Doddaballapur

Date : 07-10-2013
To.
Sri. J. M. Gowri Shankara Raju
Advocate & notary
Pakala-517112
Chittor District
Andra Pradesh
Respected sir,
Your notice dated 25-09-2013 issued on behalf of your client
Smt. K. Prabhavathi & her children to my client Sri. K. P. Ramesh
Babu S/o Perumal, has been placed in my hands by my client
with instructions to issue the reply notice as follows,
1. The averments set out in para 1 of your notice is true and
admitted.
2. The averments set out in para 2 of your notice that after the
marriage both your client and my client lived happily for some
period is true and correct. The other allegations set out in the
same para that my client has addicted to bad vices like,
drinking alcohol, debacheloring, gaming, playing cards etc
and due to the above bad vices my client did not looking after
the welfare of your client and minor childrens are all false
and incorrect and my client emphatically denied the same.
The other allegation set out in the same para that my client
has heard the words of his sister Saralamma and his mother
Kanthamma and harassed your client and her minor children
are

all

false

and

incorrect

and

the

Saralamma

and

Kanthamma are nothing to do with the family of your clients

and my client. The other allegation set out in the same para
that due to my clients bad vices my client has stopped the
education of his children and necked out your client and her
children from my clients house to heard the words of my

clients sister and mother and my client is in the clutches of

his sister and mother and harassed your client and my client
did not arranged proper amenities to your client and her
children like, food, clothes, etc, and my client had sold entire
gold worth about 10 soverign of gold article which are
presented by your clients parents at the time of her marriage
to my clients bad vices and when your client questioned
about my clients illegal acts and ill treatment about one year
ago my client had beaten your client indiscriminately and
necked out your client and her children from your house are
all false and incorrect and my client emphatically denied all
the allegations set out therein.
3. My client furthers instructs me to reply to you that the other
allegations set out in para 2 of your notice that your client has
no any other source and she came to her parents house and
joined her parents late 3 or 4 times my client came there and
made galata and beaten your client indiscriminately and when
the children obstructed my clients illegal acts my client
scolded out them from the house at Pakala town and with
great difficulty at the instance of village elders by name
Sathyanarayana, N. Munaswamy, Sreenivasalu, Ravi and etc.,
surya Prakash Naidu and some others held mediation and
suggested my client to lead happy matrimonial (marital ?)
life, but my client did not cared their words and left the place
and went to his native place and after went to his native place
my client has forced your client with an intent to sell away the
house to the third parties with a cheaper rate which is stands
in your client name one way or other my client threatening
your

client

are

all

false

and

emphatically denied the same.

incorrect

and

my

client

4. My client further instructs me to reply your notice that the

other averments that the said house is stands in the name of
your client and she did not agree to sell way the same and
she has got children and requested my client to convince, but
my client did not convince your clients words and my client
demanding your client to put her signature on the agreement
papers is not true and correct and the other allegations set
out in the same para that your client bluntly saying that she
was not showing any interest to sell the house property which
is standing in her name and if at all if my client have to sold
the same without your clients consent, your client is not
responsible for the same are all false and incorrect and
unwarranted. The other allegations set out in the same para
that your client No. 1 parents are aged parents and they have
no capacity to maintain your client is unwarranted. The other
allegation set out in the same para that my client is doing
power loom work is true and correct, but it not true that he is
getting Rs, 25,000/- per month and apart from that my client
is doing finance work and getting Rs, 10,000/- per month is
an utterly a falsehood. The other allegations set out in the
same para that my client is having a capacity to maintain
your client and thus he is liable to pay an amount of Rs,
3,000/- each per month in total Rs, 9,000/- per month to pay
the maintenance amount to your clients are all false and
incorrect and my client is not liable to pay any maintenance
to your clients. The other averments setout in the same para
that if my client fails to pay the amount your client will take
appropriate legal action as against my client through proper
court of law for recovery of maintenance amount of Rs,
9,000/- per month is unwarranted and unsustainable under

law

since

your

clients

are

not

entitle

to

claim

any

maintenance.
5. My client represent the true facts as follows : - Your clients
have not stated the true facts to you and they have mispresented to you and caused to issue an untenable notice at
the hands of you. Your client is not a prudent wife, she has
borrowed hand loans from so many persons at Doddaballapur
during her stay with my client in Doddaballapur to do the
money lending business and when she become bankrupt she
left away Doddaballapur without intimating my client. There
after the creditors came near the house of my client and
make galate and insisted my client to repay the amount which
your client has borrowed. Your client had borrowed money
from my clients friends and neighbours falsely stating that
my client had admitted to hospital and she need immediate
money for my clients treatment and believing your clients
words they have given money to your client and thereafter
they demanded my client to repay the same. In fact, my
client has not admitted to any hospital and he had not
undergone any medical treatment, but your client has falsely
represents before the creditors to have a loan from them.
Thereafter, my client came to know the fraud committed by
your client, he questioned your client and then your client had
told to my client to sell the house property which is standing
in the name of your client. Believing your clients words my
client had negotiated with the prospective buyers to sell the
house property and ultimately my client had negotiated with
one . To sell the house property for a sum of Rs,
and intimated to your client and after your clients
consent he had taken a token advance amount of Rs,
and thereafter your client had disagreed to sell the property

for the reason that the sale price is very low and therefore the
said transaction has been broken. Now the house property
has been leased for a sum of Rs,

to one

and repay the loans which your client has borrowed from
different persons. Your client has left Doddaballapur to escape
from the creditors and not for the reasons of ill treatment as
alleged by your client in your notice. My client is a obedient
husband and he is looking after your client and her children
very carefully and he is providing good education to his
children, but by the irresponsible behavior of your client the
education of the children has been destroyed, now the son of
my client is forced by your 1st client to do daily laboure work
as building construction at Pakala. My client is never necked
your clients from his house, on the other they themselves has
went away for the reasons stated supra and my client is not
at all responsible for the same and even to this day my client
is ready to maintain your client if they were come and join the
company of my client and agree to live with him as dutiful
wife and children. Your 1st client has left the house of my
client by afraid of the creditors and your 1st client has left the
company of my without any valid reasons and without
fulfilling the marital obligation with the my client she has left
the society of my client and therefore my client is advised to
file a petition for restitution of conjugal rights against your 1 st
client. Therefore your clients are not liable to get any
maintenance from my client and my client is power loom
worker (labour) and he is getting hardly Rs, 5,000/- per
month and he has to maintain her old aged mother and
therefore he is not in a position to pay maintenance of Rs,
9,000/- per month to your clients, much less your clients are

not entitle to claim any maintenance for the reasons set out
supra.

Wherefore you are hereby called upon by my client that

please advice your clients properly to withdraw the notice
and not to embark any unnecessary litigations and please
advise your clients to join the company of my client and lead
a happy life with him as dutiful wife and children. In spite of
this reply notice if your clients were to proceed further they
may do the same at their risk and cost and my client will face
the same as per law.