You are on page 1of 26


/ 2013







PETITION UNDER SECTION 12 (b) & (c) OF THE HINDU MARRIAGE ACT 1955 R/W RULE 1(V) OF HINDU MARRIAGE RULES 1956 The Petitioner state as follows: 1. The Address of the Petitioner for the purpose of summons and notices

of this Honourable court is as shown in the cause title above. He is also represented by their advocate as disclosed in the accompanied vakalath. The address of respondent for the service of summons is as that of working address of respondent. 2. The Petitioner submits that, the respondent is his wife. Their

marriage took place on ________________ at ____________________. As an evidence of the marriage the marriage Invitation card is herewith produced as Document NO. 1.


The petitioner submits that after the marriage, both petitioner and Ever since then they are

respondent lived and resided in the address as mentioned in the cause title as LAST RESIDED TOGETHER ADDRESS. residing separately in the address mentioned supra. The petitioner submits that the marriage was solemnized as per Hindu Rites, but there is no consummation of marriage between petitioner and respondent. 4. The petitioner submits that petitioner and his side elders, has

disclosed to respondent and her parents that the petitioner is a divorcee and marrying second time. The same fact is being accepted by the elders and parents of respondent side. Respondent and her parents fraudulently concealed the age of respondent and misrepresented fake and forged Jataka and performed marriage forcibly without having sane and free consent of respondent. The Xerox copy of Jataka is produced as Document-2. 5. The petitioner submits that, the fact of age difference came to the

knowledge of this petitioner on ____________ just one day before marriage, as disclosed by respondent herself, and exact date of birth is not disclosed to this petitioner, by then. Another fact that there is proposal from another boy is also disclosed by the respondent. This petitioner thought respondent is taking scope. This petitioner did not took it seriously and thought respondent is kidding with such false facts. This petitioner never raised that matter again. 6. The petitioner submits that, the respondents elders has fixed nuptial ____________ temple and ______temple, as

ceremony date on _____________. Till then this petitioner is being advised to visit Home God in ______________, being respondent families trusted gods. As per their wish on 28-07-_______ and 29-07-____________ three temples were visited by this petitioner and respondent 7. The petitioner submits that, before going on visit to temples this

petitioner on 28-07-2012 morning when waiting in respondent house, called respondent parents also to accompany them for temples, at that time respondent is taking bath in her home. The response given by respondents mother Mrs _______________ in these words CAi Ug, v, C Cm DU, Az ZVg, .. .. .. ( Husband zjU v

Vgz ) q C E ZV Cx iqP, C z DUP CAv E, P P CAv gv D z D EU J, MAzq DZ V dg wg w, MAzAzj eg iq

Cz j iqAq Eg (CAzg). This respondent took the advice as usual elders care and departed to temples. 8. The petitioner submits that, during the journey and leisure time after

visit to temples respondent repeatedly raised the personal matters of her Boss Mr ______________ (about 45 to 50 years un-married) with this petitioner. Although such discussion made this petitioner feel un easy. But later this petitioner consoled respondent and frankly said that her mother also not likes boss and office issue and this petitioner also not likes to have such issue discussed. Then all of a sudden respondent said about her mother by crying P AzU 25 g 25 g vAzq CU ZVvAv (Cwz) FU l Cg UAU PAvg, CAU zr z qv U Kg zrU KmQz. This words are the first strange words hurted this petitioner. Petitioner having confused, went to silence and consoled respondent without any further words after seeing her crying. 9. The petitioner submits that the nuptial ceremony was fixed on

____________ and this petitioner with his expense arranged the first night in __________ Resort of Mysore. On that night respondents strange behavior and talks about her past life and about other peoples like her boss life has bored this petitioner. For that this petitioner advised her to keep out all the past, respondent again raised the boss issue and wants to talk in detail about the things going on in her mind. This further confused this petitioner and advised respondent to forget everything of past and tried to convince to live happily with present, but respondents repeated such conversation has upset the mood of petitioner and there was no consummation of marriage. 10. The petitioner submits that on 31-07-2012 the resort room vacated 31-07-2012 tried to have consummation of

and later on the night of

marriage, but on that day respondent refused to have that by saying she is not feeling well, and another reason given by respondent is this petitioner cannot have children from respondent, respondent also said she did not need all those things etc. The cool manner of correspondence and love and affection before the outer world and sudden outburst of such conversation in

a cool manner when petitioner is alone has thrown this petitioner to confusion. The petitioner submits that on 01-08-2012 respondent came to


tumkur in last resided address and stayed with petitioner for 4 days. In all these four days whenever petitioner approached respondent with love, affection and care. Respondent raised the matter that she is older than petitioner, her parents have made fraud upon petitioner, she is unfit lady for procreation, showed care that this petitioner life should not be spoiled, advised petitioner to make another marriage. Etc. All the four days went without any consummation of marriage although respondent allowed to sleep with her by hugging her. No love and affection as husband and wife bestowed on this petitioner during nights and to the visible world she acted as if she is caring wife. The respondents following words often in good mood has also made this petitioner some un-easiness, to understand what respondent really intended. zAi Az qz Cg U CAi K .


