IN THE COURT OF THE METROPOLITAN MAGISTRATE : NAMPALLY,

HYDERABAD.

D.V.C.No. of 2014

Between:

1.T.Kiranmai
W/o M.Ravi Kumar
aged about 28 Yrs. Hindu, Pvt. Teacher
R/o H.No.8-3-228/214, Rehmat Nagar,
Yusufguda, Khairatabad, Hyderabad.

2. M.Mahati
D/o M.Ravi Kumar
aged about 11 Yrs. Hindu, Minor-student
R/o H.No.8-3-228/214, Rehmat Nagar,
Yusufguda, Khairatabad, Hyderabad.

3. M.Pranathi
D/o M.Ravi Kumar
aged about 7 Yrs. Hindu, Minor-student
R/o H.No.8-3-228/214, Rehmat Nagar,
Yusufguda, Khairatabad, Hyderabad.
...Applicant

AND

1.Mula Ravi Kumar

S/o Rama Krishna
aged about 39 Yrs. Hindu, Pvt. Employee
R/o H.NO.5-98/1, Kamalapur, A.P.R.Ltd.
Mangapet Mandal. Warangal Dist.

2. Mula Manikyamba
W/o Ramakrishna
Aged about 58 Yrs. Hindu, House wife,
R/o H.NO.5-98/1, Kamalapur, A.P.R.Ltd.
Mangapet Mandal. Warangal Dist.
...Respondents

APPLICATION FILED BY THE ABOVE PETITOINERS U/S 12, 18, 20, 22

OF THE PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT.
2005 (43 of 2005)

I. Description of Applicant:-

The address and description of the Applicant for the purpose of service of
summons notices etc., is the same as shown above in the cause title.

II. Jurisdiction:-
The petitioners 1 to 3 are temporarily residing because of her employment and
as such they are residing in the address given above and the respondent is a
resident of APR Ltd.Kamalapur of Warangal District within the within the local lim
its of Mangapet police Station and as such this Hon'ble Court has the territorial
Jurisdiction to entertain the present application as per Section 27 (1) (b) of the
Domestic Violence Act,2005.

III. Cause of Action:-

The cause of action for filing the present application arose on dt.21-11-
2001 when the marriage between the 1 st applicant and 1st respondent took place
and subsequently when the respondents 1 & 3 subjected the 1 st applicant to
much harassment and ultimately it is in July 2010 when the Applicant was driven
out by the Respondent No.1 by harassing her at the instance of Respondents
No.2 and 3, and on several dates subsequent to above, when the 1 st respondent
raided on the 1st complainant and subjected her to much harassment both
physical and mental and the cause of action is continuing and subsisting till
date.

IV. Description of Respondents:-

The addresses and description of the respondents for the purpose of

service of process, summons, notices is the same as shown above in the cause
title.

V. Brief facts of the case:-

The Applicant humbly submits the brief facts of the case as under:

1. That the marriage between the 1 st Applicant and Respondent was

solemnized on 21-11-2001 in Ganesh temple at Malkajgiri at about 9 p.m. as per
Hindu rites and caste, customs. It is submitted that at the time of marriage as
per demand of the Respondent and his parents, the mother of the applicant No.1
paid about Rs.50,000/- towards dowry and gave other presentations of another
Rs.50,000/- and performed the marriage by incurring expenditure of about
Rs.50,000/-. Immediately after marriage, the 1st applicant joined the respondent
for marital life and lived with him in their house at APR Ltd. Kamalapur.

2. The 1st applicant and the respondent lived for about one year only
peacefully. Thereafter, the respondent was addicted drink and used to come to
house in a drunken stage very frequently. During the wedlock of the 1 st applicant
and the respondent, the 2nd applicant was born on 12-6-2003. Later it is on Dt.8-
2-2006 they gave birth to the 3 rd applicant. The respondent used to work APR
Ltd. at Kamalapur. The respondent used to own and possess a terraced house
and about 20 cents of vacant site attached thereto. The respondent used to earn
about Rs.10,000/ per month.

