IN THE COURT CIVIL JUDGE ( S. D.

) KALYAN AT KALYAN

H. M. PETITION NO. 0F 2021

Mr. Ninad Pramod Joshi

Aged : Occupation : Service
________________________________
_________________________________
Petitioner No.1

AND
Mrs. Shirin Anant Jadhav
102, Indira Palace, Plot no 157
Kansai Section, Nr Gaondevi Mandir,
Ambernath East – 421501

Petitioner No.2

PETITION FOR DISSOLUTION OF MARRIAGE BY MUTUAL CONSENT

BETWEEN THE PETITIONERS UNDER SECTION 13(B) OF HINDU
MARRIAGE ACT, 1955

MAY IT PLEASE YOUR HONOUR :-

The Petitioners above named submit as under:-

1. The Petitioner No.1 is Hindu by religion and the Petitioner No.2 is also Hindu by religion
and therefore both are governed by the provisions of Hindu Marriage Act, 1955. The
Petitioner No.1 and No.2, both are domicile of State of Maharashtra.

2. The Petitioner No.1, then a Bachelor got married to the Petitioner No.2 then a Spinster,
daughter of Mr. _Anant Jadhav, having maiden name as Miss Shirin Anant Jadhav. The
said marriage was love marriage as both the petitioners were working in same company.
Initially they became friends and later on their friendship blossomed into love. Later on even
by opposition of family members both petitioners performed confidential registered marriage
on 7 th Dec 2019. Photocopy of Marriage certificate is annexed hereto and marked as Exhibit
“A”.

3. The Petitioners state that after their marriage they were residing apart

From each other with their respective parents. They further state that there was no physical
relationship between them as they were waiting for their marriage to be solemnized as per
Hindu rituals.

4. The Petitioner no 1 state that after the death of his father in 2018, the marriage proposal
was accepted by both the families. They met on 1 st march 2020 at the residence of petitioner
no 1 and decided to solemnize marriage as per Hindu rituals. The truth of registered marriage
was concealed by both the petitioners. From 2020 to 2021 due to Corona Pandemic both the
petitioners were staying apart in their own home. Since both were staying apart they were in
touch with each other through messages. During this they realized that there was mismatch
between both families and their views. The Petitioners are now convinced that it is
impossible for them to continue their relationship. Both the Petitioners who are educated have
now come to a conclusion that divorce between the parties is the only solution and it is in the
interest of both the parties as well, therefore, both the parties have now agreed to seek a
decree of divorce by mutual consent.

5. The Petitioners state that in the aforesaid circumstances both the parties have realized that
it would be in their interest to amicably settle their matrimonial disputes by taking divorce by
mutual consent. Marriage is not at all consummated. Both the parties have stayed apart since
their registered marriage. Neither they had any physical relation before and after registered
marriage. Hence the Petitioners have filed the present joint petition for dissolution of their
marriage for decree of divorce by mutual consent under the provisions of section 13 - B of
the Hindu Marriage Act, 1955 and pray for the same

6. The Petitioners state that they have no claims of whatsoever nature against each other. It is
further agreed between the Petitioners that the said Consent Terms shall form part of the
Consent Decree of Divorce. Annexed hereto and marked at Exhibit “B” is the copy of the
original consent terms agreed by and between the Petitioners.
7. The Petitioners have enclosed herewith pre-signed Xerox copy of Adhar card of both the
Petitioners, the same are annexed hereto and marked as Exhibit “C”

8. The Petitioners state that they have been residing separately since 7 th December 2019 after
their registered marriage and hence the mandatory period of separation of one year
immediately preceding the filing of the present petition is complied with.

9. The Petitioners state that there is no connivance or collusion between the parties.

10. The Petitioner No.1 and 2 have stayed separately at their parents’ home since their
registered marriage which are in Ambernath (E) District: Thane, for petitioner no 2 and
Dombivli for petitioner no 1 respectively, within the jurisdiction of this Hon’ble Court and
therefore this Hon’ble Court has jurisdiction to try and entertain this Petition.

11. The Petitioners state that there are no other proceedings filed or pending between the
parties with regard to the matrimonial dispute in this Hon’ble Court or in any other court in
India.

12. The Petitioners state that they have affixed the required court fees stamp to the present
petition of Rs. 100/-

13. The Petitioners state that they have annexed Memorandum of their Addresses to the
present Petition.

14. The Petitioners state they will rely upon the documents a list whereof is annexed hereto.

15. In view of what is stated hereinabove the Petitioners most respectfully pray that

(a) This Hon’ble Court be pleased to dissolve the marriage solemnized between the
Petitioners on 7 th December 2019 by decree of divorce as envisaged under section 13-B of
Hindu Marriage Act 1955,

(b) The consent terms be made part of the decree,

(c) Such other and further reliefs as the circumstance of the case may require be granted.

Filed in the court on this _____ day of __________ at _________

Mr Ninad Pramod Joshi Miss Shirin Anant Jadhav

Petitioner No. 1 Petitioner No.2

Advocate for the Petitioner No.1 Advocate for the Petitioner No.2

VERIFICATION

We, Mr Ninad Pramod Joshi , aged __ years, the Petitioner No.1 and Miss Shirin
Anant Jadhav age ____years above named residing at __________________
( petitioner no 1) and flat no 102, Indira Palace, Plot no 157 Kansai Section, Nr
Gaondevi Mandir, Ambernath East – 421501 (petitioner no 2) Thane do hereby state
and declare that what is stated in the foregoing paragraphs of the Petition is true
and correct to the best of our knowledge and information and we believe the
same to be true.

Stated and declared at Kalyan

on this ______ day of December, 2023)

Mr Ninad Pramod Joshi Ms Shirin Anant Jadhav

Petitioner No. 1 Petitioner No. 2

Identified by me

Advocate for the Petitioner No. 1