line to refuse
the respondent’s request to live with the respondent.
10. Hence the respondent humbly prays to dismiss the
case with costs.

Respondent

BEFORE THE DISTRICT

JUDGE OF FAMILY
COURT, MADURAI

H.M.O.P.No. 725 /2023

COUNTER FILED NY THE
RESPONDENT

COUNSEL FOR THE

RESPONDENT

M.S.Parthiban
M.MARUTHUPANDIAN

7871544810