IN THE COURT OF THE JUDGE OF FAMILY COURT

AT SECUNDERABAD

F.C O.P.NO. OF 2012

IN THE MATTER OF FAMILY COURTS ACT

Between:

Praveen Pinnoji Husband of Sirisha Gollapudi,

Aged: Years, OCC: Weblogic Developer in Dynasoft Synergy,
H.No: 8-2-602/13/A, Near Masjid,
Zehra Nagar, Banjara Hills,
Road # 10, Hyderabad – 500034.

…PETITIONER
AND

Sirisha Gollapudi, aged Years ,

D/o G.Bharatha Lakshmi,
Residence: QTR: IC-202,
Beside Hotel NKM's Grand,
Erramanzil Colony, Hyderabad - 500082
…RESPONDENT

1. Without prejudice to the pleas hereinafter set out, the petitioner herein
do hereby deny all the allegations made in the petition except those
that are specifically admitted hereinafter.

As regards to para (i) of the counter claim petition under reply, in so

for the contents relating to wedding gifts i.e., approximately 38 grams
of gold (chain, ring, bracelet) received by the petitioner is not disputed
. The petitioner submits that the respondent also received gold jewelry
approximately 85.58 gms which includes (One necklace with earrings,
2 rings, Mangala Sutram, Lakshmi pendant) Out of all the above, only
necklace chain is with the petitioner (she has ear rings from that
necklace set and all other items). After the wedding petitioner gifted
respondent the following jewelry Tanishq gold chain with ear rings,
Nalla pusala dhanda, Laxmi Pendant, Silver Anklets (Kalla Pattilu)

2. As regards to para (ii) of the petition under reply, petitioner submits

that both petitioner and respondent liked each other in U.S.A. But
denies that respondent supported petitioner with money while they
 were in U.S.A. In fact petitioner supported respondent financially, as
petitioner was working in SAVIN TECHNOLOGIES COMPANY as web
logic developer and was earning around 3,500 dollars per month. The
petitioner can produce the bank statement showing money transfers
from petitioner’s account to respondent’s account.
3. As regards to para (iii) of the petition under reply, the respondent
called the petitioner over phone and informed that her family members
were trying to get her married and she feels like ending her life if she
is not married to the petitioner and asked the petitioner to comedown
to India and speak to her mother about the marriage. (Petitioner can
provide U.S call details as evidence.)
4. As regards to para (iv) of the petition under reply, petitioner denies
the contents of this para and petitioner submits that both the families
were happy with the marriage and petitioner family never demanded
for any dowry as both the petitioner and respondent liked each other.
And the same is confessed by respondent’s brother –in-law in call
conversation with petitioner. Petitioner denies that his father forced
respondent’s mother to give cash on stage during the engagement.
(Video of engagement (not available with petitioner) and marriage can
be produced.)
5. As regard to para (vi) of the petition under reply, petitioner denies the
contents of this para, petitioner submits that his father treated
respondent like his daughter and respondent is making false
allegations to defame his father and his family and spending 13 lakhs
for the marriage and obtaining two loans at the time of marriage is put
to strict proof.
6. As regard to para (vii) of the petition under reply, petitioner denies the
contents of this para and petitioner submits the he was giving an
analogy with respect to marriage partners and business partners and
was comparing happiness and sorrows with profit and loss and both
has to bear them equally.
7. As regards to para (viii) of the petition under reply, petitioner denies
the contents of this para, in fact the respondent has scant respect
towards petitioners parents which reflects in her gmail chat
conversation with the petitioner and respondent never did any
household work as their was a maid in the house to do household
work.
8. As regards to para (ix) of the petitioner under reply, petitioner denies
the contents of this para, respondent is trying to defame the parents
 of petitioner by making false allegations and the petitioner never
forced respondent to have sex during menstrual period as petitioner
was having knowledge about her health conditions which the
respondent communicated to him through email chat converstion.
9. As regards to para (x) of the petitioner under reply, petitioner denies
the contents of this para, petitioner himself encouraged respondent by
sending her to software training course in Ameerpet(Geosoft) and paid
her course fee. (Evidence from register not available with the client)
10. As regards to para (xi) of the petitioner under reply, petitioner
denies the contents of this para, petitioner himself bought all the
household articles and petitioner’s mother never enquired about the
gifts given to respondent’s sister at the time of her marriage.
11. As regards to para (xii) of the petitioner under reply, petitioner
denies the contents of this para, respondent was allowed to go to her
mother’s place, in fact respondent never stayed one week straight at
petitioners house.
12. As regards to para (xiii)(Xiv) of the petitioner under reply,
petitioner denies the contents of this para, petitioner brother used
separate bedroom and he used to keep his stuff in a separate almara,
here the respondent is trying to defame petitioner family members by
making false allegations and respondent had no problem while going
out with petitioner and his brother to movies and tours.
13. As regards to para (xvi)(Xvii) of the petitioner under reply,
petitioner denies the contents of this para, respondent used to harass
the petitioner to setup separate establishment. Due to the harassment
by the respondent, parents of petitioner moved out of the house
believing that both would be happy with their marriage life.
14. As regards to para (Xviii) of the petitioner under reply,
petitioner denies the contents of this para, petitioner brother
accompanied them on the request of respondent and petitioner never
forced her to have sex while his brother was accompanying them.
(Photos of the trip can be verified)
15. As regards to para (Xix) of the petitioner under reply, petitioner
denies the contents of this para, petitioners parents left due to
respondents harrashment. In fact respondent herself all alone
consulted gynecologist about the abortion procedure without informing
the petitioner even before the petitioner knows that she is pregnant.
Respondent would compare by saying that respondents Sister's kid had
very good lastname "Rishi Inturi" and our kid would be something with
 "pinnoji" as last name and respondent clearly indicated that she
doesn't like her child to be called with that "pinnoji" last name and
Respondent was not ready to have children and aborted the child on
her will.
16. As regards to para (Xx)(Xxi) of the petitioner under reply,
petitioner denies the contents of this para, In December 2011
petitioner went to Bangalore along with respondent to work from
clients place. In fact respondent harassed petitioner asking with whom
he is sleeping at home in Hyderabad, when petitioner visited
Hyderabad to get his bike. Respondent did not allowed petitioners
parents to visit Bangalore and kept restrictions that they should stay
only for one week. Respondent was working in Black and White
Solutions Pvt, Ltd and left the job before probation period i.e., 84 days
as she was unable perform her work upto the company’s standards
which she communicated to the petitioner and asked him to find her
new job. When petitioner through his reference tried to get her a job
in his client’s company, but respondent rejected the job offer when she
was contacted by the H.R department, which can be verified by the
email communication between petitioner and his director.
17. As regards to para (Xxii) of the petitioner under reply, petitioner
denies the contents of this para, respondent threatened petitioner by
drinking 750 ml of wine, that she will end her life by jumping from the
terrace or by cutting her wrist when ever their was a discussion
between them under the influence of alcohol. On 10 th August she left
to Hyderabad saying she will give divorce. It is true that in August 17 th
to August 22nd she attendee counseling classes in Land Mark and the
notes she used to write during the counseling classes reveals her true
behavior where she call her self a fraud, lier, not able to pursue her
career due to pressure from her mother and sister and she has the
support of her husband. (Land Mark notes can be produced as
evidence.)
18. As regards to para (Xxiii) of the petitioner under reply,
petitioner denies the contents of this para, respondent returned to
petitioner on August 23rd saying that she is now a changed person. But
she was behaving same when petitioner and respondent visited
petitioners parents in Hyderabad by asking about the property share
she started creating differences in the petitioners family. It is not true
that petitioner parents asked the respondent to keep her jewelry with
them or enquired about the flat transfer.
19. As regards to para (Xxiv) of the petitioner under reply, petitioner
denies the contents of this para, on October 7 th both respondent and
petitioner visited respondent’s mother’s house. On October 8 th evening
respondent’s mother after returning from the office she started
shouting at the petitioner in the presence of her brother and
respondent family members humiliated petitioner.(Refer to divorce
petition). Petitioner vexed up with the behavior of the respondent and
after being humiliated by the respondents family and seeing that there
is no hope for reconciliation, petitioner decided to take divorce after
communicating his decision to respondent through emails. Petitioner
filed divorce on dt.24-12-2012 and after 4 months of filing divorce,
respondent filled 498A case on dt.20-04-2-13 at 18:45hrs at WPS
CCS with FIR No: 173/2013 making false allegation only to harass
petitioner and his family. After filling 498A on petitioner and his family,
petitioner got arrested on dt .22-04-2013 and produced in court on 23-
04-2013 and on 23rd petitioner was sent to Jail from Court. Petitioner
came out of jail on bail on dt.25-04-2013.
20. As regards to para (Xxviii) of the petitioner under reply,
petitioner denies the contents of this para, It is true that petitioner
worked in Mcafee Software Pvt Ltd.(INDIA) and used to earn around
Rs…per month, but now he lost his job due to 498A false case and he
has to put his resignation papers because he is unable to perform
according to company standards and right now petitioner is serving on
two months notice period. Now Petitioner is dependent on his father
who gets Rs.1400/- as pension and petitioner cannot get into new job
due to police records. It is petitioner who should be granted
permanent alimony and maintenance under sec 25 of Hindu marriage
act 1955. As respondent herself mentions in this counter that
respondent’s family is more stable than petitioner’s family. And
respondent is equally qualified and hold couple of world class
certificates from Microsoft which would easily get her job.

