1. IN THE COURT OF THE HONOURABLE SENIOR CIVIL JUDGE
AT:: SANGAREDDY
I.A.No. OF 2023.
In
HMOP.No. OF 2023.
Between:
V. Ravi Kumar
… Petitioner
A N D
V. Vanitha and another
…Respondents
A F F I D A V I T
I, Sri V. Ravi Kumar S/o Late V. Veeresham Aged about 31 years, Occ:
Pvt Driver R/O H.NO.5-1-32/7/4/A, Sainagar Colony, Sangareddy Town
and Mandal and Dist. do hereby solemnly affirm and state on oath as
follows.
That I that petitioner and the deponents herein, and Petitioner in the
main petition, hence well acquainted with the facts of this case. I signed in
swearing this affidavit. That I crave the indulgence of this Hon’ble Court to
read the averments of the plaint as a part and parcel of this affidavit.
1. I have file the present petition against respondent for decree of divorce
dissolving the marriage dt: 25-11-2007 between me and respondent
No.1.
2. I further submitted that the respondent No.1 and me was legally
wedded couple in the year 2007 and we were blessed with two
children on 2010.
3. That on 25-03-2016, myself along with respondent No.1 and children
along with my mother were going in my car to attend the marriage of
our relative. On the way, I took the memory card of respondent No.1
2. with an intention to hear the songs. To my utter surprise, I found the
telephonic conversations between respondent No.1 and another
person (who later turned out to be respondent No.2). The
conversations were vulgar and obscene. I was shocked and questioned
the respondent No.1 about the person with whom she was conversing.
She revealed about the identity of respondent No.2 who is a MRF
employee with whom she got acquainted and maintaining illegal
intimacy. I called the parents of the respondent No.1 and informed
them about the same and sent her to her parents' house. The
conversations dating prior to 25-03-2016 clearly reveal the illicit S.L
relationship between respondents. Further the respondents indulged
in sexual Confirmed Specifically intercourse several times and the
same was revealed through their calls recorded on the cell phone of
respondent No.1 The dangerous attitude of the respondent No.1 in
respect of the family is not conducive for me or to my two children to
live with respondent No.1. The criminal nature of respondent No.I
having illicit relationship with respondent No.2 was detecting their
relationship was revealed through their conversations.
4. The respondent went to the extent of committing the act in the
presence of minor daughter. The respondent No.1 had been leading an
adulterous life and the same was detected through telephonic
conversations between the respondents. by knowing the said fact I
was suffered mentally and physically and also my children suffered a
lot.
5. I have filed the telephonic conversation between respondent No.1 and
respondent No.2 in an Audio CD along with its transcript along with
65-B Certificate as the part of evidence to prove the adultery between
respondent No.1 and 2 and the said CD along with its transcript along
with 65-B Certificate was marked as Ex A5.
6. The conversations clearly reveal respondent No. 1's feelings about the
presence of my mother in the house as a hindrance to her activities.
She even went to the extent of planning to elope with respondent No.2
taking second daughter with her. The calls recorded in between the
respondents clearly establish the illicit relationship between them. The
conversations between the respondents recorded on the cell phone of
respondent No. 1 through auto call is transcript in CD and the same
is filed and admissible U/Sec.65-B of Evidence Act which was marked
as Ex A5.
7. That the respondent No.1 in her cross examination clearly admitted
that she as no objection to sent the recordings to expert opinion and
also with her sample voice.
3. 8. That the deponent further submits that the petitioner has only the
said piece of evidence to prove i.e., Ex.A5/telephonic conversations to
prove the illicit relationship between respondent No.1 and 2 and also
to prove the adultery between respondent No.1 and 2.
9. That the Hon’ble Court my direct the respondent No.1 to given sample
voice at TS Forensic Science Laboratories, Niloufer Hospital Rd, Red
Hills, Redhills, Hyderabad, Telangana 500004 and also sent Ex.A7
i.e., CD with transcripts for expert opinion. The petitioner will bare all
the expenses for respondent No.1 to give her sample voice at TS
Forensic Science Laboratories, Hyderabad.
Therefore it is prayed that this Hon’ble Court may be pleased to the
respondent No.1 to given sample voice at TS Forensic Science Laboratories,
Niloufer Hospital Rd, Red Hills, Redhills, Hyderabad, Telangana 500004 and
also sent Ex.A7 i.e., CD with transcripts for expert opinion in the interest of
justice and equity.
Place :
Date : D E P O N E N T.
Sworn and signed before me on this the day of
A D V O C A T E.
4. IN THE COURT OF THE HONOURABLE SENIOR CIVIL JUDGE
AT:: SANGAREDDY
I.A.No. OF 2023.
In
HMOP.No. OF 2023.
Between:
V. Ravi Kumar S/o. Late V. Veeresham, age 31 years, Occ: Pvt. Driver,
R/o. H.No.5-1-32/7/4/A, Sainagar Colony, Sangareddy (Town and
District)
...Petitioner/ Petitioner
AND
1. Smt. Vanitha W/o. V. Ravi Kumar, D/o. P. Sangameshwar, age 25
years, R/o. Pedda Chelmeda Village, Munipally Mandal, Sangareddy
District.
2. Nidimanur GopalNaidu Purnachandran S/o. Gopal, aged about 29
years, Occ: MRF Worker, ID No. 612094, R/o. H.No.5-1-80/6, Sanjeeva
Nagar, Sangareddy, Office Company, Sadasivpet. address MRF
...Respondents/ Respondents
PETITION FILED U/SEC 45-A OF INDIAN EVIDENCE ACT
For the reasons mentioned in the accompanying affidavit the petitioner
prays that this Hon’ble Court may be pleased to to the respondent No.1 to
given sample voice at TS Forensic Science Laboratories, Niloufer Hospital Rd,
Red Hills, Redhills, Hyderabad, Telangana 500004 and also sent Ex.A7 i.e.,
CD with transcripts for expert opinion in the interest of justice and equity.
Place :
Date . COUNSEL FOR PETITIONER.
5. IN THE COURT OF THE HON’BLE
SENIOR CIVIL JUDGE :: AT
SANGAREDDY.
I.A.No. OF 2023.
In
HMOP.No. OF 2023.
Between:
V.Ravi Kumar
… Petitioner
A N D
Smt Vanitha and anothers
…Respondents/Defendants.
PETITION FILED UNDER/SEC 45 OF
INDAIN EVIDENCE ACT
Filed on : - -2023.
Filed by : Counsel for Petitioner.
Address for service:
M/s.B.Bhoopal Reddy
Advocates,Sangareddy
