IN THE COURT OF SESSION JUDGE, AMRITSAR

Smt. ___________ w/o Sh. ______________ D/o Sh. _____________-

aged years, r/o ____________________
………………………………………………….Petitioner

Versus

Sh____________s/o Sh. __________ aged ___years,

r/_________________
………………………………………………respondent.

Petition under section 13 of the Hindu Marriage Act, 1955 for

dissolution of marriage of the petitioner and the respondent by
passing decree of divorce on the grounds of cruelty and desertion
being caused by the respondent to the petitioner and also grant of
any other relief to which the petitioner may be found entitled to
under law, equity and justice.
Sir,
The petitioner respectfully submits as under:
1. That marriage of the petitioner with the respondent was
solemnised on ______ at, Amritsar according to Hindu rites and
traditions. Affidavit of the petitioner in this regard duly attested
is filed herewith alongwith petition for the kind perusal of this
Hon’ble Court. After the marriage of the petitioner with the
 respondent both cohabited as husband and wife in the
matrimonial house of the petitioner and out of the wedlock one
male child namely _________was born on 09.11.2005 who is at
present living with respondent.
2. That status and place of residence of the parties to the petition
before and at the time of the marriage is as below:
Husband Wife
a)At the time Hindu unmarried, Hindu unmarried
of marriage Amritsar Amritsar.
b)At the time Hindu married r/o Hindu married
of filing petition Amritsar Amritsar

3. That at the time of the marriage parents of the petitioner had

given huge dowry articles in the shape of gifts to the respondent
and to his family members but the respondent and his family
members were not satisfied from the dowry articles which were
given by the parents of the petitioner to the respondent and his
family members.
4. That since the very solemnization of the marriage, the
respondent has treated the petitioner with utmost mental as well
as physical cruelty. The cruelty caused by the respondent to the
petitioner is of such extreme that the petitioner has got
reasonable apprehension that it is not proper, rather injurious to
live any more along with the respondent as his wife.
Accordingly petitioner is left with no other alternative except to
file the present petition seeking divorce of her marriage from
the respondent by way of filing the present divorce petition.
5. That it is relevant fact to mention over here that the respondent
even at the time of performance of his marriage with petitioner
 was in bad habits as he is habitual drunkard and takes
intoxicants. The respondent did not use to give money to
petitioner for spending, rather he used to ask petitioner to
bring money from her parents. Before the commencement
of the marriage, it was told by the parents of the respondent
that petitioner is earning Rs.10,000/- per month, but
respondent never bothered to pay any of the amount to the
petitioner. Respondent used to ask to petitioner to bring
money from her parents and when petitioner refused to
bring money from her parents, respondent used to beat
petitioner in the presence of his family members.
6. The behaviour of the respondent and his family members
towards petitioner was not so much good and soon after the
marriage, respondent and his family members started taunting to
petitioner by saying that her parents had not given much dowry
articles as they expected a lot and they also told to petitioner
that the articles which had been given by the parents of the
petitioner to them is of inferior quality and are not according to
their status.
7. That respondent demanded from petitioner and her parental
relations to give cash amount of Rs. 1,00,000/- along with one
motor cycle and when petitioner refused to accept this demands
of the respondent, respondent used to beat petitioner. Later on
one more astonishing fact came into knowledge of the
petitioner that respondent is a habitual thief and one
criminal case in the shape of FIR no. 39 of 2007 under
section 379 of Indian Penal code has been registered against
him by the police officials of police station ‘E’ division,
Amritsar and in that case respondent was also arrested by
 police and the above mentioned case is still pending against
him.
8. That on_____________ a male child was born from the
wedlock of the petitioner and the respondent, and when the
parents of the petitioner had came to house of the petitioner to
give gifts to the child and to the respondent and his family
members, the respondent and his family members did not
behave well with the parents of the petitioner. The respondent
and his family members told to petitioner that they expected
that parents of the petitioner will give motor cycle at the time of
birth of child and then respondent and his family members had
asked to petitioner to bring motor cycle and also cash of
Rs.1,00,000/- from her parents and when petitioner told to
respondent that her parents had already given a lot beyond their
status and now they are not in a position to give motor cycle to
respondent and after hearing these words from the mouth of the
petitioner , she was mercilessly beaten by the respondent and
his family members.

