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IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO.F-902 OF 2019

Snehal Manoj More @ )


SnehalShamraoSawant )
aged 29 years, Occ.: - Service )
Residing at G-1, KokanKinara Building No.9, )
Near Ganesh Mandir ,Kokan Nagar , )
Jogeshwari (East ),Mumbai-400060, )
Contact No. 9769991993 )
Email.:- snehalshamal@gmail.com ) …Petitioner No. 1

And

Manoj Manohar More )


aged 38 years, Occ.: - Service )
Residing at Room No. 66, E Wing , )
NandadeepCHS., Municipal Colony, )
GovandiDeonar, Mumbai-400043. )
Contact no. 9821628587 )
Email:- __________________ ) …Petitioner No. 2

CLAIM AFFIDAVIT OF
PETITIONER NO. 1

----------------------------------------

I,Snehal Manoj More @ SnehalShamraoSawantaged 29 years, Occupation:- Service,


Residing at G-1, KokanKinara Building No.9, Near Ganesh Mandir ,Kokan Nagar
Jogeshwari (East), Mumbai-400060, the Petitioner no. 1 above named, do hereby
on solemn declared as under:-

MOST RESPECTFULLY SHEWETH:

1. I state that I am Hindu by religion, Indian inhabitant, citizens of India and


domiciled in state of Maharashtra and residing at address mentioned in the
title herein above. I do not belonging to Schedule Tribe as per section 2 (2)
of Hindu Marriage Act.
2. I say that I got married to Petitioner no. 2 on 27/06/2012 and the marriage
was solemnized at SantGhadgeMaharaj Hall , Jari Mari Temple , Near
Bandra Lake, S.V. Road, Bandra (West) Mumbai-400051 Maharashtra. The
wedding took place according to hindu rites and by following the prevailing
customary rituals in the presence of the near relatives and well wishers.

3. I say that prior to the marriage I was spinster and my maiden name was Ms.
SnehalShamraoSawant and Petitioner no. 2 was bachelor.

4. I say that on the date of marriage, I was 22 years and Petitioner No. 2 was 31
years old, thus we both had attained majority and were of marriageable age
as prescribed under the law.

5. Isay that the marriage between me and petitioner no.2was a valid marriage
under The Hindu Marriage Act 1955 and none of us had any spouse living at
the time of the marriage and the relationship of mine and Petitioner no. 2
also do not fall within the prohibited degrees.

6. Isay that, after marriage we were last residing as a husband and wife at
Room No. 66, E Wing ,Nandadeep CHS., Municipal Colony,
GovandiDeonar, Mumbai-400 043, Maharashtraand thus this is treated as
our matrimonial home.

7. Isay that out of the said wedlock we do not have any child.

8. I say that, we were leading a normal married life, however for the last 4
years our views &opinions differ on many trivial issues concerning their life
style and behaviour. Our temperament, likes and nature totally mismatch
and we could not arrive on any mutual decision relating to our daily family
issues.

9. Isay that now the relationship between us has come to such a stage that it is
not at all possible to live as husband and wife any more. We both have tried
to reconcile our differences by seeking the intervention of the family
members, friends and elderly relatives, but in vain and the efforts made by
us proved futile.

10. Isay that we both have decided to live separately in different homes and
from 15/07/2014 were living separate till date. I say thatwe do not have any
physical or mental relationship between us and thus never treated ourselves
in relationship of husband & wife.
11. I say that I have exchanged all our jewellery, goods, articles and other
exchangeable items with each other on final hearing of the present petition
and after that no party has any kind of claim over any other item or
property, as per the consent terms herein.

12. Iconfirm and declare that presently there is no joint property both movable
and immovable, investment or any other asset. However if any found in
future than Iwill co-operate Petitioner no. 2 in deletion of name, separation or
distribution of the same mutually and peacefully.

13. I confirm and declare that presently there is no joint debt / loan / liability or
due of whatsoever nature in whatsoever manner. However if any found in
future than I shall bear / pay such debt / loan / liability/ dues and keep
harmless and free the Petitioner no.2.

