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PETITION FOR DIVORCE

By: R. Sachin Raj


IN THE COURT OF THE ADDITIONAL PRINCIPAL JUDGE FAMILY COURT
CHENNAI

H.M.O.P. __________ OF 2020

IN THE MATTER OF:

MRS.TAMIZHSELVI (Age: 25,


Occupation: Home maker, Address: 3/19 5th Avenue west 7th
main road Dhandeeswarm, Velachery, Chennai 600042.) ………………………..PETITIONER

VERSUS

MR.SARATHKUMAR( Age: 30. Occupation: Software Engineer, Address: NO. 28


Pattukottai Alagiri Street, Thanthai Periyar nagar,Mylapore, Chennai 60000…....RESPONDENT

PETITION FILED UNDER SECTION 13(1)(ia) OF HINDU MARRIAGE ACT, 1955

1. The marriage between the parties was solemnized on 21st January 2019 at Parthasarathy temple Chennai, by
Hindu rites and ceremonies.

2. The petitioner is from an orthodox Hindu family and is traditional in nature. In the initial days of
matrimonial life the respondent acted as loveable and caring husband. The petitioner was a house wife and was
dependant for money on her Husband. The parties were blessed with a female child on 28 December 2020. The
sexual life of the petitioner started to become saddening after the birth of the child. His attitude changed day by
day where the petitioner was ill treated
in many ways.
3. The Petitioner’s life with the respondent has been one of misery and cruelty. The Respondent, husband was
forcing her for sexual intercourse. His treatment with her was one of brutality. Even when she was suffering
from fever, respondent would not give her any respite with repeated acts of sex. The respondent had behaved
brutally in the sexual life and he used to wake up the petitioner during mid night and had violent sex with her
and when the petitioner refused or expressed her tiredness, the respondent kicked and assaulted the petitioner.
4. The Respondent even compelled her to have alcohol and he always criticized and scolded her as being
orthodox. She was forced to wear short and vulgar dress which she disliked. Thereafter, the respondent
was finding some or the other fault in the petitioner and also criticized her appearance. This criticism
was done every day.

5. Harassment and tortures were increasing day by day and the petitioner was waiting with confidence
that the respondent will realize his mistakes and correct himself, but the respondent had taken
advantage of her goodness

6. On 5th August 2020 the husband of the Petitioner has expelled the Petitioner and the child from the
house after merciless beatings, when petitioner forcefully dissented to have sex with him. The petitioner
and child was left aloof and then went to her parental home on the same day with mental agony and
distress.

7. So far, several attempts to reunite were in fact made by Petitioner’s relatives to change the attitude of
the Respondent and all turned futile because of the rude and adamant attitude of the respondent.
Anyway, the Petitioner is not interested in continuing the matrimonial life anymore since the respondent
had caused cruelty in her sexual life. Such cruelty has cause an apprehension in the mind of the Petitioner
that it will be harmful and injurious for the Petitioner and the child to continue to live with the
respondent.

8. The Petition is being presented without any unnecessary or improper delay on the part of the
Petitioner. No litigation has taken place between the parties prior to this Petition. The Petitioner
reiterates that she had not filed any Petition for Divorce in any other court of Law.

9. This Hon'ble Court has jurisdiction to entertain and try this Petition as the marriage was solemnized at
Mylapore, Chennai and the parties last resided together at Mylapore and even presently the respondent is
residing within the Jurisdiction of this Hon'ble Court.
PRAYER:

It is most respectfully prayed that,

a) The court grants decree of Divorce thereby dissolving the marriage dated 21st January 2019 between
the Petitioner and Respondent;
b) Any other relief or reliefs which the court may deem proper under the circumstances be also
awarded to the petitioner.

(SIGNAURE OF TAMIZHSELVI)

VERIFICATION

The Petitioner herein do hereby declare that the facts stated above are true to the best of my
knowledge, belief and information.

R SACHIN RAJ
ADVOCATE
5.09.2020

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