9. That it has become a matter of daily routine that the petitioner

was beaten black and blue by the respondent and his family
members for want of aforesaid Rs, 1,00,000/- and motor cycle.
It is also pertinent to mention over here that petitioner was not
provided with basic necessity of life by the respondent even
during the days of her pregnancy and she was often mentally as
well as physically tortured by the respondent and his family
members as family members of the respondent often says to
petitioner that in case she will not bring dowry articles as
demanded by them then she will be turned out of her
 matrimonial house and respondent will re marry with the girl
belonging to a rich family who could bring much dowry
articles.
10. That the parental relation of the petitioner managed to give Rs.
20,000/- to the respondent and they have requested not to
maltreat the petitioner but the respondent and the other parental
relations did not stop committing cruelty to the petitioner and
they constantly demanded a motor cycle and cash from the
petitioner.
11. That the petitioner was also astonished to see that the
respondent was living in the company of various females who
were not related to him. The respondent was having illicit
relationship with many girls and even in the presence of
petitioner, the respondent used to develop physical relationship
with such girls.
12. That ultimately on _-------------, the petitioner was beaten
mercilessly by the respondent and his family members and was
thrown out from the house of the respondent in three wearing
apparels. Respondent and his family members openly demanded
cash amount of Rs. 1,00,000/- and a motor cycle and openly
told in case petitioner wants to live with respondent, she will
have to fulfil the demands. Thereafter the petitioner and her
parental relations had tried to settle and reconcile the matter but
on the account of wrongful demand of motor cycle and cash, no
rehabilitation could be possible. Ultimately the petitioner had
moved an application for the registration of FIR against the
respondent and his other family members investigation of
which is pending at this stage.
13. That the respondent has not stayed with the petitioner w.e.f.
23.08.2007,and respondent had refused to live with the
petitioner by declaring that he has no intention to live with the
petitioner and he is living apart from the with an intention to
permanently breakup marital ties with the petitioner. The
respondent had also told to the petitioner that he has left with
the petitioner with an intention of animus descarndi and now he
will not live with the petitioner so long as her parental relation
will meet his wrongful demands of motor cycle and cash.
14. That respondent is living separately from the petitioner since
23.08.2007 and during the recent period there has not been any
cohabitation between the petitioner and the respondent. The
respondent accordingly has deserted the petitioner without any
reasonable and sufficient cause.
15. That on account of the aforesaid facts and circumstances the
petitioner is left with no other alternative except to file the
present divorce petition against the respondent and the aforesaid
acts of the respondent are sufficient to hold that respondent has
not only deserted the petitioner, rather the respondent has also
committed gravest acts of cruelty upon the petitioner as defined
under section 13 of Hindu Marriage act, 1955.Accordingly, the
present petition is required to be accepted.
16. That the petitioner has not condoned the wrongful acts of the
respondent as complained for.
17. That there is no other ground as to why the relief claimed for be
not granted to her.
18. That the petitioner has filed the present petition as the earliest
possible opportunity and there has not been any unexplained or
 undesirable delay on the part of the petitioner to file the present
petition.
19. That there is no other reason as to why the relief claimed for be
not granted to her.
20. That the petitioner has not file the present petition in collusion
with the respondent.
21. That since the marriage between the parties was performed at
Amritsar, they had lastly lived and cohabited as husband and
wife within the jurisdiction of Amritsar, as such, this Hon`ble
Court has got the jurisdiction to try and entertain the present
petition.
22. That the prescribed court fee of RS. 19.50 has been affixed on
the petition.
23. That the petition has not filed any other such like petition
against the respondent previously nor the relief claimed for has
ever been declined to the petitioner by any other court of
competent jurisdiction.
under the circumstances explained above ,it is humbly
prayed that by way of acceptance of the present prayer of the
petitioner, her marriage with the respondent may kindly be ordered to
dissolved with the immediate effect by granting the decree of divorce
as provided under section 13 of the Hindu Marriage act,1955 on the
grounds of cruelty and desertion in favour of the petitioner and against
the respondent . Complete cost of the present petition be also awarded
to the petitioner.
Any other relief to which the petitioner may be found legally
entitled to under law, equity and justice be also granted in her favour.
 Petitinor