14. I hereby agree, confirm and declare that I will never claim any kind of legal
right on Petitioner no.2’sproperty both movable and immovable, bank
account, investment or any other asset, which was hold or acquired in his
individual name before, during, after marriage and now after mutual
divorce herein, in future.

15. I agree and declare that I shall not file any complaint or adopt any Civil
and/or Criminal proceedings against Petitioner no.2 regarding any act done
by him during the existence of marriage, separation and in future after
mutual divorce herein. Further I agree, confirm and declare that if there is
any complaint or Civil / Criminal case pending in any of the Court of Law
in India or out of India, then the same now stands withdrawn
unconditionally and voluntarily against each other after mutual divorce
herein. Also we should not adopt any malpractices to defame each other or
our families and in no circumstances use any such documents or material
acquired during the existence of marriage & after mutual divorce herein.

16. I agree and confirm that I will not use the name and surname of Petitioner
No. 2 after mutual divorce herein, for any purpose in future. I agree and
confirm herein that petitioner no. 2 is free to re-marry and I will not create
any obstacle in Petitioner no. 2 ’s re-marriage.

17. I say that I will never hold Petitioner no. 2 responsible or liable for any
maintenance or alimony in future forever.

18. I state that there has been irretrievable break down of marriage and the
same has become totally dead and beyond any hope of salvage.
19. I state that in view of the above circumstances, I have now mutually agreed
that there is no point for the continuance of the marital relationship between
us and we have decided to settle the matter amicably by seeking legal means
by filing a Mutual Consent Petition under the provision of section 13-B of
the Hindu Marriage Act, 1955, by which the we are governed.

20. I have mutually agreed upon certain terms and conditions more specifically
set out in the consent terms.

21. I state that it is desirable and necessary under the facts and circumstances of
the present case, that the marriage should be dissolved in the mutual
interest of us.

22. I state that the mutual consent to the present affidavit has not been obtained
by any force, fraud or under influence.

23. I submits that there is no other case pending before any court of law for
dissolution of marriage between both the Petitioners.

24. I submits that there is no collusion and connivance between us, while filing
this affidavit.

25. I state that I have read and understood the contents of this claim affidavit
and the same are as per my instructions only.

Place : - Bandra, Mumbai.

Dated this _____ day of _________ , 2019

[Vikrant C. Deshpande] [Snehal Manoj More @ SnehalShamraoSawant]


Advocate for Petitioner No. 1 & 2 Petitioner No.
1
VERIFICATION

I, Snehal Manoj More @ SnehalShamraoSawantthe Petitioner no. 1 do hereby


solemnly affirm and state that whatever stated hereinabove is true and correct to
the best of my knowledge and I believe the same to be true.

Solemnly affirmed at Mumbai )

Dated this _____ day of _________, 2019 )

Identified by me

[Vikrant C. Deshpande] [Snehal Manoj More @ SnehalShamraoSawant]


Advocate for Petitioner No. 1 & 2 Petitioner No.
1

IN THE FAMILY COURT MUMBAI AT, BANDRA


M. J. PETITION NO. F-902 OF 2019

Snehal Manoj More @ )


SnehalShamraoSawant )
aged 29 years, Occ.: - Service )
Residing at G-1, KokanKinara Building No.9, )
Near Ganesh Mandir ,Kokan Nagar , )
Jogeshwari (East ),Mumbai-400060, )
Contact No. 9769991993 )
Email.:- Snehalshamal@gmail.com ) …Petitioner No. 1

And

Manoj Manohar More )


aged 38 years, Occ.: - Service )
Residing at Room No. 66, E Wing , )
NandadeepCHS., Municipal Colony, )
GovandiDeonar, Mumbai-400043. )
Contact no. 9821628587 )
Email:- __________________ ) …Petitioner No. 2

CLAIM AFFIDAVIT OF
PETITIONER NO. 2

________________________________

I, Manoj Manohar More aged 38years, Occupation:- Service, Residing at, Room
No. 66, E Wing , Nandadeep CHS., Municipal Colony, GovandiDeonar, Mumbai-
400043.the Petitioner no. 2 above named, do hereby on solemn declared as under:-

MOST RESPECTFULLY SHEWETH:

1. I state that I am Hindu by religion, Indian inhabitant, citizens of India and


domiciled in state of Maharashtra and residing at address mentioned in the title
herein above. I do not belonging to Schedule Tribe as per section 2 (2) of
Hindu Marriage Act.

