Firstly, file an application to refer her virginity test certificate to be verified by the Medical Board. The truth will soon emerge.
Secondly, potency and consummation are different subjects, which you are to note. A person can be potent but may not consummate the marriage owing to extraneous reasons. She may herself deny the conjugal rights and then file a divorce petition in the court claiming the respondent is impotent.
Separate the issues. First provided adequate medical proof that you are potent, then show to the court by the behavior that marriage has been consummated. Inform the court that you enjoyed blissful conjugal relationship and she was very enthusiastic in bed, and in fact participated in all the normal s*xual activities.
Actual approach to the medical tests. You need to be very careful about how to get the tests done. The tests are divided into three parts - Now after the trial starts, get her evidence completed. You will stand in the witness box and finish yours and other corresponding witnesses croxx-examination. After everything is done, file an application in the court summoning the doctors who did the Semen Analysis, Penile Doppler Scan and the doctor who issued the medical certificate.Court Behavior Drop the bomb that you are always willing to undergo any medical tests anywhere recommended by the court, and challenge the girl that is she willing to drop the case if the results come against her. Now imagine what will be her reaction to this uncomfortable question. If she says yes, the judge will come to the conclusion that she is a fraud. If she says no, she will have to prove why for which she will have no answer.
Do mention in your statement of objection that you underwent the medical tests at her instance. However if she makes an allegation that the documents are fake, you can use the doctrine of aprobate reprobate during written submission stage and not earlier.
Tests and Doctors
1. Semen analysis
2. Penile Doppler Scan
3. Visual Examination
The doctors play a very important role in this. Always approach a URO-ANDROLOGIST in the Fertility department. No other doctor will suffice.
I know that it is impossible for a normal man to get an erection in public places (unless you are a pervert ;) ). How to overcome the problem ? The doctor will ask you if you can get a normal erection, or you will be administered a erection inducing drug for the tests. Refuse the drugs, inform the doctor that you are confident of getting a natural erection but need some time and privacy, which will be given by the doctor. Before you go for the tests, go to any pharmacy shop and purchase sildefanil (viagra/penegra) pills. Take one pill 30 minutes prior to the tests. You will get a natural erection. Take along some adult magazine, masturbate in the hospital premises and provide the semen sample.The doctor will make a note in the file that you have a natural erection. Very important that you get it noted down.
For penile doppler test, again refuse the erection inducing drug, take the pill 30 minutes prior to the test and get the scan completed. The key in getting successful test is breathing normally. Do not breathe rapidly, because the blood starts flowing to the heart and brain rather than to the penis. The doctor will think that the blood flow is abnormal and will make a note of it in the chart, which will go against you. Relax, laugh, take along your buddy, crack some dirty jokes, but ensure that you are not stressed out. The report should show that blood flow is normal and hence no damages such as venus leak or damages to the veins.
The final test is visual examination. The doctor will examine your penis in two states, flaccid and aroused. He will ask you to cough and examine for damages to the organ. Again refuse the erection inducing drugs, pop a pill 30 minutes before the test and get it examined.
The medical certificate should mention that all tests were done on the subject, in a naturally aroused state. Ensure that details such as your correct name, dates of tests, age etc are correct in the certificate.
Psychological Problem
The next problem you may encounter is psychological problem. The allegation will be like that you suffer from some fear psychosis or perverseness which prevents you from getting an erection. If that is mentioned in the complaint/petition/notice, approach any government clinic and get in touch with the doctor. In my case, me suffering from psychological issues were brought up during the evidence time, which the judge refused to consider. I do not have any experience in how to overcome such tests successfully.
Doctors Evidence.
Accompany the court officer who will serve the summons to the above mentioned doctors. Find out their daily consultation fees and pay 50 % over that amount to the doctors privately. They hold the key to get the dismissal. Inform them to get all the medical records in original form. Confirm the dates and the procedure to them. Both you and doctor must sing the same tune and speak the same language. Inform them that the questions they face will be with reference to faking the certificates, forging of their signatures, that they have taken bribes, tests were not conducted on you but somebody impersonating you.
After the doctor's testimony, comes the written submission part. Inform the court that these doctors are top-notch specialists in their respective fields, the hospitals are highly reputed, they are neutral witnesses and have no benefit in giving testimony in your favor.
Oh and good luck, do not worry, be confident, cheerful and positive. It is very important for you to be present before the judge at all stages. He will visually examine you to see if you have any physical characteristics why may confirm the falsehood presented in the petition.
Where impotency is the cause of a marriage remaining unconsummated it may be that (a) both the husband and the wife are impotent, (b) the husband alone is impotent, or (e) the wife alone is impotent. Impotency may be relative impotency, that is a person may be incapable of s*xual intercourse with a particular person only though capable of normal s*xual intercourse with another person. The incapability may be either physical or mental. Now let us take the case of a woman who is totally frigid (mental incapability to have s*xual intercourse) and she is so not relatively but absolutely. Certainly this would be a case of impotency. Now such a woman (an "inanimate" woman) will not cease to be impotent if a man forcibly penetrates his penis into her v**gina. The last two cases relied upon by Mr. Rebello are of this type. An "inanimate" man cannot penetrate for s*xual intercourse. A man having s*xual intercourse cannot be said to be "inanimate" or impotent. The fact that he has been "persuaded" or "lured" or "seduced" makes no difference, nor does it make any difference that this was only a single act of copulation. In our case the man has copulated with her, that is penetrated her for s*xual intercourse. Certainly this is no case of impotency. All the best.