3. The applicant NO.1 submits that the respondent NO.1 is addicted to all
sorts of vices. From the early days of the marriage itself, the respondent used to
come to house in a drunken stage and used beat 1 st applicant mercilessly. Even
though the father of the 1st respondent was therein the house and attempted to
stop him, the respondent never heed his words and on the other hand, he used
to scold his father even. The 2 nd respondent who is the mother of the 1 st
respondent used to give false support to the 1 st respondent. The 1st applicant
suffered the physical and mental harassment caused to her by the 1 st and 2nd
respondents for several years with all patience. While so during March. 2007
when the 3rd applicant felt sick and the 1st applicant brought her to Hyderabad to
provide treatment to her, the 1st respondent did not co-operate but on the other
hand used to torture the 1 st applicant by way of his attitude and used to beat the
1st applicant. The father of the 1 st applicant died prior to the marriage. The 1 st
respondent all the time used to take advantage of the fact that the parental
family of the 1st applicant has no male assistance. All the time he used to
comment the mother and sister of the 1 st applicant in a vulgar and filthy
language. The respondents 1 & 2 never allowed the 1 st applicant to go to her
mother’s house except for the purpose of the delivery of the applicants 2 & 3.
Similarly he never allowed even any of the other relatives of the 1 st applicant to
their house. All the time he used to treat the 1 st applicant as a slave. While so,
during the year 2008, as the 3 rd applicant was suffering from Asthma, the 1 st
applicant requested her maternal grandfather to provide medicine to the 3 rd
applicant. The 1st respondent used to suspect even when the maternal
grandfather talk to her over phone by saying all vulgar language and used to
harass her both physically and mentally. As such in the year 2008, the 1 st
applicant asked her maternal grandfather to stop sending of medicines. Even
thereafter also there was no change in the conduct or behavior of the 1 st
respondent. The 1st respondent did not even allow the 1 st applicant to attend to
the marriage of her younger sister in the year 2009. By the time of the marriage,
the 1st applicant completed only 10th class and joined in a vocational course.
Considering the said fact at the time of engagement, though the 1 st respondent
agreed to continue the study of the 1 st applicant, he did not allow the 1 st
applicant to continue her studies and as such, she left the study within one
month from the date of marriage. However with great difficulty with an intention
to complete atleast a degree, the 1st applicant made several efforts to convince
him and attended to a Entrance Examination at Yeturi Nagaram and though the
1st respondent passed the Entrace examination, he did not allow her to join in
degree. He did not even provide any monitory assistance for her study of degree
examination. However, with the money sent by her mother, the 1 st respondent
despite the fact that the 1 st respondent used to cause obstructions in getting her
degree completed, with all patience, the 1 st applicant completed degree in B.A.
and also taken teacher training. As and when the 1 st applicant attended to the
limited classes also, he used to create a scene and used to abuse and beat the
1st applicant mercilessly. While so, it is in April 2010, on the ground that the 1 st
complaint’s mother telephoned to the 1 st complainant, the 1st respondent beat
the 1st complainant and raided on her with a knife and attempted to kill her at
about 12 noon. It is because of the intervention of the 1 st respondent’s father,
the life of the 1st applicant was saved. Having not satisfied, the 1 st respondent
again caused burning injury with a iron pattakaru. Having learnt about the
torture caused by the 1st respondent when the father of the 1st respondent much
worried about the safety of the 1 st applicant in their house, and at the active
advise of the maternal uncle of the 1 st respondent by name Ganti Srinivasarao
who is working as advocate-clerk, got sent the 1 st applicant alongwith the
applicants 2 & 3, to the house of the junior paternal uncle of the 1 st applicant at
A.S.Rao Nagar, Hyderabad. The 1st applicant stayed at their house for about one
week only. The paternal uncle of the 1st applicant again attempted to convince
the 1st respondent and sent the 1 st applicant to marital life again. Even thereafter
also there was no change in the attitude of the 1 st respondent but on the other
hand, the physical harassment became severe and the 1 st respondent illegally
detained the 1st applicant from attending her degree examinations. Later, in July
2010, the 1st respondent driven out the 1st applicant along with her children and
having no other go, she went to her mother’s house at Hyderabad. While so
living in Nov.2011, the mother of the 1 st applicant made another effort to get the
1st applicant joined for marital life. Though, the 1 st applicant ignoring the severe
physical and mental harassment caused to her, agreed to join for marital life, the
1st respondent did not accept her ultimately deserted the 1 st complainant.
Therefore the attempt made by the mother of the 1 st applicant for getting the 1st
applicant and the 1st respondent for re-union was an utter failure and ultimately
having decided to live on her own, the 1 st applicant joined in a private job at
Hyderabad and started living on her own. While so, though, the 1 st respondent
kept the children for few months ultimately brought them and left them with the
1st applicant in July 2013. Since then the children of the 1 st applicant are with her
only and they are residing separately on their own. The 1 st respondent never
cared for the welfare and safety of the applicants at any point time. He never
even send any amount for their maintenance. The meager amount received by
the 1st applicant being salary is not sufficient for their sustenance. On the other
hand, all the time, the 1st respondent at the active instance of the 2 nd respondent
calling the 1st applicant over phone and used to abuse her in filthy language and
used to threat her with a danger to their lives. The applicant No.1 is
apprehending any amount of danger in the hands of the respondents 1 & 2.
Hence under the circumstances, having no other go, the applicants are obliged
to file the present petition before the Hon’ble court for the reliefs claimed
hereunder. Hence the petition.