The petitioner submits that

on 05-08-2012 the petitioner took

respondent to her mother house and as usual shastra left her there and returned back. The petitioners second marriage and its flowing direction has given a great shock to this petitioner. Whenever such experience is confessed with close friends and close relatives of petitioner, all suspected this petitioner only and never heard by any one with sympathy. 13. The petitioner submits that on 07-08-2012 between 7-30 to 8-30

when respondent and petitioner is conversing in telephone respondent took sudden decision that she will join work there (mysore) only and never come back, when conversation was made with her mother her mother has also stated same thing. When this petitioner asked for what sake they have made marriage, her mother threatened to go for suicide by consuming poison. This conversation broken the heart of the petitioner. Later when called back the respondent explained in cool manner that she is 7 years older than this petitioner, even if her parents have defrauded she is not ready to defraud, she said she is falling tree, she said this petitioner still having plenty of life, she said this petitioner should get children etc. These attitude has shown petitioner a great disaster in second marriage and still the petitioner

consoled himself and got confidence to convince respondent, by thinking that respondent is feeling self guilty and avoiding this petitioner and she will overcome that. 14. The petitioner submits that on 11-08-2012 respondent was taken by

this petitioner to tumkur house to get convince respondent to forget past and live happily and arrange for happy honeymoon in Andaman and Nicobar islands. In the mean time at one occasion when the respondent suddenly switched her phone off and suddenly changed her behavior and stopped weeping. When petitioner asked who called and why she is crying her reply was silence. To check with whom respondent was talking, her phone was opened in front of her and surprised to see that it is her boss name and number. There also this petitioner never raised that as an issue. In the 19 days of her stay respondent has intermittently talked such words like U AiVz, l Ai, .. .. U U Az, g DV qt, .. .. PP UP C d f Ez, Pzg gP v U Ew, .. .. EAz z DU .. .. Ct zq Q E Ct Kq Az

v, Pmg AiiP all these words are a real shock to this petitioner and petitioner still thought respondent is playing drama and creating fear psychosis with the petitioner, just to return to her past working life. 15. The petitioner submits that the consequences the petitioner was

facing after marriage was un-believed by even mother of petitioner. The respondents behavior to the outer world and with petitioners close relatives and respondents false accusation against this petitioner before close relatives and converse behavior before this petitioner has itself sprouted a suspicion of respondents real intention. Respondent never allowed this petitioner to consummate marriage with and postponed with one pretext or other. Respondent pressurized this petitioner to send her to work with her previous job in Mysore. Without having any hopes this petitioner in a deep confusion advised respondent to seek permission from petitioners mother. 16. The petitioner submits that the respondents dual talks and views

spoken before relatives of petitioner and before petitioner has forced this petitioner to record her voice conversation for the first time on 30-08-2012.

During that conversation the mother of petitioner, the respondent and this petitioner discussed in detail about her problem. In the entire conversation of one hour respondent disclosed following facts. a. b. c. d. e. f. She sought permission from petitioner mother to go to mysore to shift She confesses to have been 6 years older than petitioner. Tries to convince her mother-in-law (petitioners mother) to arrange Tries to convince that she is not fit for marriage and procreation. She repeatedly says she is not physically fit. For the first time she says she is having medical report about her her parents to new house (new cause created before petitioners mother).

for another marriage for this petitioner.



The petitioner submits that the first such conversation of respondent When respondent is

has created a shock to the petitioners mother.

departing from petitioners house on 02-09-2012 respondent took all her belongings and tactfully got petitioner mothers gold bangles also. The respondent accompanying this petitioner reached her mother house. 18. The petitioner submits that, by suspecting the attitude and intention

of respondent, this petitioner after having seen so many messages of conflicting character, by changing to new android telephone began recording all the conversations and messages from there onwards. The software in android phone is of such character that each oral conversation has to be saved after finished conversation. At several times when this petitioner was in utter confusion and due to sudden incoming call and due to some technical error few conversations were not saved. The major conversations were saved as evidence as to her insanity, dual personality, perverseness, cruelty, crookedness, confessed extra marital relationships, immorality and bad and mad approach to married life and relationships. The conversations containing DVD is produced as Document-3 which contains Quoted conversations (21), Unquoted conversations (29), Video Record (5), which in detail disclosed in list of documents is produced along with this petition.


The petitioner submits that, repeatedly respondent used her phone send messages to petitioners mobile number

number ______________ to below. a. b. c. d. e. f. g. h.

