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IN THE HONOURABLE COURT OF THE PRINCIPAL DISTRICT JUDGE

DOP NO : 17/2024
Between:
Eda Agnes Priyanka ….Petitioner
And
Eda Sreenivas Kumar …Respondent

COUNTER FILED ON BEHALF OF THE RESPONDENT

1. The averments in the petition are all not true, valid, and binding on this
respondent.
2. The averments in the petition that the petitioner got married to the respondent at
Ramachandra Gardens in Palakollu of west Godavari on 06-06-2019 according
to Christian rites and custom and that the Dr. Sudhakar , syam babu and sekhar
babu acted as marriage elders on behalf of the petitioner and that immediately
after marriage the petitioner joined the respondent at his house at Hyderabad
and lead martial life for a period of 3 months only and that there are no issues in
between them during their wed-lock and that as per the demand of the
respondent and his family members the father of the petitioner gave Rs.
50,00,000/- towards dowry in presence of the aforesaid marriage elders and that
immediately after marriage she has joined the respondent in his house at
Hyderabad and at that time the parents of the petitioner gave sari samanulu
worth of Rs. 5,00,000/- and at the time of joining with the respondent, the
respondent and his family members also used to reside in the same house and
that from the date of joining with the respondent in the matrimonial home the
father and mother of the respondent used to see the petitioner in different way
by abusing the petitioner for each and every thing stating that they are well off
and harassed the petitioner stating that she has brought less dowry and used to
state that at least she would have brought one crore as dowry and that the
respondent, his parents, his sister used to harass her mentally in different ways
and that the respondents and his family members used to harass by saying that
the petitioner is staying in the house but not paying atleast the house rent and
current bill and that the sister of the respondent is a divorcee and she also used
to stay in the same house and that after 2 months the respondent took the
petitioner to ICON Hospital for medical checkup and there the doctor informed
that the petitioner is pregnant and from that day the respondent and his family
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members used to harass her mentally stating that the baby in the stomach is not
at all related to the respondent and because of the metal harassment done by
them the petitioner thought of committing suicide and that the respondent and
his family members used to harass her for doing abortion and then the petitioner
questioned them that why she has to undergo abortion for which the respondent
and his family members stated that until she brings Rs. 50 lakhs as additional
dowry she should not give birth to children and used to threaten that they will
perform another marriage to the respondent and that on 22-9-2019 When the
petitioner is not feeling well and taking rest the respondent along with his
parents and sister brought some juice and asked the petitioner to consume it so
that she will be well and then the petitioner has taken that juice and from then
after some time she got severe stomach ache and some bleeding took place and
the petitioner questioned the respondent and his family members that she is
getting bleeding and what they have done to her and then they stated that they
are not interested for me to give birth for children and so they have mixed some
abortion tablets in the juice and made the petitioner to drink it and it worked
well and the respondent and his family members are laughing by seeing each
other and then she requested the respondent and his family members to take her
to hospital for treatment for which they stated that it is waste of expenses for
them to take to the hospital and asked the petitioner to go to her parent’s house
and then the petitioner having no other option left the matrimonial home on the
night of 23-9-2019 and came to her parent’s house on 24-9-2019. The petitioner
submits that that after reaching Vizianagaram, her parents have taken her
immediately to PVR Hospitals wherein the doctor has examined her and
advised necessary clinical examinations and after that the doctor has conducted
abortion because of mis-carriage and after that as the respondent did not come
forward to take her back to the matrimonial home the father of the petitioner
has taken the petitioner to the matrimonial home on 9-11-2019 and during her
stay in the matrimonial home the sister of the respondent used to harass the
petitioner stating that the petitioner doesn't suits to her brother and also used to
state that as her husband gave divorce to her she will see that the petitioners life
will also spoiled and harassed the petitioner in different ways and that the sister
of the respondent used to tell un-necessary things against the petitioner to the
respondent and instigated the respondent to harass the petitioner and that the
one Tadi Christoper who is the uncle of the respondent used to come to their
house and harassed mentally saying that they have left the match who agreed to
give 1 crore dowry to the respondent and they performed marriage with the
petitioner and harassed the petitioner to bring additional dowry and that on one
fateful day the respondent bet the petitioner black and blue saying that the
petitioner should not be alive with over excitement hit the head of the petitioner
