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Petitioner : Chinchu
Vs.
Respondent : Siju
AFFIDAVIT
8. While so, I became pregnant. Even during the said period, the
respondent and his mother tortured me, both physically as well
as emotionally, resulting in severe health hazards and
emotional trauma to me. They have refused to provide proper
care and medication to me on the ground of deficiency of
dowry. Having realized my pathetic condition and miserable
situation, my brother entrusted Rs. 50,000/- with the
respondent and his parents in September 2010, hoping against
hope, that at least then I would have a happy and peaceful
marital life, but in vain.
12. The respondent and his parents have done everything possible
to make my life painful, miserable and hellish at my
matrimonial home. I suffered all the cruelties and harassments
meted out by the respondent and his parents, hoping that the
respondent would change and I would have a happy and
peaceful marital life. The cruelties and harassments increased
day by day.
18. The 28th day ceremony of the child is not conducted so far due
to the non co-operation on the part of the respondent and his
family members. Even though a conciliation talk was held at
the residence of the sister of my mother at the initiative of my
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19. The cohabitation was brought to an end due to the acts and
deeds of the respondent and his mother. The sincere and
earnest efforts made by me and my family members for a
peaceful and harmonious family life were failed due to the
adamant, uncooperative, indifferent and hostile attitude of the
respondent. The respondent and his family members treated
me as a cash point and unpaid servant.
All the facts stated above are true and correct to the best of my
knowledge, information and belief.
Deponent : Chinchu
PETITIONER/PETITIONER
Vs.
RESPONDENT/RESPONDENT
Petitioner : Chinchu
Pres
ented On : 17.12.2010
Petitioner/Petitioner
Chinchu
Vs.
Respondent/Respondent
9
Siju
INJUNCTION PETITION
Petitioner: Chinchu
PETITIONER
Vs.
RESPONDENT
7. While so, the petitioner became pregnant. Even during the said
period, the respondent and his mother tortured the petitioner,
both physically as well as emotionally, resulting in severe health
hazards and emotional trauma to the petitioner. They have
refused to provide proper care and medication to the petitioner on
the ground of deficiency of dowry. Having realized the pathetic
condition and miserable situation of the petitioner, her brother
entrusted Rs. 50,000/- with the respondent and his parents in
September 2010, hoping against hope, that atleast then the
petitioner would have a happy and peaceful marital life, but in
vain.
than the petitioner and that even now the respondent could get
better proposals than her etc.
10. The respondent’s parents added fuel to the fire by supporting and
even prompting him to shout at and maltreat the petitioner with
the ulterior motive of harassing the petitioner. The parents of the
respondent unnecessarily interfered in each and every personal
and private matter of the spouses and deliberately created rifts
and misunderstandings between them so as to achieve their
sinister goal of separating the petitioner and the respondent.
11. The respondent and his parents have done everything possible to
make the life of the petitioner painful, miserable and hellish at her
matrimonial home. The petitioner has suffered all the cruelties
and harassments meted out by the respondent and his parents,
hoping that the respondent would change and she would have a
happy and peaceful marital life. The cruelties and harassments
increased day by day.
12. The daily domestic life of the petitioner became a constant source
of stress, strain, tension, anguish and anxiety on account of the
acts and deeds of the respondent and his family members. The
respondent has always taunted the petitioner stating that she is
not a person either worth or fit to be his wife. The respondent has
ridiculed the petitioner stating that she is incompetent to be his
wife causing severe dejection and pain to the petitioner.
13. The respondent and his mother always wanted to dominate and
command the petitioner and kept on nagging and harassing the
petitioner on myriad ways. The respondent has expected the
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petitioner to bow down to his whims and fancies and to obey his
commands and perversions without any objection. The
respondent and his people are spreading scandalous remarks
against the petitioner and her family members with an intention
to harass, defame and humiliate them in public.
14. The respondent and his parents have continued to abuse, accuse,
harass, illtreat, taunt, ridicule and humiliate the petitioner with
the ulterior motive of getting more dowry from the family of the
petitioner. Having realized that they cannot get anymore amount
or gold from the petitioner by any means, after having forcefully
taken her last remaining, one pair ear rings, in July 2010, at a
time when the petitioner was seven months pregnant, the
respondent has abandoned the petitioner at her house.
Thereafter, the respondent and his family members have not even
enquired about the petitioner.
16. The respondent filed false and frivolous police complaints against
the petitioner and her mother with an intention to further harass
the petitioner and the child. The S.I. of Police, Aluva has
summoned the parties, and after having convinced the innocence
of the petitioner, directed the respondent and his family members
to behave properly towards the petitioner and her family
members, and further directed the respondent and his parents to
hand over her gold ornaments and belongings to the petitioner
forthwith.
