Marriage Annulment Petition When Wife Used Insane Tactics to Destroy Husband Life

7/28/2019 Marriage Annulment Petition When Wife Used Insane Tactics to Destroy Husband Life

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IN THE COURT OF THE FAMILY JUDGE AT -----------

M.C. / 2013

In the matter of the Hindu Marriage Act, 1955.

PETITIONER VS RESPONDENT

NAME:

S/O:

AGE: 35 YEARS

OCCUPATION:

PRESENT ADDRESS:

PRESENT WORKING ADDRESS:

LAST RESIDED TOGETHER

ADDRESS;

NAME:

D/O:

AGE: 42 YEARS

OCCUPATION:

PRESENT RESIDENTIAL

ADDRESS:

PRESENT WORKING ADDRESS:

LAST RESIDED TOGETHER

ADDRESS;

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 noticesof 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. Theirmarriage took place on ________________ at ____________________. As an evidence

of the marriage the marriage Invitation card is herewith produced as

Document NO. 1.


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3. The petitioner submits that after the marriage, both petitioner andrespondent lived and resided in the address as mentioned in the cause title

as LAST RESIDED TOGETHER ADDRESS. Ever since then they are

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, hasdisclosed 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 theknowledge of this petitioner on ____________ just one day before marriage, asdisclosed 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 nuptialceremony date on _____________. Till then this petitioner is being advised to

visit Home God in ______________, ____________ temple and ______temple, as

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 thispetitioner 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


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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 aftervisit 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 vacatedand later on the night of 31-07-2012 tried to have consummation 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


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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 bythis 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 wasfacing 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 viewsspoken before relatives of petitioner and before petitioner has forced this

petitioner to record her voice conversation for the first time on 30-08-2012.


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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. She sought permission from petitioner mother to go to mysore to shifther parents to new house (new cause created before petitioners mother).

b. She confesses to have been 6 years older than petitioner.c. Tries to convince her mother-in-law (petitioners mother) to arrangefor another marriage for this petitioner.

d. Tries to convince that she is not fit for marriage and procreation.e. She repeatedly says she is not physically fit.f. For the first time she says she is having medical report about herproblem.

17. The petitioner submits that the first such conversation of respondenthas created a shock to the petitioners mother. When respondent is

departing from petitioners house on 02-09-2012 respondent took all herbelongings 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 intentionof 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.


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19. The petitioner submits that, repeatedly respondent used her phonenumber ______________ to send messages to petitioners mobile number

_______________- and the respondents several message mode is quoted herein

below.

a. Several times she showed love and affection in message.b. Several times she threatened this petitioner.c. Several times she confessed and encouraged petitioner to have secondmarriage.

d. Several times she threatened to have divorce at once.e. Several times she threatens not to give any divorce and insists thatshe will continue her harassment.

f. Several times makes wild allegations and alleges illegal relationships.g. With wild imagination respondent tags petitioner as pervert with hercousin sister ____________ on 04-12-2012 message, this was suitably replied.

h. On 08-01-2013 respondent messages to petitioner that her husbanddied 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 Ayyappamala, 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 affairswith 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 topetitioners new house along with her father and mother on Friday (22 -03-

2013) 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 isnot 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.


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m. Starting from reason of age factor and self-guilty and work continuingintention, 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 real cause, false

allegation with work collegaues and family friends, which is in all split

personality of respondent.

20. The petitioner submits that, the conversation over telephones ofpetitioner 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 startedconversation 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 JzgP

.. ..

M: CAU Csg Ez, AU MAz CsgEz, JjU MAzAz Csg Ez, JjU Ez. AiijU E AiijU P

Cz. .. .. M U Csg Ez Pu JjU Ez .. .. M: FU C AzC 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 petitioneragain 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


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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: dv 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 CPgPAq , 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 EzC 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 respondentalone came to petitioners house all of a sudden. On that night this petitioner

recorded voice conversation that ensued in between petitioner and


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respondent. Totally about 21 minutes of voice record is there, in that record,

the respondent speaks following things.

