IN THE COURT OF THE HON’BLE ADDL.

JUDICIAL FIRST
CLASS MAGISTRATE, AT: SANGAREDDY.

M.C. No. 7 Of 2018

Between:

Smt. M. Anjamma
…Petitioner

A N D

M. Nagesh Goud
…Respondent

CHIEF AFFIDAVIT FILED BY THE PETITIONER AS A PW1

I, Smt. M. Anjamma, W/o. M. Nagesh Goud, Aged about 44 years, Occ.:

Housewife, presently R/o. C/o. K. Dasharath, H. No. 3-1, Vill: Ghanapur, Mdl:
Patancheru, Dist.: Medak-Telangana, do hereby solemnly affirm and sincerely
state on oath as follows:-

1. I submit that my marriage was solemnized with the respondent on 15-

05-1981 as per the Hindu rites and customs at Vill: Kondapur (Mdl), Dist:
Medak. It was an arranged marriage, at the time of the marriage on the
demand of the respondent; my father arranged an amount of Rs. 10,000/-
cash, 6 tulas gold and 1 Tula Hand rings and household articles all the things
towards dowry. Thereafter I entered into the matrimonial life and lived happily
for period of 6 years. Out of our wed lock I blessed with two children’s namely
one daughter namely Rani and One Son namely Srikanth Goud.

2. I further submit that after 6 years of the marriage, the respondent real
character came into picture. The respondent use to consume alcohol regularly
and beat me without any reasons. The respondent started torturing me
physically and mentally by using filthy language. The respondent behaviour is
adamant. Being I illiterate and bounded by my in-laws, I am not found any
ways to complaint against the respondent.

3. I further submit that the respondent abusing my family members in

filthy language and using uncertain words. The respondent demanded to bring
additional dowry, if I fails to bring such dowry amount then the respondent is
going to give divorce. I scared and immediately informed my parents about the
incidents took place in my matrimonial home. Immediately my parents and
family members arranged the money in the interest of my matrimonial life
happily. Thereafter I and my family members went to my-in-laws house and
 ::2::
asked about the behaviour of the respondent, the respondent managed the
elders at the moment and settle the issue and succeeded in convince I and my
family members. My family members believing the words of the elders and
having no more option other than to settle the issue in the interest of my
livelihood. Thereafter the respondent rejoined with me.

4. I further submit that soon after one month the respondent again started
harassing me physically and mentally for additional dowry and the respondent
not doing any work at that time and I am doing labour work and getting
amounts to lead my life along with my two children and staying at Vill:
Ghanapur, Mdl: Patancheru, Dist: Medak

5. I further submit that presently the respondent is having ancestral

properties and doing real estate business in surrounding villages. The
respondent getting Rs. 20,000/- per month. The earnings of the respondent
use by the family members of the respondent for lavish and luxuries personal
necessities, but not for the purpose of the house hold expenditure. The
respondent or his family members never given any importance to me and never
consider me as a family member, they used me as a slave. I informed about the
same to my parents and family members, they not having any option other
than convincing me to compromise the life for the sake of my future and
children livelihood.

6. I further submit that the petitioner along with her children was
compelled to leave the matrimonial house in order to protect the life of the
petitioner and her children due to life threat in the hands of the respondent.
The petitioner is vexed with the attitude of the respondent and thereafter the
petitioner shifted to her parents place and lives their own life with the help of
their parents and family members, the only reason to come to parents place to
avoid the torture and harassment of the respondent.

7. I further submit that I am done the marriage of my daughter with help of

my family members only and the respondent did not give any single pie to the
marriage expenditures.

8. I further submit that my parents were died and after I along with my
children went to Ghanapur Village and live with separately with the help of my
family members. I am living separately with the respondent since last 20 years.
 ::3::
9. I further submit that I am residing at separately and I have no source of
income to lead my livelihood and to maintain myself and my children to live
with dignity. I am not in a position to maintain ourselves and I am not having
any movable and immovable properties. So it has become very difficult for me
to maintain myself and my children. The Respondent has intentionally deserted
me to escape from all the responsibilities. But the respondent is totally
neglected me without giving any maintenance to me and my children and I am
unable to maintain myself with old age ailments. At present I am suffering with
old aged ailments. Now I am depending upon hand loans from my relatives.

10. I further submit that presently I am suffering with High blood pressure,
Knees pain etc., and I am taking regular health check up and spend per month
Rs. 2,000/- for medicine.

11. I further submit that the respondent is doing a real estate business and
having ancestral agricultural lands in Ghanapur Village and earning sum of
Rs. 20,000/- per month. There are no body to look after my daily needs
maintenance and expenses of the proceeding. Unless granted an amount of Rs.
10,000/- per month towards maintenance of me as I am suffering from old age
ailments as I need regular medical checkup and special care and my minimum
requirements for shelter, food, clothes. Otherwise I will be put to severe and
irreparable loss, injury and serious hardships.

12. I filed the following documents to prove my case and the same may be
marked as exhibits on my behalf in the above M.C.

1. copy Election I.D. Card of the petitioner.

2. copy of Aadhaar Card of the petitioner.
3. Original Copy of Electricity Bill, dt: 05-07-2016.
4. Original Copy of Electricity payment receipt, dt: 25-07-2016
5. copy of ration card of the petitioner.
6.

Therefore I am prayed this Hon'ble Court may be pleased to grant

maintenance of Rs. 10,000/- per month (Rupees Ten Thousand Only) towards
regular medical checkup, minimum requirements of shelter, food, clothes and
arrears from the date of neglecting maintain and deserting and to pass such
other order or orders as this Hon’ble Court deems fit and proper in the
interests of justice.
Sworn and singed on this the
19th day of July, 2018 at DEPONENT
Sangareddy

ADVOCATE/SANGAREDDY
 IN THE COURT OF THE HON’BLE ADDL.
JUDICIAL FIRST CLASS MAGISTRATE,
MEDAK DISTRICT,
:: AT SANGAREDDY ::

M.C. No. 7 Of 2018

Between:

Smt. M. Anjamma
…Petitioner

A N D

M. Nagesh Goud
…Respondent

CHIEF AFFIDAVIT FILED BY THE

PETITIONER AS A PW1

Filed on:

Filed by: Counsel for the Petitioner

Addresses for Service:

____________________________________________
M/s. R.S. ASSOCIATES,
T. RATAN SINGH,
A. ASHWIN GOUD,
J. KALPANA,
ADVOCATES,
#24-43/2, Beside Triveni Talent School,
Ashoknagar, R.C. Puram, HYDERABAD-32.