VI. Prayer:-

It is therefore prayed that this Hon'ble Court may be pleased:

(a) to direct the Respondent No.1 to pay monetary relief under section 20
(d) at the rate of Rs.4,000/- per month for maintenance of the Applicant No.1
and Rs.3,000/- each to the applicants 2 & 3 for their maintenance and
educational expenditure,

(b) to pass an order under section 18 and 20 to return of dowry lanchanams

and Stridhana of Rs.50,000/- from the 1st Respondent together with interest @
12% p.a. interest from dt.21/11/2011,

(c) to direct the Respondents to pay Rs.10,00,000/- towards compensation

and damages for the mental torture and emotional distress caused by the acts of
domestic violence committed by the Respondents No.1 & 2 .

(d) to direct the Respondents to pay Rs.10,000/- towards costs of this

application.
(e) to pass a preventive order against the respondents 1 & 2 not to visit the
house of the complainants or her place of employment and harass them or
subjecting them to any sort of cruelty or otherwise,

(f) to punish the Respondents as per law.

(g) and to pass such other relief or reliefs as this Hon'ble court may deem fit
and proper in the above mentioned circumstances in the interest of justice.

Be pleased to consider.

COUNSEL FOR THE APPLICANT.

DATE: 18-11-2014
HYDERABAD. APPLICANTS
 IN THE COURT OF THE
METROPOLITAN MAGISTRATE :
NAMPALLY, HYDERABAD.

D.V.C.No. OF 2014

BETWEEN:

T.Kiranmai & others.

..Applicant

and

Mula Ravi Kumar

..Respondents

APPLICATION FILED U/S 12, 18,

20, 22 OF THE PROTECTION OF
WOMEN FROM DOMESTIC
VIOLENCE ACT. 2005 (43 of 2005)

FILED ON: 18-11-2014

FILED BY:

M/s Pappu Srinivasarao,

Advocate
Flat NO.505, Koumudhi Residency,
St.NO.13, Road NO.3,
Nagarjuna Nagar, Taranaka,
Secunderabad-500017.

COUNSEL FOR APPLICANTS

 FORM – III
(See Rule 6 (4) and 7)

AFFIDAVIT UNDER SECTION 23 (2) OF THE PROTECTION OF WOMEN FROM

DOMESTIC VIOLENCE ACT, 2005

IN THE COURT OF THE METROPOLITAN MAGISTRATE : NAMPALLY,

HYDERABAD.

In the name of ______________________ P.S.

D.V.C.No. of 2014
Between:

1.T.Kiranmai
W/o M.Ravi Kumar
aged about 28 Yrs. Hindu, Pvt. Teacher
R/o H.No.8-3-228/214, Rehmat Nagar,
Yusufguda, Khairatabad, Hyderabad.

2. M.Mahati
D/o M.Ravi Kumar
aged about 11 Yrs. Hindu, Minor-student
R/o H.No.8-3-228/214, Rehmat Nagar,
Yusufguda, Khairatabad, Hyderabad.

3. M.Pranathi
D/o M.Ravi Kumar
aged about 7 Yrs. Hindu, Minor-student
R/o H.No.8-3-228/214, Rehmat Nagar,
Yusufguda, Khairatabad, Hyderabad.
... Applicant

AND

Mula Ravi Kumar

S/o Rama Krishna
aged about 39 Yrs. Hindu, Pvt. Employee
R/o H.NO.5-98/1, Kamalapur, A.P.R.Ltd.
Mangapet Mandal. Warangal Dist.
... Respondents

AFFIDAVIT

I, T.Kiranmai W/o M. Ravi Kumar aged 28 Yrs. HIndu, Pvt. Employee, R/o
H.No.8-3-228/214, Rehmat Nagar, Yusufguda, Khairatabad, Hyderabad do
hereby solemnly and sincerely affirm and sincerely state on oath as follows:

1. That I am the applicant NO.1 in the accompanying application for different

reliefs filed for myself and my daughters who are applicants 2 & 3.

