DIVORCE PETITION ON GROUND OF CRUELTY FORMAT
(DIVORCE PETITION ON GROUND OF CRUELTY FORMAT)
BEFORE THE PRINCIPAL JUDGE, FAMILY COURTS, RAMGARH
HMA /2024
IN THE MATTER OF
BASANTI … PETITIONER
Versus
VEERU …RESPONDENT
PETITION FOR DISSOLUTION OF MARRIAGE BY A DECREE OF DIVORCE UNDER SECTION 13(1)(i-a) OF THE HINDU MARRIAGE ACT, 1955
MOST HUMBLY SHOWETH
- The Petitioner is filing this petition seeking dissolution of marriage by a decree of divorce, on account of the fact that the Petitioner has been treated with cruelty by the Respondent.
- That the status, age and place of residence of the parties at the time of solemnization of the marriage and at the time of filing of this petition were/as follows:
| Wife (Petitioner) | Husband (Respondent) | |||||
| Status | Age | Place of Residence | Status | Age | Place of Residence | |
| At the time of Marriage | Single/Hindu | Single/Hindu | ||||
| At the time of filing petition | Married /Hind | Married/Hindu | ||||
3. That there is no issue out of the wedlock.That Petitioner is resident of Ramgarh and drives a horse cart to earn her living. The Respondent has approached her for marriage. The Respondent has represented that he works in a factory and is capable of taking care of her.
4. That relying on the representation of the Petitioner, the Respondent agreed to marry with the Petitioner. The marriage of the Petitioner with the Respondent was solemnised according to Hindu rites and ceremonies.
5. That after the marriage the Petitioner was shocked to know that Respondent does not work anywhere but rather a thief and also a drunkard.
6. The Respondent comes back every evening drunk and beats the Petitioner. In fact on xxxxxxx the Respondent hit the Petitioner with a stick causing a fractured bone in hurt. She has to visit hospital and her hand was bandaged. Because of this She could not drive horse cart for around a month. The Copy of the Medical Report is attached herewith and marked as Annexure A.
7. The Respondent also filed a police complaint on the basis of which and FIR has been lodged with the police station, Ramgarh. Copy of FIR is attached herewith and marked as Annexure B.
8 That whatever earning the Petitioner make out of driving horsecart is snatched by the Respondent forcefully.
9. That on xxxxxxxx_the Petitioner has gone to visit her Maushi. When she returned back she came to know that her horse has been sold by the Respondent to get some money so that the Respondent could buy wine. After taking help of police, she could recover the Horse.
10. That it has become dangerous for mental as well as physical well being to live with the Respondent, as such the Petitioner was constrained to leave the matrimonial house.
11. That the Petitioner has not condoned the acts of cruelty of the Petitioner.
12. That this Petition has not been filed with collusion with the Respondent.
13. That this Hon’ble Court has jurisdiction to entertain this Petition as the Petitioner resides within the jurisdiction of this Court. Marriage has also been solemnised within the jurisdiction of this court.
14. That the Petitioner has paid the requisite court fee of _______rupees.
PRAYER
In light of the above, it is respectfully prayed that this Hon’ble court may graciously be pleased to:
1.Dissolve the marriage of the parties by a decree of divorce;
2. Pass any order and other such orders as this Hon’ble Court may deem fit and proper in the interest of justice.
PETITIONER
THROUGH
Xxxxxx
ADVCOATE
VERIFICATION
I, the above named Petitioner, state on solmen affirmation that the contents of paragraphs __ to ___ of the above petition are true and correct to the best of my knowledge and belief. Further, the legal submissions made in para ____ are believed to be true by me on information and legal advice received. Last Paragraph is a prayer clause to this Hon’ble Court. Verified at Ramgarh on this __ day of August, 2024.
________________________________________________
Note: Petition has be accompanies by Index, Memo of Parties and Affidavit.
PETITIONER
