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Meena HMOP Petition
Meena HMOP Petition
H.M.O.P.No. OF 2022
Meena, F/A. 25 years,
D/o. Ravi,
No.48/27A,
Singa Perumal Kovil Sannathi Street,
Kancheepuram,
Tamil Nadu – 631 501. …Petitioner
-VS-
Perumal, M/A. 34 years,
S/o. Seenivasan,
D.No.2, Ground Floor,
Vimal Chand Street,
Sri Parasnath Nagar,
Iyappanthangal,
Chennai – 600 077. …Respondent
The address for service of all notices and processes on the petitioner is
at the address stated above.
The address of the respondent for service of all notices and process is
at the address stated above.
1) The petitioner submits that the marriage between the petitioner and
the respondent was solemnized on 26-04-2019 at Shri Panchamuga
Vinayagar Kovil Aarupadai Murugar Thirukoil, Omalur Main Road,
Yercaud Adivaram, Salem – 636 008 as per the Hindu rites and
customs. The respondent herein exchanged garland with the
petitioner and tied the sacred thread (Thaali) around the
Respondent’s neck with three knots in the presence of friends. The
said marriage was a love marriage conducted by the petitioner and
respondent on their own.
2) The petitioner submits that after the marriage, both set up their
matrimonial residence at Salem. Out of their wedlock, they were
blessed with a male child named Prathyush born on 12-02-2020.
5) The petitioner submits that once she came to know about the true
colours of the respondent herein, she agreed to the marriage arranged
by her parents with another person. During that time, the respondent
created a Facebook account in the name of the petitioner and
uploaded her intimate pictures taken along with the respondent
herein and thereby forcing the petitioner herein to stop her marriage.
Further, when the petitioner avoided the respondent, he emotionally
blackmailed her by saying that he would commit suicide if the
petitioner does not pay heed to the respondent.
6) The Petitioner submits that when the petitioner came to know that
the Respondent was not working as a Sales Manager in ICICI
Prudential and questioned him regarding the same during the month
of June 2019, she was assaulted by the respondent. The Petitioner
further submits that she came to know that the Respondent was
remanded to Salem Central Jail in the month of September 2019 for a
Cheating case registered at Sooramangalam Police station for 45 days
when the petitioner was pregnant. Subsequent to his release, the
petitioner came to know that a picture of her with her husband was
forwarded in WhatsApp that both of them were involved in Cheating
and Forgery thereby tarnishing her reputation and causing mental
agony. Enraged by being defamed and accused of an offence of which
she was innocent, she questioned the respondent about the same. At
that time, the respondent slapped the petitioner on her cheeks and
kicked her in stomach. It is further submitted that during the month
of October 2019, the respondent pushed away the petitioner and
snatched away her sacred thread (Thaali) to accomplish his vices.
9) The petitioner submits that when the petitioner was carrying the
second child and suffering in pain, without paying heed to the
petitioner’s needs, the respondent-husband deserted her for almost a
fortnight from 06th May 2021 to 19th May 2021. He came to visit her
only after the death of the 2nd baby which died in womb stillbirth on
20-05-2021. This averment is made only for the purpose of placing on
record the detriment suffered by the petitioner and to show the
recklessness of the respondent herein.
14) The petitioner due to the acts of cruelty on part of the respondent
suffered severe mental trauma and lack of peace, apart from physical
injuries and therefore she came away to Kancheepuram in May 2022
to her parent’s home to recover emotionally and also to institute this
petition for divorce.
17) The petitioner submits that there was no force, fraud or undue
influence in filing this petition.
18)It is submitted this Honourable Court has jurisdiction to entertain
and decide this petition as the last matrimonial residence D.No.2,
Ground Floor, Vimal Chand Street, Sri Parasnath Nagar,
Iyappanthangal, Chennai – 600 077 where the petitioner lastly
resided together with the respondent falls within the jurisdiction of
this Honourable Court.
19) The petitioner submits that no similar petition is pending before any
other Court in India.
20) The cause of action for this petition arose on 26-04-2019 when the
marriage was solemnized between the petitioner and respondent in
accordance with Hindu rites at Shri Panchamuga Vinayagar Kovil
Aarupadai Murugar Thirukoil, Omalur Main Road, Yercaud
Adivaram, Salem – 636 008 and thereafter on 05-03-2020 when the
respondent obtained a decree of divorce dissolving the marriage
between him and his first wife named Latha and thereafter virtually
every day when the petitioner was subjected to acts of cruelty both
physical and mental due to which the petitioner has suffered
irreparable harm to her psychological and physical wellbeing and
thereafter.