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to a wall and tried to kill the petitioner and that the same thing has been
informed to her father and in turn the father of the petitioner went to the house
of the respondent along with the mother of the petitioner and elders by name
Ravi Kumar and Prakash and all of them requested and convinced the
respondent and his family members to look after the petitioner properly and
came back and that after that the petitioner is not feeling well and then asked
the respondent and his family members to send her to her parent’s house for
treatment and then the respondent and her family members refused to send her
and also refused to provide proper medical treatment and then the parents of the
petitioner has sent the elders by name Ravi Kumar and Yesurathanam to the
house of the respondent and they got convinced the respondent and their family
members and sent the petitioner to the parent’s house on 10-03-2020 and that
after coming to the parent's house she used to call the respondent but the
respondent did not respond to her and surprisingly kept the number of the
petitioner in black list and that when the respondent is not responding the father
of the petitioner took the petitioner to the matrimonial home with the elders by
name Prakash, Ravi Kumar and Yesurathnam and dropped her and that from
then onwards the respondent and his family members did not allow to stay her
in the bedroom of the respondent and made her to stay in a small room and
harassed her mentally and physically and that the respondent and his family
members treated her like a servant maid and even did not allow her to go
outside and confined her in the house itself and that finally on 6-7-2020 the
respondent and his family members necked out the petitioner from the
matrimonial home and the petitioner having no other option came to her
parent's house and that seeing the all the above said circumstances and incidents
she got understood that the respondent is not at all interested to continue the
matrimonial life with the petitioner and further submits that all the above acts
and incidents done by the respondent and her family members including the
respondent the petitioner has broken her heart against the respondent and also
broken all the love and affection towards the respondent which the petitioner is
having till now and all her hopes that one or the other day the respondent will
join the petitioner and lead happy married life turned futile and that with all the
above acts done by the respondent and his family members she came to an
opinion that in the present circumstances there is no use to continue efforts for
re-union with the respondent and so the petitioner came to a decision to obtain
divorce from the respondent and that the embittered relationship in between the
petitioner and the respondent has not witnessed any moment of peace from the
last 50 months except the marital relationship is only on paper. The petitioner
submits that the multiple battles in between them and the repeated failures in
mediation and conciliation is at least testimony of this fact that no bond now
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survive between them, it is indeed that the marriage has been broken down
irretrievably and that the marital relationship in between them has become more
bitter and acrimonious over years which inflict cruelty and that the long
separation and absence of cohabitation and the complete breakdown of all
meaningful bonds and existing bitterness in between both of them itself is
cruelty and that there is a desertion in between the petitioner and the
respondent from 50 months and also the respondent is not intending to take
back the petitioner in future inspite of number of mediations which are
conducted by the parents of the petitioner and so there is no fun in continuing
the marital tie. The petitioner submits that form the date of her marriage she has
been treated with all cruel acts by the respondent and his family members and
so the present petition is filed for divorce and that the cruelty done by the
respondent and his family members has caused apprehension in her mind that it
would be harmful and injurious for the petitioner to live with the respondent
and that the respondent though he is fully aware about his dislike towards the
marriage with the petitioner for the reasons best known to him married the
petitioner by suppressing the said fact and committed fraud and cheating
towards the petitioner and her family members and the said fraud and cheating
was exposed only with the stay of her with the respondent and that the
respondent treated her with cruelty and by doing all the above said acts and that
she has been subjected to mental cruelty by the respondent and his family
members all these days the above acts of the respondent are sufficient to
tantamount to cruelty and that she was mal-treated, harassed and black magic
applied on her by the respondent.
3. The contents of the petition are all not true correct and the petitioner created
false story to file this petition and petitioner is put strict proof of all the
allegations of the petition.
4. This respondent submits that the marriage between the petitioner and this
respondent was arranged marriage and marriage between them took place at
palakollu, West Godavari district according to Christian rites and caste custom
on Dt 06-06-2019. At the time of marriage this respondent was working in
Hyderabad as Assistant Manager at Indian Bank and his family was settled in
