In the court of the Prl.

District Judge, Nellore

D.O.P.No : 244/2022
Dasari Nigel Vikas Kumar
S/o Vijaya Kumar
Christian aged about 30 years
R/o Flat No: G4 Pavani Park Apartment
More Supermarket Road, Magunta Layout
Nellore - 524004
SPSR Nellore Dist ….Petitioner
VS
Pallem Meghana
W/o Dasari Nigel Vikas Kumar
Presently at
C/o G.V. Ravi Varma
Chief Mechanical Engineer, APSRTC
O/o Bus Bhavan, APSRTC
Vijayawada City
Krishna Dist ….Respondent

Petition filed U/S 10 (X) of The Divorce Act, 1869

on behalf of the Petitioner

1. It is humbly submitted that the petitioner Dasari Nigel Vikas Kumar is son of
Vijay Kumar, Christian, aged about 30 years, R/o Flat No: G4 Pavani park
apartment, Magunta layout, Nellore, SPSR Nellore District, and his address
for service of all summons and process is that of his advocates S. Murali
Krishna B.Tech., B.L., M. Lakshmayaah B.Sc., B.L., D.No: 25-3-232, Nethaji
Nagar, 4th street, Nellore, SPSR Nellore District.

2. It is further submitted that the respondent address for service of all notices
and process is the same as stated above.

3. The petitioner humbly submits that nearly about three years ago,
respondent’s mother as mutual friend of one Malleswari got introduced to
petitioner’s mother developed acquaintance with petitioner’s family, there
from the mother of respondent noticed that the family of the petitioner as
well sounded, in that context, the mother of respondent found that the
petitioner as unmarried and only son to his parents, with that the
respondent’s mother introduced the respondent to the petitioner, then
onwards as per the instructions of respondent’s mother, the respondent
developed intimacy with the petitioner for a reasonable period of time and
placed marriage proposal to marry her, for which the petitioner requested
time and through bonafide enquiry found that the respondent as not
suitable woman to him, in accordance to that, the petitioner refused to
marry the respondent, to that effect, the respondent committed suicide
and got admitted at KIMS Hospital, Nellore. Then respondent along with
 her mother emotionally blackmailed the petitioner and threatened him
with dire consequences stating that respondent would initiate criminal
cases against the petitioner unless the petitioner get married the
respondent without dissent, to that effect on 19.02.2020 marriage of the
petitioner was performed with the respondent as per Christian rites and
customs at Saint Blessica Church, opposite PWD grounds, Vijayawada in the
presence of both side elders and well-wishers.

4. The petitioner further submits that the marriage was solemnized and
consummated. Further with immediate effect after marriage, on
20.02.2020 respondent joined cohabitation at her in-laws’ house situated
at Military Colony, Dargamitta, Nellore. Further the respondent and the
petitioner lived together happily in the association of petitioner’s parents
for a period of one week, thereafter the respondent started to dispute with
petitioner’s repeatedly for four months with an intent to put up separate
family at new house that owned by petitioner’s mother at Pavani park
apartment, More super market road, Magunta Layout, Nellore, meanwhile
mediations went futile for the above matter and the respondent stood
strongly to put up a separate family even though the petitioner requested
her that he is only son and he has responsibility to look after his parents.
Moreover, the respondent threatened the petitioner with dire
consequences stating that she would commit suicide, if not fulfilled her
demands along with the demand of conveying the ownership of the flat at
Pavani apartments that belongs to the mother of the petitioner to her
favour. The petitioner further submits that for the above said demand of
conveying the property the petitioner refused and for that the respondent
ceased to perform marital obligations with the petitioner and also used to
quarrel with the mother of the petitioner without any reason, such that,
the respondent subjected petitioner to cruelty both physically and mentally
causing much mental agony in order to fulfill her unlawful demands.

5. Further submitting that, despite respondent’s harassments, having no other

go, to satisfy the respondent’s ill wills, the petitioner got shifted the house
and put up separate family as per the respondent demand at flat no: G4,
Pavani park apartment, More super market road, Magunta layout, Nellore,
even then, the respondent used to quarrel with the petitioner at late nights
without any reason in an intoxicated state as a chain smoker and after
quarreling she used to leave the house at that time and return home at her
convenience, for which the petitioner was subjected to severe physical and
mental cruelty.