Through councel

XXXX
Advocate

Verification
Verified that the contents of the paras no. 1 to 23 of the petition
above are true and correct to the best of my knowledge and belief and
upon the information received and believed to be correct. Last
unnumbered relates to prayer clause.

petitioner
IN THE COURT OF SESSION JUDGE, AMRITSAR

………………………………………………….Petitioner

Versus
……………………………………respondent.

Petition under section 13 of the Hindu Marriage Act, 1955 for

dissolution of marriage of the petitioner and the respondent by
passing decree of divorce on the grounds of cruelty and desertion
being caused by the respondent to the petitioner and also grant of
any other relief to which the petitioner may be found entitled to
under law, equity and justice.
 AFFIDAVIT
I, ______________________________ do herby solemly declare and
affims as under:-

1. That marriage of the petitioner with the respondent was solemnised

on at according to
Hindu rites and traditions. Affidavit of the petitioner in this regard
duly attested is filed herewith alongwith petition for the kind
perusal of this Hon’ble Court. After the marriage of the petitioner
with the respondent both cohabited as husband and wife in the
matrimonial house of the petitioner and out of the wedlock one
male child namely Danish Rana was born on 09.11.2005 who is at
present living with respondent.
2. That status and place of residence of the parties to the petition
before and at the time of the marriage is as below:
Husband Wife
a)At the time Hindu unmarried, Hindu unmarried
of marriage Amritsar Amritsar.
b)At the time Hindu married r/o Hindu married
of filing petition Amritsar Amritsar
3. That at the time of the marriage parents of the petitioner had given
huge dowry articles in the shape of gifts to the respondent
and to his family members but the respondent and his
family members were not satisfied from the dowry
articles which were given by the parents of the petitioner
to the respondent and his family members.
4. That since the very solemnization of the marriage, the
respondent has treated the petitioner with utmost mental
as well as physical cruelty. The cruelty caused by the
 respondent to the petitioner is of such extreme that the
petitioner has got reasonable apprehension that it is not
proper, rather injurious to live any more along with the
respondent as his wife. Accordingly petitioner is left with
no other alternative except to file the present petition
seeking divorce of her marriage from the respondent by
way of filing the present divorce petition.
5. That it is relevant fact to mention over here that the
respondent even at the time of performance of his
marriage with petitioner was in bad habits as he is
habitual drunkard and takes intoxicants. The respondent
did not use to give money to petitioner for spending,
rather he used to ask petitioner to bring money from her
parents. Before the commencement of the marriage, it
was told by the parents of the respondent that petitioner is
earning Rs.10,000/- per month, but respondent never
bothered to pay any of the amount to the petitioner.
Respondent used to ask to petitioner to bring money from
her parents and when petitioner refused to bring money
from her parents, respondent used to beat petitioner in the
presence of his family members.
6. The behaviour of the respondent and his family members
towards petitioner was not so much good and soon after
the marriage, respondent and his family members started
taunting to petitioner by saying that her parents had not
given much dowry articles as they expected a lot and they
also told to petitioner that the articles which had been
given by the parents of the petitioner to them is of
inferior quality and are not according to their status.
7. That respondent demanded from petitioner and her
parental relations to give cash amount of Rs. 1,00,000/-
along with one motor cycle and when petitioner refused
to accept this demands of the respondent, respondent
used to beat petitioner. Later on one more astonishing
fact came into knowledge of the petitioner that
respondent is a habitual thief and one criminal case in the
shape of FIR no. 39 of 2007 under section 379 of Indian
Penal code has been registered against him by the police
officials of police station ‘E’ division, Amritsar and in
that case respondent was also arrested by police and the
above mentioned case is still pending against him.
8. That on 09.11.2005 a male child was born from the
wedlock of the petitioner and the respondent, and when
the parents of the petitioner had came to house of the
petitioner to give gifts to the child and to the respondent
and his family members, the respondent and his family
members did not behave well with the parents of the
petitioner. The respondent and his family members told
to petitioner that they expected that parents of the
petitioner will give motor cycle at the time of birth of
child and then respondent and his family members had
asked to petitioner to bring motor cycle and also cash of