_______________- and the respondents several message mode is quoted herein Several times she showed love and affection in message. Several times she threatened this petitioner. Several times she confessed and encouraged petitioner to have second Several times she threatened to have divorce at once. Several times she threatens not to give any divorce and insists that Several times makes wild allegations and alleges illegal relationships. With wild imagination respondent tags petitioner as pervert with her On 08-01-2013 respondent messages to petitioner that her husband


she will continue her harassment.

cousin sister ____________ on 04-12-2012 message, this was suitably replied. died 5 days before and rest shastra of removing turmeric and kumkum is pending, this was suitably replied. i. On 16-01-2013 when this petitioner has been wearing Ayyappa mala, respondent messaged petitioner alleging she doubts that petitioner has affair with one family friend V (who is having 24 year old son), and further seeks confirmation about that doubt, this was suitably replied. j. On 12-03-2013 again respondent alleges on hearsay illegal affairs with one family friend V (who is having 24 year old son), who is work collegue in C (mysore) and one T (who is also married) and superior officer in C, (mysore) both are work colleagues in mysore C and family friends and well-wishers, having intimacy with petitioners mother and sister. k. On 19-03-2013 respondent messaged petitioner that she is coming to petitioners new house along with her father and mother on Friday (22-032013) and asked address, and petitioner called respondent seven times to give address of new house, but not received. Later message with address sent accordingly. l. On 20-03-2013 a message was sent by respondent, that respondent is not receiving call due to criminal mind of petitioner. And in the same evening respondent alleges by saying that her elders are telling her that this petitioner is living with adulterous life by keeping some one and leading happy life. This is replied suitably.


Starting from reason of age factor and self-guilty and work continuing

intention, the sms conversation went round in targeting petitioner mother, false allegation of cruelty, false allegation of dowry demand, false allegation against petitioner habbit and in the middle confesses the personality of respondent. 20. The petitioner submits that, the conversation over telephones of real cause, false allegation with work collegaues and family friends, which is in all split

petitioner and respondent in the phone numbers herein before mentioned has the following peculiar facts as per its dates. The relevant extracts of facts of conversation is quoted herein below for kind perusal of the Honble court. The other conversation is also placed before court totally amounting to 55 files, each conversation is of different duration and both petitioner and respondent is freely expressing their response without any forethought or compulsion. There are other conversation with one _________-family friend of respondent. There is one conversation with respondent mother. Etc., 21. The petitioner submits that, On 30-09-2012 when respondent started

conversation with petitioner, respondent enrages petitioner to have asked astrology when he visited north indian temples, this irked the petitioner and stated that when jataka and age itself is lie how astrology will cure, later when exact date of birth is asked as stated by her own people respondent has shamelessly spoken these words M: PPAq Az Aiig E m Jzg P .. .. M: CAU Csg Ez, AU MAz Csg Ez, JjU MAzAz Csg Ez, JjU Ez. AiijU E AiijU P Cz. .. .. M U Csg Ez Pu JjU Ez .. .. M: FU C Az C dv PAq n, U jgz, C PAq zP gP. .. .. .. Totally respondent used vulgar and insane language and imaginary self-confessions and self-accusations without any reason or provocation, just for a word that some of her relative has spoken her exact date of birth. 22. The petitioner submits that, On 30-09-2012 when this petitioner

again called respondent she with high and abusive voice exploded with following words M: K v QU Az CAv P U. vP vg Pu wm wg CAv wU, U UAq q. .. .. M: DU

JjU Ai, C

v, vAV v, Jg g, AU P

R zP iq Cz CU U P CAv, 15 Az Cz CU U l F 3 wAUU qPg g DU UPUv. .. ..M: d v v wjPP vg vPvV EAii CAv, wU, vPvVAi U e iq. .. M: gPq iq d wAz Mvl U. vVgjAz rz mg P vP Ez v, gzP, gPq irP .. .. Aii U CPAq z iq, E Ar v ev wgV , J P Zr ZAq Av, v MAzj q q CAv, Jg Z Mvjz U En Pu, i d v Cg g vPv Ez r, C C q AU, M P Aii U P vP Az q r, K J P irgz, K P iqAq E ev NqV .. .. M: Cz AiiP Cz U QU Az C

PgPAq , C C wg Aq n U jz, j .. .. M: C UAq Pu, Cz Az U C v Aq 3 d n, g Pu Czg Aiig vg r, q 2 P PArz AiijU K CAi iqP CAv ir, DAi q Ev P gdRg i U C Pig i, Ez zP zg iqz Aiig Aiig zs Az zP iqr CAv, Cv Az Nr A, ir s iqP CAv Agz, .. .. M: zsg Jgz C C Pv Vzv, Ez zsg, E Pz

zsg ir CAv .. .. VI: U Jz CAz v Png wg Csg Ez C vAv Ez. DAii!) .. .. M C d v U Azg, C ngg, C U jgg, C C j. g Dz irPAq f iqwgz j Cz . g S ir CAv wzPArAii, E EAz 4 d t P jPAq irPAq Ez Hg Egw. .. .. Totally respondent used vulgar language with confession or dramatic threats or confession as to immoral way of living in prostitution, illegal relationships, extra marital relationships before and after marriage. Respondent in an insanity spoken all un healthy words which showed the gravity of insanity in her approach. 23. The petitioner submits that, on 05-10-2013 at 8-30 pm respondent

