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DISTRICT- PURBA MEDINIPUR.

IN THE COURT OF LD. ADDITIONAL DISTRICT & SESSION JUDGE 1st Court AT
CONTAI
Matrimonial Suit No- ………………/2020
In the matter of:
An application of divorce under section 25(i) of Special Marriage Act,1954.
-and-
In the Matter of :-
Priyanka Sahoo,
aged about 21 years,
W/o.- Sri Abhijit Pradhan,
Of Vill.-Medinipur,P.O-Paya Medinipur, P.S.-
Digha , Dist.- Purba Medinipur, Pin-721428 ,
By religions-Hindu, By occupation-Household
work, By Nationality-Indian,
Presently residing at-C/O & D/O-Sri Suresh
Sahoo, Vill. & P.O-Jashateghari,P.S.-Ramnagar ,
Dist.- Purba Medinipur, Pin-721446
Mob No.9979222554.
…………………………….. Petitioner.

-AND-
Sri Abhijit Pradhan, aged about 28 years.
Of Vill.-Medinipur, P.O-Paya Medinipur, P.S.-
Digha , Dist.- Purba Medinipur, Pin-721428 ,By
religions-Hindu,
By occupation-Business, By Nationality-Indian,
….……………………..Respondent.

The humble petition of the petitioner above named most

respectfully sheweth:-
1. That both the parties of the suit are Hindu and they are living in the
aforesaid address within the territorial jurisdiction of the Ld. Court.
2. That the petitioner and respondent are known to each other for a
pretty long period and due to such long standing intimacy love
affairs between the parties were developed and as such
consequence both of them agreed to marry each other.
3. That the petitioner informed such fact of having love affairs with
the respondent to her parents and the respondent also informed
such fact of having love affairs with the petitioner to his parents.
4. That after having consultation with each other both the parties gave
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notice as required under the Special Marriage Act, 1954 on

06/09/2020 and on that date it was settled that both of them would
appear before the marriage Officer on 13/09/2020 for
solemnization of their marriage before the Marriage Officer.
5. That on 13/09/2020 both the petitioner and respondent presented
themselves voluntarily before the Marriage Officer ,Namely- Sunil
Kumar Mali, office address Vill-Ramnagar, Contai,
Midnapore(Purba), West Bengal, India, Pin-721441 and ultimately
our marriage solemnized before the said Marriage Officer on
13/09/2020 corresponding to ....... day of ..... 1427 B.S., and a
certificate of marriage was issued bearing certificate no-
WB34500204020500102544-2020-109448 dated 13/09/2020 in
favour of your petitioner and the respondent.
That after completion of the formalities of such solemnization of
marriage under the Special Marriage Act, 1954 the petitioner asked
the respondent to take her to her matrimonial home on the self
same date which the respondent disagreed due to unknown reason.
However ,the respondent assured that the petitioner would be taken
to his house within 15 days for consummation of their marriage and
for living as husband and wife.
6. That after the registration of marriage the respondent make ruthless
behavior with your petitioner and the respondent became
arrogant,shameless. That the respondent didnot talk with your
petitioner properly and your petitioner made a request to meet with
the petitioner. After several request of your petitioner the
respondent agreed to meet with your petitioner. That on
10/11/2020 your petitioner met the respondent on the ramnagar
bus stand and asked him to take the petitioner to his house for
residing together as husband and wife . At this the respondent told
that he is not agreeable to accept the marriage and he is not at all
inclined to accept your petitioner as his married wife.
7. That your petitioner relied upon the respondent with the hope of
leading conjugal life with the respondent. But all of her hopes of
residing with the respondent as husband and wife ended at that
time When the respondent on 10th day of November 2020 informed
your petitioner that he is unable to bring your petitioner to his
house for consummation of their marriage and he is also not
inclined to consummate such marriage solemnized before the
Marriage Officer on 13/09/2020 . At the same time , the respondent
being disagreed to consummate the said marriage proposed for
annulment of their marriage solemnized under the Special Marriage
Act ,1954 on 13/09/2020 on the ground of non-consumption of
their marriage , and also owing to his willful refusal to effect such
consummation of marriage with the petitioner by the respondent
after taking her to his house.
8. That , finding no other alternative , your petitioner informed the
aforesaid matter to all the members of her house . They are being
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dissatisfied with the conduct of the respondent agreed to effect