2. I say that I got married to Petitioner no. 1 on 27/06/2012 and the


marriage was solemnized at SantGhadgeMaharaj Hall , Jari Mari
Temple , Near Bandra Lake, S.V. Road, Bandra (West) Mumbai-400051
Maharashtra. The wedding took place according to hindu rites and by
following the prevailing customary rituals in the presence of the near
relatives and well wishers.

3. I say that prior to the marriage Petitioner no. 1 was spinster and her
maiden name was Ms. SnehalShamraoSawant and I was bachelor.
4. I say that on the date of marriage, I was 31 years and Petitioner No. 1 was
22 years old, thus we both had attained majority and were of
marriageable age as prescribed under the law.

5. I say that the marriage between me and petitioner no. 1was a valid
marriage under The Hindu Marriage Act 1955 and none of us had any
spouse living at the time of the marriage and the relationship of mine
and Petitioner no. 1 also do not fall within the prohibited degrees.

6. I say that, after marriage we were last residing at Room No. 66, E
Wing ,Nandadeep CHS., Municipal Colony, GovandiDeonar, Mumbai-
400 043, Maharashtra and thus this is treated as our matrimonial home.

7. I say that out of the said wedlock we do not have any child.

8. I say that, we were leading a normal married life, however for the last 4
years our views & opinions differ on many trivial issues concerning their
life style and behaviour. Our temperament, likes and nature totally
mismatch and we could not arrive on any mutual decision relating to our
daily family issues.

9. I say that now the relationship between us has come to such a stage that
it is not at all possible to live as husband and wife any more. We both
have tried to reconcile our differences by seeking the intervention of the
family members, friends and elderly relatives, but in vain and the efforts
made by us proved futile.

10. I say that we both have decided to live separately in different homes and
from 15/07/2014 were living separate till date. I say that we do not have
any physical or mental relationship between us and thus never treated
ourselves in relationship of husband & wife.

11. I say that I have exchanged all our jewellery, goods, articles and other
exchangeable items with each other on final hearing of the present
petition and after that no party has any kind of claim over any other item
or property, as per the consent terms herein.

12. I confirm and declare that presently there is no joint property both
movable and immovable, investment or any other asset. However if any
found in future than I will co-operate Petitioner no. 1 in deletion of name,
separation or distribution of the same mutually and peacefully.
13. I confirm and declare that presently there is no joint debt / loan /
liability or due of whatsoever nature in whatsoever manner. However if
any found in future than I shall bear / pay such debt / loan / liability/
dues and keep harmless and free the Petitioner no. 1.

14. I hereby agree, confirm and declare that I will never claim any kind of
legal right on Petitioner no. 1’s property both movable and immovable,
bank account, investment or any other asset, which was hold or acquired
in his individual name before, during, after marriage and now after
mutual divorce herein, in future.

15. I agree and declare that I will not file any complaint or adopt any Civil
and/or Criminal proceedings against Petitioner no. 1 regarding any act
done by him during the existence of marriage, separation and in future
after mutual divorce herein. Further I agree, confirm and declare that if
there is any complaint or Civil / Criminal case pending in any of the
Court of Law in India or out of India, then the same now stands
withdrawn unconditionally and voluntarily against each other after
mutual divorce herein. Also they should not adopt any malpractices to
defame each other or our families and in no circumstances use any such
documents or material acquired during the existence of marriage & after
mutual divorce herein.

16. I agree and confirm that Petitioner no. 1 will not use the name and
surname of mine after mutual divorce herein, for any purpose in future. I
agree and confirm herein that petitioner no. 1 is free to re-marry and I
will not create any obstacle in Petitioner no. 1 ’s re-marriage.

17. I say that Petitioner No. 1 will never hold me responsible or liable for any
maintenance or alimony in future forever.

18. I state that there has been irretrievable break down of marriage and the
same has become totally dead and beyond any hope of salvage.

