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1) The Petitioner submits that the petitioner and the Respondent wassolemnized on 26/02/2012 at ……………………………………………………… ThePetitioner submits that at the time of marriage as per the demand ofRespondent and his family members the Petitioner!s parents performed themarriage with a pomp and gaiety and borne Rs"# la$hs and 10 tulas of %old

towards marriage e&penses"

2) The Petitioner submits that the Respondent from the day one of the marriageused to abuse the petitioner and her siblings with 'lthy language for ea(hand e ery silly reason" The Petitioner submits that her family members boreall the insults without demur with a fond hope that in due (ourse they will beforgotten"

*) +n the ,ear ……" the petitioner and the respondent were blessed with a male

(hild at …………………""-yderabad" The Respondent and his parents starteddemands of 1 Tula gold et( but the parents of Petitioner were not in a positionto ful'll the demands of the Respondent and his family members as they boredeli ery e&penses " The Petitioner was tortured and humiliated and thrownout of the house" The Petitioner submits that her parents and siblings used to(onsole her and (on in(e her to remain with the Respondent" .urthermorethe Petitioner submits that!s she su ered all the insults and harassment inthe hands of the Respondent with an intention to safeguard the familyesteem and not to remain as a burden at maternal house"

) The Petitioner submits that when the matter was pla(ed before elders the

Respondent admitted his guilt and too$ the Petitioner to the matrimonyhouse" The Petitioner submits that it be(ame a ritual for the Respondent toabuse and lea e her at parental house again when elders (all for mediationbringing the Petitioner ba($ by ma$ing false promises" The Petitioner submitsthat she was e&ed and e&asperated by the attitude of the Respondent"

) hen the Petitioner (on(ei ed for the se(ond time the harassment of theRespondent rea(hed its zenith and he left the Petitioner and their 'rst (hild atPetitioner parent!s house on …………" when they were out of station" 3fterse(ond deli ery a female (hild was born in the year…………" 4either theRespondent nor his family members turned out to see the baby or thePetitioner till today"

6) The Petitioner is leading a miserable life with her two small (hildren" ThePetitioner is a housewife and is fa(ing e&treme trouble to lead li elihood" TheRespondent is well pla(ed in his (areer and drawing a handsome salary of Rs"60 000 per month" The Petitioner submits that she and her (hildren are fa(ingmu(h hardship in sustaining their li elihood" .urthermore The Petitioner

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submits that she has no independent sour(e of in(ome to maintain herselfand (hildren and does not want to be a burden to her family"

#) That the Petitioner is dis(arded by the respondent intentionally who wassupposed to maintain her as per law and (ustoms" The Respondent rather

being a lawful husband and father herein willfully negle(ts the Petitioner andthe (hildren respe(ti ely"

5) That there is no other suit or analogous pro(eeding 'led or pending in eitherbefore this -onble ourt or before any other (ourt of law in between thepartied herein (laiming for the similar relief"