The above named plaintiff states as follows:
1. The plaintiff was given in marriage at Rajahmundry to the defendant.
2. The defendant, after her marriage with the plaintiff, lived with her guardian but, for occasional visits her husband’s place till she attained majority in 1994.
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ADVERTISEMENTS:
3. The defendant is an unemployed man. He was unable to maintain the plaintiff and discharge his minimum marital obligations. Being anxious of the welfare of the plaintiff, the defendant was asked by the guardians of the plaintiff to come over to the plaintiffs house as illotom son-in-law and live there.
4. The defendant turn out to be a worthless fellow and was found to be incompetent to discharge marital obligations. He would not work often left home for couple of months without intimation to the plaintiff or anybody in her house.
5. He returned thereafter, lived with the plaintiff amicably and went away again not to return this time.
ADVERTISEMENTS:
6. The defendant and plaintiff before the desertion were living in Guntur at the residence of the plaintiffs uncle.
7. The defendant has neglected and has failed to provide for the maintenance of the plaintiff for a continuous period of more than two years. He failed perform, without reasonable cause, his marital obligations. This sort of negligence on his part made the life of the plaintiff miserable.
8. The plaintiff in the aforesaid circumstances is entitled to a decree of dissolution of her marriage with the defendant on grounds mentioned above as contemplated in S. 2(ii)(iv) and (vii) of the Dissolution of Muslim Marriage Act, 1939.
Written Statement:
ADVERTISEMENTS:
1. It is true that the defendant is the husband of the plaintiff. However, the defendant never deserted or ill-treated the plaintiff. On the other hand, the plaintiff used to harass the defendant for luxuries like colour television, scooter and used to insult the defendant in public contending that the defendant who was not capable of providing luxuries to the family ought not to have married at all.
2. The defendant further submits that on…. the plaintiff necked out the defendant as the defendant failed to bring home Television. Since then the defendant made futile attempts to mediate through Karimullah and Nawab Ali, elders of their community.
3. The defendant is willing to live with the plaintiff even now. Hence, the defendant submits that the suit may be dismissed with costs.