19. I state that in view of the above circumstances, I have now mutually
agreed that there is no point for the continuance of the marital
relationship between us and we have decided to settle the matter
amicably by seeking legal means by filing a Mutual Consent Petition
under the provision of section 13-B of the Hindu Marriage Act, 1955, by
which the we are governed.
20. I have mutually agreed upon certain terms and conditions more
specifically set out in the consent terms.

21. I state that it is desirable and necessary under the facts and circumstances
of the present case, that the marriage should be dissolved in the mutual
interest of us.

22. I state that the mutual consent to the present affidavit has not been
obtained by any force, fraud or under influence.

23. I submits that there is no other case pending before any court of law for
dissolution of marriage between both the Petitioners.

24. I say that there is no collusion and connivance between us, while filing
this affidavit.

25. I say that I have read and understood the contents of this affidavit and
the same are as per my instructions only.

Place : - Bandra, Mumbai.

Dated this _____ day of _________ , 2019

[Vikrant C. Deshpande] [Manoj Manohar More]


Advocate for Petitioner No. 1 & 2 Petitioner No.
2
VERIFICATION

I, Manoj Manohar More the Petitioner no. 2 do hereby solemnly affirm and state
that whatever stated hereinabove is true and correct to the best of my knowledge
and I believe the same to be true.

Solemnly affirmed at Mumbai )

Dated this _____ day of _________, 2019 )

Identified by me

[Vikrant C. Deshpande] [Manoj Manohar More]


Advocate for Petitioner No. 1 & 2 Petitioner No.
2
IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ )


SnehalShamraoSawant )
aged 29 years, Occ.: - Service )
Residing at G-1, KokanKinara Building No.9, )
Near Ganesh Mandir ,Kokan Nagar , )
Jogeshwari (East ),Mumbai-400060, )
Contact No. 9769991993 )
Email.:- Snehalshamal@gmail.com ) …Petitioner No. 1

And

Manoj Manohar More )


aged 38 years, Occ.: - Service )
Residing at Room No. 66, E Wing , )
NandadeepCHS.,Municipal Colony, )
GovandiDeonar, Mumbai-400043. )
Contact no. 9821628587 )
Email:- __________________ ) …Petitioner No. 2

To,
The Principal Judge and other
Hon’ble Judges of this
Hon’ble Family Court.
At Bandra, Mumbai.
----------------------------

Petition u/s sec 13 (B) of the Hindu


Marriage Act, 1955, for decree of divorce
by mutual consent

The humble joint petition of the Petitioner No. 1 and Petitioner No. 2 above
named.
MOST RESPECTFULLY SHEWETH:
 
1. Both the Petitioners are Hindu by religion, Indian inhabitant, citizens of India and
domiciled in state of Maharashtra and residing at address mentioned in the title
herein above. They are not belonging to Schedule Tribe as per section 2 (2) of
Hindu Marriage Act.

2. Both Petitioners married to each other on 27/06/2012 and the marriage was
solemnized at SantGhadgeMaharaj Hall , Jari Mari Temple , Near Bandra
Lake, S.V. Road, Bandra (West) Mumbai-400051 Maharashtra. The wedding
took place according to hindu rites and by following the prevailing
customary rituals in the presence of the near relatives and well wishers. The
said marriages is not registered at Registrar of marriages.

Annexed herein & marked Exhibit ‘A’ is the original marriage wedding card.
Annexed herein & marked Exhibit ‘B’ is original marriage photographs.

3. Both the Petitioners states that prior to the marriage Petitioner No. 1 was
spinster and her maiden name was Ms. SnehalShamraoSawant and
Petitioner no. 2 was bachelor.

4. Both the Petitioners submit that on the date of marriage, Petitioner No. 1
was 22 years and Petitioner No. 2 was 31 years old, thus both Petitioners had
attained majority and were of marriageable age as prescribed under the law.

5. Both the Petitioners submits that the marriage between both Petitioners was
a valid marriage under The Hindu Marriage Act 1955 and none of the
parties had any spouse living at the time of the marriage and the
relationship of the Petitioner no. 1 and Petitioner no. 2 also do not fall within
the prohibited degrees.

