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BEFORE THE COURT OF PRINCIPAL FAMILY JUDGE

AT BANGALORE

M.C. NO.________/2024
BETWEEN:
1. Sri K Satish
s/o Kaviayamani,
Aged about 33 years,
#39/64,2nd cross,
Gangappa layout, shakthi Nagar,
Bangalore North , Doorvaani Nagar,
Bangalore 560 016. PETITIONER 1

2. Smt S Devika
w/o Sri K Satish,
Aged about 30 years,
No 54, 5th cross,
Tirumanglanagar,
Vinayakapuram, Chennai,
TamilNadu600011 PETITIONER II

AND
NIL RESPONDENTs

MEMORANDUM OF PETITION UNDER SECTION 13(B) OF


HINDU MARRIAGE ACT 1955

The petitioners above named submit as follows:-

1. That the addresses of the Petitioner for the purposes of court


notices, summons etc. is as shown in the cause title and that of
his counsel Sree Vasavi Associates Deepak Kumar BV, Advocates
No 21/1, Legal Minds 2nd Cross, Subbannachari Lane, Cottonpet,
Bangalore 560 053.
2. The petitioners herein above are presenting this Joint petition for
the dissolution of their marriage solemnised in between them on
27/05/2018. The petitioners submits that they are Hindu by
religion, Their marriage was solemnized in accordance with the
Hindu customs and traditions prevailing in both the families and
the marriage was solemnized on 27/05/2018 at SRR
kalyanamantapam, OMBR layout, 5th main, B Chennasandra
main road, Banaswadi, Bangalore – 560 043 Marriage invitation,
Marriage photographs and Aadhar card of petitioners is marked
as Annexure A,B,C.

3. The petitioners submits that after their marriage they started


their marital life as husband and wife, #39/64,2ndcross,
Gangappa, layout,, shakthi Nagar, Bangalore North , Doorvaani
Nagar, Bangalore 560 016.

4. It is submitted there is no compatibility or understanding


between the petitioners in matrimonial life from the day one of
the marriage. There is no consummation and cohabitation
between the petitioners till today.

5. It is submitted That since 09/06/2018, the petitioners could not


live together under a common roof that both the petitioners are
living separately, that due to the misunderstandings and there
being no compatibility, the chances of petitioners leading
together future matrimonial life is very remote.

6. It is further submitted that there is no issue born to both the


petitioners.

7. The marriage between the petitioners is a broken marriage and


has reached the stage beyond understanding and there is no
positive chances of living together as husband and wife.

8. That all the efforts of reconciliation between the parties to


continue the present marriage has failed and there are no further
chances of reconciliation between the parties any more. In fact
petitioner no 1 had to seek police help against the petitioner No 2
has he is alcoholic and use to abuse the petitioner No 1
physically and mentally, police authorities however advised him
to take care of the petitioner no 1 and sent them back yet there
was no change and efforts of reconciliation between the parties
to continue the present marriage has failed.

TERMS AND CONDITIONS:

9. Without admitting the allegations made by the both the parties


herein, the marriage solemnized between them on 27/05/2018 shall
be dissolved on consent of both the petitioners.

10. It is further submitted that the petitioner I is paying Rs 10,00,000/-


(Ten Lakhs only )by way of DD towards her permanent alimony.

11. It is agreed that both the petitioners shall not file any other Civil,
Criminal (or) maintenance cases against each other (or) their family
members.
12. Both the petitioners shall lead their individual lives according to
their wish and fancies and hereinafter there shall not be interference
in each others family life.

13. Both the petitioners shall not claim any rights over the properties of
the other and at the same time.

14. That both the petitioners have agreed to file joint petition
for the dissolution of their marriage without any undue
influence, coercion, force or any expectation.

15. That out of marriage between the petitioners there is no issues


as there was no cohabitation, there is no collusion between the
petitioners in filing this joint petition.
16. It is submitted that in the presence of the well wishers, friends
and relatives both the petitioners have agreed to obtain mutual
divorce petition without claiming any future maintenance.

17. That both the petitioners are unable to live in a common roof
as husband and wife. Under these circumstances, both the
petitioners have come to conclusion to file this mutual divorce
petition.

18. It is further submitted that both the petitioners hereby agree


that exchange of any articles, gold ornaments, Silver, Clothes,
and other utensils at the time of mediation at court . The second
party will not claim maintenance in future and there will be no
liabilities between the parties.

19. The petitioners are residing at the address shown in the cause
title and this Hon’ble court has got territorial jurisdiction to try
the joint petition at Bangalore.
20. The cause of action arose for the petition arose on
27/05/2018 when both parties got married at SRR Kalyana
mantapam Bangalore and when both the petitioners have
separated from each other on 9/0/2018 and residing separately
and subsequently on all dates, within the jurisdiction of this
Hon’ble Court.

21. The petitioners have not filed any other petition on the same
cause of action before this Hon’ble Court or any other court other
than filing of this joint petition.

22. For the purpose of Court fee payable on this petition as per
Schedule-II, Article-I of the Karnataka Court Fee and Suit
Valuation Act is paid on this petition a sum of Rs.100/- which is
also jurisdiction of this Hon’ble Court being the fixed court fee.
WHEREFORE, the petitioners respectfully pray that this
Hon’ble Court may be pleased to pass a Judgment and Decree: -

i) For granting a decree of divorce by dissolving the marriage of


the petitioners solemnized on 27/08/2018 and when they
started living separately since 9/06/ 2018 and pray to grant a
Decree of Divorce for separation.

ii) Pass such other order or orders as this Hon’ble court may be
deems fit to grant in the facts & circumstances of the case, in
the interest of justice & equity.

1.

2.

ADVOCATEFOR PETITIONERS PETITIONERS

VERIFICATION

I, Sri K Satish and Devika S the petitioners 1 & 2 respectively


in the above case, do hereby state and verify that what are all
stated above are all true and correct to the best of our
knowledge, belief and information.

1.

2.

Bangalore PETITIONERS
Date:

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