Hyderabad though they hail from Palakollu, West Godavari District.
5. This respondent submits that the petitioners hail from Pallakollu, West
Godavari District though settled in vizianagaram District and the parents of
petitioner informed that the petitioner doing job and getting Rs 65,000/- per
month by working in Infosys at Hyderabad and she is earning equivalent to that
of the respondent. When the respondent family was planning to perform the
marriage between the petitioner and the respondent at Hyderabad but the
parents of the petitioner requested them to perform the marriage at Palakollu
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which is nearest to both the parties and subsequently the marriage was
solemnized at palakollu, West Godavari District and all the marriage expenses
were spent by the respondent and there was no dowry presented bye famly of
petitioner.
6. The respondent submits that immediately after the marriage, the petitioner
joined conjugal society along with respondent at Hyderabad and after two
months the respondent came to know that the petitioner was conceived.
Knowing that petitioner got conceived the respondent took the petitioner to
ICON Hospitals at Kukatpally, Hyderabad and used to closely monitor the
health of the petitioner, the respondent along with his family used to look after
the petitioner properly by providing nutritious food, medicines for growth of the
baby in the womb and also towards the health of the petitioner. In the month of
September 2019, the petitioner was diagnosed and she was affected by
Chickenpox, after due consultation with Dr Sasirekha, ICON Hospital at
Kukatpally Hyderabad, the petitioner had been taken care by the respondent and
his family members to recover and doctor advised the petitioner to undergo
TIFA scan on 01-10-2019 to access the situation of the health of the fetus
properly due to contraction of chickenpox by mother and it was tough for the
respondent to digest the same. Knowing the same, the parents of the petitioner
called the petitioner to come to Vizianagaram stating that they will provide
better treatment as the petitioner maternal uncle by name Dr Sudhakar, who was
working in ESI Hospital Vishakhapatnam has good circle of practicing fellow
Doctors in Gynaecology in Vizianagaram town and they will provide the best
treatment to the petitioner and believing the words of the petitioners father, the
respondent along with the petitioner came to vizianagaram hoping to find good
treatment and the petitioner left to Hyderabad for work leaving the petitioner at
the petitioners house thinking that the petitioner and the baby in the womb of
the mother were in safe hands.
7. The respondent submits that the petitioner along with her father, mother and
maternal uncle, Dr Subhakar misguided the respondent that they have consulted
many colleagues of Dr Subhakar and all suggested that the fetus should be
removed immediately as there is every chance of fetus being affected by
Chickenpox virus. The respondent further submits that without the consent or
intimation to the respondent, Dr Subhakar along with petitioner parents have
got abortion done to the petitioner at PVR Hospitals, Station Road,
Vizianagaram on 29.09.2019 under the supervision of Dr Sudhakumari,
Gynaecologist who is a close friend of Dr Subhakar. Knowing this immediately
the respondent rushed to the operation theatre and asked them to show the scan
report or any other report evidencing the abnormal growth of the baby which
they denied, and petitioner parents have necked the respondent out of the
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Hospital and used filthy language against him. Inspite of the above said fact,
respondent stayed at Vizianagaram and directed the petitioner to come to
Hyderabad if she can travel or to come immediately after the recovery.
Accordingly, the petitioner came to Hyderabad on 09.11.2019.
8. This respondent submits that his elder sister by name Chandana who was a
divorcee and was staying in the same house along with respondents and family,
which the petitioner along with her parents could not tolerate her stay in the
said house and they started uttering that she is unable to bear children and she
used to abuse her as Transgender. Unable to bear the words of the petitioner
along with her parents many times, the sister of the respondent tried to commit
suicide. Respondent further submits that petitioner along with her parents used
to pressurize respondent to transfer the entire properties held in the name of
respondent parents and respondent sister in the name of the petitioner and also
insisted the elder sister of this respondent shall leave the house and never to
come back.
9. This respondent submits that the petitioner with the abetment of her parents
started quarrelling with the age-old parents of the respondent and demanding
them to hand over the entire earnings of respondent and his parents to herself
for managing the family and further submits that the respondents or his family
never asked about the earnings or expenditures of the salary that the petitioner
is earning. The respondent further submits that the days passed hardly for the
respondent, the petitioner along with her parents further added the demand to
set up a separate family by leaving the age-old parents and the same was
refused by the respondent stating that his father health condition is not good and
need assistance which his mother alone cannot afford due to her old age.
10.This respondent further submits that even the parents of the petitioner along