6. Both the Petitioners submits that, after marriage they were last residing as a
husband and wife at Room No. 66, E Wing , Nandadeep CHS.,
Municipal Colony, GovandiDeonar, Mumbai-400 043 and thus this is treated
as their matrimonial home.

7. Both the Petitioners state that out of the said wedlock they do not have any
child.
8. The Petitioners submit that, there were difference of opinion between them
from the last 4 years and their views & opinions differed on many trivial
issues concerning their life style and behaviour. Their temperament, likes
and nature totally mismatch and they could not arrive on any mutual
decision relating to their daily family issues.

9. The Petitioners state that now the relationship between them has come to
such a stage that it is not at all possible for them to live as husband and wife
any more. The Petitioners have tried to reconcile their differences by
seeking the intervention of the family members, friends and elderly
relatives, but in vain and the efforts made by them proved futile.

10. The Petitioners state that they both have decided to live separately in
different homes and from 15/07/ 2014they are living separate till date. The
Petitioners state that they do not have any physical or mental relationship
between them and thus never treated themselves in relationship of husband
& wife.

11. The Petitioners will exchange all their jewellery, goods, articles and other
exchangeable items with each other on final hearing of the present petition
and after that no party has any kind of claim over any other item or
property, as per the consent terms herein.

12. The Petitioners confirm and declare that presently there is no joint property
both movable and immovable, investment or any other asset. However if
any found in future than petitioners shall co-operate each other in deletion
of name, separation or distribution of the same mutually and peacefully.

13. The Petitioners confirm and declare that presently there is no joint debt /
loan / liability or due of whatsoever nature in whatsoever manner.
However if any found in future than Petitioner/s shall bear / pay such
debt / loan / liability/ dues and keep harmless and free the other Petitioner.

14. The Petitioners hereby agree, confirm and declare that they will never claim
any kind of legal right on each other’s property both movable and
immovable, bank account, investment or any other asset, which was hold or
acquired in their individual name before, during, after marriage and now
after mutual divorce herein, in future.
15. The Petitioners agree and declare that they shall not file any complaint or
adopt any Civil and/or Criminal proceedings against each other regarding
any act done by them during the existence of marriage, separation and in
future after mutual divorce herein. Further both the Petitioners agree,
confirm and

declare that if there is any complaint or Civil / Criminal case pending in any of
the Court of Law in India or out of India, then the same now stands withdrawn
unconditionally and voluntarily against each other after mutual divorce
herein. Also they should not adopt any malpractices to defame each other or
their families and in no circumstances use any such documents or material
acquired during the existence of marriage & after mutual divorce herein.

16. The Petitioner no. 1 wife agrees and confirms that she will not use the name
and surname of Petitioner No. 2 after mutual divorce herein, for any
purpose in future. The Petitioners agree and confirm herein that they are
free to re-marry and no Petitioner will create any obstacle in each other’s re-
marriage.

17. The Petitioner no. 1 wife agrees and confirms that she waives her claim of
maintenance and alimony permanently from Petitioner no. 2 and will never
hold him responsible or liable for any maintenance or alimony in future
forever.

18. The Petitioners state that there has been irretrievable break down of
marriage and the same has become totally dead and beyond any hope of
salvage.

19. In view of the above circumstances, the Petitioners have now mutually
agreed that there is no point for the continuance of the marital relationship
between them and they have decided to settle the matter amicably by
seeking legal means by filing a Mutual Consent Petition under the provision
of section 13-B of the Hindu Marriage Act, 1955, by which the Petitioners are
governed.

20. The Petitioners have mutually agreed upon certain terms and conditions
more specifically set out in the consent terms. Annexed herein & marked
Exhibit ‘C’ are the consent terms.
21. The Petitioners state that it is desirable and necessary under the facts and
circumstances of the present case, that the marriage should be dissolved in
the mutual interest of the Petitioners.

22. The Petitioners state that the mutual consent to the present divorce has not
been obtained by any force, fraud or under influence.

23. That the cause of action for filing this instant petition arose from 15/07/2014
and both the Petitioners have now agreed to seek a divorce by mutual
consent.