alone came to petitioners house all of a sudden. On that night this petitioner recorded voice conversation that ensued in between petitioner and

respondent. Totally about 21 minutes of voice record is there, in that record, the respondent speaks following things. a. b. c. d. e. f. g. She says she came to discuss about divorce. She says she is in the verge of menopause and no use to petitioner. She says she and her family will support for second marriage of Refused to come and sleep with petitioner. She says if petitioner is averse to have third marriage, she is ready to She says she has eaten the food at the hands of petitioners mother and She says z zAil P , EU zP


die after December and then happily can marry third time. she has to act according to dharma to her.

Vzv CAv w (9-14 z P Az). All of a sudden she changes her words when petitioner asks to speak loud zP Vzv CAv wq .. .. EAz z iqAq ZVg (9-28 z P Az) (These duality came to light recently). h. i. She says lets have divorce happily. She says she still loves petitioner Says someone has alleged extramarital affairs allegation against

deeply. petitioner before her mother. Ultimately on 06-10-2012 when petitioner was coming out from bathroom, respondent was holding petitioners mobile in her hand and suddenly kept back. After verifying mobile about the conversation record it was intact and later it was found that entire messages were deleted by respondent to that date, only one message which was saved in sim was available to the date of 28-08-2012. 24. The petitioner submits that, on 28-10-2012, respondent called

petitioner by above phone numbers, cool conversation took place, and respondent demanded divorce from petitioner. Dramatic allegation of extramarital affairs against petitioner started. Emotional blackmail started. Straight rejection to live with petitioner. Hearsay allegation of loose character, extramarital affairs with many alleged against petitioner. Respondent not ready for any conciliation efforts in the midst of elders of

both families. Respondent repeatedly uses such words like


PqAig CAv sUP L Aiii rqq vAz v U E CAv AiZ ir. sUP Egz sUAv M, Aiig P z irPArg, dP Az Az ivqP AiUv E, U Aiig K ir, .. .. .. wife PqAig Aiig Az Az s CjU JPq vjz, U Aiig Aiig K irzg CAv U s Uv, .. .. wife: UAq q Aiig q U.. .. Cz K z Uv M UAq Ar l nz CAz CU Hl ZVz, CzP Hl AiiP P CAv Pz. CzP j g AiiP F iv Pg CAv z. .. .. .. wife: U q P . Jg PgzPAq , U Evx iq. The respondent at initial stages shown cause of self-guilty in age factor and proposal of another marriage for petitioner, before leaving matrimonial home shown cause to make home arrangements to respondents father and mother. Later respondent changed to strange cause of physical unfitness and health grounds, medical records added, later changed to self-accusation of bad character, later changed to accusation of cruelty and extra marital affairs of this petitioner. The respondent thus had repeatedly changed her stand with split personality, psychic illness, insanity, non-socialising and assuming no one is on her side, rejecting all her own relatives, fearing bad repercussions from her own relatives. Hallucinations and imaginations in representations and allegations. Emotional threats and allegations. 25. The petitioner submits that, on 02-11-2012 respondent called this

petitioner and started conversation asking for birthday party to her sister family. When refused to give any party respondent provoked this petitioner to give divorce. Later when called to come and live with matrimonial house, respondent shows that there is father and mother responsibility. When petitioner accepts to forsee the respondents father and mother also, respondent flatly refuses and demands for divorce alleging imaginary extramarital affairs to this petitioner. Respondent strangely starts allegation against her mother in-law (that is this petitioners mother) that chandramma is not liking to leave petitioner and respondent to live happily. Later provokes this petitioner to ask respondents mother for defrauding, she says in these words wife: Aig v irzg, U Uw, CzP e irg, v PlPz UAzz v Png, E ElPAq AiiP Ag iqP. dU ZV zP DUv, AiZ ir,

C PjPAq P F qV

ev zPP DUv. d J vA

MAig, U Jz E MAz zP Ez Egv. ZVg. Mg CjPAq zPz, Jg CjPAq zPP DU. .. .. wife: U _____ CAi irgz. PP Mqz P. iAg Aiigzz Z PaPAq qz P. .. .. Wife: C iAU l it irPAq Pu CzP K ivq. w w J jPAq ir CAv. .. .. wife: PgzPAq Az t qA P, ZA AiiP z Ai, t AiiP q irPP m irz, PgzPAq Jg. U P.E. Aig AiigAiig CAzg Cg PgzPAq gw. .. .. wife , AiiP g, U Pz FZPq Cs ElPAq, PAq C U, Ez AiivP P U, AiiP P qP ev w CAv. .. .. wife: z z, iAjU JjU t P Ezg, Cg g g wAU Pg, Cg ev Ag ir P, CU CjU UvUv. .. .. In this date also respondent by allegating many hearsay things demands divorce and accepts her parents have defrauded this petitioner. Respondent by having names of previous work ex-colleagues in mysore of this petitioner wants to blackmail with non-existing gossips and affairs. Respondent alleges strange nonexisting things against former divorce life of this petitioner. 26. The petitioner submits that, On 10-11-2012 this petitioner after