Rs.1,00,000/- from her parents and when petitioner told
to respondent that her parents had already given a lot
beyond their status and now they are not in a position to
give motor cycle to respondent and after hearing these
words from the mouth of the petitioner , she was
 mercilessly beaten by the respondent and his family
members.
9. That it has become a matter of daily routine that the
petitioner was beaten black and blue by the respondent
and his family members for want of aforesaid Rs,
1,00,000/- and motor cycle. It is also pertinent to
mention over here that petitioner was not provided with
basic necessity of life by the respondent even during the
days of her pregnancy and she was often mentally as well
as physically tortured by the respondent and his family
members as family members of the respondent often says
to petitioner that in case she will not bring dowry articles
as demanded by them then she will be turned out of her
matrimonial house and respondent will re marry with the
girl belonging to a rich family who could bring much
dowry articles.
10. That the parental relation of the petitioner managed to
give Rs. 20,000/- to the respondent and they have
requested not to maltreat the petitioner but the respondent
and the other parental relations did not stop committing
cruelty to the petitioner and they constantly demanded a
motor cycle and cash from the petitioner.
11. That the petitioner was also astonished to see that the
respondent was living in the company of various females
who were not related to him. The respondent was having
illicit relationship with many girls and even in the
presence of petitioner, the respondent used to develop
physical relationship with such girls.
12. That ultimately on 23.08.2007, the petitioner was beaten
mercilessly by the respondent and his family members
and was thrown out from the house of the respondent in
three wearing apparels. Respondent and his family
members openly demanded cash amount of Rs.
1,00,000/- and a motor cycle and openly told in case
petitioner wants to live with respondent, she will have to
fulfil the demands. Thereafter the petitioner and her
parental relations had tried to settle and reconcile the
matter but on the account of wrongful demand of motor
cycle and cash, no rehabilitation could be possible.
Ultimately the petitioner had moved an application for
the registration of FIR against the respondent and his
other family members investigation of which is pending
at this stage.
13. That the respondent has not stayed with the petitioner
w.e.f. 23.08.2007,and respondent had refused to live with
the petitioner by declaring that he has no intention to live
with the petitioner and he is living apart from the with an
intention to permanently breakup marital ties with the
petitioner. The respondent had also told to the petitioner
that he has left with the petitioner with an intention of
animus descarndi and now he will not live with the
petitioner so long as her parental relation will meet his
wrongful demands of motor cycle and cash.
14. That respondent is living separately from the petitioner
since 23.08.2007 and during the recent period there has
not been any cohabitation between the petitioner and the
 respondent. The respondent accordingly has deserted the
petitioner without any reasonable and sufficient cause.
15. That on account of the aforesaid facts and circumstances
the petitioner is left with no other alternative except to
file the present divorce petition against the respondent
and the aforesaid acts of the respondent are sufficient to
hold that respondent has not only deserted the petitioner,
rather the respondent has also committed gravest acts of
cruelty upon the petitioner as defined under section 13 of
Hindu Marriage act, 1955.Accordingly, the present
petition is required to be accepted.
16. That the petitioner has not condoned the wrongful acts of
the respondent as complained for.
17. That there is no other ground as to why the relief claimed
for be not granted to her.
18. That the petitioner has filed the present petition as the
earliest possible opportunity and there has not been any
unexplained or undesirable delay on the part of the
petitioner to file the present petition.
19. That there is no other reason as to why the relief claimed
for be not granted to her.
20. That the petitioner has not file the present petition in
collusion with the respondent.
21. That since the marriage between the parties was
performed at Amritsar, they had lastly lived and
cohabited as husband and wife within the jurisdiction of
Amritsar, as such, this Hon`ble Court has got the
jurisdiction to try and entertain the present petition.
Deponent
Verification
I, the above named deponent, do hereby solemnly declare and affirm
that the contents of the paras no. 1 to 21 of the affidavit above are true
and correct to the best of my knowledge and belief and upon the
information received and believed to be correct.
deponent
IN THE COURT OF SESSION JUDGE, AMRITSAR

