DEED OF SETTLEMENT

This deed of settlement is made at Delhi on this ____ of November, 2021

between ________________, hereinafter called as First Party/Husband
___________________, hereinafter called as Second Party/Wife.

Whereas, the parties are husband and wife of each other. The marriage
between the parties was solemnized on 26th November, 2015 according
to Hindu Vedic Rites at ________________ according to Hindu Rites
and ceremonies. The parties, after marriage had been living as husband
and wife at Doha(Qatar), and one female child, ___________ is born to
the parties from this wedlock.

Whereas the differences arose between the parties due to marital

discords and as such there is no-cohabitation between the parties since
December, 2017.

Whereas, due to above differences the first party has filed a petition for
Divorce U/S13 (1)(ia) of the Hindu Marriage Act, and the same is
pending before the Court of _____________PCJ, Family Courts, East,
Karkardooma Courts.

Whereas, the First Party has filed a complaint bearing number CT

52/2021 filed under Section 200 Cr.PC against the Second Party before
Sh ____________, MM, Karkardooma Court, and the same is pending;

Whereas the First Party has filed a guardianship petition pending

before ___________, PCJ, Family Courts, East, Karkardooma Courts
and the same is pending

Whereas the Second Party/wife filed a complaint u/s 12 of the

Protection of Women from Domestic Violence Act, 2005 against the
 First Party which complaint is still pending trial before the court of Ms.
______________, Ld. MM. Mahila Court, East, Karkardooma Courts,
Delhi.

Whereas the Second Party had filed a complaint in CAW Cell against
the First Party and FIR bearing number _________ has been registered
at _______ P.S.

Whereas, in between the parties made various efforts for settlement of

their disputes through the process of mediation, through their common
friends and relatives and through their advocates and a final settlement
is reached between the parties by which settlement the parties agree
with each other on following terms.

(1) That the First Party shall make a payment of Rs. _________. The same
shall be paid in the following maner-

a) At the time of First Motion- _________________ by way of DD

b) At the time of Second Motion- _________________ by way of DD.

(2) That the Second Party undertakes to open Fixed Deposit for
____________ in an account held by second party in the name of Baby
_______________. Second party undertakes and agrees that the entire
amount from the fixed deposit shall be used exclusively towards
____________. The same shall be done within two weeks of receving
the second installment and the same shall be intimated by the Second
Party to the First Party.

(3) That the said amount shall be the full and final settlement amount and
no parties shall have any other future claim in respect of the other party.

(4) That the second party shall hold full custody of ____________.
(5) That it is further agreed between the parties that after receiving/paying
the settled amount, both the parties shall be left with no claims against
each other of any nature and shall be free to live their lives
independently without interference of each other and shall not claim
any movable or immovable properties of husband and his family
members and vice-versa also both the parties and their relatives shall
not file any case/litigation against each other in future pertaining to this
marriage.

(6) That neither of the parties will not file any case/complaint against each
other in future in relation to their marriage.

(7) That after all the conditions are fufilled by both the parties, second
motion shall be filed immediately without waiting for the cooling
period by filing waiver of cooling period application.

(8) That in case either of the parties backs out, before the filing of the
second motion, the other party shall be liable to make a payment of Rs.
5,00,000/- to the other party as a penalty along with the sum that has
been paid till that day by the party at default, and shall hold the right to
continue the respective litigation.

(9) That it is also settled between the parties that they shall not lodge any
police report or file any case against each other in future, after this
settlement is satisfied in respect of the disputes already settled under
this agreement.

(10) That the parties are making this settlement with their free will and
consent and without any force, fraud or undue influence against each
other.
 Now in witness whereof the parties have signed on this Deed at Delhi
on the date, month and year as mentioned above in the presence of the
witnesses.

Witnesses FIRST PARTY

1.

2. SECOND PARTY