getting missed call from respondent, telephoned to respondent and heard her as saying her mother died. Later call disconnected by her. Again on same day within 10 minutes respondent telephoned back this petitioner and called for Deepavali festival. And with some conversation suddenly changes her stand and threatens to see how petitioner will take divorce, without even raising of such topic by petitioner. The respondent words flows like this: wife U U J. Avg J Qvz JPq. U EAU GVzg Aiiz Pu. Cz AU v q vUwAi r. .. .. .. (Husband: U q q.) .. .. wife: q q, vPj Eg g Egw. Ez zP Aii U zq Aii Az Ez. JjU Ez Gvg Pqz. D P J Qv Av PU z ir Ptg PvAi U irz. g Cz Aii P v vPv Ez. GVzg i. EAv U vUAq V CAv U PnAi CAv. .. .. .. wife i z. C wy iq, C z iq. qVPAq iqv. z iq. .. .. wife: g z gAiz, UAq CPAq qj vUAq

CAv A wAz, J gz El vU qP. PjP MUq. z CU JjU Mz iq. U Pqg CjU Mz iq. .. .. wife: ir, iqz gz ElP q, J JPjAm, qj P, PAq ige P. gr irP Cz Jq P CAv. .. .. .. wife: E Ez Pu Pm Ez. J jU AzU P. Uz zU. Aig A A DUU. ig Jg g g Aqw PnPAqg Aq P . MjU JPqz Mqz Pw. P. PU VPAq Ag irz D gdRg C CU ir, D UU. .. .. Totally Respondent turns her stand and takes decision to file all types of false cases against petitioner and alleges extra marital affairs to every family member of petitioner, uses obscene words of unfit character and insane habit. The petitioner submits that, On 19-12-2012 respondent called


petitioner, when petitioner through SMS enquired about respondents mothers threat to petitioner. The conversation went through with intermittent threats and acceptance of having affair with respondent boss. This has spoiled the thoughts of re-union and this petitioner was very much disturbed about the psychic behaviour of respondent. The relevant conversation is quoted below M MAz iv PP. Jg Az vm PA D qV q Pm P CAv PAii Eg Husband: Pz Aiivz. M: C C Cz qPAi vjPArg. Husband :- Cz AU vjn. M: w P . CzP Al g DUv E. Cz U Uv. Aiiz jw vAz Aiiz PgtP DU zQggU. j. EzP j U K PUv . Husband: U K Uw Pt P DVn. M: FU U Aqw P q P CAv AiZ iqPVgz . .. .. .. Husband: Jq K E Pt m irPwAi. M: C Cz Ez L qAm Pg. Husband: Cz Uv Pg E CAv. M: z. q CzP AU ivqwAi. iv Jwzg q, C CAwAi. Pz V Pq CAv CAz CzP Q E CAwAii. q Pt CAz Uq n g irPAq Az ir, UPVv U CAv CAwAi. K iq. Husband : Aii iv CA. FU K U PA U AiiP ivqwAi. K AUz M: C Cv Az D s CAP Jg PjPAq ivrz. Husband: K ivrz. KAv. MM: C

P E U q P v. Pqw CAv w v, AiiP F vvAi U. .. .. Husband: Cv z , qj P Pw CAz, PAq ige P Pw CAz, M: RArv CAz. u qA ev Cjg ev C wgUwz E wgUwz AU AU CAv CAz U eg DU. vg CAz E CAv C. dU Drgz d. .. .. Respondent needlessly all of a sudden raises her boss issue, imagines herself that there is an allegation from petitioner and uses words she has kept him in these words- Husband : K Cz jwAi j. M DAi. jAi E . Jgql vAAi CAv PwAi, Aiiz Ez ivrAi, MAz D PP UwAi CAv. Husband: Cz U Uw. M AU ElP. Egz. DAi. EAi EnPArAi CAv AU EnP. EnPAq E K iqPUv. q w J Uv C Uw UAq DUP CAv K? Husband: E K . M: j C. j z q EAz s ir w qQPAr CAv. AU w qQPAr. Husband: qAi Aii w Ezv. M: AiijU Uv. Husband: K ZZV ivq EAi. q U AU j Cv AU iq. M: CAi AU C CgiV Eg. Aiig vAzg irqP E Pw ErPAq Avg. Husband : U Uw. M: Cz irPP CAv E QAim iqwAi. As per respondent drinking, enjoying women, going to race course is all the natural way of life when she only raised about her brothers whom she was rearing them as sons Husband: zg qv. m qw FU JgqAiz s CAz zg rgz. Husband: zg

qv. AiijU K DUv CAv AiijU Uv. FU U vAzg DVnz P Aiz AUv Plg CPUv. M: P Fvg K ir igAi.