21)The petitioner values this original petition for the purpose of Court
fees under Schedule II Article 1 of Tamil Nadu Court Fees Act and
pays a sum of Rs.50 as Court fee.
VERIFICATION
PETITIONER
LIST OF DOCUMENTS FILED UNDER ORDER VII RULE 14(1) OF THE
CODE OF CIVIL PROCEDURE
S.No Date Description Nature Ex
no.
1 --- Marriage Invitation Original
2 26.04.2019 Marriage Receipt issued by Original
Temple
3 --- Pre-Natal Ceremony Photos Original
4 12.02.2020 Birth Certificate of the Petitioner’s Original
1st child
5 --- Fake IDFC Investment Bond Photocopy
documents prepared by the
petitioner
6 --- e-Courts Case status for the case Photocopy
in O.P.(H.M.O.P) No.190 of 2019
on the file of Principal Sub Judge,
Kancheepuram
7 05.03.2020 Decree and judgement in O.P. Webcopy
(H.M.O.P) No.190 of 2019 on the
file of Principal Sub Judge,
Kancheepuram
8 18.02.2021 FIR in Crime No.51 of 2021 on Photocopy
the file of Inspector of Police,
Chitlapakkam Police Station
9 20.05.2021 Burial Report of the petitioner’s Original
second child
10 02.11.2021 Lease Agreement of the last Original
Matrimonial Residence
11 --- Aadhar Card of the Petitioner Photocopy
12 --- Registration Certificate for the Photocopy
vehicle bearing Reg No.
13 --- Voter ID of the Petitioner Photocopy
14 --- Photos of the Respondent under Photocopy
Police Custody with ATM Cards
15 --- Whatsapp Forwaded Picture Photocopy
showing the Petitioner as involved
in fraudulent activities
16 --- Screenshots of respondent Photocopy
promising to return petitioner’s
father’s money
17 FIR in Crime No.230/2021 on the
file of Anaicut, Police Station
18 --- Car Pledge Bank Statement
VERIFICATION
PETITIONER
Nil at Present
PETITIONER
O.P.No. /2022
(Versus)
Mr.S.PERUMAL …RESPONDENT
VAKALATNAMA
Advocate
ACCEPTED: The address for service of the said Advocate is
20
Advocate for …………………..
BEFORE THE HON’BLE SUB COURT AT POONAMALLEE
I.A.No. of 2022
IN
H.M.O.P.No. of 2022
AFFIDAVIY OF MEENA
1. I am the petitioner herein and the petitioner in the above HMOP and
as such I am well acquainted with the facts of the case.
2. I submit that I do not know the various procedures and laws relating
to the case and specifically, I do not know to represent the matter
before the Hon’ble Court. I submit that the main petition is for Decree
of Nullity on the ground of bigamy which involves substantial question
of law and question of fact. Further I am not in a position to conduct
my case efficaciously without the assistance of my advocates.
Therefore, I require the assistance of a legal practitioner to represent
the case and to explain the law involved in this litigation.
ADVOCATE::CHENNAI
BEFORE THE HON’BLE SUB COURT POONAMALLEE
I.A.No. of 2022
In
O.P.No. of 2022
PETITIONER
RESPONDENT
PETITIONER
VERIFICATION
PETITIONER
BEFORE THE SUB COURT JUDGE
AT POONAMALLEE
H.M.O.P.No. OF 2022
…Petitioner
-VS-
H.M.O.P.No. OF 2022
…Petitioner
-VS-
H.M.O.P.No. OF 2022
…Petitioner
-VS-
DOCUMENT NO:
DATE:
DESCRIPTION:
U.SABARI KUMAR (2284/2019)
R.MUTHU RAMANANAND
(5787/2021)
COUNSEL FOR PETITIONER
Mobile: 8248665601
muthuanandattorney@gmail.com
BEFORE THE SUB COURT JUDGE
POONAMALLEE
H.M.O.P.No. /2022
…Petitioner
-VS-
VAKALATNAMA
U.SABARI KUMAR (2284/19)
R.MUTHU RAMANANAND (5787/21)
COUNSEL FOR PETITIONER
Mobile: 8248665601
muthuanandattorney@gmail.com
BEFORE THE SUB COURT JUDGE
AT POONAMALLEE
H.M.O.P.No. OF 2022