IN THE COURT OF JUDICIAL MAGISTRATE 1st CLASS

FAMILY COURT, KKD COURTS, NEW DELHI

Matrimonial Petition No. ___ Of 2019

IN THE MATTER OF:-

SH.__________
S/O_______
R/O_________ PETITIONER

VERSUS

SMT. _______
D/O_________
R/O__________ RESPONDENT

PETITION FOR DIVORCE U/S 13(i)(b) OF HINDU MARRIAGE ACT, 1955

The above-named petitioner most respectfully states as under:

1. That the petitioner was married to the respondent on _______ at___ within the
jurisdiction of this Hon’ble Court and the marriage was performed accordance with the
Hindu rites and ceremonies.
2. That the petitioner and respondent lived together at ____ till ____ and thereafter the
respondent left the matrimonial house and deserted the petitioner and his company
without any reasonable cause. The respondent residing with her parental family at ____
without the consent and against the wish of the petitioner.
3. That on___ the respondent left the house of the petitioner in the absence of the petitioner
and without informing to him, the respondent ran away from the matrimonial home with
her ornament and bearings. On asking whereabouts the respondent, petitioner came to
know that respondent is living in her father’s house and therefore with intent to bring the
respondent back the petitioner visited to her father-in-law’s residence on___ and
requested the respondent to come with him, but she instantly refused to obey the
petitioner and her matrimonial obligations.
4. That the willful neglect of the respondent towards her matrimony and her withdrawal
from her matrimonial house is without any sufficient reason. The respondent intends to
bring cohabitation with the petitioner permanently to an end. The petitioner deserted by
the respondent since last 3 years and she never rejoined the petitioner even after several
efforts to take her back. Thus the marriage is completely broken down and there is no
possibility that the parties can unite again.
 5. That there is no collusion between the parties in filling the petition.
6. That the cause of action accrued to the petitioner against the respondent within the
jurisdiction of this Hon’ble Court on____ when the respondent deserted the petitioner and
thereafter continued day by day.
7. That the valuation of the petition is fixed at Rs. _____ on which a fixed Court-fee Rs.___
has been paid.

PRAYER:

It is therefore, most respectfully prayed that,

1. That a decree for divorce in favor of the petitioner and against the respondent leading to
permanent dissolution of marriage of the parties to this petition, be passed.
2. That the cost of the petition please be awarded to the petitioner.

New Delhi Petitioner

Dated: __/__/2019

Through Counsel
 IN THE COURT OF JUDICIAL MAGISTRATE 1st CLASS
FAMILY COURT, KKD COURTS, NEW DELHI
Matrimonial Petition No. ___ Of 2019

IN THE MATTER OF:-

SH.__________
S/O_______
R/O_________ PETITIONER

VERSUS

SMT. _______
D/O_________
R/O__________ RESPONDENT

AFFIDAVIT

I, Sh. ________, s/o Sh. _________, aged about __ Years, r/o ____, Employed in _____ as
_______, do hereby solemnly affirm and declare on oath as under-

1. I, ____, the petitioner above-named, do hereby state on solemn affirmation that the
contents of this petitioner in paras 1 to 7 are true and correct to the best of my personal
knowledge and I am competent to swear this affidavit.
2. That the accompanying petitioner has been drafted under my instructions and its contents
are true and correct to the best of my knowledge.

DEPONENT

VERIFICATION:

This is verified at New Delhi on ____ day of July, 2019, that the contents of the above affidavit
are true and correct to best of my knowledge and nothing is false nor any material facts has been
concealed there from.

DEPONENT