Husband: U Uw. M: ZV JAeAii irz, P, Az irz, g Dqwzg, El Dqwzg, G JAeAii irzg, Prwz zg DV Ez j. Husband : U qz Eg Ai M: Cgg Cg zP VPAq gw CAv Uv Ez. Husband : U Uw. M: gegV Ez. Husband : U Uw. Husband: UwAz Cg U ivqgz. P Cg. Cg U ivqgz.


The petitioner submits that, On 23-12-2012 respondent telephoned

this petitioner at night 10-45pm and said that she decided to exit from the life of petitioner, she says M: zQAz JQm DU E. zsz

Az zg DUP gAi Aiv iqz Mz.

Husband: .. .. Cv

CPAi, CAi ElPArAi C v rwzg CAz, DAii Cz CU PU. AuAi PAi) M: RArv CAz . (06-12-2012 ms

Husband; Cz z C v V qv Cv.

M E CAv . U z U. CAz d. CA. JzjU CA. .. .. .. .. Husband : Cz Vz Vg Wl Ad MAz MAz P. J AwAi qw Uw Cz. d E t P n. z v. JgqAiz CU K

vAzg Pn. sg q AZ CU z DAi. Czg v C v Uw. Dz DAi PAq ige DUPz Aii Aii U Z vg CP irPAr CAv Uv. 8 wAU rAi M: z. Husband: 8 wAU rAi. DAi w MAz eAi g DV EgP CAv Aiz . E? M E CAv w . Uv E. MAz . g DV zP Aiv irz. E CAv . vA P. s DV C iqw. U miU vA wg. eg irPq Ez s zQ PAqPAg v Ez. s zq Pz Az iqz. mi iv Az iqPU CAv. AiiPAz vA s DV C irz F zP U. Eg zs zP AiUv V. F qUU Aiiz jw CAi DUgz. Ai MzVP CAv m iq Eg qV. j Cz U gAig VU zU 4 iv Aiv. Respondent after accepting cruel allegation made by her against the chastity of this petitioners mother, respondent goes back to her original state of not willing to lead married life and decides herself that she is not having such character to live in the midst of good people. M: MAz iv w P. v vA dj Ez. RVg RArv lq Pmg. Husband : U Uw Ad Pmg Pmg NV Az

Pmj CAv 100 j Ai. M: q Pu ZVgP C. Husband: K Uw C. M: E itPV Aii qV . E M sg irgz P. Husband: Aii jw sg ir CAv z v UvUP. M: ZVgP AiiVg C. CzP q P q zPP q. F zP U q ZVg. These words of respondents confession still thrown this petitioner to delima and thoughts of diversity attacked this petitioner, is respondent really in any trouble, but when looked into respondents cruel behaviour has brought repeated shock.


The petitioner submits that, the above stand of respondent that she is

implicated in some vicious circle has made this petitioner to dilemma and to know her real intention and counseling this petitioner approached Commissioner of police Mysore on 03-01-2013 and pleaded to have counseling to respondent and protection for the above strange behavior. There respondent turned her table and accepted to come back to matrimonial home and behaved as if she is perfectly normal. Respondent accepted to come to tumkur before police and even after persuasion she changed her stand. The petitioner submits that, later respondent began allegating


against mother of petitioner and began to indirectly and directly threaten this petitioner to drag petitioners mother to court. The conversation made by respondent in her call to petitioner on 03-01-2013 is filled with abusive and false allegations against petitioners mother for the first time. Respondent wants to make new type of emotional allegations and threat to weaken the petitioner. Rejects to live with petitioner and forces to give divorce. Even when offered to live separately without petitioners mothers presence, respondent turns her allegation against this petitioner. M: q . CU AiiV gz E E. j. AiiP Pg DU 10 j Pgzg gw . j. .. .. M: v. C P gr E Pu .. .. M: C. P CVz Pg D vP Uwg. gz CAv zsg irAi. .. .. Husband: E E. M: D zsg Az Azg, Az P iq. Az Azg q Pl l z U Ci DUv. .. .. M: q U E E. s Cs U qP EAfAig, Um UAq mg D V Egg P, zAil CAvg rPAq ZVj. zP Evx irl AzP U. PgzPAq Vz Pg DU A, FU CU s irz K CAv. aU v ivqq CAz, Husband: j FU. M: UAq Egz D, C U z ivqq CAv. gAz: NP NP.. DAi. UAq Az EgP v. M: UAq Pu Cz. CU K P UAq . Husband: j DAi Pq . M: P s. Husband: DAi NP. M P s. D vPv Lv q. Nrz qv zAi Nrl. MU iqwg Jg AUg AU. PgzPAq Pg DU w. J. Fv s iq CAv. .. .. M:

UAq Pu C P ZAzU. UAq 10000 EAq UAl irPvAv. Czs lg vgv. .. .. M: U vAg JzjU U QPAq Prv. .. .. Husband : j EAwAv Z Z Cz jv EAi . .. .. Husband: sAi EAi Ad. .. .. M: sAiE. UAq JPq wAzPArgz Cg C. .. .. M: q Cv g Al CAv DUz, CzP ZjPAiiV CzP K P Cz gPq irPAq grAiiVg. Az vAzgAiiUz q. .. ..


