clas ANE COURT‘OF THE Jub; ia IC’ PHAR Between; Mo, LP.Sudeepika ali ; ae 2.1.Roopa sTee “s Deepika pETITIONE! jad L.Venkateswara Prasad RESPONDENT “Venkateswara Praad, aged about 9 Sears» esented by her mother ~ Natural guardian i.e., > 1s Petiti Both are Hindus, residing at Yygor No.25/485-5, Near Anjineya swamy temple, Parthasarathy Naar, Dharmavaram : ADDRESS _ : Sti D. Vijaya Ragjavendra FOR Smt J.Suma Latha, Cell N6,9703101055 SERVICE — Advocates ‘ Dharmavaram Email :babu.sumal 1 @gmail,com 2.Respondent : L.Venkateswara Prasad S/O Lingampalli Chinna Singaraiah , aged about 44 years, Hindu, Business, residing at D.No.2-506, Ragithota Palem village, Tadiptri Mandal. The petitioner submit that 3. The 1* Petitioner is the legally weeded wife of the Respondent, The marriage between the 1* Petitioner and the Respondent was solemnized on 12.06.2011 as per the Hindu Marriage rites and customs prevailed in their community at Sree Chowdeswari devi Thogata veera Kshatriya Kalyana Mantapam, Gandhi Nagar, Dharmavaram.tely after the marriage, join the imoni: dent at Ragithota Palem, Tadipatri matrimonial home i" aac _ hearente of tae Repo and they lived happily alo! : : about ce year. The 1% Petiti Submits that during the wed lock between the 1 Petitioner aif the Respondent, they begot one daughter i.e., the Petitioner N¢#- The 1" Petitioner submit that at the time of iinarrings between tie 1* Petitioner and Respondent, the parents of the 1* Petitioner gav@ to the Respondent and his parents 13 tulas of gold ornaments andRS.1,50,000/- towards the perks. 4. The 1 Petitioner, im 5. The 1* petitioner submit that immediately after seven months from the date of marriage the 14 Petitioner conceived her pregnancy and immediately the respondent and his parents are started to harass the 1* Petitioner and tHey, are openly proclaiming if the 1+ Petitioner begotten female child we forcibly necked out the 1* petitioner from the matrimonial house and the respondent and his parents demanded the 1* Petitioner for nt dowry for that the 1* petitioner requesting the respondent the parents of the let iti 0 capacity to giye..additiohal-dowry to the ionerfSubmit that the respondent and his of the 1* petitioner and without any showing mercy as she is carrying a child. 6. The 1" Petitioner submit that finally she begotten a female child i.e, 2n4 Petitioner in the year 2012 at RDT Hospital Bathalapalli having knowledges about the female child by the Respondent the respondent and his Parents even not came to look his child and also they are proclaiming that we don’t want the 1s petitioner as well as the 2” petitioner as the 2"4 petitioner is a female child and the respondent informed to the 1% petitioner through a phone call that he don't want to continue a marital life. The 1* Petitioner submit that the Parents of the 1st other elders approached the Respondent and_ hi requested them to accept the petitioners and lived happy marital life and the respondent and his parents only on the request of the petitioner and her parents they are accepting to take back the petitioner and her child and immediately the petitioner and her child went to her matrimonial house, but the Respondent and his parents have not show any mercy on the Petitioner and her child and behaving as rood force and showing cruel nature on the petitioner and openly proclaiming that he don't want to lead marital life with the petitioner as the Respondent with an intention to get second marriage with another women intentionally necked out the petitioner and her child in the year 2014 and again the parents of the petitioner requested the respondent and his Parents to take petitioner with is parents andback the petitioner to matrimonial house = oie 5 the respondent accepted the petitioner pi oe ee again the respondent and his pasts anne necke i harass the petitioner and her chi and ect H e and with petitioner and her child from the gatrimonial =, fm any alternative the petitioner andbet eC house. ’ 7. The 1* Petitioner submits thatthe Respondent and his parents have necked out the Petitioners | her matrimonial house without any justifiable reasons refused a nepiected: to maintain the Petitioners in spit ving sufficient ao 's maintain the petitioners since thi of the 1* petitioner are very poor and helpless persons sssion by tailor and the parents of the 1* Petitioner are “@Mebl adjust the amount of more amount as described by the Resp no other alternative except to stay in the Hence 1* Petitioner's parents are unab needs,of.the Petitioners and 1» pg herself and also 2ad whatsoever the 1*t Pel petitioner ‘and é er to maintain herself due to mental agony caused by the Respondent aiid his parents the health of 1s Petitioner is spoil. The Re ent is having sufficient means to maintain the petitioners but refused and neglected the petitioners without having justifiable reason, 8. The 1* petitioner submits Hat the Respondent having two houses and one house site at Tadipatri town which are valued about Rs.40,00,000/- and the R lent is also working as medical senior scientist he is getting income of Rs.80;,00,000/- per month. The Respondent is having sufficient means willfully, intentionally deserted the Petitioners 1 and 2 without any just cause to maintain the Petitioners though the Petitioner No.1 is absolutely no means to maintain herself. The Petitioner No.1 has no other alternative except to approach the Honle court to file this petition. 9. The 1* Petitioner submit that in this harden days expenses of the 1% Petitioner to minimum maintenance and 1" Petitioner is entitled for the maintenance of Rs.20,000/- to the 1* Petitioner ang Rs.15,000/- to the nd Petitioner Lad month from the Respondent, failing which great prejudice 4n¢ unjust will be caused to the petitioners.ed that the Hon'ble court may be ‘Ummon the Respondent and make he Respondent to pay monthly © 1 Petitioner and Rs.15,000/- onth from the date of filing the rs as the Hon'ble court deems fit Ses of the case in the interest of 10. Hence it is therefore Pleased to take the case 07 i enquiry, and order, direc’ m&intenance of Rs.20,000/- the other 2m¢ petitioner per Petition, and pass such other’ and proper under the circum justice. 1s\ PETITIONER (FOR Minor Petitioner No.2 ) I the above named Petitioner-doGere by solemnly affirm and declare that what are stated in the akgyr Paras are having been read over and explained to me in Telugu ahd @fter admitting by me to be true and correct to the best of my knowledge; belief and information) 1 signed upon this at Dharmavarémon day of January 2022 : 1st’ PETITIONER or Petitioner No.2 ) 1, 12.06.2011 Wedding card Filed 2. Marriage photo with C.D. Filed ADVOCATE FOR THE PETITIONERS