IN THE COURT OF SENIOR CIVIL JUDGE PALAMEENER CAMP AT

KUPPAM

HMOP No 2023

Between:

T.Mohan krishna
….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:-
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 -
7989277819, 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 state that he married the respondent, who is his wife, in
accordance with the customs of their religious ceremony. In accordance with
Hindu rituals, the marriage was solemnised on May 26, 2023 at SLV
Kalanamandapam Santhipuram. The petitioner parents furnished the Respondent
with one Mangalyam chain, Mangalasutharam weighing approximately 40grams
purchased at Manoj Jerellers V.Kota bill dated 22/2/2023, 12/5/2023, and Silk
sarees valued around 50000/- (fifty thousand Rupees only). Prior to the marriage,
the petitioner's parents also presented a sum of Rupees 1,20,000/- (one lakh twenty
thousand rupees only) to the Respondent in the presence of MS Subramanyam S/o
Srinivasulu Chetty of Ramakuppam, Madhu S/o Kodhandappa of JK Puram at the
Respondents parents residence, and all wedding expenses bore by the Petitioner.

4. The petitioner state that after the marriage, Respondent joined petitioner at
petitioner's house in Mattam village of Santhipuram Mandal, where the petitioner
and respondent lived together for about 3 days along with petitioner's parents and
petitioner's elder brother, and the petitioner working as a supervisor at Bijapur
Milk Dairy in Gandarmakulapalli of K.Kota Mandal, and the respondent working
for Accenture company as a Rugular Contractor in Bangalore.

5. The petitioner state that on 2/6/2023, the respondent's mother, Meena, took
the respondent to spend some days at the respondent's parent's house in J K Puram.
The petitioner submit that that there was no sexual relationship between the
petitioner and respondent, that no conjugal happiness was provided by the
respondent as a wife to the petitioner from the beginning of the marriage, and that
the respondent completely neglected the petitioner, and respondent was not
interested in marriage, and during the first night day the respondent was moody,
emotionless, and expressed with the petitioner, that she was 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, if the petitioner is tried
to touch her, that without sufficient reason she avoided the petitioner, that without
sufficient justification, 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 came to lead a family life, and the petitioner made a phone call to the
respondent and she did not show any interest to talk with the petitioner, and from
July to now, the respondent has kept the petitioner's contact number in block mode,
the respondent's actions show that the respondent has no love and affection for the
petitioner and she completely ignores her.

7. The petitioner submits that from 2/6/2023 to the present, the respondent has
been staying months together with her parents' house, and the respondent has
shown no interest in leading a married life with the petitioner. The petitioner
further submits that in 3 days of living by the respondent, the petitioner and his
family members have given the respondent an honored position in the house as
woman in half her husband and completes the petitioner with the view to mutual
fidelity continue, in other words, the petitioner loves the respondent too much and
has never used abusive or insulting language towards the respondent, and has never
quarreled with the respondent in order to have a good marital life. However, the
respondent denied the petitioner's conjugal rights without any rationale or reason.

8. The petitioner claims that throughout the months of June and July 2023, my
client visited the respondent's home and requested that the respondent come and
join the petitioner's home, but the respondent failed to do so. In this regard, the
petitioner has convened several panchayaths, and though the respondent agreed to
join the matrimonial house, the respondent has failed to keep up the respondent
promise, and whenever the petitioner comes and calls the respondent, the
respondent has purposefully avoided the petitioner and openly stated that the
respondent is not intended to live with the petitioner. The petitioner claims that the
respondent is merely following the advise of her parents and relatives, although she
is not interested in living.

9. The petitioner claims that the petitioner conducted panchayathis at the

respondent's parents' house more than 19 times, has not changed his behaviour
despite advice from village elders not to 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 of V.Kota Mandla, M.S.Subrabmanyam of Ramakuppam, as
well as respondent's uncle Raju and his wife Vanijamma, all came to Respondent's
native village and convened at Gangamma Temple, all called to Respondent and
her family members to the panchayathi, but neither the respondent nor her parents
attended or responded to the said panchathi, so the petitioner returned to that place.

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
on:18-10-2023 she refused to take the notice and with a intention to harass the
petitioner and his parents the respondent and his relatives 9-10-2023 lodged a
complaint before SHO of Kyasam Balla PS, and the Police called the petitioner
and his family members for counseling, hence on 10-10-2023 petitioner and his
family members attended before SHO of Kyasam Balla 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.