The petitioner submits that, on 06-01-2013 when petitioner called the

respondent, the conversation of respondent is mainly concentrated on getting compensation and getting divorce. The relevant conversation runs like this M: zq PqPUv CAv F vg g iqwAi. .. .. Husband: C Pu AqwU zq Pqz f irz d Cz. .. .. M: MAz . FU P Egz U Aiiz jwAi MAz aP aPzg PAjn E. CzPg U F jw vl iqwAi. Husband: PArv E MAz P. ____________ CAv AUjAz s irl zjzg. Ad CqPm CAv zg. AigU. M Cz AZ J s ir l nzg D

Husband: Aiig U K Uv. M: MAz J Pv j gz

EzU U K P Cz PP C. .. .. M: Pg Aqw U Pg. Aig PgzPAq Az U Az q U. .. .. .. M: P CAv z UAq U U CAv Aii Pm . Aii P Cz EP nz. .. .. M: vg ZAe iqP gr E. U zq PqPUv CAv PP, jAe vUP ev zPP CAv CAz D zP U q. .. .. Finally respondent gives option to petitioner to have a settlement by paying money as compensation or to go to court for divorce or to suffer like this daily. 32. The petitioner submits that, on 08-01-2013 when petitioner called

respondent for having hurted with the message of respondent that this petitioner is dead. The relevant conversation run like this Husband : K Ad AUAz m . AAzs AiizP E. UAq vz CAv e iqwAi. zQ CAv P irz. M: Aiiv Pg DU

Pgz Cv sUP vz. Ez m Am UAq vz. wg Cv Cj PAP vUAiP gv Egz. Ez v. .. .. M: 3 vjR P Ptwz. Cz irPwAi irP U. q

Pwg v g C PwU Q Cj PAP EQ Pw CU. iAUP Av PAq l C, Cv Cz iqz Pu. v P. P . gPq irP . irP gPq. J CAi Cg Uv .


The petitioner submits that, on 14-02-2013, effort made in one

____________s house in mysore, who is family friend of respondent, (There is a hidden video recording of such conversation which is produced along with DVD document no.3) during the conversation respondent alleges that one cousin sister of petitioner T was asking petitioner through phone how many times sexual intercourse has taken place initially when respondent is in tumkur and so respondent alleges that she is not having privacy. This type imaginary allegations mixing and blaming close relatives and friends has increased day by day. At last elders of respondent decided and put a condition that this petitioner should arrange separate house and there after they will send respondent. In order to see that result also petitioner made separate residence in B quarters and got sanction on 01-03-2013. The copy of such sanction is produced as Document-4 and copy of salary deduction for such quarters is produced as Document-5 for kind perusal of the Honble court. 34. The petitioner submits that, on 23-03-2013 when respondent gave

miss call from 988____________, this petitioner called back and during conversation respondent makes false allegations and accuses petitioner is making false rumours about her character. Respondent also accuses petitioner is tagging her with her cousin husband (a new hearsay allegation) at the same time accepts in the conversation that her Boss is her dream and nothing wrong in learning and talking about him and generalizes the issue. Later all types of communication was stopped from petitioner side. 35. The petitioner submits that, in this way respondent without giving avoided to

her valid and sane consent to marriage for having suppressed the fact of age difference by her parents has after marrying this petitioner consummate the marriage. Initially represented as self-guilt of age

difference, attempting to self confession of things happened with her boss, changed to reason of shifting her aged parents to new house and deserted, later changed her stand to having severe disease, later changed her stand of

encouraging petitioner to have third marriage, later encouraged to have divorce, later finding extra marital hearsay allegations on every one including herself, petitioner, her parents, petitioners mother, etc etc etc. Later changed her version of filing dowry case, later changed her version of filing harassment case on petitioners mother, later changed her version of threatening false cases, later changed her version to get compensation and divorce, later changed her version to threats from her relatives as lasted in conversation on 26-01-2013. All these stands of respondent is a clear fraudulent mis-representation of sane consent to marriage. All these stands of respondent is insane reactions and threats for monetary gain and respondent affected with such split personality and insanity unfit for giving valid and legal consent to a valid marriage. All these stands of respondent is a clear insanity and unfit nature for a normal human being. It is nothing but a criminal mentality with split personality and insanity for exploitation of law to do extortion and continuing to lead an immoral life. 36. The petitioner submits that, the respondent has withdrawn herself

