IN THE COURT OF HON’BLE FAMILY JUDGE MUMBAI, AT

MUMBAI
P. A. No. /2021
Mr. JAY
Age:- 50 Years, Occupation:- Business,
R/At. Dadar, Mumbai -400070,
…Petitioner

V/S

Mrs. JUHI
Age:- 45 Years, Occupation:- Business ,
R/At. Dadar, Mumbai -400070

…Respondent

Petition for Divorce on the Ground of Desertion u/s 13 [1] [i-b]

of Hindu Marriage Act, 1955
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The Petitioner most respectfully submits as under:

1. The Petitioner state and submits that the petitioner and the
Respondent were married under the provisions of Hindu Marriage
Act 1955. On Wednesday 15.01.1994, the marriage was solemnized
between petitioner and respondent at 12.10 p.m., at Dadar, Mumbai
according to Hindu religion, vaidic rites and ceremonies. Two
children were born the said wedlock to respondent and petitioner –
a son in 1995 and a daughter in 1997.

2. The petitioner state that after marriage the petitioner and

respondent started residing in Kurla, Mumbai where they rented a
2 BHK apartment.

3. Petitioner state that he owned a grocery store, whereas

respondent was unemployed. After six years of marriage, that is, in
the year 2000 respondent wished to start the business of paying
guest hostel. As respondent was unemployed, she could not avail
loan in her name. So respondent asked petitioner to finance her
business setup. To finance respondent’s business petitioner sold his
grocery store. Petitioner got Rs. 40 lac after selling his grocery shop.
Petitioner state that all the money he got after selling his shop was
invested in respondent’s business.

4. The Petitioner state that respondent successfully set up

business by using petitioner’s money. Within 2 years, business
started and flourishing and respondent started earning good profit
from it.
5. The petitioner state that one day after a small argument
respondent threw out petitioner from house. Respondent did not
even allowed to take belongings of petitioner. Also respondent
humiliated petitioner by using abusive language.

6. The petitioner state and submits that after being thrown out
of the house he attempted to start new business with whatever
saving he was left with, but eventually his business failed and he
came under huge debt.

7. The petitioner further state that the respondent is living lavish

lifestyle from the profit earned through her business which was
financed by petitioner and respondent is solely responsible for
petitioner’s bad financial situation.
It is humbly prayed for a Decree as under:
a. That the marriage solemnized On Wednesday 15.01.1994, at
Dadar, Mumbai be dissolved, by Decree of Divorce.

b. The respondent used petitioner’s money and for business and

later disowned the petitioner. Considering petitioner’s
financial condition permanent maintenance be granted u/s 25
of Hindu Marriage Act, 1955

c. Leave be granted to amend the Petition, if so required.

d. Any other just and equitable orders be passed in the interest

of justice, for which the Petitioner shall ever remain duty
bound to pray.
Filed On:- 5.10.2021
At Mumbai
Mr. Jay
Petitioner

VERIFICATION
I, Mr. Jay, Age:- 50 Years, Occupation:- Business, R/At. Dadar,
Mumbai - 400070 the Petitioner herein, do state and verify, that whatever
stated in Para 1 to 7 above is true and correct, the best of my knowledge, belief
and information, which I believe to be true and correct. Thus so stated and verified
on this 5th day of October 2021 at Mumbai.

Mr. Jay
Petitioner