6. Further humbly submitting that, in order to fulfill her dream to lead

luxurious life, the respondent used to demand the petitioner with proposal
to buy pet dog worth of Rs 60,000/-, in addition to that , respondent used
to theft the petitioner’s money pertaining to his daily business transactions
that kept in almirah, accordingly respondent already addicted to bad vices,
respondent used to put conditions to the petitioner to buy costly alcohol
 for her and also respondent refuse to prepare food and asks to get from
Hotel regularly. Further, respondent used to make calls to cashier of the
petitioner continuously in the absence of petitioner to secure personal
details of the petitioner and to instigate him for her penny needs. Further,
respondent uses utter words against petitioner without any reason so as to
insult the petitioner with abusive and filthy language. Further, the
respondent used to dispute with the petitioner attributing illegal intimacy
to him stating that, the petitioner is not suitable for her as he is fair to that
of her. There upon, as insisted by the respondent and her family members
to release of respondent’s gold ornaments at Muthoot finance, although
the petitioner expressed his financial crisis, respondent put deaf ear and
strictly demanded the petitioner, at that juncture, having no other go, the
petitioner adjusted and arranged the funds from his business transactions
and got released those gold ornaments even though his business is running
with losses and due to which the business was wind-up after sometime.
There by the respondent caused lot of trouble to the petitioner and
subjected him to cruelty.

7. The petitioner further submits that, the respondent left the association of
the petitioner on 22-11-2021, without intimation to him. On appraisal he
learnt that the respondent went to her elder sister’s marriage which was
taken place on 26th November, 2021, till now the respondent never
returned the house of the petitioner and not joined for cohabitation,
although the petitioner tried to contact the respondent directly or by other
means, it became vain due to evasive nature of the respondent, such that
the respondent caused much mental agony to the petitioner with her
attitude. Further, despite of several counseling before elders were already
taken place to pacify the matter and the same are failed due to evasive
nature of the respondent.

8. The petitioner humbly submits that the respondent resorted to the above
continuous dire acts against petitioner causing much insult and mental
agony to him and also annoying his family members, therein the petitioner
got vexed and sent legal notice dt:05.12.2021 and the same was received
by the respondent. Further, the respondent not chooses for cohabitation
but approached police there by the petitioner and respondent were got
counseling and the respondent agreed about her bad vices before the
police and showed her arrogant attitude, for that the counseling went in
futile. For the reasons stated above it warranted for the petitioner to file
this suit. The contents of the list of documents may be read as part and
parcel of this petition.

9. The cause of action arose on 19.02.2020 when the petitioner got married
with the respondent and subsequently on the above said junctures, and all
it arose within the jurisdiction of the Hon’ble court. There is no any
 collusion between the petitioner and the respondent to file this petition
and no similar petition is pending before any court of law.

10. A Court fee of Rs.30/- is paid here with under Article 1(iii) of Sch. II of the
A.P. Court fees and suits valuation Act.

11.The petitioner therefore, prays this Hon’ble court may be pleased

(i) To pass a decree in his favor, by dissolving the marriage between the
petitioner and respondent, dt: 19.02.2020, on the grounds of cruelty.
Otherwise he would be put to serious injuries and irreparable
damages.
(ii) To grant such other relief and reliefs that deems fit and proper in the
circumstances of the case.

Filed by me I, the petitioner, do here by declare that the

facts stated above are true to the best of
my knowledge, information and
belief.
Advocate for the petitioner.

List of Documents:

1. The Marriage photo of the petitioner and the Respondent.

2. The wedding card of the petitioner and the Respondent.
3. A Xerox copy of the Marriage certificate of the petitioner and the Respondent.
4. Copy of legal notice dated 5.12.2021 along with RP receipt to the respondent
4. Postal Acknowledgement card pertaining to legal notice.
5. The Xerox copy of the Aadhar card of the petitioner.
6. The Xerox copy of the Aadhar card of the respondent.

Advocate for the petitioner.