IN THE COURT OF THE HON’BLE SENIOR CIVIL JUDGE

AT GODAVARIKHANI
H.M.O.P.No.48of 2024
Between:
YANAMULA @ SANTHAKARI SWAPNA, W/o Sunil, Aged 35 years,
Occu: House Maker R/o H.No. 21-6-120/9, Pragathinagar, FCI road,
Fertilizer City, Ramagundam Mandal of Peddapalli District.
...Petitioner
AND
YANAMULA SUNIL S/o Suresh, Aged 33 years, Occu: Private Employee
In Hetro Company R/o: H.No. 1-2-39/1, Ganjipet, Gadwal,
Gadwal (Rural), Mahabub Nagar District.
...Respondent

COUNTER PETITION FILED BY THE RESPONDENT

May it please your Honour,

The above named Respondent begs to submit as follows:
I, YANAMULA SUNIL S/o Suresh, Aged 33 years, Occu: Private Employee in
Hetro Company, (Presently working in Dr. Reddy’s Labs), R/o: H.No. 1-2-39/1,
Ganjipet, Gadwal, Gadwal (Rural), Mahabub Nagar District, and do hereby
solemnly affirm and sincerely state on oath as follows:

Brief facts of the case are as follows:

It is submitted that the Petitioner and the Respondent got married on May27, 2017
at Pragathinagar, Godavarikhani as per Hindu rites and customs.
Conti...Page 2
 2
Admittedly, the marriage was a love marriage.

It is submitted that the Petitioner and the Respondent are classmates while
pursuing B. Pharmacy in the year 2009 to up to completion of their M. Pharmacy
in the year 2014. After getting married they lived in a rented house for more than
two years. The mentality and behaviour of the Respondent are well known to the
house owners. Moreover,

It is submitted that the the Respondent worked as a Research Associate-I and Jr.
Officer in AR &D department in the Analytical Research and Development in
Hetero Labs Limited, Hyderabad for the period 04.01.2016 to 29.07.2019; he
worked as a Research Associate –II in Jodas Expolm Pvt. Limited, Hyderabad for
the period 01.11.2021 to 31.10.2022; and worked with Dr Reddy’s Labs,
Hyderabad. All are medical oriented organisations which required periodical
medical examinations to the all employees. During his tenure no any adverse
remarks held with regard to consumption of alcoholics. (Copies of office orders are
filed as material papers).
It is submitted that the household articles are purchased by the Respondent through
Reliance Retail Limited (Copy of bill is filed as material paper).

It is submitted that the Respondent deposing that the Petitioner alleged a false
statement in the petition as if the Respondent used to consume alcohol in daily, had
illegal contact with another lady, came to the house in the late nights and started
harassing the petitioner physically and mentally to bring additional dowry of Rs. 2,
00,000/- , used to suspect the chastity of the petitioner, used to abused and beat her
indiscriminately in the night by coming home consuming liquor. However, the
Petitioner has neither complaint to the police station concerned nor has taken any
steps to send legal notice for dissolution of marriage under Section 13 (10 (i-a) of
The Hindu Marriage act, 1955.
Conti...Page 3
3
It is submitted that the above petition was filed with an oblique motive and by way
of vengeance towards Respondent. The allegations in the petition are too vague
and general in nature. There are no specific allegations/incidents levelled against
the Respondent as stated by the Petitioner at the Paras 2 to 6 of the petition.

It is submitted that the Respondent went to his in-laws house and called his wife
home, however, she refused to join him. The Respondent regularly and
periodically contacted the Petitioner and urged her to come back as the Respondent
is always ready and willing to join and live with his wife. Again in later date he
asked her to come back, but the same proved futile.

It is submitted that the Respondent all along has tried to live with the Petitioner,
however, the Petitioner refused to accept him. The Respondent is ready and willing
to live with the Petitioner.