24. Both the Petitioners submit that their marriage was solemnised at
SantGhadgeMaharaj Hall , Jari Mari Temple , Near Bandra Lake, S.V. Road,
Bandra (West ) Mumbai – 400051, Therefore the present honourable court
has got the jurisdiction to try & entertain this Petition filed u/s 13 (B) of The
Hindu Marriage Act, 1955.

25. The Petitioners submits that there is no other case pending before any court
of law for dissolution of marriage between both the Petitioners.

26. It is submitted that the court fee of Rs. 100 /- is paid herein.

27. The Petitioners submits that there is no collusion and connivance between
both the Petitioners, while filing this Petition.

28. The Petitioners state that they have read and understood the contents of this
Petition and the same are as per their instructions only.

In the above circumstances, the Petitioners humbly and respectfully submit


and pray as herein below:-

a] that this Hon’ble Court be pleased to pass an Order, Decree and Judgment
of Divorce and thereby dissolving the marriage solemnized on 27/06/2012
, between the above Petitioners under the Provision of section 13 (B) of The
Hindu Marriage Act, 1955.

b] any other relief as this honorable court may deem fit and proper.

Place : - Bandra, Mumbai.


Dated this _____ day of March , 2019

[Vikrant C. Deshpande] [Snehal Manoj More @


SnehalShamraoSawant]
Advocate for Petitioner No. 1 & 2 Petitioner No.
1

[ManojManohar More]
Petitioner no. 2

VERIFICATION

I, Snehal Manoj More @ SnehalShamraoSawantthe Petitioner no. 1 do hereby


solemnly affirm and state that whatever stated hereinabove is true and correct to
the best of my knowledge and I believe the same to be true.

Solemnly affirmed at Mumbai )

Dated this _____ day of March, 2019 )

Identified by me

[Vikrant C. Deshpande][Snehal Manoj More @ SnehalShamraoSawant]


Advocate for Petitioner No. 1 & 2 Petitioner No.
1

VERIFICATION

I, ManojManohar More,the Petitioner no. 2 do hereby solemnly affirm and


state that whatever stated hereinabove is true and correct to the best of my
knowledge and I believe the same to be true.

Solemnly affirmed at Mumbai )

Dated this _____ day of March 2019 )


Identified by me

[ManojManoharMore]
Petitioner no. 2

[Vikrant C. Deshpande]
Advocate for Petitioner no. 1 &2

IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant )


aged 29 years, Occ.: - Service )
Residing at G-1, KokanKinara Building No.9, )
Near Ganesh Mandir ,Kokan Nagar , )
Jogeshwari (East ),Mumbai-400060, )
Contact No. 9769991993 )
Email.:- nehal_______________________ ) …Petitioner No. 1

And
Manoj Manohar More )
aged 38 years, Occ.: - Service )
Residing at Room No. 66, E Wing , )
NandadeepCHS., Municipal Colony, )
GovandiDeonar, Mumbai-400043. )
Contact no. 9821628587 )
Email:-Snehalsharma@gmail.com ) …Petitioner No. 2
CONSENT TERMS
 
1) Both the Petitioners are agreed and declared that both the Petitioners have agreed to
dissolve their marriage solemnized on 27/06/2012 by mutual consent as
contemplated under 13 (B) of Hindu Marriage Act, 1955.

2) Both the Petitioners agree, confirm and declare that they will never claim any kind of
legal right on each other’s property both movable and immovable, bank account,
investment or any other asset, which was hold or acquired in their individual name
before, during, after marriage and now after mutual divorce herein, in future, except
mentioned herein below.

3) Both the Petitioners agree and declare that shall not file any complaint or adopt
any Civil and/or Criminal proceedings against each other regarding any act
done by them during the existence of marriage, separation and in future after
mutual divorce herein. Further both the Petitioners agree, confirms and declare
that if there is any complaint, or Civil / Criminal case pending in any of the
Court of Law in India or out of India, than the same now stands withdrawn
unconditionally and voluntarily against each other right now after mutual
divorce herein. Also they should not adopt any malpractices to defame each
other or their families and in no circumstances use any such documents or
material acquired during the existence of marriage & after mutual divorce
herein.