Smt.SoniaTalwar Versus Sh. Naresh Rana @ Dimple

(Divorce petition u/s 13 HMA)
AFFIDAVIT
I, Smt. Sonia Talwar w/o Sh. Naresh Rana D/o Sh.Nand lal aged 25
years, r/o H. No. 1445/7, Gali Kotu Mal, chowk phulla wala,Amritsar do
herby solemly declare and affims as under:-

1. That marriage of the petitioner with the respondent was solemnised

on ______ at, Amritsar according to Hindu rites and traditions.
Affidavit of the petitioner in this regard duly attested is filed
herewith alongwith petition for the kind perusal of this Hon’ble
Court. After the marriage of the petitioner with the respondent both
cohabited as husband and wife in the matrimonial house of the
petitioner and out of the wedlock one male child namely
_________was born on 09.11.2005 who is at present living with
respondent.
2. That status and place of residence of the parties to the petition
before and at the time of the marriage is as below:
Husband Wife
 a)At the time Hindu unmarried, Hindu unmarried
of marriage Amritsar Amritsar.
b)At the time Hindu married r/o Hindu married
of filing petition Amritsar Amritsar

3. That at the time of the marriage parents of the petitioner had given
huge dowry articles in the shape of gifts to the respondent and to
his family members but the respondent and his family members
were not satisfied from the dowry articles which were given by the
parents of the petitioner to the respondent and his family members.
4. That since the very solemnization of the marriage, the respondent
has treated the petitioner with utmost mental as well as physical
cruelty. The cruelty caused by the respondent to the petitioner is of
such extreme that the petitioner has got reasonable apprehension
that it is not proper, rather injurious to live any more along with the
respondent as his wife. Accordingly petitioner is left with no other
alternative except to file the present petition seeking divorce of her
marriage from the respondent by way of filing the present divorce
petition.
5. That it is relevant fact to mention over here that the respondent
even at the time of performance of his marriage with petitioner was
in bad habits as he is habitual drunkard and takes intoxicants. The
respondent did not use to give money to petitioner for
spending, rather he used to ask petitioner to bring money from
her parents. Before the commencement of the marriage, it was
told by the parents of the respondent that petitioner is earning
Rs.10,000/- per month, but respondent never bothered to pay
any of the amount to the petitioner. Respondent used to ask to
petitioner to bring money from her parents and when
 petitioner refused to bring money from her parents,
respondent used to beat petitioner in the presence of his family
members.
6. The behaviour of the respondent and his family members towards
petitioner was not so much good and soon after the marriage,
respondent and his family members started taunting to petitioner by
saying that her parents had not given much dowry articles as they
expected a lot and they also told to petitioner that the articles which
had been given by the parents of the petitioner to them is of inferior
quality and are not according to their status.
7. That respondent demanded from petitioner and her parental
relations to give cash amount of Rs. 1,00,000/- along with one
motor cycle and when petitioner refused to accept this demands of
the respondent, respondent used to beat petitioner. Later on one
more astonishing fact came into knowledge of the petitioner
that respondent is a habitual thief and one criminal case in the
shape of FIR no. 39 of 2007 under section 379 of Indian Penal
code has been registered against him by the police officials of
police station ‘E’ division, Amritsar and in that case
respondent was also arrested by police and the above
mentioned case is still pending against him.
8. That on_____________ a male child was born from the wedlock of
the petitioner and the respondent, and when the parents of the
petitioner had came to house of the petitioner to give gifts to the
child and to the respondent and his family members, the respondent
and his family members did not behave well with the parents of the
petitioner. The respondent and his family members told to
petitioner that they expected that parents of the petitioner will give
motor cycle at the time of birth of child and then respondent and
 his family members had asked to petitioner to bring motor cycle
and also cash of Rs.1,00,000/- from her parents and when
petitioner told to respondent that her parents had already given a lot
beyond their status and now they are not in a position to give
motor cycle to respondent and after hearing these words from the
mouth of the petitioner , she was mercilessly beaten by the
respondent and his family members.

