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Date 01 whIch made over

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Date of taking over to Court.
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In the noon to anlwar the claIm and you are

dlr0cted to 'pVOdllce 00 that day all the docum'mts upon which you Intend
\0 (illy In support of your defelice,
TaKIl notIce \hat In def6Yu1t of your appearnce on the d3Y before
menUoned the sult wHl be heard and ,detormlned in your ObStmc9.
Given under my hand the seal of court this' IS-._S·,)')·d.ay of 200
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Judge
Sncnstadar
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Civil Proceeding No 139 12012

In the matter of:

A petition VIS 13 (1) (ia) and fib) of the Hindu Marriage Act 1955
for dissolution of marriage ..

AND

In the matter of:

Deepalisa Sahu aged about 28 years

WIO Rakesh Kumar Sahoo
DIO Rabindra Kumar Sahu, Plot No.331,
Radhakrushnanagar (Garage Chhak)
Old Town, P.O- Bhubaneswar-Zo l Ouz
P.S.-Lingaraj Police Station,Bhubaneswar,Dist- Khurda

Petitioner

-Vrs.

Rakesh Kumar Sahoo Aged about 36 years

S/O Babaji Charan Sahoo, Plot No-818/2502,
Bank Colony,Gobindeswar Lane; Old Town,
P.O.- Bhubaneswar-75 1002
P.S.- Lingaraj Police Station.Bhubaneswar.Dist- Khurda

....................... , Opposite Party

The humble petition of the

above named petitioner

Most Respectfully Sheweth:-

l.That The petitioner and the opposite party are govern by Hindu Marriage Act 1955.The
marriage of the petitioner and opposite.party was solemnized as per the Hindu rites and
customs on 27-01-2006 at Ashish Kalyan Mandap,Samantarapur, Bhubaneswar in
presence of the parcnts.wellwishers and relations of both the family.

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2. That as per the demand of dowry ~~~Ofihe o~posite party, the parents of
the petitioner paid ready cash of Rs.2, 50,OOO/-(TWQ Jaklls-fifty thousand) only in shape of
cheques of state Bank of India,Bapujinagar Branch as well as two pairs of gold
neckless,four pairs of ear rings, one pair of chain ear ring,19 numbers of finger rings, two
pairs of bangles, one pair of Chud to the bride and one gold bracelet and one gold chain to
the bride groom and all the above gold ornament would be more than 20 tolas which would
be around Rs. 3 lakhs Besides the parents of the petitioner had given all the wooden
articles like double bed cot, sofa set,almirah and other house hold properties and brass,
silver and steel utensil as per the demand of the opposite parties.

3. That after the marriage both the petitioner and opposite party went to the house of
opposite party situated in Govindeswar Lane of old Town,Bhubaneswar to lead a happy
conjugal life.

4. That after a fortnight of the marriage the opposite party and his parents could know that
the petitioner had incurred a study loan of Rs. 3 lakhs (three lakhs) for the B.Tech
I' Engineering studies and knowing non-payment of the huge outstanding dues of the loan
I amount against the petitioner, the opposite, party and his parents showed unsympathetic
attitude, ill-treated the petitioner in-petty matters and created anguish, disappointment and
1I frustration .Due to indecent behavior of the opposite party and his parents the petitioner
felt humiliated. The opposite party also started illegitimate demand of further dowry after
the marriage and when it was not fulfilled deprived conjugal rites to the petitioner and the
1 opposite party strained all his relation with the petitioner and did not shared the bed with
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the petitioner.

5. That the petitioner is a graduute Engineer, very simple, polite, compromising in nature
and born from a reputed cultured family. She adjusted all the mental and physical torture
made to her with hope of reconciling the matter with the opposite party but the opposite
party did not care for her goodness and simplicity, deprived her conjugal right with the
opposite party and created animosity with her as a result of which the petitioner left the
matrimonial home on dated 07-03-2008 to save her life.

6. That the petitioner tried her best to reconcile the matter with the opposite party and went
to Bangalore, the work place of the opposite party on 25-03-2008 to meet the opposite
party with a view to pacify and resolve the differences but the opposite party seeing her
became furious without any reason, took away her original passport forcibly and left for
U.S.A. on 13-04-2008 neither taking the petitioner with him nor giving any information
regarding his leaving for U.S.A.

7. That the petitioner finding no other alternative again went to the matrimonial home to
pacify / reconcile the attitude of the opposite party and their parents but the opposite party
and his parents tortured her physically by assaulting her in petty mistakes, did not allowed
her a squire meal a day and required medicirleSdulfng her illness and was left to the mercy
of the opposite party and his parents as an unwanted penon in the matrimonial home..