17. The 28th day ceremony of the child is not conducted so far due to
the non co-operation on the part of the respondent and his family
members. Even though a conciliation talk was held at the
14
18. The cohabitation was brought to an end due to the acts and deeds
of the respondent and his mother. The sincere and earnest
efforts made by the petitioner and her family members for a
peaceful and harmonious family life were failed due to the
adamant, uncooperative, indifferent and hostile attitude of the
respondent. The respondent and his family members treated the
petitioner as a cash point and unpaid servant.
21. The petitioner has a reasonable apprehension in her mind that the
continuation of marital relationship would be injurious, harmful
and dangerous to her and the child. The aforesaid conduct and
behaviour has adversely affected the health of the petitioner. The
respondent had made several times clear that he is not interested
to continue with the marital relationship with the petitioner and
sought for legal termination of marriage. The petitioner has
decided to end her matrimonial life with the respondent. It will be
physically and mentally impossible for her to live along with the
respondent any more. The agony and misery she was undergoing
were untold.
Hence it is most humbly prayed that this Hon’ble Court may be pleaded
to:
(B) Pass a judgment and decree directing the respondent to pay Rs.
10,00,000/- (Rupees Ten Lakhs only) to the petitioner as permanent
alimony.
(C) Allow the petitioner to recover her entire cost from the respondent
and
(D) Pass such other reliefs, as this Hon’ble Court may deem fit and
necessary to meet the ends of justice.
Petitioner: Chinchu
VERIFICATION
Petitioner: Chinchu
17
Presented On : 7.12.2010
O.P.No. /2010
Petitioner
Chinchu
Vs.
Respondent
Siju
Petitioner : Chinchu
Form No.1
(See Rule.5)
Take further notice that if you fail to file your appearance in person or
vakalathnma as directed above, or if you fail to appear before the judge on
the day before mentioned the petition may be ordered to be set do on Board
on the same day or any subsequent day as ‘undefended’ and you will be liable
to have a decree or order passed against you.
Witness………………………………………………………………………………….Principal
Judge at…………………………………………………………………………………………aforesaid,
this……………………….day of ………………………………………….2010
Seal
Petitioner :
Chinchu, aged 20 years, D/o. late Mohanan, Mohana Vilasam, Keezhmadu,
Erumathala P.O., Aluva Taluk, Ernakulam District,Pin-683 112
Presented On : 7.12.2010
Petitioner
Chinchu
Vs..
Respondent
Siju
Petitioner : Chinchu
O.P.No. of 2010
Petitioner Chinchu
Vs..
Respondent Siju
PROCESS MEMO
herewith the process court fee for Rs.12.50, Courier Cover notice form
Petitioner : Chinchu
21
Presented On : 7.12.2010
O.P.No. /2010
Petitioner
Chinchu
Vs.
Respondent
Siju
PROCESS MEMO
22
Petitioner : Chinchu
Petitioner : Chinchu
Vs.
Respondent : Siju
AFFIDAVIT
All the facts stated above are true and correct to the best of my
knowledge, information and belief.
Deponent : Chinchu
PETITIONER
Vs.
RESPONDENT
Petitioner : Chinchu
24
Presented On : 20.9.2010
Petitioner/Petitioner
Chinchu
Vs.
Respondent/Respondent
Siju
Petitioner: Chinchu
Petitioner : Chinchu
Vs.
Respondent : Siju
AFFIDAVIT
All the facts stated above are true and correct to the best of my
knowledge, information and belief.
Deponent : Chinchu
PETITIONER
Vs.
RESPONDENT
Petitioner : Chinchu
27
Presented On : 20.9.2010
Petitioner/Petitioner
Chinchu
Vs.
Respondent/Respondent
Siju
Petitioner: Chinchu
Presented On : 22.10.2010
Petitioner
Chinchu
Vs.
Respondent
Siju
PROOF OF DELIVERY
29
Ganesh G. Pillai
Counsel for the Petitioner
VAKALATH
BEFORE THE HON'BLE FAMILY COURT, ERNAKULAM
O.P.No. of 2010
Advocate
Accepted
Advocate
Aravindam Edakattuparambil,
Pootholi Lane,
Kombara Junction,
Kochi-18.
Presented on : .8.2010.
BEFORE THE
HON'BLE FAMILY
COURT, ERNAKULAM
O.P.No. of 2010
Petition : Jyothi
Maya D Almeida
Respondent : Antony
Ginu
___________
GANESH.G.PILLAI
LEKHA GANESH
Advocates
31