a. She says she came to discuss about divorce.b. She says she is in the verge of menopause and no use to petitioner.c. She says she and her family will support for second marriage ofpetitioner.

d. Refused to come and sleep with petitioner.e. She says if petitioner is averse to have third marriage, she is ready todie after December and then happily can marry third time.

f. She says she has eaten the food at the hands of petitioners mother andshe has to act according to dharma to her.

g. She says z zAil P , EU zPVzv 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. She says lets have divorce happily. She says she still loves petitionerdeeply.

i. Says someone has alleged extramarital affairs allegation againstpetitioner 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 calledpetitioner by above phone numbers, cool conversation took place, and

respondent demanded divorce from petitioner. Dramatic allegation of extra-

marital 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


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both families. Respondent repeatedly uses such words like wife:

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 thispetitioner 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,


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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, UPz 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 non-

existing things against former divorce life of this petitioner.

26. The petitioner submits that, On 10-11-2012 this petitioner aftergetting 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: Uq 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


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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 fileall 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.

27. The petitioner submits that, On 19-12-2012 respondent calledpetitioner, 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. JgAz 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 Alg DUv E. Cz U Uv. Aiiz jw vAz Aiiz PgtP DU

zQggU. j. EzP j U K PUv . Husband: UK Uw Pt P DVn. M: FU U Aqw P q PCAv AiZ iqPVgz . .. .. .. Husband: Jq K E Pt m irPwAi. M: C Cz Ez L qAm Pg. Husband: CzUv Pg E CAv. M: z. q CzP AU ivqwAi. iv Jwzgq, 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 PAU AiiP ivqwAi. K AUz M: C Cv Az D s CAPJg PjPAq ivrz. Husband: K ivrz. KAv. MM: C


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P E U q P v. Pqw CAv w v, AiiP F

vvAi U. .. .. Husband: Cv z , qj P Pw CAz, PAqige P Pw CAz, M: RArv CAz. u qA ev Cjg ev CwgUwz 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 : KCz jwAi j. M DAi. jAi E . JgqlvAAi CAv PwAi, Aiiz Ez ivrAi, MAz D PPUwAi 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 qEAz 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 AUiq. M: CAi AU C CgiV Eg. Aiig vAzg irqP E PwErPAq Avg. Husband : U Uw. M: Cz irPP CAv EQAim 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. mqw FU JgqAiz s CAz zg rgz. Husband: zgqv. 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 zPVPAq gw CAv Uv Ez. Husband : U Uw. M: gegVEz. Husband : U Uw. Husband: UwAz Cg U ivqgz. P Cg. Cg U ivqgz.

28. The petitioner submits that, On 23-12-2012 respondent telephonedthis 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


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Az zg DUP gAi Aiv iqz Mz. Husband: .. .. Cv CPAi, CAi ElPArAi C v rwzg CAz, DAii

Cz CU PU. M: RArv CAz . (06-12-2012 msAuAi PAi) Husband; Cz z C v V qv Cv.

M E CAv . U z U. CAz d.CA. JzjU CA. .. .. .. .. Husband : Cz Vz Vg WlAd 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 vC 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 . UvE. 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: KUw C. M: E itPV Aii qV . E M sgirgz P. Husband: Aii jw sg ir CAv z v UvUP.M: ZVgP AiiVg C. CzP q P q zPPq. 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.


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29. The petitioner submits that, the above stand of respondent that she isimplicated 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.

30. The petitioner submits that, later respondent began allegatingagainst 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 toweaken 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 Pgr E Pu .. .. M: C. P CVz Pg D vPUwg. gz CAv zsg irAi. .. .. Husband: E E. M: Dzsg Az Azg, Az P iq. Az Azg q Pl

l z U Ci DUv. .. .. M: q U E E. s Cs UqP 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 KP UAq . Husband: j DAi Pq . M: P s. Husband:DAi NP. M P s. D vPv Lv q. Nrz qvzAi Nrl. MU iqwg Jg AUg AU. PgzPAq

Pg DU w. J. Fv s iq CAv. .. .. M:


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UAq Pu C P ZAzU. UAq 10000 EAq UAl

irPvAv. Czs lg vgv. .. .. M: U vAg JzjUU QPAq Prv. .. .. Husband : j EAwAv Z Z Cz jvEAi . .. .. 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. .. ..