As regards to para (Xxviii) of the petitioner under reply, petitioner

denies the contents of this para, it is not true that respondent’s family
paid Rs.15 Lacks in cash to the petitioner’s family at the time of the
marriage which is put to strict proof. And petitioner received gold
jewelry approximately 38 grams as weeding gift, where as respondent
received gold jewelry approximately 85.58 gms which includes (One
necklace with earrings, 2 rings, Mangala Sutram, Lakshmi pendant)
Out of all the above, only necklace chain is with the petitioner (she has
 ear rings from that necklace set and all other items). After the
wedding petitioner gifted respondent the following jewelry Tanishq
gold chain with ear rings, Nalla pusala dhanda, Laxmi Pendant, Silver
Anklets (Kalla Pattilu) as wedding gift at the time of the marriage. In
fact when petitioner and respondent where living in Bangalore ,
respondent harassed petitioner to deposit RS.45,ooo/- per month from
petitioner’s salary in her bank account and later from this deposited
amount she forced petitioner to make a fixed deposit of Rs.2,50,000/-
in AXIS BANK on her name. And this amount is still Fix deposited on
her name.(Bank Statements Pg 102 and Fixed deposit receipt Pg 104
to 109 can be produced as evidence)
21. Respondent talks about her relationship with ex-boyfriend
Pramod in her email chat conversation (Pg 127) with petitioner.
22. Respondent was in regular touch over phone with her colleague
Madan Kumar from Black & White Solutions even though she quit her
job while the petitioner was in his office for a long durations which is
inappropriate for a married woman and the same behavior was
observed with her one more male friend named Balakrishna. Madan is
the same person who was spotted by petitioner and his neighbors in
petitioner’s house during his absence with locked doors. (call details
can be provided as evidence).