annulment of marriage solemnized in between the petitioner and
the respondent under the Special Marriage Act , 1954 . In order to
avoid all future complications and to maintain the prestige and
dignity of her family.
9. That , in fact there was no consummation of marriage in between
the petitioner and the respondent till date and due to refusal to
effect such consummation of marriage by the respondent , the
marriage solemnized under this Act required to be annulled by a
decree of nullity under the Special marriage Act, 1954.
10. That it is also submitted that any marriage solemnized under this
Act shall be annulled by a decree of nullity if the marriage has not
consummated owing to the willful refusal of the respondent to
consummate the marriage and, it is further submitted that the
respondent has willfully refused to consummate the marriage on
13th day of September 2020 , when the cause of action for this suit
arose.
11. That there is no collusion and/or connivance in between the
petitioner and the respondent in presenting the instant application.
12. That there were no previous proceedings with regard to the
marriage in question by or on behalf of any party .
13. That this ld. Court has jurisdiction to entertain this application as
both the parties have been residing within the territorial
jurisdiction of the Ld. Court.
14. That the cause of action for this suit arose on 13/09/2020 and also
on 10/11/2020 when the respondent refused to effect
consummation of marriage with your petitioner on account of their
marriage solemnized on 13/09/2020 under the Special Marriage
Act,1954.
15. That ad-valorem court fees of Rs.-100/ is paid herewith.
16. That other grounds would be argued at the time of hearing before
the Ld. Court.
Under the above circumstance your Honour may
graciously be pleased to annul the marriage
solemnized on 13/09/2020 corresponding to... day
of .......1426 B.S. ( Vide certificate no-
WB34500204020500102544-2020-109448, dated
13/09/2020) under the Special Marriage Act, 1954
by a decree of nullity under section 25(i) of the
Special Marriage Act, 1954 and to pass an order for
annulment of the said marriage having no effect
from the date of such decree and pass as such other
order / orders as your Honour deems fit and proper.
And For which Act of kindness, your petitioner as
in duty bound, shall ever pray.

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DISTRICT- PURBA MEDINIPUR.

IN THE COURT OF ADDITIONAL DISTRICT & SESSION
JUDGE 1st Court AT Contai.

Mat Suit No- /2020

Priyanka Sahoo, ………………………….Petitioner.

-VS-
Sri Abhijit Pradhan,………………Respondent.
Affidavit on behalf of the Petitioner
I, Priyanka Sahoo,
aged about 21 years,
W/o.- Sri Abhijit Pradhan,
Of Vill.-Medinipur,P.O-Paya Medinipur, P.S.-
Digha , Dist.- Purba Medinipur, Pin-721428 ,By
religions-Hindu, By occupation-Household work,
By Nationality-Indian,
Presently residing at-C/O & D/O-Sri Suresh
Sahoo, Vill. & P.O-Jashateghari,P.S.-Ramnagar ,
Dist.- Purba Medinipur, Pin-721446, do hereby
solemnly affirm and declare as follows:-
1. That I am the petitioner of this Mat Suit and I am well conversant
about the facts and circumstances of this case. It is true to the best of
my knowledge and belief.
2. That the Statements made in the foregoing paragraphs 1 to 16 of the
petition of U/S 25(i) of Special Marriage Act.,1954 are true to the
best of my knowledge and belief. It is true to the best of my
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knowledge and belief.

3. That I am swearing this Affidavit in support of my Statements made
in the said application U/S 25(i) of Special Marriage Act.,1954 It is
true to the best of my knowledge and belief.
Verification
Statements made above are True to
the best of my knowledge and belief.
Prepared in my office

Advocate, Deponent
Date:
Known to me and Identified by me .

Advocate,
Date:

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