4) The Petitioner no. 1 wife agrees and confirms that she will not use the name
and surname of Petitioner No. 2 after mutual divorce herein, for any purpose
in future. The Petitioner No. 2 will always co-operates the Petitioner no. 1 to
change her name. Both the Petitioner agrees and confirms herein that they are
free to re-marry and no Petitioner will create any obstacle in each other’s re-
marriage.

5) Both the Petitioners confirms that they have exchanged all their goods, articles
and other exchangeable items with each other before filing of this Petition and
no party has any kind of claim over any other item or property.

6) The Petitioners confirm and declare that presently there is no joint property
both movable and immovable, investment or any other asset. However if any
found in future than petitioners shall co-operate each other in deletion of
name, separation or distribution of the same mutually and peacefully.

7) The Petitioners confirm and declare that presently there is no joint debt /
loan / liability or due of whatsoever nature in whatsoever manner. However if
any found in future than Petitioner/s shall bear / pay such debt / loan /
liability/ dues and keep harmless and free the other Petitioner.

8) The Petitioners state that out of the said wedlock they do not have any child.

9) The Petitioner no. 1 wife agrees and confirms that she waives her claim of
maintenance and alimony permanently from Petitioner no. 2 and will never
hold him responsible or liable for any maintenance or alimony in future
forever.

Place : - Bandra, Mumbai.

Dated this _____ day of March , 2019


[Vikrant C. Deshpande] [Snehal Manoj More @ SnehalShamraoSawant]
Advocate for Petitioner No. 1 & 2 Petitioner No.
1
[ManojManohar More]
Petitioner no. 2

IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

COURT FEES
[Vikrant C. Deshpande]
Advocate for Petitioner No. 1& 2

IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

INDEX

---------------------------------------------------------------------------------------------------------

SR. NO PARTICULARS PAGE

---------------------------------------------------------------------------------------------------------

1. Roznama

2. Petition

3. Affidavit of Petitioners No. 1 & 2

4. List of Documents

5. Exhibit `A’

Original Marriage Photographs

6. Exhibit `B’
Originalweddingcard
7. Exhibit `C’

Copy of consent terms

8. Copy of Pan Card&Aadhar card of Petitioner No. 1 & 2

9. Memorandum of Address of Petitioner No. 1 & Petitioner No. 2

10. Application for appointing Advocate

11. Vakalatnama

12. Court fees


IN THE FAMILY COURT MUMBAI
AT, BANDRA

M. J. PETITION NO. F - 902 OF 2019

Snehal Manoj More @


SnehalShamraoSawant
.… Petitioner No. 1

And

ManojManohar More
.… Petitioner No. 2

CLAIM AFFIDAVIT OF

PETITIONER NO. 2

this 7th day of October , 2019

(Shri Vikrant C. Deshpande)


Advocates for Petitioner no. 1 & 2
Shop No.3, Cancer Pisces CHS ltd
Janakalyan Nagar, Behind Fire
Brigade, Malwani No. 1, Malad
(West), Mumbai - 400 095.
Office Tel.:- 7738793982
022-40142937

Email id:- legal_chamber2011@yahoo.com


IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

Application for appointing advocate in the above matter

MAY IT PLEASE YOUR HONOUR:-

We, SnehalManoj More @ SnehalShamraoSawant, the Petitioner No. 1


&ManojManohar More, the Petitioner No. 2 above named most humbly and
respectfully beg submit as under :-

1. and possibly a question of law is involved in our case and ourselves shall
not We say that the above petition is on today’s board.

2. We say that our selves will not be able to plead our case as we do not have
the adequate legal knowledge be able to or in position to conduct we case
on my own adequately.

3. It is therefore necessary for me to take the assistance of an Advocate; we


therefore pray that we may be permitted to appoint Shri.Virkant C.
Deshpande, Mrs.Vanita Y. Orpe, Mrs. Shilpa A. Jadhav, Mrs.
SabhyataRajpurohit&Shri. Devendra C. ParabAdvocates, to appear and
plead on our behalf in the above matter. Hence as per rule 37, the Family
Court (Court) Rules 1988, we may be granted permission to appoint an
advocate as name mentioned above.

