IN THE HON’BLE FAMILY COURT AT SHIIVAMOGGA

M.C. No.:_____/2019

Petitoner : Shivananda

V/s

Respondent : Smt. Suma

STATEMENT OF OBJECTIONS TO THE MAIN PETITION

The above stated respondent humbly submits as follows:

1. It is submitted that the respondent is the legally wedded wife of the petitioner and their
marriage was solemnized on 21/05/2019 at K.E.B Samudhaya Bhavana, Shivamogga as per
the custom and rituals prevailed in their community. Prior to the date of marriage an
engagement ceremony was also held in the resident of the respondent at railway quarters,
Shivamogga on 23/11/2018. On the date of engagement the respondent’s parents gifted gold
ornaments and cloths to the petitioner.

2. It is submitted that the respondent was brought up from her childhood in the parental
house of the petitioner at Navule and from the beginning all the family members of the
petitioner and the respondent have agreed to take the respondent as daughter-in-law of the
petitioner’s family. The same was known to the petitioner also. The petitioner had also
voluntarily expressed his willingness to marry the respondent and it was the petitioner who
waited for the said occasion.

3. It is also pertinent to state that after the engagement ceremony, the respondent’s parents
performed the marriage at K.E.B Samudhaya Bhavana on 21/05/2019 meeting all the expenses
of the marriage. During the ceremony a gold chain, gold bracelet, gold ring, Rs. 2,00,000/- and
also household utensils were also given to the petitioner as dowry. Even after the marriage the
petitioner kept on demanding a higher cash amount with the parents of the respondent saying
that he wanted to purchase some more auto-rickshaws. In that connection the petitioner used
to pickup quarrels with the respondent and her parents.

4. Subsequent to the marriage about one and half months both the petitioner and the
respondent led a happy marital life in Navule. Both the couple visited their relatives as per the
customs. The petitioner looked after the respondent with abundant love and affection during
that period.
5. It was a blue from the bolt for the respondent to learn the petitioner had already married
to another girl by name Bhagyalakshmi, D/O Govindaraju, R/O Jayanagar 3rd cross
Shivamogga on 02/06/2019 and got the marriage duly registered. The said second wife
Bhagyalakshmi also knew about the marriage of the petitioner with the respondent much
earlier. It is also pertinent to state that the petitioner got manipulated the documents as if the
said marriage took place on 13/01/2019. On coming to know of the said objectionable act on
the part of the petitioner the respondent and all her family members raised stout objections.
6. It is submitted that from that day onwards the petitioner stopped visiting the marital
home. The respondent has been able to collect information that the petitioner has arranged a
separate house at Ravindra Nagar beside railway track, Shivamogga and residing with his
second wife Bhagyalakshmi. The petitioner has completely and culpably ignored and neglected
the respondent. Despite the respondent being subjected to all sorts of desertion and cruelty she
continued to stay in the marital home along with her mother-in-law and petitioner’s brother
performing for marital obligations. It is further pertinent to state that the respondent has
suffered immense mental agony at the threshold of her marriage and thereby the petitioner has
tarnished and destroyed her life.
7. As a matter of fact the respondent’s parents and petitioner’s brother and relatives made
all efforts to resolve the said controversy but unfortunately the petitioner has not cooperated
with them. Since the petitioner has not shown any inclination to perform his legal obligations
and resorted to illegal measures it has become inevitable for the respondent to take recourse to
the legal action.
8. It is submitted that the respondent is about to initiate criminal action against the
petitioner and his second wife Bhagyalaxmi for the offence of bigamy in the competent law
Courts. Interestingly the petitioner has filed the above case seeking a decree for dissolution of
marriage solemnized between him and the respondent on 21/05/2019 at K.E.B Samudhaya
Bhavana, Shivamogga, in the said petition. The petitioner has resorted to make false and
baseless allegations against the respondent only to nurture his hawkish intentions.
9. It is important to mention that the petitioner has completely neglected and ignored the
respondent and failed to provide maintenance to her as he has abandoned the respondent
immediately after about one and half months from the date of marriage.
10. The avertments in para 2 of the petition that the respondent is legally wedded wife of
the petitioner and their marriage took place on 21/01/2019 are admitted. It is also admitted that
it is an arrange marriage. It is true that the respondent is none other than the daughter of the
parental aunt of the petitioner. The avertments in para 3 of the petition that immediately after
the marriage the petitioner came to know that it is a forced marriage are false and incorrect.
11. The avertments in para 4 of the petition that in spite of repeated request by the
petitioner the respondent turned deaf ear and refused to join the petitioner to continue the
marital relationship which has amounted to cruelty and the respondent has failed to perform
marital obligations are all absolutely meaningless.
12. The avertments in para 4 is ofcourse true but the said seperation has occurred not an
account of the wrong committed by the respondent but it is on the account of the fault
committed by the petitioner.
THEREFORE, the respondent humbly prays that the Hon’ble court may kindly be pleased to
dismiss the above petition with costs in the ends of justice.
Advocate for Respondent Respondent
____________________ ______________

What are all stated in above paras are true and correct to the best of my knowledge belief and
information
Place: Respondent
Date: _____________