with her maternal uncle Dr Subhakar have demanded the respondent to transfer
all the properties held in the name of the respondent parents in the name of
petitioner immediately or else the petitioner would be taken back to her parents'
house and perform another marriage. Accordingly, the petitioner was taken
away by her father on 06.07.2020 by threatening the respondent that all his
family members will be booked in number of false criminal cases, as the father
of the petitioner happens to be Assistant Commandant, APSP 5th Battalion,
Vizianagaram and he can influence local police. In the said manner, as of
threatens by the father of the petitioner, the petitioner along with the help her
father by misusing the power and contacts foisted false cases against the
respondent and his family members in Cr No 11/2021 and same is pending
before the Hon'ble Sessions Court.
11.This respondent submits that his father is suffering is with a rare Bone Marrow
disorder with low blood platelet count and requires frequent blood transfusions
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every week and many a times respondent has informed the petitioner about the
health condition of his father, but the petitioner never acted positively or spoke
to the respondent in a sympathetic way and on the other hand made false
allegations against the respondent and his family members and forced them to
come to Vizianagaram all the way to attend Police station and Courts with cruel
intention filed false criminal cases against the respondent and his family.
12.This respondent submits that the petitioner has filed false cases against the
respondent and his family members along with DVC and fled to Canada for
past 3 years and since then managed to conceal the contact details of petitioner
and her whereabouts to the respondent. Respondent have tried many ways to
contact the petitioner thereafter but the mobile no, WhatsApp etc have been
changed and was a hard nut to crack for the respondent to contact the petitioner.
Respondent and his parents have made many attempts to contact the petitioner
and her parents to request her to join the conjugal society but all the attempts by
the respondent turned to be futile.
13.This respondent submits that the petitioner father, Retired Assistant
Commandant, APSP 5th Battalion, Vizianagaram used to pose himself as DSP
Vizianagaram (Law & order) and used to threaten each and every person who is
sent for mediation and conciliation for reunion by the respondent. The
petitioner's father, who holds a position of authority, allegedly used his
influence to intimidate mediators and threatened legal action against anyone
attempting to facilitate reconciliation. Despite the respondent's willingness to
reconcile and rebuild the marital relationship, the petitioner's parents have
continuously obstructed any efforts for reunion. Respondent further submits
that though petitioner is willing to lead a happy martial life with respondent, the
parents of the petitioner had never allowed her to lead a happy life with
respondent.
14.The respondent submits that the allegations leveled by the petitioner are
baseless, fabricated, and only intended to harm the respondent's reputation and
dignity. The respondent further submits that if the petitioner returns to the
matrimonial home the respondent is ready to accept her, the respondent is more
than willing to reconcile and lead a happy and harmonious married life with her.
The respondent firmly believes in the sanctity of marriage and is committed to
resolving the issues amicably. If the petitioner is willing to resolve these matters
with sincerity and return to the conjugal society, the respondent is ready to work
towards a peaceful and successful marital relationship. The Petitioner with a
malafide intention and to degrade the dignity, integrity and reputation of the
respondent approached this Honourable court with unclean hands by
suppressing the true facts.
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15.This respondent submits that the respondent was not at fault and he is not
responsible for leaving the petitioner from the society of this respondent and as
such the respondent is not willing to give divorce to give to the petitioner.
16. This respondent submits that there are no grounds to grant divorce to the
petitioner by dissolving the marriage happened between him and the petitioner
as the grounds alleged in the petition are not correct and true.
17.This respondent submits that this Petition filed by the Petitioner for Dissolution
of marriage between the petitioner and the respondent with all false allegations
is not maintainable under the law
18.Hence this respondent prays the Honourable Court may be pleased to dismiss
the Petition with costs and render justice.

ADVOCATE FOR THE RESPONDENT RESPONDENT

VERIFICATION

The facts stated above are true and correct to the best of my knowledge,
belief and information and I understood the same and signed/put my thumb
impression on this 18th day of June of 2025 at Vizianagaram.

RESPONDENT
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IN THE HONOURABLE COURT OF THE PRINCIPAL DISTRICT

DOP NO : 17/2024
Between:
Eda Agnes Priyanka ….Petitioner
And
Eda Sreenivas Kumar …Respondent

MEMO FILED BY ON BEHALF OF THE PETITIONER

It is to submitted that the Honourable court order pay costs of Rs.50 /-

Therefore, prays the Honourable court may be pleased to kindly be

Hence, this memo.

ADVOCATE FOR THE PETITIONER