9. That it has become a matter of daily routine that the petitioner was
beaten black and blue by the respondent and his family members
for want of aforesaid Rs, 1,00,000/- and motor cycle. It is also
pertinent to mention over here that petitioner was not provided
with basic necessity of life by the respondent even during the days
of her pregnancy and she was often mentally as well as physically
tortured by the respondent and his family members as family
members of the respondent often says to petitioner that in case she
will not bring dowry articles as demanded by them then she will be
turned out of her matrimonial house and respondent will re marry
with the girl belonging to a rich family who could bring much
dowry articles.
10.That the parental relation of the petitioner managed to give Rs.
20,000/- to the respondent and they have requested not to maltreat
the petitioner but the respondent and the other parental relations
did not stop committing cruelty to the petitioner and they
constantly demanded a motor cycle and cash from the petitioner.
11.That the petitioner was also astonished to see that the respondent
was living in the company of various females who were not related
to him. The respondent was having illicit relationship with many
 girls and even in the presence of petitioner, the respondent used to
develop physical relationship with such girls.
12.That ultimately on _-------------, the petitioner was beaten
mercilessly by the respondent and his family members and was
thrown out from the house of the respondent in three wearing
apparels. Respondent and his family members openly demanded
cash amount of Rs. 1,00,000/- and a motor cycle and openly told in
case petitioner wants to live with respondent, she will have to fulfil
the demands. Thereafter the petitioner and her parental relations
had tried to settle and reconcile the matter but on the account of
wrongful demand of motor cycle and cash, no rehabilitation could
be possible. Ultimately the petitioner had moved an application for
the registration of FIR against the respondent and his other family
members investigation of which is pending at this stage.
13. That the respondent has not stayed with the petitioner w.e.f.
23.08.2007,and respondent had refused to live with the petitioner
by declaring that he has no intention to live with the petitioner and
he is living apart from the with an intention to permanently
breakup marital ties with the petitioner. The respondent had also
told to the petitioner that he has left with the petitioner with an
intention of animus descarndi and now he will not live with the
petitioner so long as her parental relation will meet his wrongful
demands of motor cycle and cash.
14.That respondent is living separately from the petitioner since
23.08.2007 and during the recent period there has not been any
cohabitation between the petitioner and the respondent. The
respondent accordingly has deserted the petitioner without any
reasonable and sufficient cause.
 15.That on account of the aforesaid facts and circumstances the
petitioner is left with no other alternative except to file the present
divorce petition against the respondent and the aforesaid acts of the
respondent are sufficient to hold that respondent has not only
deserted the petitioner, rather the respondent has also committed
gravest acts of cruelty upon the petitioner as defined under section
13 of Hindu Marriage act, 1955.Accordingly, the present petition is
required to be accepted.
16.That the petitioner has not condoned the wrongful acts of the
respondent as complained for.
17.That there is no other ground as to why the relief claimed for be
not granted to her.
18.That the petitioner has filed the present petition as the earliest
possible opportunity and there has not been any unexplained or
undesirable delay on the part of the petitioner to file the present
petition.
19.That there is no other reason as to why the relief claimed for be
not granted to her.
20. That the petitioner has not file the present petition in collusion
with the respondent.
21.That since the marriage between the parties was performed at
Amritsar, they had lastly lived and cohabited as husband and wife
within the jurisdiction of Amritsar, as such, this Hon`ble Court has
got the jurisdiction to try and entertain the present petition.

Deponent
Verification
I, the above named deponent, do hereby solemnly declare and affirm
that the contents of the affidavit above are true and correct to the best
of my knowledge and belief and upon the information received and
believed to be correct.

DEPONENT