31. The petitioner submits that, on 06-01-2013 when petitioner called therespondent, 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. M Cz AZ J s ir l nzg DAigU. Husband: Aiig U K Uv. M: MAz J Pv j gzEzU U K P Cz PP C. .. .. M: Pg Aqw UPg. Aig PgzPAq Az U Az q U. .. .. .. M: PCAv 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 calledrespondent for having hurted with the message of respondent that this

petitioner is dead. The relevant conversation run like this Husband : KAd AUAz m . AAzs AiizP E. UAq vz CAv e

iqwAi. zQ CAv P irz. M: Aiiv Pg DUPgz 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


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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 .

33. 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 gavemiss 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 givingher valid and sane consent to marriage for having suppressed the fact of age

difference by her parents has after marrying this petitioner avoided to

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


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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 herselffrom 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 themysore 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 nomeans 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


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respondents insanity, invalid consent, and misrepresented and perpetuated

fraud. Hence this petition.

39. The petitioner submits that, the typed copies of major relevantconversations contained in DVD is under progress, the copies will be

submitted at the time of evidence or very shortly, the downloaded form

of conversation in SMS from 07-10-2012 to 22-03-2013 from

petitioners mobile is produced as Document- 6 for kind perusal of the

Honble court.

40. The petitioner submits that, the unsound mind of respondent is notbeing 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 abovepetition 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 Article1 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. Petitioner.


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V E R I F I C A T I O N

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

IN THE COURT OF THE FAMILY JUDGE AT

M.C. / 2013



NAME: NAME:

AFFIDAVIT VERIFYING THE PETITION


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I, ________________ S/o late ____________________ and ________________, Hindu, Aged

about ________ years, R/a ________________, Tumkur, do hereby solemnly affirm

and state on oath as follows: -

1. I am the petitioner in the above petition and I am fully acquaintedwith the facts of the case.

2. I submit that the averment of facts stated in Para 1 to 42 of thepetition 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:


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M.C. / 2013



NAME: NAME:

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.


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M.C. / 2013



NAME: NAME:

A F F I D A V I T

I, _________________ S/o late _______________ and ________________, Hindu, Aged

about 35 years, R/a ________________, Tumkur, do hereby solemnly affirm and

state on oath as follows: -

1. I am the petitioner in the above petition and I am fully acquaintedwith the facts of the case.

2. I submit that I have filed the above case for Declaration of mymarriage 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:


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TUMKUR

M.C. / 2013



NAME: NAME:

LIST WITH DOCUMENTS

NO PARTICULARS

1 MARRIAGE INVITATION CARD

2 XEROX COPY OF JATAKA

3 CONVERSATIONS CONTAINING DVD

VIDEO RECORDED ON 14-02-2013

UNQUOTED PHONE CONVERSATIONS

4 _____________ QUARTERS SANCTION LETTER

5 SALARY CERTIFICATE OF PETITIONER

6 DOWNLOADED FORM OF SMS MESSAGE

Tumkur.

Dated: Petitioner.


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M.C. / 2013



NAME: NAME:

INDEX

NO PARTICULARS C.FEE

1 PETITION UNDER SECTION 12 (b) & (c) OF THE HINDU

MARRIAGE ACT 1955 R/W RULE 1(V) OF HINDU

MARRIAGE RULES 1956 IN TWO SETS

100-00

2 VERIFYING AFFIDAVIT

3 APPLICATION UNDER SECTION 13 OF THE FAMILY

COURT ACT

4 AFFIDAVIT IN SUPPORT OF IA

5 VAKALATH

6 LIST WITH DOCUMENTS

7 COPIES OF PETITION, DOCUMENTS WITH LIST TO

RESPONDENT

8 PROCESS MEMO WITH POSTAL COVER AND REQUISITE

STAMP

16-00

9

10

Tumkur.

Dated: Petitioner.

Documents

Marriage Annulment Petition When Wife Used Insane Tactics to Destroy Husband Life