OM 03/02/2020

K.RAMULU YADAV, B.A.LL.B

ADVOCATE
H.NO19-119,DANDUGADDA
KOTHAKOTA (Town & Mandal)
9490412871
TO,
S.B. CHANNAGOUDAR
B.A.LL.B
ADVOCATE
TIMMASAGAR TEMPLE ROAD,HUBBALLI
DHARWAD (Dist) KARNATAKA
REPLY NOTICE
Under the instructions and authority of my client Smt Divya W/O Myla Naveen
Joseph, Dlo M. Chennaiah, Age; 31 Years, Occur House wife, R/O H. No, Kotha Kota
village and Mandal Wanaparthy Dist. I am authorized to give the following Reply Notice to
you.
It is informed through this reply notice to your legal notice dated; 23-01-2020.
1. That it is true my client is legally wedded wife of your client and the marriage was
performed on 03-05-2019. At St. Peter's Church Hubblli as per the Christian Religious
customs and rituals.
2. That with a ray of hope of a prosperous and peaceful marital life, it is in correct to your's
client has married with my client by incurring all the marriage, at the time of marriage my
client's parents are give dowry of Rs: 7,00,000/- (Seven Lakh of Rupees) net cash and 4tols
of gold Chain and gold ring articles And after marriage my client came and joined in the
company of your client, it is false my client is adamant nature lady and from the day one
itself. after marriage quarreled your client and his second brother with my client, with one
and other pretext without any reasons. In fact my client is very innocent, she does not know
about the quarrels. It is false and incorrect my client left the in-laws house only after 3 days
of the marriage and went to paternal home and returned only during august 2019 thereafter
you were with my client only for 21 days and again went to your parental home.
3. My client is a good intention and with a intention to perform the conjugal duties with my
client. In fact your client not having a good manner and good intention to lead marita life
with my client, and intentionally he harassed to my client, it is in correct and baseless my
client is tabbing over the cell phone and always used to send message receive messages,
phone calls, and it is incorrect my client used to spare full time in the cell phone even during
midnights. many a time your client used man handle and beate to my client to you are not
smart. And bring additional dowry of Rs; 10,00,000/-(Ten Lakh Rupees) Though my client is
adjusted and done her marital duties with your client but he is not adjust with my client.
4. It is false and baseless allegation made by your's client against my client, that during the
stay your client disclosed that my client living paramount at maternal place. In fact my client
and her family members are very respectable persons and very respected family as such my
client never ignore to give respect to others, being a wife of your how she ignore to give
respect to her husband i.e. your client. but she never came to parent house without any
intimation of your client. She come her parent house consent of the her husband. Till today
your client did not come with my client parents home their biological needs.
5. It is false to your client while undergone mental agony and embezzlement because my
client attitude.
6. Your client has never seen with love and affection to my client. as such your client is not
interesting to give minimum love and food to my client and never provide minimum
medicine to my client. Further some times your client's attitude is very danger on my client
and he used abused filthy language with my client, she could not say that the filthy language
as a human being such type of language he used on my client.
7. It is false to say that my client left the matrimonial company of my client on 21-08-2019
and since then my client did not turn up to your client and there is no even taking terms
between my client and your's client. You are client not attends minimum duties though my
client bare all those things. In fact my client has bare your client's family members
harassment and lived with them in their house. Further it is to inform you through this reply
some times your client's brothers were also threatening to my client.
Further it is to inform you through this reply notice your client come to my client parent's
house kotha kota come and lay down his wife. my client is always ready to join with the
company of your client, but your client and his brothers are harassing to my client in a
different types as such she is fearing to join and bringing of additional dowry, therefore you
have to advice to your client not to harass to my client and to give advice to your client how
to look the wife in the society, and he has given all the false information to you and advice to
him and his mother to stop the illegal action against my client. Other wise my client will be
take appropriate legal action against on your client and his parent in the court of law.
And advice to your client to give expenses of this reply notice of Rs;5,000/-

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