IN THE COURT OF THE SUBORDINATE JUDGE, PERUNDURAI
[Link]. of 2024
[Link]
W/o Late [Link],
No.106, Kothukkarar Street,
Melapalayam Post,
Chennimalai,
Perundhurai, Erode-638051
…. Plaintiff
Vs
[Link]
w/o [Link]
No.101, Sathy Main Road,
Opposite to Government Higher Secondary School,
Kasipalayam, Thadapalli Village,
Gobichettipalayam Taluk, Erode-638454
…. Defendant
PROOF AFFIDAVIT
I, [Link] W/o Late [Link], aged about 44 years, residing at
No.106, Kothukkarar Street, Melapalayam Post, Chennimalai, Perundhurai, Erode-638051 do
hereby solemnly affirm and sincerely states as follows;
1. I humbly submits that, I am working as a Helper in Senthil Clinic for the past over
15 years and has dedicatedly undertaken the responsibility of caring for stray
dogs, devoting considerable time and effort to their protection and well-being.
2. I humbly submits that, the my husband, Late Mr. Shanmugasundaram, was
employed as a Clinic Attender under Dr. Vijayakumar in Vijay Clinic until his
demise on 20-08-2015 due to cardiac arrest. Following my husband's demise, I
single-handedly raised my two children, Namely Mr. Mohanraj (aged about 26
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years) and Mr. Meganathan (aged about 20 years) and fulfilling my parental duties
with utmost care and responsibility.
3. I humbly submits that, I brings to the attention of the Court that on 11-12-2023,
the Defendant filed a petition for dissolution of marriage against her husband, Dr.
Vijayakumar, which was taken on file by The Hon’ble Subordinate Judge of
Gobichettipalayam under [Link].180/2023.
4. In the said petition in page no.4, the Defendant herein made numerous allegations
against her husband, including a statement alleging threats from her husband and
his family members regarding dowry demands and if the defendant herein fails to
give more dowry, the defendant’s husband and his family shall leave the
defendant and marry me to the defendant’s husband. The exact phrase of the
words in the petition is reproduced as follows. “VI.மேலும் திருமணமான ஒரு
மாதத்திலேயே எதிர்மனுதாரரும் அவரது குடும்பத்தாரும்
வரதட்சணை கேட்டு மனுதாரரை கொடுமைப்படுத்த ஆரம்பித்தார்கள்.
எதிர்மனுதாரரின் மூத்த சகோதரருக்கு திருமணத்தின் போது 70
பவுன் நகை போட்டார்கள் எனவும், ஆனால் மனுதாரருக்கு குறைவாக
போட்டுள்ளார்கள் எனவும், எனவே மீதி 40 பவுன் தங்க நகையும்
ரொக்கம் தொகை ரூபாய்.10,00,000.00/- கேட்டு வாங்கி வர கோரி
மனுதாரரை கொடுமைப்படுத்த ஆரம்பித்தார்கள். அதனை வாங்கி
வராவிட்டால் மனுதாரரை விட்டுவிட்டு ஏற்கனவே எதிர்மனுதாரரின்
மருத்துவமனையில் பணிபுரியும் துளசி என்ற விதவை பெண்மணியை
இரண்டாம் திருமணம் செய்து கொள்ள போவதாக அவரும் அவர்
குடும்பத்தார் அனைவரும் சேர்ந்து மனுதாரரை மிரட்டி
உள்ளார்கள்“.
5. I humbly submits that, the defendant in an evil intention included these allegations
in her petition as said above. I doesn’t have any connection with the defendant’s
husband except that I am employed under the brother of defendant’s husband.
6. I humbly submits that, I came to know about these allegations on 19-02-2024,
which caused shock and distress to me, as conveyed by Dr. Mohanasundaram, the
owner of Senthil Clinic, where I am employed and I was nearly traumatized after
reading the defendant’s petition and the defamatory statement in it.
7. I humbly submits that, after getting to know about the baseless allegations made
by the defendant, I inquired this with [Link] and his parents, they denied
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making any such kind of ugly statements mentioned by the defendant in her
petition, and I, exercising my ordinary prudence, believes that they shall not
express such behaviour.
8. I humbly submits that, the Defendant's intention in making these allegations is
malicious, aiming to disgrace and insult me. It is emphasized that I am actively
seeking a marriage alliance for my elder son, Mr. Mohanraj and in this stage the
defendant is trying to establish falsified matrimonial relation with Dr.
Vijayakumar is completely atrocious and deprecates my dignity.
9. I humbly submits that, the defendant statements as referred above is scandalous
and full of lies without any evidence. The said statement in the petition is not
bonafide nor made in good faith. The statements in the petition was made with an
evil intention to insult me in public forum. After the statements made in the
petition, my prestige was very much damaged in the eyes of the public, employer,
co-employees, relatives and friends. It also hurts my personal feelings and I am
suffering colossal amount of mental agony. It also affects the marriage of my elder
son and my reputation and my family.
10. I humbly submits that, the Defendant's actions were motivated by enmity and
vengeance, which severely damaged my reputation and caused significant mental
anguish and depression over the past days.
11. I contends that my dignified life, built over the years, has been gravely injured by
the Defendant's baseless and malicious accusations.
12. I am estimating the damage caused at Rs. 5 Lakhs. I also issued a registered legal
notice to the defendant on 28.02.2024 through my advocate seeking her to revoke
the allegations and demanding the defendant to pay her Rs. 5 Lakhs as damages.
The defendants received the same on 01.03.2024 but did not came forward to
revoke the allegation made by her nor chose to pay the amount. she also not cared
to give a reply even. Hence this suit.
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I therefore prays that this Hon’be Court may be pleased to pass a decree against the defendant
(a) to revoke the statement made by the defendant in page no.4 of her petition for Dissolution
of marriage in [Link].180/2023;
(b) to pay an amount of Rs. 5 Lakhs as damages/compensation for the pain and mental agony
suffered by the plaintiff;
(c) to pay the cost of this suit and such other reliefs that this Hon’ble Court deems fit and
proper in the circumstances of the suit.
Signed this before me at Erode on this 21st day of march 2024
Advocate
List of Documents
[Link] Date Document Nature
1 11.12.2023 Copy of Petition filed by defendant in Photo copy
[Link].180/2023
2 28.02.2024 Legal notice issued by the plaintiff Office copy
3 29.02.2024 Postal acknowledgement for legal Photo copy
notice issued by the petitioner
4 Postal track showing the delivery of E-copy
legal notice issued by the petitioner
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IN THE COURT OF THE PRINCIPAL
SUBORDINATE JUDGE OF PERUNDURAI
[Link]: OF 2024
[Link]
…Plaintiff
`-Vs-
[Link]
... Defendant
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Proof Affidavit filed by the Plaintiff.
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