IN THE COURT OF THE _____________ JUDGE AT _________

MATRIMONIAL CASE NO. __________ OF 20__

IN THE MATTER OF:

MRS. WI  Mrs Geeta Shankar nee Dubey PETITIONER

VERSUS

MR. HU Mr Viraj Shankar DEFENDANT

PETITION FOR DECREE OF DIVORCE UNDER SECTION 13(1)(ia) OF HINDU MARRIAGE

ACT, 1955

MOST RESPECTFULLY SHOWETH:

 

The Petitioner, above named states as under:

1. That marriage of the Petitioner and the Respondent was solemnized on 15 december 2016 at
Dehradun, Uttrakhand according to Hindu rites and ceremonies. The marriage was registered
with the Registrar of marriages on 18 december 2016 the Sub-Registrar (III) Office at Dehradun,
Uttarakhand. Certified copy of the extract from the concerned register is attached herewith
as Annexure P-1.

2. That the status and place of residence of the Parties to the marriage before the marriage and at
the time of filing this petition is given as under:

i) Place of residence before the Marriage: Dehradun, Uttarakhand

ii) Place of residence at the time of filing the Petition: Dehradun, Uttarakhand
3. That from the the marriage Petitioner has been conceived with pregnancy.

4. That the Petitioner and his wife were living together happily for the first 6 months of their
marriage.  that Mr Vijay Shankar(husband) accused Mrs Geeta Shankar(Petitioner) of having an
extramarital affair. The situation worsened when on 26/Oct/2016 defendant suddenly appeared at
the office of Petitioner in that of drunkenness and thereafter causing a ruckus.

5. That Defendant also threatened petitioner and when one Mr Amit Pathak intervened and tried
to calm him down Defendant resorted to physical assault. As a result of this, the Security tried to
withhold him and eventually, the Police came and arrested the husband of Petitioner. Petitioner
bailed out Defendant.

6. That on 29/Oct/2016, couple thereafter took leave from their respective places of work for 2
weeks and left for Dehradun.

7. That on On 01/Nov/2016 Petitioner after seeking permission from her In-Laws invited her
parents to their home to discuss the matter. 

8. That on 18/Nov/2016, on petitioner’s birthday, Defendant  again consumed a lot of alcohol

and misbehaved with the Petitioner in front of their guests. The party was ended on an abrupt
note. After the party ended there was a lot of argument between the couple and in this condition,
Defendant physically assaulted the Petitioner resulting in minor injuries on her face but a major
injury on her shoulder which dislocated.

9. That Petitioner did not complain regarding this to anyone. Such events of physical assault
eventually began to occur on a daily basis. Defendant forced the Petitioner into leaving her job
and becoming a housewife.

10. tTat Defendant  began to keep a check on the Petitioner was meeting and also installed
various CCTV cameras at their home to see who came to meet the Petitioner in his absence or
when Petitioner left home.

11. That on 10/Dec/2016 in a state of drunkenness, Defendant punched the Petitioner and broke
her nose. She was rushed to the hospital by her neighbours but she refrained from lodging any
police complaint. Unapologetic for his actions Defendant next began to sexually assault the
Petitioner. 

12. That on 25/Dec/2016, Petitioner informed Defendant that she’s pregnant. She expected that
Defendant would be happy and overjoyed but instead, Defendant pulled out a Pistol and
threatened Petitioner and asked her to confess to him that she was involved in an extra-marital
affair and questioned her of the legitimacy of the child.

13. That the Petition is not being presented in collusion with the respondent.

14. That the Petition is being presented without any unnecessary or improper delay on the part of
the Petitioner.

15. That There is no other legal ground as to why the decree prayed for should be not granted in
favour of the Petitioner.

16.That no litigation has taken place between the parties to the Petition earlier.

17. That this Hon'ble Court has jurisdiction to entertain and try this Petition as the marriage was
solemnized at 18 december 2016 the parties last resided together at New Delhi and even
presently the respondent is residing within the Jurisdiction of this Hon'ble Court.

18. That In the facts and circumstances of case mentioned herein above this Hon'ble Court may
graciously be pleased to:
 

PRAYER

That the Petitioner, therefore, prays:

a) for grant of decree of Divorce in favour of Petitioner and against the Respondent; and

b) Any other relief or reliefs which the court may deem proper under the circumstances be also awarded
to the petitioner.

PETITIONER
 THROUGH

______________., Advocate

Place :

Date :

VERIFICATION

I, WI, state on solemn affirmation that whatever contained in paragraphs 1 to Para No 12 of the
Petition is true to my own knowledge and that whatever contained in paragraphs No 13 to Para
No 18 is based on information received and believed to be true to me.

Signed and verified this _______ day of _______ 20 _______ at _______

PETITIONER