This document is a petition filed in the Honorable Additional Family Court at Visakhapatnam by Dharsipudi Kameswari Manasa against her husband Dharsipudi Sudeer Kumar seeking a divorce on the grounds of cruelty and misrepresentation. The petitioner alleges that the respondent and his family misrepresented his employment status and income prior to the marriage. Despite receiving large dowry payments, the respondent and his family continued to harass and demand additional dowry from the petitioner. The petitioner further alleges that the respondent confined and threatened to kill her when she refused to pay more dowry. She escaped and filed a police complaint. The petitioner is now seeking a decree of divorce from the court.

1. IN THE COURT OF THE HONORABLE ADDITIONAL FAMILY COURT AT
VISAKHAPATNAM
/2016
BETWEEN:
DharsipudiKameswariManasa,
……….Petitioner
AND:
DharsipudiSudeer Kumar,
……. Respondent
PETITION Filed Under section 13 (1) (1a) (1b)OF FAMILY COURTS ACT
I. The petitioner is:-
Dharsipudi Kameswari Manasa, D/o, Venkata Ramakrishna, W/o D.Sudeer
Kumar, aged 29 years, House wife, Vijayaratna Towers, Flat No. 503, Doctors
Colony, Pedawaltair, Visakhapatnam
The Addresses of the petitioner is the purpose of the notices, by the Court
is stated above and care of her Advocates Sri P V S N Gupta, Smt.P.Lakshmi Gupta,
D.No.29-8-9A, F-6 & 7, Sai Manasa Apts., Lalita Colony, Dabagardens,
Visakhapatnam – 530 020.
II. The Respondent is :-
DharsipudiSudeer Kumar, S/o D. Ramakrishna, aged 32 years, Employee,
Vijayaratna Towers, FlatNo. 503, Doctors Colony, Pedawaltair, Visakhapatnam.
The address of the respondent is for the purpose of notices or summons,
etc, by the Court is as stated above.
III. Brief Facts of the Case:
1. The petitioner is the legally wedded wife of the respondent and the
marriage was performed at her parents’ house at Anakapalle by spending
huge amounts towards marriageexpenses.
2. The petitioner submits that the respondent parents, have impressed her
parents by saying that their son is software engineer working in a Multi
National Company drawing a salary of Rs.5,00,000/- per month and as such
the dowry shall be in communicate with his official position as a software
engineer.

2. 3. The respondent: parents have also her parents saying they have two
houses at Visakhapatnam and pleading to constant a house at Bangalore.
On believing their words, petitioner parents have presented the following
articles together with cash.
i. Dowry 30 lakhs gold (9 lakh worth)
ii. 21/2 Silver articles (1 lakh)
iii. 2 lakh to Sister & Mother-in-law
iv. I lakh FD in Manasa
v. 2 lakh saresaman
4. The petitioner submits that the marriage was consummated and she joined
the respondent along with his parents at Visakhapatnam and spent for
some time happily but she noticed the behavior of the respondent in not
attending to his normal duties and he used to spend time at house &
outside only and on suspicion, she has questioned the attitude of the
respondent and as such he suddenly rebuked her and warned her not to
question him and she has no business to question his behavior and he is at
liberty to behavior in his own way and when the petitioner has informed
the same to her in-laws, they supported their son only and this issue has
become serious fromtime to time.
5. It is submitted that the petitioner who belongs to an orthodox family
consoled herself with a hope of finding a change in the attitude of the
respondent it is submitted that while the petitioner was at marital home,
the respondent had made a demand to his laws to the petitioner to arrange
for a sum of Rs.1,00,000/- and the glad that he has secured an job at
foreign but an enquiry made by the parents of the petitioner it was
released that the acts & deeds are from petitioner really and that he was
recommended fromserious even before marriage with the petitioner.
6. It is submitted that the respondent used to behave strangely and he joined
hands with his parents on and confined her in a room and bet
her with a threat to kill her, if she does not arrange Rs.10,00,000/- towards
additional dowry and out of fear she escaped from the hands of the
respondent and his parents and made a phone call to her parents and in
turn they have parents take, the petitioner to their house and she
remained at the parents house at Anakapalli and lodged a police complaint
against the respondent and his parents and while the case in pending the
respondent used to send messages through mobile by scolding her and
using unparliamentary words which cannot be repeated as they are insult
to aggressive and after the saving of the messages recorded and a case
also is filed to the cyber cell and the sameis pending.
7. The summary of the messages are nothing but unparliamentary,
abusive, leading to characters messages sent assassination and suspicion of
the fidelity of the petitioner.
8. The messages are recorded and the copy of the messages are herewith
enclosed which may be read as part of this petitioner.

