BEFORE THE HONOURABLE FAMILY COURT

THIRUVANANTHAPURAM

OP(HMA) NO----------2021

BETWEEN
AJITHA VS PETITIONER

AND
VIMAL KUMAR TS RESONDENT

PETITON FOR DIVORCE

(Filed under section 13(10 (1a) (1b) of the Hindu marriage Act of 1955 and section 7 (1) explanation
(a0 and 5(c) of the Family courts Act 1984 r/w Rule 3 of the family Courts (Kerala) Rules 1989)

NAME AND ADDRESS OF PETITIONER

Ajitha VS, aged 32 Years,

D/o Sadahsivan, Deepa Bhavan, MP Appan Road
Vazhutahcadu, Thiruvanthapuram

All notices and processes in the name of the petitioner may be served upon her counsel, Renjith R
Nair, LA Court Centre, Vanchiyoor, Thiruvananthapuram.

Name and Address OF RESPONDENT

Vimal Kumar TS, aged 40 years

S/o Thankappan, Shivkripa, Giri nagar
Poojappura, Trivandrum

All notices and processes in the name of the respondent may be served on the above address

The petitioner most humbly begs to submit as:-

1. The petitioner is legally wedded wife of the respondent. Their marriage was solemnised as
per the custom prevailing in the Hindu Nair community at Attukal Devi temple on 22/11/2012.

2. The marital life of the petitioner was not at all smooth and harmonious from the very
inception. The petitioner was ousted from the matrimonial house by the mother-in law immediately
after she became pregnant. The entire matrimonial house her mother-in –law and her husband
meted out cruelty to the petitioner by manhandling her on almost all days.

3. The respondent took her to her house at vazhutahcadu when she became pregnant and
thereafter he did not take care of the petitioner. He did not even spend any amount to meet the
delivery expenses of the petitioner.
4. Even after birth of the child neither the respondent nor his mother took care of the
petitioner and the child.

5. On persistent compulsion, the petitioner and the child were taken to Poojappura and they
started living together in a separate rented house.

6. The respondent squandered way the entire salary amount on alcoholic drinks and in a
drunken stage he very often manhandled the petitioner and the child. The respondent demanded
more amount as dowry and manhandled the petitioner on that account also.

7. Unable to resist the intolerable mental and physical torture and, the petitioner was
constrained to intimate her mother and brother to take her back to her house so as to save the
petitioner and the child with an intention to put an end to the matrimonial life forever(5/10/2015).

8. Thus the respondent is guilty of committing cruelty and desertion and it is impossible for
the petitioner and the child to live with the respondent as it is risky for the life of the petitioner and
the child. So the only alternative remedy open to the petitioner is to file this O. P for divorce.

9. There is no collusion between the petitioner and the respondent in filing this application.

10. The cause of action for this petition has arisen on 22/11/2012, the date on which the
marriage was solemnised and on 510/2015, the date on which the respondent deserted the
petitioner and the respondent last resided together which is within the jurisdiction of this
honourable Court. Hence this Court has jurisdiction to entertain this petition.

RELIEFS

1. A Decree dissolving the marriage between the petitioner and the respondent solemnised on
22/01/2012.

2. To pass all orders to the petitioner as it deem necessary.

COURT FEES AND PETITION VALUATION

The petition is valued for Rs 50/- under Schedule II Article 2(ii) of Kerala Court Fee and suit valuation
Act and said amount is paid herewith.

Sd/- Sd/-
Advocate Petitioner
What are all stated above are true and correct to the best of my knowledge information and belief.

Dated this the first day of February 2021

Sd/
Petitioner
List of documents
Photocopy of marriage Certificate
Photo copy of birth certificate of the child
BEFORE THE HONOURABLE FAMILY COURT

THIRUVANANTHAPURAM

OP(HMA) NO----------2021

BETWEEN
AJITHA VS PETITIONER

AND
VIMAL KUMAR TS RESONDENT

AFFIDAVIT

I, Ajiha VS, D/o Sadasivam,aged 32 years, residing at Deepa Bhavan, MPAppan Road,
vazhutahcadu, Thiruvanthapuram do hereby solemnly affirm and sate as follows:-

1. I am the petitioner in the above Original petition and I am well acquainted with the facts of
the case.

2. The petition is for a decree of divorce

3. I have produced all documents to prove my case. I have not suppressed any material facts.

4. There is no collusion between me and the respondent in filing this petition

5. I have verified this petition and declare that I am conversant with the facts stated therein
and they are true and correct to the best of my knowledge, information and belief.

Dated this the 1st day of February 2021

SD/-

Deponent

Solemnly affirmed and signed before me by the deponent who is personally known to me in my
office at Vanchiyoor, Trivandrum

SD/-

Advocate