8. That when the conjugal relations in between the petitioner and opposite party went
beyond any reconciliation, the parents of the petitioner arranged a meeting of both the
family and relations on 21-09-2008 in Hotel Jana path.Bhubaneswar and at Lingaraj
Temple premises Bhubaneswar on 25-01-2009 and the petitioner again went to the
matrimonial home on 16-02-2009 to reconcile the attitude of the opposite party and his
parents but all were in vain as the opposite party and his parents again demanded further
dowry with threat of dire consequences of physical and mental torture
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9. That physical and mental lo~ towards th.rn,lftition~r again continued in the
matrimonial home which became ~~earapl§ ~ pwtione!. Further the opposite party
denied any conjugal right to the pet}; ioner although the petitioner tried her best to pacify
the dowry demand with humbleness-a the opposite ..partyand his parents did not care for
the well being of the petitioner an:ti!P . ~j'~all her gold ornaments and personal
belonging. The petitioner became help1ess '0 ~'fue physical and mental torture of the
opposite party and his parents. More over the opposite party denied bluntly, her due
conjugal right.

10. That the parents and relations of the petitioner tried their best to settle up the dowry
issue amicably and called a reconciliation meeting on 10-3-2010 to settle up the matter
with a view to create good conjugal relationship between the petitioner and the opposite
party but the parents and relations of the opposite party misbehaved the petitioner in the
reconciliation meeting and by that time the opposite party and his parents had already
drove the petitioner out from their house on 28-03-2009 and inspite of repeated apology
they refused to take her back her to their.house. Now the opposite party is serving at
Infosis, Bhubaneswar as an Engineer and the petitioner is unemployed as she left her job
on the demand of the opposite party and now depends upon her parents for her
maintenance since 28-3-2009.

II.That the cause of action arose within the territorial jurisdiction of this Hori'ble court
and as the petitioner is a lady is exempted from payment of Court fees.

12. That the petitioner seeks the following reliefs-

(a) Decree of divorce may be.passed in favour of the petitioner dissolving the marriage
-Of the petitioner and opposite party held on 27-1-2008 as there is no hope of re- -
union.

(b) Permanent alimony/maintenance of Rs.25 lakhs (Rupees Twenty Five lakhs) be

given to the petitioner as well as return of the dowry amount, gold ornarnents and
other house hold properties which would be cost around Rs.7.S lakhs (Rupees Seven
Lakhs and Fifty thousand) as there is no place of the petitioner in the house of the
opposite party who already has deserted her since 28-3-2009.

(c) An amount ofRs.25, OOO/-(twenty five tbousand) as the cost of the proceeding and
litigation expenses.

(d) Any other relief/relieves which the Hon'ble court may think deem and proper

PRAYER

The petitioner, therefore prays that this court may graciously be pleased to pass ail.
order for dissolution of the marriage of the petitioner solemnized with the opposite party
on 27-1-2008 and pass a decree of divorce in favour of the petitioner against the opposite
party and permanent alimony/maintenance of Rs.25 Lakhs(Rupees Twenty five lakhs) to
the petitioner and to return the dowry money, gold ornaments as well as the house hold
,I properties amounting to Rs.7.S lakhs ( Rupees seven lakhs and fifty thousand) to the
petitioner along with cost of the proceeding ands litigation expenses ofRs.25,OOOI-(Rupees
Twenty five thousand) and any other order/orders as the court may think deem and proper
,1 and for this act of kindness the petitioner as duty bound shall ever pray.

Bhubaneswar
Dated 17-4-20121
fi1n;o;,
By thlt Petitioner through
Advocate
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I, Deepalisa Sahu,ageu about 28 years W/O Rakesh Kumar Sahoo, D/O Rabindra Kumar
Sahu,resident of Radhakrushnanagar,Plot No.331 ,Garage Chhaka,Old Town,Bhuaneswar-
751002,P.S.-Lingaraj P.S.,Bhubaneswar,Dist- Khurda do hereby verify that the facts stated
above are true to the best of my knowledge and belief and I have not suppressed any
material facts.

Bhubaneswar
Verificant
Dated 17-4-2012

Affidavit

I, Deepalisa Sahu aged about 28 years w/o Rakesh Kumar Sahoo/O Rabindra Kumar Sahu,
resident of Radhakrushnanagar ,PIot.N 0331 ,GarageChaka, OldTown,Bhubaneswar,P.S.-
Lingaraj P .S.,Bhubaneswar-7 51002,Dist-Khurda,do hereby solemnly affinn and state as
follows>

i) that I am the petitioner in this petition.

ii) That the fact stated in this petition is true to the best of my knowledge and belief.

Identified

Deponent
Advocate