from the matrimonial obligation. Though efforts were made to reconcile the issue, but for the conduct and attitude of the respondent the same could not yielded any result, due to confirmed insanity attitude as elicited above. 37. The petitioner submits that, the respondent is living separately in the

mysore and working in mysore and recently changed her residential address which is not known to this petitioner. The respondent is a working women having sufficient means for her livelihood, due to that addiction of working or due to her self proclaimed extra-marital activities or due to best reasons known by respondent herself have done all above un-natural activities to this petitioner, has proclaimed herself insane. 38. The petitioner submits that, the petitioner has thought that there is no

means in living separate withdrawing from the matrimonial obligation and has decided to know exact truth behind the behavior of respondent to convince and get back to normal life. But the facts spoken out by respondent with imaginations/hallucinations shows she is unfit for normal married life, and to give her valid consent also. The petitioner is left with no other option but to approach this court for annulment of marriage for the reasons of

respondents insanity, invalid consent, and misrepresented and perpetuated fraud. Hence this petition. 39. The petitioner submits that, the typed copies of major relevant the downloaded form for kind perusal of the

conversations contained in DVD is under progress, the copies will be submitted at the time of evidence or very shortly, petitioners mobile is produced as Document- 6 Honble court. 40. The petitioner submits that, the unsound mind of respondent is not of conversation in SMS from 07-10-2012 to 22-03-2013 from

being declared by any court of law. There is no collusion between petitioner and respondent for having filed this petition. The petitioner has not filed any other petition against the respondent on the same cause of action or any petition or suit is pending in respect of the subject matter of the above petition. The petition is filed within one year from the date of marriage. 41. The petitioner submits that, the cause of action to file the above

petition arose on 22-07-2012 when the petitioner was given in marriage to the respondent and subsequently when the petitioner was mentally and physically harassed and subsequently the insanity of respondent came to the knowledge of the petitioner as during 2013. The petitioner and respondent before their separation has last resided in the above last resided address within the jurisdiction of this Honourable Court. 42. A fixed Court fee is submitted herewith on this petition as per Article

1 Schedule II of the Karnataka Court Fee and Suit Valuation Act. Therefore, the petitioner pray that this Honourable Court be pleased to pass a decree declaring the marriage between the petitioner and the respondent dated ____________ took place at ______________ as null and void in the interest of justice and equity.

Advocate for Petitioner.


VERIFICATION I, the petitioner in the above case do here by declare that what is facts stated in all the paragraphs of the petition above is true and correct, to the best of my knowledge, belief and information.

Tumkur Dated: Petitioner


M.C. / 2013

In the matter of the Hindu Marriage Act, 1955.





I, ________________ S/o late ____________________ and ________________, Hindu, Aged about ________ years, R/a ________________, Tumkur, do hereby solemnly affirm and state on oath as follows: 1. 2. I am the petitioner in the above petition and I am fully acquainted I submit that the averment of facts stated in Para 1 to 42 of the

with the facts of the case. petition are true and correct. I am swearing to the above facts as true and correct. I the deponent above named do hereby solemnly affirm and state on oath that this is my name and signature and that the contents of this affidavit are true and correct. Identified by me Deponent. Advocate. Tumkur Dated:


M.C. / 2013

In the matter of the Hindu Marriage Act, 1955.




APPLICATION UNDER SECTION 13 OF THE FAMILY COURT ACT: For the reasons stated in the accompanying affidavit, this Honourable Court be pleased to permit the petitioner to engage counsel in the interest of justice and equity. Tumkur. Dated: Petitioner.


M.C. / 2013

In the matter of the Hindu Marriage Act, 1955.




AFFIDAVIT I, _________________ S/o late _______________ and ________________, Hindu, Aged about 35 years, R/a ________________, Tumkur, do hereby solemnly affirm and state on oath as follows: 1. 2. I am the petitioner in the above petition and I am fully acquainted I submit that I have filed the above case for Declaration of my with the facts of the case. marriage with the respondent as null and void. I am not acquainted with the legal aspects. Hence I am not in a position to prosecute the case without the assistance of an advocate. Hence this accompanying application. Therefore, I pray that this Honourable Court be pleased to permitted me to engage the counsel by allowing the accompanying I .A. in the interest of justice and equity. I the deponent above named do hereby solemnly affirm and state on oath that this is my name and signature and that the contents of this affidavit are true and correct. Identified by me Deponent. Advocate. Tumkur Dated:



/ 2013

In the matter of the Hindu Marriage Act, 1955.






4 5 6


Tumkur. Dated: Petitioner.


M.C. / 2013

In the matter of the Hindu Marriage Act, 1955.





Tumkur. Dated: Petitioner.