In the light of the facts stated and for the reasons afore mentioned, it is prayed that
the Hon’ble Court may be pleased to dismiss the petition as devoid of merits and
be pleased not to pass a decree of divorce for dissolution of marriage in between
the Petitioner and the Respondent, solemnized on 27.05.2017 and pass such other
relief or reliefs for the Respondent is otherwise entitled in the circumstances of the
case.

Counter petition facts are as follows:

1. I am the Respondent herein in the above H.M.O.P.No.48of 2024 and as
such, I am well acquainted with the facts of the case.

2. It is most respectfully submit that the facts stated and averments made in the
petition are not all true and correct. Such of facts stated and averments made

Conti...Page 4

4
 in the petition which are not hereby specifically admitted to be true shall be
deemed to have been denied and the Petitioner is put to strict proof of the
same.

3. It is most respectfully submit that the Petitioner and the Respondent are
Hindus by religion and they both are governed by “Mitakshara School of
Law”.

4. It is most respectfully submitted that it is true that the Petitioner is the

legally wedded wife of the Respondent and our marriage was solemnized on
27.05.2017 as per caste and customs prevailed in our community at
Pragathinagar, Godavarikhani. It is most respectfully submit that the
Petitioner and Respondents are the classmates while pursuing B. Pharmacy
in the year 2009 to up to completion of their M. Pharmacy in the year 2014.
The Petitioner and Respondents are majors while studying in college, and
fell in love with each other. After consulting both of our either sides parents
and their acceptance our love marriage was performed in the presence of
both of our parents, caste elders and relatives. After getting married, we lead
happy marital life for a period of about two years and fully enjoyed conjugal
rights continued and uninterruptedly right from our marriage solemnized.

5. It is most respectfully submit that it is not true as alleged by the Petitioner at

Para 2 of the petition that at the time of marriage, the parents of the
petitioner gave an amount of Rs. 5, 00,000/- net cash, 10 Thulas of gold and
house hold articles worth of Rs. 2, 00,000/- to the respondent. After
marriage, the petitioner joined the society of the respondent and lead happy
married life for a period of one month and the respondent used to consume
alcohol in daily and had illegal contact with another lady and came to house
in the late nights and stated harassing the petitioner physically and mentally
to bring additional dowry of Rs. 2,00,000/-. The Petitioner is put to strict
proof of the same.
Conti...Page 5

5
6. It is most respectfully submit that we got love married by the acceptance and
in the presence of our both side parents, caste elders and relatives. As such
no question of rising of demanding additional dowry.

7. It is most respectfully submit that it is not true as alleged by the Petitioner at

Para 3 of the petition that the Respondent used to suspect the chastity of the
Petitioner whenever she had on occasion to speak to any relative and with
the suspension in mind the Respondent used to abuse and beat her
indiscriminately in the night by coming home consuming liquor. The
Petitioner is put to strict proof of the same.

It is most respectfully submit that I worked with Hetero Labs Limited,

Hyderabad as Junior Officer and Research Associate-I from 04.01.2016 to
29.07.2019. As per my relieving cum service certificate of the Company my
character and conduct was satisfactory. Now, I am working at Dr. Reddy’s
Labs, Hyderabad as Analytical Scientist. Both are medical based Companies
which maintain regular periodical medical checkups to each and every
employee. As such no question of consuming alcohol in daily as stated by
the Petitioner. (Copy of the service certificate by the Hetero is filing as
material paper).

8. It is most respectfully submit that it is not true as alleged by the Petitioner at

Para 4 of the petition that the Petitioner being new has dragged her life
without revealing facts of the Respondent by honouring the family prestige
and image in the society, further by observing that she will be deprived and
defamed before her family members, relatives, society as they were having a
lot of expectations. All the dreams and expectations of the Petitioner went in
vain, her future is ruined forever, bared all the harassment physically,
mentally even though the Respondent made her blue and black most of the
occasions, under the guise of demand of additional dowry by remaindering
her. The Petitioner is put to strict proof of the same.
Conti...Page 6

