IN THE COURT OF HON’BLE PRL.
SENIOR CIVIL JUDGE,
CUM ASST. SESSIONS JUDGE RANGA REDDY DISTRICT AT SHADNAGAR
H.M.O.P. No. 11 of 2022
Between:
M. Anand Kumar
...Petitioner
AND
Smt. M. Rashika Naik
…Respondent
WRITTEN ARGUMENTS FILED ON BEHALF OF PETITIONER
1. It is submitted that the Respondent is the legally wedded wife of the Petitioner.
The marriage between the petitioner and respondent was performed on 25.11.2020
at Janardhana Garden A/c, Sai Nagar-2, Nagaram Road, Nizamabad as per the rites
and customs of Hindu Religion and in the presence of elders and well wishers from
both sides and it is an arranged one.
2. It is further submitted that the petitioner was not interested in taking dowry
as such no dowry was given except some customary articles were presented to the
respondent at the time of the marriage. After marriage, the petitioner and the
respondent lived together at petitioner’s resident i.e H.No.13-129/8 Srinagar colony,
Farooqnagar mandal, Shadnagar, Ranga Reddy District-509216 and the marriage
was not consummated.
3. It is further submitted that that some disputes arose between the petitioner
and the respondent due to your indifferent attitude of the respondent. The
petitioner waited patiently as the respondent are new to the family and it requires
some time to settle down in the family.
4. It is further submitted that the respondent never treated the petitioner as her
husband. She never cooperated with the petitioner as a dutiful wife. The respondent
refused to have any physical contact with the petitioner. In the month of March,
2021 Vexed with the attitude of the respondent, the petitioner questioned the
respondent. Then the respondent informed the petitioner that she was not
interested to live with the petitioner. At the instance of elders and well wishers in
the month of March, 2021, the matter is settled amicably between the petitioner
and the respondent. The petitioner bore all the harassment with a fond hope that
the respondent would mend her ways and cooperate with the petitioner and behave
as a dutiful wife.
5. It is further submitted that in the month of June, 2021 the respondent have
expressed that she wanted to visit her paternal home to attend a pooja , and the
respondent informed the petitioner that her brother is coming to take the
respondent to her paternal home .The respondent brother came to the petitioner
house and the respondent went to her paternal home . It is further submitted that
the respondent promised the petitioner that she will return back in 1 week. After
completion of 1 week, the petitioner requested the respondent to come back and
join his conjugal life. The respondent expressed that she is not interested to live
with the petitioner. The petitioner tried to convince the respondent to come down to
join with him but in vain. On the next day, the respondent father made a phone call
to the petitioner’s brother and informed that the respondent father is not interested
to send the respondent to join conjugal life with the petitioner and also made all
false allegations on the petitioner.
6. It is further submitted that the respondent informed the petitioner that she
was not interested to marry the petitioner and it was a forceful marriage against her
will and that the petitioner is not a perfect match to the respondent and that the
respondent are not inclined to reside with the petitioner. The petitioner was
emotionally and mentally disturbed by the respondent behaviour and completely
shattered. The petitioner submits that there were many incidents which have
occurred during the respondent stay at the petitioner’s house to show the
respondent adamant attitude towards the petitioner’s and his parents.
7. It is further submitted that the respondent informed her relatives that the
respondent is not happy with the petitioner and also made all false allegations on
the petitioner. The respondent never acted as a dutiful wife and never showed love
and affection towards the petitioner. Inspite of several negotiations between the
petitioner and the respondent there is no change in the respondent attitude.
8. It is further submitted that he requested the respondent to join him, several
requests, but in vain. At last, the petitioner parent’s received a phone call from
respondent mediators fixed a meeting on 26-01-2022 at nizamabad i.e respondent
residence. On 26-01-2022 , at the instance of elders and well wishers both the
family discussed about the issues between the petitioner and the respondent . At
that time of discussions the respondent expressed that she is not interested to live
with the petitioner. The petitioner felt heartbroken.
9. It is further submitted that the respondent lodged a false complaint against
me and my family members in V Town Nizamabad PSA vide FIR No.39/2022 u/sec.
498-A,506,354 IPC , further the respondent filed a false complaint i.e DVC No.53 of
2022 in II Addl. Judicial First class magistrate, Nizamabad against me and family
members to harass us mentally with false allegations. All the actions of the
respondent would amount to mental cruelty on the petitioner. Having left with no
other alternate remedy, the petitioner approached this Hon’ble Court duly filed the
present petition seeking Divorce to dissolve the marriage Dt. 25.11.2020.
10. It is further submitted that the petitioner marked Ex.P1 to P3 documents to
prove his case.
It is therefore prayed that this Hon’ble Court may be pleased to pass a decree and
judgment in favor of the petitioner by dissolving the marriage Dt. 25.11.2020
between the petitioner and the respondent by decree of divorce on the grounds of
cruelty and pass such other or further reliefs as this Hon’ble Court deems fit and
proper in the circumstances of the case in the interest of justice.
Dt.19-11-2024 COUNSEL FOR THE PETITIONER
IN THE COURT OF HON’BLE PRL. SENIOR
CIVIL JUDGE,
CUM ASST. SESSIONS JUDGE RANGA
REDDY DISTRICT AT SHADNAGAR
H.M.O.P. No. 11 of 2022
Between:
M. Anand Kumar
...Petitioner
AND
Smt. M. Rashika Naik
…Respondent
WRITTEN ARGUMENTS FILED ON
BEHALF OF PETITIONER
Filed on: 19-11-2024
Filed by:
M/s. SATYA LAW CHAMBER
P. SATYANAND
Advocates
Counsel for petitioner
