Divorce Petition

 

CIVIL PROCEDURE CODE DISSOL DIS SOLUTION UTION OF MARRIAGE MARRIAGE

IN THE COURT OF, PRINCIPAL JUDGE, PATIALA PATIALA HOUSE COURT COU RT

 

IN THE MATTER OF:

Smt. SUMAN D/O Shri KISHORI R/O B-!", ROHINI################ ROHINI#####################.........................PETITIONER  #####.........................PETITIONER   

$ERSUS

Shri RAJ S/O Shri SANJA% KUMAR  R/O D-& KAROL BAGH################# BAGH#####################.........#.DEFENDANT ####.........#.DEFENDANT

PETITION UNDER SECTION 13 OF THE HINDU MARRIAGE ACT,1995 FOR DISSOLUTION OF THE MARRIAGE BY A DECREE OF DIVORCE

 The Petitioner Petitioner respectfully respectfully submits submits as under:under:1. That the Petit Petitione ionerr and the Responde Respondent nt were lawful lawfully ly married acco according rding to tradition traditional al Hindu Vedic rites on the 2 nd day of December 2010 at the residence of mt uman at Rohini. Hereto anne!ed and mar"ed E'hi(it )A) is a copy of the marriage certificate of  the said marriage. 2. #fte #fterr the marria marriage ge the petit petitioner ioner an and d the respon respondent dent li$ li$ed ed toget together her as husba husband nd and wife and consummated their marriage at the residence of the respondent and out of the said wedloc" a child was born namely hi$i"a born on 1% &ebruary 201'.

(. That from the $ery beginning of the marriage the beha$ior of the respondent was not

good towa goo toward rdss pe pettitio tione nerr .Th Thee res respo pon nde dent nt is hab abit itu ual of dai ailly dri drin" n"in ing g and gambli gam bling) ng)lot lotter tery y and aft after er dri drin"i n"ing ng the resp respond ondent ent alw always ays use used d to gi$ gi$ee mer mercil ciless ess  beating to the petitioner. The respondent used to spent all his earning on ta"ing li*uor  and gambling. The respondent pressuri+ed the petitioner to bring the amount of Rs. %0,000)- from her parents and when the petitioner refused to bring the amount then the respondent ga$e merciless beating to the petitioner. The parents of the petitioner ga$e the amount of Rs. 20,000)- and Rs. (0,000)- to the respondent on two occasions but the respondent did not meant his ways rather he continuously tortured the petitioner to

 

 bring more money from the parents. The respondent always taunted the petitioner by gi$ing gi$ ing abu abusi$ si$ee and unp unparl arliam iament entari arily ly lan langua guage ge wit withou houtt any cau cause se in abu abusi$ si$ee and unparliamentarily language without any cause in the presence of relati$es and friends. The life of petitioner became li"e a hell due to the respondent is beha$ior.

'. That although the parents of the respondent arranged a $ery decent marriage according

to his fin financ ancial ial cap capaci acity ty and ga$ ga$ee suf suffic ficien ientt dow dowry) ry)st stri ri Dha Dhan n ite items, ms, but yet the respon res ponden dentt was $ery gre greedy edy in nat nature ure from the $er $ery y beg beginn inning ing of mar marria riage. ge. The respondent sold entire /ewelries and ornaments of petitioner on playing lottery and drin"ing. The respondent committed a lot of cruelties with the petitioner and turned out the petitioner, only due to the reason that the petitioner had refused the bring from the  parents. The life of the petitioner has been made li"e hell. The respondent threatened that he will not "eep and maintain the petitioner till his demands are not fulfilled by her   parents.

%. Tha Thatt $ar $ariou iouss Pan Pancha chayat yatss wer weree con con$en $ented ted at the house of the respo responde ndent nt and the

respondent and the parents of the petitioner re*uested the respondent to "eep and maintain the petitioner but the respondent clearly refused to "eep and maintain the  petitioner. The last Panchayat P anchayat was con$ened on 1 st December 201%, in the presence of  respectable relati$es in which hri Parimal s)o. hri Hariom R) achipur gaon,  oida3 and hri 4hagwan ) hri hi$"umar R) ector '1, oida3 were also  present but the respondent did not agree to "eep and maintain the petitioner without obtaining the illegal amount of Rs %0000)- from the parents of the petitioner.

5. That the petitioner bears all type of cruelties because the petitioner wanted to sa$e her 

marriage life and do not want to spoil her life. 6any times the relati$es ad$ised the respondent to get 7off to drin" and to beha$e properly but to no use. The petitioner also tried to ad$ise the respondent many times to change his beha$ior and not to drin" but the respondent refused to accept the legitimate re*uest of the petitioner and relati$es.

8. That the respondent has deserted the petitioner without any reasonable and /ustifiable

cause and rhyme and hence it has become impossible for the petitioner to li$e more in the company of the respondent therefore, the petitioner is entitled for a decree of  di$orce on the grounds of cruelties.

 

9. That the cause of actions to file the present petition accured to the petitioner many

times when the respondent abuses in the filthy language and the petitioner was beaten merci me rcile less ssly ly.. Th Thee caus causee of acti action onss also also accr accrue ued d on % th  :anu :anuar ary y 20 2015 15,, wh when en th thee respondent turned out the petitioner along with her minor daughter. T The he cause of action thereafter arose on each and e$ery date when, the Panchayats were con$ented and it lastly arose on 10th  :anuary 2015, when the respondent clearly refused to "eep and maintain the petitioner, hence this petition.

;. That the parties are Hindus by Religion.

10. That the present petition has not been by the petitioner filed in collusion with the

respondent.

11. That no such petition is pending or has been filed or decided by any court of law on the

same sub/ect matter between the same parties.

12. That the petitioner has no legal impediments why the relief bought for its not granted

to the petitioner.

1(. That the petitioner is still residing at   D-((5,