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IN THE HON’BLE COURT OF I ADDITIONAL CHIEF METROPALITAN

MAGISTRATE, VIJAYAWADA.

DVC.No: 16/2020
BETWEEN:-

PIRANGI.YOGITHA : PETITIONER

VS

PIRANGI.DURGA VENKATA KRISHNA : RESPONDENTS

WRITTEN OBJECTION/REPLY TO THE PETITION U/S 23 r/w 20 of Cr.P.C

THE RESPONDENT MOST RESPECTFULLY SUBMITS AS FOLLOWS:

1) That the above mentioned Petitioner filed before the Hon’ble

Court to pleased to pass interim orders for maintenance of
Rs.41,000/- per month.

2) The likelihood of creating further complications on

Petitioners false averments through interim order is already
explained in the objections and it may be read as part and
parcel of this reply objection and same to be adopted in order
to avoid repetition.

3) The Respondent files detail statement and objections and deny

domestic violence and other allegations of cruelty, demand for
dowry, physical assaults etc., and points out that there is no
specific allegation in the complaint and all the allegations
are vague. No specific dates were mentioned etc.

4) The Respondent also filed affidavit swearing to several

contents and alleges that petitioner has filed false statement
of facts in her complaint and affidavit. She is the trouble
maker. Now lately alleging false things wants to misuse law
for unlawful gains by the abuse of process of court.

5) This meaning of domestic relationship has sense when we come

to definition of domestic violence and the purpose of the Act.
The purpose of the Act is to give remedy to the aggrieved
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Persons against domestic violence. The domestic violence can
take place only when one is living in shared household with
the respondent. The acts of abuses, emotional or economic,
physical or sexual, verbal or nonverbal if committed when one
is living in the same shared household constitute domestic
violence. When both are residing separately for year’s
together and mere allegation when one is living separate,
cannot be covered under Domestic Violence Act.

6) If the application is allowed petitioner may drag on the

proceedings and hence for speedy justice the matter may be
heard on merits after suitable enquiry.

7) If the application is allowed, grave injustice and injury will

be caused to the respondent. Since petitioner is happily
living with her parents and no immediate economic assistance
is needed on the grounds of her own drawbacks in the averments
of her petition. 

8) I deeply pray your Honour to consider all the legal aspects

either for interim order or for order on merits in the ends of
justice.

9) The Respondent is not an ATM machine to provide the

maintainance to petitioner who has deserted the respondent by
giving invalid,unreasonable ground for the reason best known
to her.The said acts of petitioner not only harass the
respondent in addition she has caused violation of every
condition of marriage obligation.
10) The petitioner is a MCA graduate and can do a job. But the
petitioner is intentionally not doing any job only to gain the
maintenance from the Respondent.
11) The Petitioner has never showed her interest towards the
respondent to Re unite by showing only false allegations
against Respondent.
12) The attitude of the Petitioner towards the baby is improper
and has only showed the fake love towards the baby and it is
clear evident from the whatsapp messages put by the petitioner
on dated 23/6/2017,24/7/2017 during her pregnancy.
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13) The respondent as a father does not want to allow the

child’s life to be spoiled due to the petitioner's vindictive
attitude.

14) It is further submitted that the Respondent wants to take

complete handover of the baby as he has already crossed the
feeding stage from mother. The respondent will be ready to
join the child in a Residential English medium school so that
the education of the child will be taken care.
15) It is further submitted that the Respondent would like to
meet the child during every date of hearing without fail.
16) It is further submitted that the DVC case was filed after
the 3 years from the date the petitioner has left the
Respondent which clearly shows that the allegations are
frivolous.
17) It is submitted that the Respondent’s father prays to this
court to give his grandson immediately for few days to reside
with him as he wants to cherish the happy moments with him.
This petitioner never allowed to show him till date.
18) Wherefore in view of above facts and laid down law, this
respondent humbly prays this Hon’ble court to keep pending the
Interim application and direct petitioner to prove her case on
merits to provide any relief as claimed for, by substantially
proving her allegations in the ends of justice. 

ADVOCATE FOR RESPONDENT SIGNATURE OF THE RESPONDENT

BANGALORE
DATE: 27/11/2019