13. The petitioner submits that there are no proceedings pending before any
court between the parties.

14. The petitioner last residing at Mattam village of Santhipuam Mandal

within the jurisdiction of this Hon’ble Court. There is no collusion between the
petitioner and respondent to file this petition.

15. 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 9-10-2023
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.

16. 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.

17. 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. Original return cover of notice with acknowledgment.
 IN THE COURT OF SENIOR CIVIL JUDGE PALAMEENER CAMP AT
KUPPAM

HMOP No 2023

Between:

T.Mohan krishna
….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 26.05.2023 at SLV Kalanamandapam

Santhipuram Mandal, Kuppam
Taluk, Chittoor District,
b) The name of the parties and their : 1.Mohan Krishana, S/o. T.R.
occupation Chalapathi Setty, residing at 1-89,
Mattam Village and Gundusettipalli
post, Santhipuram Mandal, Chittoor
District, Andhra Pradesh.
2. Smt. S. Nishkrutha, D/o. S.
Venkataramaiah Chetty, residing at J
K Puram, Near Nayara Petrol Bunk,
Raju Pet Road Kyasamballa Hobli
KGR Taluk, Kolar District Karnataka
 State.

c) The place and address where the parties : The petitioner last resided at,
reside or last resided together with the Mattam Village, Santhipurma
jurisdiction of the court Mandal, Chittoor District, Andhra
Pradesh.

d) The names of the children if any of the : Nil

marriage together with their date of birth
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, There is no sexual relationship
the matrimonial offences alleged to other between the petitioner and
grounds upon which the relief is sought respondent, respondent is neglected
together with full particulars thereof so and not provided conjugal happiness
far as such particulars are known to the to the petitioner and also respondent
petitioner caused mental harassment and
cruelty caused towards the petitioner,
from the beginning of the marriage.

h) In case of alleged desertion the date and : The desertion took place one year 6
circumstances under which it began back at Mattam Village, of
Santhipuram Mandal, of Kuppam
Taluk and since then both the
petitioner and respondent living
separately.
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 of
offences alleged for other ground upon divorce. There is no sexual
which the relief is sought together with relationship between the petitioner
the full particulars thereof, so far as and respondent, respondent is
particulars are known to the petitioner neglected and not provided conjugal
happiness to the petitioner and also
respondent caused mental harassment
towards the petitioner, from the
beginning of the marriage.
Counsel for the Petitioner Petitioner

IN THE COURT OF SENIOR CIVIL JUDGE PALAMEENER CAMP AT

KUPPAM

HMOP No 2023

Between:

T.Mohan krishna
….Petitioner

And:

S.Nishkrutha …
Respondent

AFFIDAVIT FILED ON BEHALF OF THE PETITINOER

 I, 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. Do hereby solemnly affirm states as follows:

3. I submit that I have married the respondent, who is his wife, in accordance
with the customs of our religious ceremony. In accordance with Hindu rituals, the
marriage was solemnized on May 26, 2023 at SLV Kalanamandapam
Santhipuram. My parents furnished the Respondent with one Mangalyam chain,
Mangalasutharam weighing approximately 40grams purchased at Manoj Jerellers
V.Kota bill dated 22/2/2023, 12/5/2023, and Silk sarees valued around 50000/-
(fifty thousand Rupees only). Prior to the marriage, my parents also presented a
sum of Rupees 1,20,000/- (one lakh twenty thousand rupees only) to the
Respondent in the presence of MS Subramanyam S/o Srinivasulu Chetty of
Ramakuppam, Madhu S/o Kodhandappa of JK Puram at the Respondents parents
residence, and all wedding expenses bore by the Petitioner.

4. I submit that after the marriage, Respondent joined me at my house in

Mattam village of Santhipuram Mandal, where me and respondent lived together
for about 3 days along with my parents and my elder brother, and I am working as
a supervisor at Bijapur Milk Dairy in Gandarmakulapalli of K.Kota Mandal, and
the respondent working for Accenture company as a Rugular Contractor in
Bangalore.

