IN THE COURT OF THE DISTRICT JUDGE (FAMILY COURT), CHANDIGARH

Dr.MANSHER SINGH AGED ABOUT 30 YEARS S/O SH. ASHISH SINGH RESIDING
NEAR AIIMS NEW DELHI.

…………………. Petitioner

VERSUS

SUNIDHI AGED ABOUT 25 YERAS S/O Sh. NARESH RESIDING NEARS JYOTHI
CHOWK, JALANDHAR

…………. RESPONDENT

Petition under Section 13 of Hindu marriage

Act, 1955 ( as amended upto date) for

Dissolution of marriage by decree of divorce

Sir,

The Petitioner respectfully submits as under:-

1. That the Petitioner is a resident of Phagwara was very intelligent and hardworking
person. He belonged to middle class family. He was a junior resident.
2. That he liked Respondent a resident of Jalandhar. She was extremely beautiful but was
just a matriculate. Petitioner married Respondent in 2014 acc to Sikh rities.
3. That being at AIIMS due to heavy patient intake, Petitioner had long working hours. He
occasionally came to meet Respondent and also seldom attended her calls.
4. That in the matrimonial home, there lived a distant cousin of Petitioner named balveer he
was working in a pharma company in phagwara.
5. That Balveer and Respondent became friends and used to spend long hours together once
balveer was back from office.
6. That in the meantime, Petitioner got fellowship from super specialization at Mumbai and
he left for his post-doctoral studies. Respondent insisted on going with him but he
refused to take her stating that his parents were alone at home.
7. That Respondent file petition for restitution of conjugal right in august 2016. The court
allowed the petition. After arranging for reasonable accommodation Petitioner took his
parents and respondent to Mumbai in dec 2016 but respondent kept talking to balveer for
long hours.
8. That after approximately a year sunidhi and Petitioner was blessed with a baby girl. The
child was majorly taken care of by the grandmother.
9. That respondent was not taking good care of the child and was mostly on the phone.
After celebrating his first celebrating, sunidhi along with her baby came back to Punjab
without informing Petitioner and his parent

10. When petitioner called her she did not attend to his call rather sent a sms sharing his bank
details asking him for transferring a sum of 20000 per month for daughter care and
maintenance.

11. That Petitioner leaving his very important assignment came to Jalandhar to get her
maintenance. Heated arguments turned quarrel between the two but no- solution was
worked out.

12. That initially for three month petitioner sent Rs 10000 in Respondent bank account but
thereafter stopped.

13. That in august 2019 when petitioner came to attend a conference in pgi, Chandigarh, he
went to meet Respondent and her daughter. He was very happy to see his daughter who
was almost 1.5 years now.

14. That the child was with the maid who looked very untidy. He tried to mix with the child
but the baby did not.

15. That Petitioner got very upset to see respondent along with balveer in a car as balveer
came to drop her home. He immediately asked for divorce and his child custody to which
respondent bluntly refused.

16. That thereafter petitioner tried to contact the respondent but all in vain as respondent
blocked petitioner from all the contact and social media and clearly instructed petitioner
and his family that not to contact her.

17. That the above said act and conduct the respondent caused great mental cruelty to the
petitioner. The respondent has treated the petitioner with cruelty and the petitioner has
not in any manner condone the cruelty .the marriage between the petitioner and
respondent has been irretrievably broken

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 desertion may kindly be passed in favour of the petitioner and
against the respondent along with costs of the petition. It is prayed accordingly.
 PETITONER.
Through counsel:
__ Advocate, _____________.

VERIFICATON:
Verified that the contents of Para’s No.1 to 12 and 14 of the petition are true to best of my
knowledge and Paras No. 16 & 17 of the petition are true to best of my belief as information
received by me through my counsel.

Verified at Chandigarh

Date:-