In the Court of District Judge . …………
Application No . ………………..of ………………..
In
Suit No …………… ………………..of ………………..
Smt. A …………………………………………. Applicant/Petitioner
Vs
Shri B………………………………………………….…… Opposite Party/Respondent
I, Smt. A, aged about ………………..years, wife of Shri …………………………………………………..resident of
………………………………………………………………………………….. do solemnly affirm and state as follows:
1 That I am the petitioner in the above noted petition and as such fully acquainted with the facts deposed to below.
2. That I was married with Shri ……………..………..at ……………….…………..with Hindu rites and thereafter the petitioner went to reside at ………………………..………..being the place of the respondent’s residence.
3. That on the first night of the marriage, the respondent came drunk and started to quarrel with me on the ground that my father has not given sufficient dowry in marriage. I said to him that my father has given dowry as per his financial capability and he cannot give more dowry, and on this, the respondent started abusing me in the most coarse and insulting language and started beating with his fists and cane. I was saved by the relatives present in the house, who came to attend the marriage.
4. That on the next day I came back to my father’s residence.
5. That on ……………………………………….…..the respondent came to my father’s place and requested me to come to his place and he promised that he shall behave properly in future. I accompanied him to his house on ………………………………………………
6. That the respondent behaved properly for three days, and thereafter on the night of ……………………..………………..he came drunk and started to abuse me in the most vulgar and insulting language on the ground that why my father cannot give
Rs …..……………..to him for starting business.
7. That I came to know from the talks between the respondent and his friends that the respondent is engaged in smuggling of gold, drugs, etc., and he remains in the company of the smugglers.
8. That on the night of ……………………..the respondent without provocation, threw a knife at me, thereby inflicting a severe wound in my right hand and kicked off the kettle; in which water for preparation of tea for the respondent’s brothers was being boiled causing severe burns on my left hand.
9. That due to great and continued cruelty practised on me by the respondent, I left his
house on ……………….. and came to the house of my father at
………………..and from and after the said date I am living separately.
10. That I have not submitted any application under section 14 of the Hindu Marriage Act, 1955 to present the petition before the expiry of one year since the date of marriage, before this court or any other court.
11. That there is no living children of the marriage.
12. That the attempts for reconciliation were made by the relatives of both the parties during the months of ………………..but there is no reasonable probability of reconciliation between the parties.
13. That the above circumstances show that my case is one of exceptional hardship to me and in the interest of justice, I should be granted a decree of divorce with the respondent and for that purpose may be allowed to submit application for divorce before the elapse of one year since the date of marriage.
I Smt. A, above named do hereby verify that the contents of paragraphs 1 to 12 are true to my knowledge and the contents of paragraph 14 are based on legal advice, which I believe to be true. Nothing material has been concealed and no part of it is false. So help me God.
Verified at ………………..on this ………………..day of ………………..20 ………………..
Date ……………….. Deponent
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