3. 9. It is submitted that respondent harassed the petitioner by adopting,
deceitful practice and by mis - representing the status as software engineer
drawing a salary of Rs.5,00,000/- per month at the time of her marriage
and she was also subjected to legal cruelty for the sake of money and as
such the case on filed for the grant of divorce by dissolving the marriage
that such place on 12-08-2014 at Rao Gopal Kalyan Mandapam at
Anakapalli on the grounds of legal cruelty and mis-representation of the
respondents status as a Software Engineer in Multi National Company
drawing a salary of Rs.5,00,000/- per month.
Hence the petition.
Cause of action for the petition arose on when the respondent
married the petitioner according to the Hindu religious, caste and custom
where from 12-08-2014, the respondent and the petitioner separated from
the matrimonial obligation which shows permanently repatriated
matrimonial obligation As such, they said respondent is guilty of desertion
for more than two years and also guilty of cruelty where the said petitioner
and respondent got married and the petitioner is now residing all within
this jurisdiction of this honourable courtat Visakhapatnam.
No similar petition was filed either before the honourable court or
any other court. This petition is not presented in collusion with the
respondent.
This being the petition filed under Section 13 (1) (a) (1a) (1b) of
Hindu Marriage Act, 1956 a fixed court fee of Rs. is paid under
section article of A.P.C.F & S.V.Act.
PRAYER
The petitioner therefore prays that this honourable court may be
please to pass an order and decree that:
(a) To pass a decree and orders of divorce by dissolving the marriage
date 02-02-2012 between the petitioner and respondentand
(b)for the costs of this petition and
(c) To pass such directions and relief as the honourable court deem
fir under the circumstanceof the case.
PETITIONER

4. Verification:
I, Smt Darshipudi Kameswari Manasa, W/o Darshipudi Sudeer Kumar,
Hindu aged 29 years, House wife, Vijayaratna Towers, Flat No. 503, Doctors
Colony, Pedawaltair, Visakhapatnam do hereby declare that the facts
stated in the petition are true and correct to the best of my knowledge,
information and belief, Hence, verified on this day of 2016 at
Visakhapatnam
LISTOF DOCUMENTS
S.No. Date Description of the Documents Remarks
1 12-08-2014 F.I.R Xerox Copy
2 24-03-2015 Letter of DIG of Police Xerox Copy
3 29-10-2010 Charge sheet Xerox Copy
4 03-09-2012 Out-Patient Ticket Xerox Copy
Visakhapatnam
Date: Advocate for the petitioner

5. IN THE HONOURABLE COURT OF VADDL DISTRICT CUM FAMILY
JUDGE AT VISAKHAPATNAM
I.A.NO: /2015
IN
O.P.NO: /2015
BETWEEN:
DharsipudiKameswariManasa,
D/o Venkata Ramakrishna,
Aged 29 years, Housewife,
Vijayaratna Towers,
Flat No. 503, Doctors Colony,
Pedawaltair, Visakhapatnam
……….Petitioner
AND:
DharsipudiSudeer Kumar,
S/o D Ramakrishna,
Aged 32 years, Employee,
Vijayaratna Towers,
Flat No. 503, Doctors Colony,
Pedawaltair, Visakhapatnam
……. Respondent
PETITION FILED UNDER SECTION 13 OF FAMILY COURT ACT
For the reasons stated in the accompanying Affidavit the Petitioner
prays the Honourable Court may be pleased to permit them to be represented
by Advocates P. Lakshmi Gupta and PVSN Gupta in the interests of Justice
Visakhapatnam
Date: Advocate for Petitioner

