Petition For Divorce Uis 13 (I) (B) of HMA, 1955

 

IN THE COURT OF JUDICIAL MAGISTRATE 1st CLASS FAMILY COURT, KKD COURTS, NEW DELHI Matrimoniall Petition No. ___ Of 2019 Matrimonia

IN THE MATTER OF:SH.__________ S/O_______  R/O_________

PETITIONER  VERSUS

SMT. _______  D/O_________  R/O__________

RESPONDENT

PETITION FOR DIVORCE U/S 13(i)(b) OF HINDU MARRIAGE ACT, 1955

The above-named petitioner most respectfully states as under: 1. That That the the pe peti titi tion oner er was was marr marrie ied d to the the re resp spon onde dent nt on __ ____ ____ ___ _ at at__ ___ _ wi with thin in th thee  jurisdiction of this Hon’ble Court and the marriage was performed accordance with the Hindu rites and ceremonies. 2. That That the petit petition ioner er and respond respondent ent lived lived together together at ____ till ____ and thereaft thereafter er the respond res pondent ent left left the matrim matrimoni onial al house house and desert deserted ed the petiti petitioner oner and his company company without witho ut any reasonable reasonable cause. The respondent respondent residing residing with her parental parental family at ____  without the consent and against the wish of the petitioner. 3. That on___ the the respondent respondent left left the house of the the petitioner petitioner in the the absence of the the petitioner  petitioner  and without informing to him, the respondent ran away from the matrimonial home with her ornament and bearings. On asking whereabouts the respondent, petitioner came to know that respondent is living in her father’s house and therefore with intent to bring the respond res pondent ent back back the petiti petitioner oner visite visited d to her fat father her-in -in-l -law’ aw’ss reside residence nce on___ on___ and reques req uested ted the responden respondentt to come come with with him, him, but she instan instantl tly y refuse refused d to obey the  petitioner and her matrimonial obligations. 4. That That the willfu willfull neglec neglectt of the respond respondent ent toward towardss her matrimon matrimony y and her withdra withdrawal wal from her matrimonia matrimoniall house is without without any sufficien sufficientt reason. reason. The respondent intends to  bring cohabitation with the petitioner permanently to an end. The petitioner deserted de serted by the respondent since last 3 years and she never rejoined the petitioner even after several efforts to take her back. Thus the marriage is completely broken down and there is no  possibility that the parties can unite again.

 

5. That there there is no collusion collusion between between the the parties parties in filli filling ng the petitio petition. n. 6. That That the the ca caus usee of ac acti tion on ac accr crue ued d to the the pe peti titi tione onerr again against st the re resp spon onden dentt wi with thin in th thee  jurisdiction of this Hon’ble Court on____ when the respondent deserted the petitioner and thereafter continued day by day. 7. That the valuatio valuation n of the petition petition is fixed fixed at Rs. Rs. _____ on which which a fixed Court-fe Court-feee Rs.___  has been paid.

PRAYER: It is therefore, most respectfully prayed that, 1. That a decree decree for divorc divorcee in favor of of the petitio petitioner ner and against against the the respondent respondent leading leading to  permanent dissolution of marriage of the parties to this petition, petition, be passed. 2. That the the cost of of the petiti petition on plea please se be awarded awarded to the the petitione petitioner. r.

 New Delhi Dated: __/__/2019

Petitioner 

Through Counsel

 

IN THE COURT OF JUDICIAL MAGISTRATE 1st CLASS FAMILY COURT, KKD COURTS, NEW DELHI Matrimoniall Petition No. ___ Of 2019 Matrimonia

IN THE MATTER OF:SH.__________ S/O_______  R/O_________

PETITIONER  VERSUS

SMT. _______  D/O_________  R/O__________

RESPONDENT

AFFIDAVIT I, Sh. ________, s/o Sh. _________, aged about __ Years, r/o ____, Employed in _____ as  _______, do hereby solemnly affirm and declare on oath as under1. I, ____, ____, the the pe peti titi tione onerr ab abov ovee-na name med, d, do hereb hereby y st stat atee on so sole lemn mn af affi firm rmat atio ion n th that at th thee contents of this petitioner in paras 1 to 7 are true and correct to the best of my personal knowledge and I am competent to swear this affidavit. 2. That the accompanyi accompanying ng petitioner petitioner has been drafted drafted under under my instructio instructions ns and its contents contents are true and correct to the best of my knowledge.

DEPONENT VERIFICATION:

This is verified at New Delhi on ____ day of July, 2019, that the contents of the above affidavit are true and correct to best of my knowledge and nothing is false nor any material facts has been concealed there from.

DEPONENT