UNIVERSITY OF PETROLEUM & ENERGY STUDIES

SCHOOL OF LAW

B.A, LL.B. (HONS.) EL

V SEMESTER

ACADEMIC YEAR: 2018-19 SESSION: AUG-DEC., 2018

DIVORCE PETITION

FOR

Civil Drafting

Under the Supervision of: Mrs. Arpi Jain

SUBMITTED BY:

ARUSHI KUMAR (20)

 IN THE COURT OF HON’BLE DISTRICT JUDGE, DELHI.
HMA PETITION No. 95 OF 2013

Deepak Maheshwari son of Shri Rohan Maheshwari resident of 420, Block

C, Indira Nagar, Delhi.
…PETITIONER

VERSUS

Smt. Rashmi Shukla wife of Shri Deepak Maheshwari D/o Rahul Shukla R/o
B-190 Vasant Vihar, Pune.
…..RESPONDENT

PETITION UNDER SECTION 13 OF THE HINDU MARRIAGE ACT,

PETITION FOR DISSOLLUTION OF THE MARRIAGE BY A DECREE
OF DIVORCE

SIR/Madam
The petitioner respectfully submits as under:-
1- That the petitioner was married with the respondent on 6 October, 2010 at
Delhi according to Hindu rites and ceremonies in the presence of friends,
relatives and family members of both the parties. An affidavit to this effect
is enclosed herewith the petition.
2- That the status of the parties before the marriage and at the time of filing
the present petitioner were/are as under
PETITIONER RESPONDENT
Status Residence
i) Before Marriage
Deepak Maheshwari, 420, Block C, Indira Nagar, Delhi.
Smt. Rashmi Shukla, B-190 Vasant Vihar, Pune.
ii) At the Married -do- Married -do-time of filing of this Petition
The petitioner is residing at Block C, Indira Nagar, Delhi and the
respondent is residing at B-190 Vasant Vihar, Pune.
3- That the petitioner is the bank manager and works in the branch of HDFC
bank in Delhi. The petitioner’s family resides in Delhi. The respondent is the
bank manager and works at the branch of SBI in Pune.
4- That after the marriage, the petitioner asked the respondent to move to
Delhi by moving a transfer application. She never accepted the proposal nor
even denied it. The parties had a heated conversation in 2012 through a
telephonic conversation.
5- That after some time, the respondent give the reason of not moving the
transfer application as she was due in her promotion, so if she moved it now
she will not get the promotion. The petitioner found it a genuine reason and
understood it and waited for the time till she get the promotion.
6- That the petitioner went to Pune for giving a surprise visit to his wife. He
found that the promotion was done in 2013 and his wife was in live-in
relationship with a man from last 3 years.
7- That the petitioner asked for the divorce from the respondent but she
denied to give it by claiming that she has ditched the guy with whom she
was in live-in relationship.
8- That the petitioner bears all type of cruelties because the petitioner
wanted to save his married life and do not want to spoil her life. The
petitioner also tried to advise the respondent many times to move back to his
town but the respondent refused to accept the legitimate requests of the
petitioner and the relatives.
9- That the respondent has cheated the petitioner without any reasonable and
justifiable cause and rhyme and hence it has become impossible for the
petitioner to live more in the company of the respondent therefore, the
petitioner is entitled for a decree of divorce on the grounds of cruelties and
cheating.
10- That the parties are Hindus by religion.
11- That the present petition has not been by the petitioner filed in collusion
with the respondent.
12- That no such petition is pending or has been filed or decided by any
court of law on the same subject matter between the same parties.
13- That petitioner has no legal impediments why the relief sought for is not
granted to the petitioner.
14- That the petitioner is still residing at Delhi, the marriage was solemnized
at 6 October, 2010 within the jurisdiction of this hon’ble court therefore, this
hon’ble court has got the jurisdiction to entertain and try the present petition.
15- That a fixed court fee has been paid on the petition.

PRAYER:
It is, therefore, prayed that a decree for Divorce Under section 13 of the
Hindu Marriage Act, 1955 thereby dissolving their marriage of the petitioner
and the respondent on the grounds of cruelty and cheating may kindly be
passed in favor of the petitioner and against the respondent along with costs
of the petition. It is prayed accordingly.

PETITONER.
Through counsel:
Aditi Singh Advocate, District and Sessions Court, Delhi.

VERIFICATON:
Verified that the contents of Paras No.1 to 12 and 14 of the petition are true
to best of my knowledge and Paras No. 13 & 15 of the petition are true to
best of my belief as information received by me through my counsel. Last
Para is the prayer before this hon’ble court.
Verified at ___________ on ___________

PETITONER.