6. IN THE HONOURABLE COURT OF VADDL DISTRICT CUM FAMILY
JUDGE AT VISAKHAPATNAM
I.A.NO: /2015
IN
O.P.NO: /2015
BETWEEN:
DharsipudiKameswariManasa,
D/o Venkata Ramakrishna,
Aged 29 years, House wife,
Vijayaratna Towers,
Flat No. 503, Doctors Colony,
Pedawaltair, Visakhapatnam
……….Petitioner
AND:
DharsipudiSudeer Kumar,
S/o D Ramakrishna,
Aged 32 years, Employee,
Vijayaratna Towers,
Flat No. 503, Doctors Colony,
Pedawaltair, Visakhapatnam
……. Respondent
AFFIDAVIT FILED UNDER ORDER XIX RULE (1) OF C.P.C.
I, Smt. Dharsipudi Kameswari Manasa, D/o, Venkata Ramakrishna, W/o
D.Sudeer Kumar, aged 29 years, House wife, Vijayaratna Towers, Flat No. 503,
Doctors Colony, Pedawaltair, Visakhapatnam
1. I submit that the petitioner is the legally wedded wife of the respondent
and the marriage was performed at her parents’ house at Anakapalle by
spending huge amounts towards marriageexpenses.
2. I submit that the petitioner submits that the respondent parents, have
impressed her parents by saying that their son is software engineer
working in a Multi National Company drawing a salary of Rs.5,00,000/-
per month and as such the dowry shall be in communicate with his
official position as a softwareengineer.
3. I submit that the respondent: parents have also her parents saying they
have two houses at Visakhapatnam and pleading to constant a house at
Bangalore. On believing their words, petitioner parents have presented
the following articles together with cash.
i. Dowry 30 lakhs gold (9 lakh worth)
ii. 21/2 Silver articles (1 lakh)

7. iii. 2 lakh to Sister & Mother-in-law
iv. I lakh FD in Manasa
v. 2 lakh saresaman
4. I submit that the petitioner submits that the marriage was
consummated and she joined the respondent along with his parents at
Visakhapatnam and spent for some time happily but she noticed the
behavior of the respondent in not attending to his normal duties and he
used to spend time at house & outside only and on suspicion, she has
questioned the attitude of the respondent and as such he suddenly
rebuked her and warned her not to question him and she has no
business to question his behavior and he is at liberty to behavior in his
own way and when the petitioner has informed the same to her in-laws,
they supported their son only and this issue has become serious from
time to time.
5. It is submitted that the petitioner who belongs to an orthodox family
consoled herself with a hope of finding a change in the attitude of the
respondent it is submitted that while the petitioner was at marital
home, the respondent had made a demand to his laws to the petitioner
to arrange for a sum of Rs.1,00,000/- and the glad that he has secured
an job at foreign but an enquiry made by the parents of the petitioner it
was released that the acts & deeds are from petitioner really and that
he was recommended from serious even before marriage with the
petitioner.
6. It is submitted that the respondent used to behave strangely and he
joined hands with his parents on and confined her in a
room and bet her with a threat to kill her, if she does not arrange
Rs.10,00,000/- towards additional dowry and out of fear she escaped
from the hands of the respondent and his parents and made a phone
call to her parents and in turn they have parents take, the petitioner to
their house and she remained at the parents house at Anakapalli and
lodged a police complaint against the respondent and his parents and
while the case in pending the respondent used to send messages
through mobile by scolding her and using unparliamentary words which
cannot be repeated as they are insult to aggressive and after the saving
of the messages recorded and a case also is filed to the cyber cell and
the sameis pending.
7. The summary of the messages are nothing but unparliamentary,
abusive, leading to characters messages sent assassination and suspicion
of the fidelity of the petitioner.
8. The messages are recorded and the copy of the messages are herewith
enclosed which may be read as part of this petitioner.
9. It is submitted that respondent harassed the petitioner by adopting,
deceitful practice and by mis - representing the status as software
engineer drawing a salary of Rs.5,00,000/- per month at the time of her

8. marriage and she was also subjected to legal cruelty for the sake of
money and as such the case on filed for the grant of divorce by
dissolving the marriage that such place on 12-08-2014 at Rao Gopal
Kalyan Mandapam at Anakapalli on the grounds of legal cruelty and mis-
representation of the respondents status as a Software Engineer in
Multi National Company drawing a salary of Rs.5,00,000/- per month.
10.I therefore pray that it is highly necessary in the interests of justice and
equity that the honourable court may be pleased to consider my
affidavit as evidence to pass the decree as prayed for as otherwise I will
suffer hugeloass and injury.
Deponent
Solemnly affirm and signed before me on this day of 2016 at
Visakhapatnam.
Advocate