6
9. It is most respectfully submit that it is not true as alleged by the Petitioner at
Para 5 of the petition that all the colourful dreams of the Petitioner were
ruined, her future was in darkened, was been leading life in depression, only
to save guard herself suffering from guilty feeling, with a fond hope that the
Respondent and his mother will change their attitude again the Respondent
and his mother harassed the Petitioner. Finally, the Petitioner informed the
harassment meted out by the Respondent and his mother towards her to the
parents of the Petitioner upon which, the parents of the Petitioner called the
Respondent to talk with him but he did not come. Finally, in the month of
December 2021the Respondent and his mother abused me in most filthy
language and beat him with hands and demanding the Petitioner to bring
additional dowry and necked out the petitioner from their house by taking all
the gold ornaments of the Petitioner and further stated that they will allow
the Petitioner if she bring the additional dowry. Having no other alternative,
the Petitioner has been residing at her parents’ house. Even though the
Petitioner could not sleep well, used to woke up suddenly, realizing her
harassment meted on her earlier by the Respondent as of at that time. The
Petitioner is put to strict proof of the same.

10. It is most respectfully submit that it is not true as alleged by the Petitioner at
Para 6 of the petition that the Petitioner concludes that the Respondent has
no respect towards the Petitioner and his family and the Respondent has no
moral values, as such the Petitioner apprehends danger with the attitude of
the Respondent and also feels it is no more safer for her to live in conjugal
relation with the Respondent, and with the acts of the Respondent, the
Petitioner apprehends that her future will damage. Because the cruel
behaviour of the Respondent, the Petitioner concludes that it is no safer for
her to live and continue marital life with the Respondent. Hence, the
Petitioner is constrained to file this petition for dissolution of her marriage
with the Respondent by a decree of divorce. The Petitioner is put to strict
proof of the same.
Conti...Page 7
7
11. It is most respectfully submit that the precious time of this Hon’ble court
would not have been wasted if the Petitioner had approached before the
presence of both of our family members, caste elders and other society
elders for mutual consent to the annulment of the marriage. The Petitioner is
not ready to come out before the society elders to settle the issue or to settle
amicably before the Family Counselling Centres like ‘Sakhi’ being
established by the Government Authorities concerned. And the Petitioner
ought to have been issued legal notice for dissolution of marriage. The
Petitioner also ought to have been lodged complaint against the Respondent
for cruelty, demanding of additional dowry and other allegations made in the
petition herein. But the Petitioner did not do so. The Petitioner directly
knocked the doors of this Hon’ble court.

12. It is most respectfully submit that the Respondent is not ready to accept for
dissolution of marriage by way of divorce and want to live together. The
Hon’ble court may be pleased to direct the Petitioner to live together by way
of re-union and for restitution of conjugal rights.

PRAYER:
In the light of the facts stated and for the reasons afore mentioned, it is
prayed that the Hon’ble Court may be pleased to dismiss the petition as
devoid of merits and be pleased not to pass a decree of divorce for
dissolution of marriage in between the Petitioner and the Respondent,
solemnized on 27.05.2017 and pass such other relief or reliefs for the
Respondent is otherwise entitled in the circumstances of the case.

DEPONENT
Solemnly affirmed and signed before me
On this day of 2024 at Godavarikhani.

ADVOCATE
 VERIFICATION

I, YANAMULA SUNIL S/o Suresh, Aged 33 years, Occu: Private

Employee in Hetro Company R/o: H.No. 1-2-39/1, Ganjipet, Gadwal,
Gadwal (Rural), Mahabub Nagar District, do hereby declare that the facts
stated in the above paragraphs i.e. from 1 to 12 are true to the best of my
knowledge, belief and basing on record. Hence, I verify the same as true and
correct on this day of 2024.

DEPONENT

LIST OF DOCUMENTS

1. Wedding Card
2. Xerox copy of Aadhar Card of Respondent
3. Xerox copy of Aadhar Card of Petitioner
4. Xervice certificate of Hetero Labs
5. Xerox copy of Jodas Expolm Pvt. Limited
6. Xerox copy of Dr. Reddy’s Labs

Station: Godavarikhani,
Date: 2024.