MEMORANDUM OF CIVIL REVISION PETITION
(UNDER ARTICLE 227 OF CONSTITUTION OF INDIA)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
Civil Revision Petition No. Of 2025
Against
DVC No. 30 of 2023
(On the File of the Judicial Magistrate -II, Tambaram)
1. Arjun Raj
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
2.N. Mariaappan
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
3,M. Bhakya Lakshmi
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
…Petitioners
Vs.
S.Deepa,
D/o.R.Seetharaman,
No.14, Ex- Serviceman Enclave,
Agaram Road,
Selaiyur,
Chennai- 600 073.
…Respondents
CIVIL REVISION PETITION
The Address for service of all Notices and processes on the Petitioner is that of his
Counsel M/s L.MURUGANANTHAM, A.RAGHURAMAN, M.SHANKAR,
Advocates, having Office at No.369/100, Bharatha Matha Street, East Tambaram,
Chennai – 600 059.
The Address for service of all notices and processes on the Respondents is the same as
stated above.
The Petitioner above named begs to prefer this Memorandum of Grounds of Civil
Petition against the Domestic Violence Petition in D.V.C.No. 30 of 2023 on the file of
the Judicial Magistrate -II, Tambaram for the following among other;
GROUNDS
1. The Petition filed by the Respondent is arbitrary, without valid reasons and
bereft of any material particulars and is therefore liable to be set aside.
2. The Petition filed by the Petitioner does not contain the bare particulars required
to constitute the Domestic violence against 2 nd and 3rd Petitioners even as
defined under Section 3 of The Protection of Women from Domestic Violence
Act, 2005.
3. Respondent had herself admitted in legal proceedings that she had lived along
with 2nd Petitioner and 3rd Petitioner only for five days. Respondent herself
admitted that she is living in her parents house and not with 1 st Petitioner from
the year 2013. Even all those allegation contained in the petition filed by
Respondent against all the petitioners are completely false and frivolous. The
Petitioner filed the petition with malafide intention to abuse the process for her
vested interest to harass the Petitioners.
4. Even all the allegations filed by Respondent would show that the complaint
itself had been raised by Respondent for almost every allegations against
Petitioners only long after the expiry of the statutory time and hence there is
clear jurisdictional error in initiating this proceedings. Mere vague allegations
had been raised by the Respondent without even making any complaint even
before Police. Respondent had demanded Fifty lakhs from the 1 st Petitioner
through her own what’s app number by sending the message from her number to
the number of the Petitioner and only when that demand was not met
Respondent had malafidely instituted the complaint that too after a long time of
expiry of the limitation. This complaint is clear abuse of the process.
5. The Petitioners state that the Petitioners took all the necessary steps to take care
of the Respondent but it was the Respondent who deserted the Petitioner without
telling the Petitioner.
6. The Petitioners state that the Respondent’s had thrown the allegations against
Petitioners without any valid reasons and the Respondent was never interested
to live a normal life with this petitioner.
7. The Petitioners state that the Respondent has wantonly filed the present Petition
to harass the Petitioners with the frivolous allegations.
8. The Petitioners state that the Respondent deserted the Matrimonial home and
did not return back even after several requests from the Petitioners.
9. The Petitioners state that that the Petitioners son left to USA for Job only for the
Welfare of the Respondent and there was no severe allegations against the
Petitioners son in any manner which might affect the matrimonial life.
10. The Petitioners state that the Petitioners never demand any dowry from the
Respondent before or after the marriage and was taking care of her as their own
daughter.
11. The Petitioners state that the 2nd Respondent left the matrimonial house on her
own decision; the Petitioners never sent her to her parent’s house. Initially the
Petitioners son and the Respondent After both the Petitioner lived happily in the
beginning of the marriage and thereafter due to the influence of the Respondent
parent’s who insisted the Respondent not to take care of the Peitioners son in his
day to day activities. Thereafter in the year October -2013 the Respondent left
the matrimonial house on her own due her childbirths, she living with under
parent’s guidance.
12. The Petitioners state that the Respondent has filed the present Petition with
imaginary allegations suppressing the real facts and circumstances in the Case.
In any event, the impugned complaint is liable to be quashed to promote justice
and also to avoid miscarriage of justice.
13. The Petitioners reserves their right to additional grounds if so warranted at the
time of final hearing.
It is therefore prayed that this Hon’ble Court may be pleased to dispense with the
production of certified copy of the Complaint in D.V.C.No. 30 of 2023 on the file of the
Judicial Magistrate -II, Tambaram and pass further suitable orders and thus render
justice.
It is therefore prayed that this Hon’ble Court may be pleased to Dispense With the
presence of the Petitioners in D.V.C.No. 30 of 2023 on the file of the Judicial
Magistrate-II, Tambaram pending disposal of the main Civil Revision Petition and pass
such further or other orders as this Hon’ble Court may deem fit and proper in the
circumstances of the case and thus render justice.