2. That being conversant with the facts and circumstances of the case, I am
competent to swear this affidavit.
3. That the deponent and other applicants lived with the Respondent NO.1 at
his house at Kamalapur APR LTd., Warangal district since their marriage on
dt.21-11-2001 till July 2010 when the 1st complainant was driven out by the
respondents 1 & 2 by subjecting her to severe physical and mental harassment
and cruelty and thereafter, the 1 st complainant lived with her mother for some
time and now she is residing at Yusufguda by doing a private job.

4. That the details provided in the present Application for the grant of relief
under Section (s) 18, 19, 20 and 22 have been entered into by me/at my
instructions.

5. That the contents of the application have been read over, explained to me
in English/telugu.

6. That the contents of the said application may be read as part of this
affidavit and are not repeated herein for the sake of brevity.

7. That the applicant apprehends repetition of the acts of domestic violence

by the Respondent(s) against which relief is sought in the accompanying
application.

8. That the Respondent has threatened the Applicant that the complainant
should bring additional dowry and he has harassed the complainant on one
pretext or the other and caused physical and mental torture. Ultimately the
respondent has sent out the complainant from the matrimonial home without
there being any provocation from the complainant. (Detailed complaint
enclosed).

9. That the reliefs claimed in the accompanying application are urgent in as

much as the applicant would face great financial hardship and would be forced to
live under threat of repetition/escalation of acts of domestic violence complained
of in the accompanying application by the Respondent(s) if the said reliefs are
not granted on an ex-parte ad-interim basis.

10. That the facts mentioned herein are true and correct to the best of my
knowledge and belief and nothing has been concealed therefrom.

Be pleased to consider.

DEPONENT
 VERIFICATION
I, T.Kiranmai W/o M. Ravi Kumar aged 28 Yrs. HIndu, Pvt. Employee herein
do hereby declare that the contents and particulars of the suit schedule are true
and correct to the best of my knowledge, belief and information. Hence verified
at HYDERABAD. on 31-10-2014

Deponent
 IN THE COURT OF THE METROPOLITAN MAGISTRATE : NAMPALLY,
HYDERABAD.

D.V.C.No. OF 2014

BETWEEN:

T.Kiranmai & others.

…. Applicant
AND

Mula Ravi Kumar

…..Respondent

I, T.Kiranmai W/o M. Ravi Kumar aged 28 Yrs. HIndu, Pvt. Employee, do hereby
appoint and retain

PAPPU SRINIVASARAO
Advocate

Advocate/s to appear for me/us in the above Suit/Appeal/Petition/Case and to

conduct and prosecute or defend the same and all proceedings that may be taken in
respect of any application for execution of any decree or order passed therein. I/We
empower my/our Advocate/s to appear in all miscellaneous proceedings in the above
suit or matter till all decrees or order are fully satisfied, or adjusted, to compromise and
obtain the return of documents and draw any money that might be payable to me/us in
the said suit or matter and I/We do further empower my/our Advocate/s to accept on
my/our behalf service of notice of all or any appeal or petition filed in any court or
appeal Reference or Revision with regard to the said suit or matter before disposal of
the same in Honourable Court.

I certified that the executant who is well acquainted with English, read this
Vakalatnama that the contents of this Vakalatnama were read out and explained in
Urdu/Hindi/Telugu to the executant he/she/they being unacquainted with English, who
appeared perfectly to understand the same and signed or put his/her/their name or
mark in my presence.

Identified by Sri _______________________________

Executed on 17-11-2014 ADVOCATE

At HYDERABAD.
 IN THE COURT OF THE
METROPOLITAN MAGISTRATE : NAMPALLY,
HYDERABAD.

D.V.C.No. OF 2014

BETWEEN:

T.Kiranmai & others.

….Applicant
AND

Mula Ravi Kumar & another.

…Respondents.

VAKALAT

ACCEPTED

FILED ON: 17-11-2014

FILED BY:

M/s Pappu Srinivasarao,

Advocate
Flat NO.505, Koumudhi Residency,
St.NO.13, Road NO.3,
Nagarjuna Nagar, Taranaka,
Secunderabad-500017.

Counsel for Applicants.