5. I submit that on 2/6/2023, the respondent's mother, Meena, took the

respondent to spend some days at the respondent's parent's house in J K Puram. Me
also claims that there was no sexual relationship between me and respondent, that
no conjugal happiness was provided by the respondent as a wife to myself from the
beginning of the marriage, and that the respondent completely neglected me, and
respondent was not interested in marriage, and during the first night day the
respondent was moody, emotionless, and expressed with me, that she was in
monthly periods, and after she spent 3 days also she was moody, and abnormally
quit, and she does not allow me to have sex or even not interested, if I is tried to
touch her, that without sufficient reason she avoided me, that without sufficient
justification, it was caused mental cruelty, and I was suffered do to act and
behavior of the respondent.
6. I submits that after the respondent went to her parent's house, she never
came to lead a family life, and I made a phone call to the respondent and she did
not show any interest to talk with the me, and from July to now, the respondent has
kept my contact number in block mode, the respondent's actions show that the
respondent has no love and affection for me and she completely ignores me.

7. I submits that from 2/6/2023 to the present, the respondent has been staying
months together with her parents' house, and the respondent has shown no interest
in leading a married life with me. I further submits that in 3 days of living by the
respondent, myself and my family members have given the respondent an honored
position in the house as woman in half her husband and completes with me the
view to mutual fidelity continue, in other words, myself loves the respondent too
much and has never used abusive or insulting language towards the respondent,
and has never quarreled with the respondent in order to have a good marital life.
However, the respondent denied with me conjugal rights without any rationale or
reason.

8. I submit that throughout the months of June and July 2023, my client visited
the respondent's home and requested that the respondent come and join my home,
but the respondent failed to do so. In this regard, I has convened several
panchayaths, and though the respondent agreed to join the matrimonial house, the
respondent has failed to keep up the respondent promise, and whenever I comes
and calls the respondent, the respondent has purposefully avoided me and openly
stated that the respondent is not intended to live with me. I claims that the
respondent is merely following the advice of her parents and relatives, although
she is not interested in living.

9. I submit that I conducted panchayat at the respondent's parents' house more

than 19 times, has not changed his behavior despite advice from village elders not
to come for to restitute her conjugal rights, and finally on 20-9-2023, I and their
parents and other caste elders namely Sri. Vasanth Reddy, Kittappa, Ramu of
J.K.Puram Village, M.Nagaraju of Kanamanayanapalli of V.Kota Mandla,
M.S.Subrabmanyam of Ramakuppam, as well as respondent's uncle Raju and his
wife Vanijamma, all came to Respondent's native village and convened at
Gangamma Temple, all called to Respondent and her family members to the
panchayat, but neither the respondent nor her parents attended or responded to the
said panchathi, so myself returned to that place.

10. I submits that on 4-10-2023 he issued notice to the respondent to come and
join with me at matrimonial home in order to lead happy married life with in a
week, but the respondent did not received the notice and on:18-10-2023 she
refused to take the notice and with a intention to harass me and my parents the
respondent and my relatives 9-10-2023 lodged a complaint before SHO of Kyasam
Balla PS, and the Police called me and my family members for counseling, hence
on 10-10-2023 me and my family members attended before SHO of Kyasam Balla
PS, but the respondent and her family members failed attended before SHO.

11. I submits that I tolerating the harassment and torture made out by the
respondent that even the respondent not restitute her conjugal rights towards me.

12. I submits that I unable to bare the torture casing by the respondent I 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
me and therefore obliged to file this petition for decree of divorce and for judicial
separation with the respondent this petition. Hence, I obliged to bring this petition
for dissolution of marriage that took place between the me and the respondent by
decree of divorce.

13. I submits that there are no proceedings pending before any court between
the parties.

14. I was last residing at Mattam village of Santhipuam Mandal within the
jurisdiction of this Hon’ble Court. There is no collusion between the me and
respondent to file this petition.

15. The cause of action of the petition arose on when I married the respondent
on 26.05.2023 at SLV Kalanamandapam Santhipuram in accordance with Hindu
customs. When the respondent used to torture and harass me mentally by not
restitute her conjugal rights towards me, when and finally on 20-9-2023. I conduct
panchayath before elders when the respondent or her family members did not come
to panchayathi, and that on 4-10-2023. I issued notice to the respondent to join and
lead happy married life, when the respondent was refuse to take the notice, and
when on 9-10-2023 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
me and when the respondent harassed me to not restitute her conjugal rights to
words me and when the respondent not having interest to lead happy married life
and since from 5 months the respondent not came to me, from the beginning of the
marriage I did not have any sexual relationship with the respondent, myself and
the respondent last resided at Kuppam municipality 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 :