It is therefore prayed that this Hon’ble Court may be pleased to stay further
proceedings of in D.V.C.No. 30 of 2023 on the file of the Judicial Magistrate-II,
Tambaram pending disposal of the main Civil Revision Petition and pass such further or
other orders as this Hon’ble Court may deem fit and proper in the circumstances of the
case and thus render justice.
It is therefore prayed that this Hon’ble Court may be pleased to call for records
pertaining to D.V.C.No. 30 of 2023 on the file of the Judicial Magistrate-II, Tambaram
and strike off the names of the revision petitioners as abuse of process of law and pass
such further or other orders as this Hon'ble Court may deem fit and proper in the
circumstances of the case and thus render justice.
Dated at Chennai this the 06th day of March 2025
COUNSEL FOR PETITIONERS
MEMO
Value of the Domestic Violence Case : Incapable
Court Fee paid in Domestic Violence Case :
Value of the Civil Revision Petition : Incapable
Court Fee Paid : Rs. 500
Dated at Chennai this the 06th day of March 2025
COUNSEL FOR PETITIONERS
MEMORANDUM OF CIVIL MISCELLANEOUS PETITION
(UNDER ARTICLE 227 OF CONSTITUTION OF INDIA)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
Civil Miscellaneous Petition No. Of 2025
In
Civil Revision Petition No. Of 2025
Against
DVC No. 30 of 2023
(On the File of the Judicial Magistrate -II, Tambaram)
1. Arjun Raj
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
2.N. Mariaappan
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
3,M. Bhakya Lakshmi
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
…Petitioners/Petitioners
Vs.
S.Deepa,
D/o.R.Seetharaman,
No.14, Ex- Serviceman Enclave,
Agaram Road,
Selaiyur,
Chennai- 600 073.
…Respondents/Respondents
PETITION FOR DISPENSE WITH
For the reasons stated in the accompanying petition, this Hon’ble Court may be pleased
to dispense with the production of certified copy of the Complaint in D.V.C.No. 30 of
2023 on the file of the Judicial Magistrate -II, Tambaram and pass further suitable
orders and thus render justice.
Dated at Chennai this the 25th day of February 2025
COUNSEL FOR PETITIONERS/PETITIONERS
MEMORANDUM OF CIVIL MISCELLANEOUS PETITION
(UNDER ARTICLE 227 OF CONSTITUTION OF INDIA)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
Civil Miscellaneous Petition No. Of 2025
In
Civil Revision Petition No. Of 2025
Against
DVC No. 30 of 2023
(On the File of the Judicial Magistrate -II, Tambaram)
1. Arjun Raj
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
2.N. Mariaappan
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
3,M. Bhakya Lakshmi
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
…Petitioners/Petitioners
Vs.
S.Deepa,
D/o.R.Seetharaman,
No.14, Ex- Serviceman Enclave,
Agaram Road,
Selaiyur,
Chennai- 600 073.
…Respondents/Respondents
PETITION FOR DISPENSE WITH
For the reasons stated in the accompanying petition, this Hon’ble Court may be pleased
to Dispense With the presence of the Petitioners in D.V.C.No. 30 of 2023 Pending on
the file of the Judicial Magistrate-II, Tambaram and pass such further or other orders as
this Hon’ble Court may deem fit and proper in the circumstances of the case and thus
render justice.
Dated at Chennai this the 25th day of February 2025
COUNSEL FOR PETITIONERS/PETITIONERS
MEMORANDUM OF CIVIL MISCELLANEOUS PETITION
(UNDER ARTICLE 227 OF CONSTITUTION OF INDIA)
IN THE HIGH COURT OF JUDICATURE AT MADRAS
Civil Miscellaneous Petition No. Of 2025
In
Civil Revision Petition No. Of 2025
Against
DVC No. 30 of 2023
(On the File of the Judicial Magistrate -II, Tambaram)
1. Arjun Raj
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
2.N. Mariaappan
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
3,M. Bhakya Lakshmi
No. 2/495, Mullai Nagar,
Soolakarai Medu,
Virudhunagar Taluk,
Virudhunagar.
…Petitioners/Petitioners
Vs.
S.Deepa,
D/o.R.Seetharaman,
No.14, Ex- Serviceman Enclave,
Agaram Road,
Selaiyur,
Chennai- 600 073.
…Respondents/Respondents
PETITION FOR STAY
For the reasons stated in the accompanying petition, this Hon’ble Court may be pleased
to stay further proceedings of in D.V.C.No. 30 of 2023 on the file of the Judicial
Magistrate-II, Tambaram pending disposal of the main Civil Revision Petition and pass
such further or other orders as this Hon’ble Court may deem fit and proper in the
circumstances of the case and thus render justice.
Dated at Chennai this the 25th day of February 2025
COUNSEL FOR PETITIONERS/PETITIONERS