And for this act of kindness, we shall ever pray.

Solemnly affirmed at Mumbai )

This day of _________ 2019 )

[SnehalManoj More @ SnehalShamraoSawant]


Petitioner No. 1

[ManojManohar More]
Petitioner no. 2
[Vikrant C. Deshpande]
Advocate for Petitioner No. 1& 2
IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

ROZNAMA
-------------------------------------------------------------------------------------------------------------
Office Notes, Office Memoranda of Coram, Court’s or
Appearance, Court’s order or Direction, Judge’s Order
-------------------------------------------------------------------------------------------------------------
-------------------------------------------------------------------------------------------------------------
Office Notes, Office Memoranda of Coram, Court’s or
Appearance, Court’s order or Direction, Judge’s Order
-------------------------------------------------------------------------------------------------------------

[Shri Vikrant C. Deshpande]


Advocate for Petitioner No. 1 & 2
IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

AFFIDAVIT IN SUPPORT OF PETITION

I, Snehal Manoj More @ SnehalShamraoSawant, the Petitioner No. 1, do hereby


state on solemn affirmation as follows:-

1. I say that I have filed the above Petition under sec 13 (B) of the Hindu
Marriage Act, 1955 for Divorce by Mutual Consent and as set out more
particularly in the Petition.

2. In the said connection, I crave leave to adopt and reiterate each and every
statement, averment, and submission as contained in the Petition as if the
same has been specifically set out herein and separately restated. I pray
that the same be treated as a part of this Affidavit.

Solemnly affirmed at Mumbai )

This________day of ___________ 2019)

[Shri Vikrant C. Deshpande]


Advocate for Petitioner No. 1& 2

(SnehalManoj More @ SnehalShamraoSawant)


Petitioner No. 1
IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

AFFIDAVIT IN SUPPORT OF PETITION

I, ManojManohar More, the Petitioner No. 2, do hereby state on solemn affirmation


as follows:-

1. I say that I have filed the above Petition under sec 13 (B) of the Hindu
Marriage Act, 1955 for Divorce by Mutual Consent and as set out more
particularly in the Petition.

2. In the said connection, I crave leave to adopt and reiterate each and every
statement, averment, and submission as contained in the Petition as if the
same has been specifically set out herein and separately restated. I pray
that the same be treated as a part of this Affidavit.

Solemnly affirmed at Mumbai )

This _____ day of ______2019 )

[Manoj Manohar More]


Petitioner No. 2

[Shri Vikrant C. Deshpande]


Advocate for Petitioner No. 1 & 2
IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

LIST OF DOCUMENTS

1. Original Marriage Photograph –Exh. A


2. Original Wedding Card- Exh. B
3. Original Consent Terms – Exh. C
4. Copy of Pan card &Aadhar card of Petitioner No. 1 & 2

Filled in the Court of Bandra on ____ day of March 2019

[Snehal Manoj More @ SnehalShamraoSawant]


Petitioner No. 1

[ManojManohar More]
Petitioner No. 2

[Shri Vikrant C. Deshpande]


Advocate for Petitioner No. 1 & 2
IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

MEMORANDUM OF REGISTERED ADDRESS

Snehal Manoj More @


SnehalShamraoSawant
Residing at G-1Kokan KinaraBuilding ,
No.9, Near GaneshMandir ,Kokan Nagar ,
Jogeshwari (East ),Mumbai-400060.

[Snehal Manoj More @ SnehalShamraoSawant ]


Petitioner No. 1

[Shri Vikrant C. Deshpande]


Advocate for Petitioner No. 1 & 2
IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

MEMORANDUM OF REGISTERED ADDRESS

Manoj Manohar More


Residing Room No. 66, E Wing ,
Nandadeep CHS., Municipal colony,
GovandiDeonar,
Mumbai-400043.

[ManojManoharMore ]
Petitioner No. 2

[Shri Vikrant C. Deshpande]


Advocate for Petitioner No. 1 & 2
I AM NOT A MEMBER OF THE WELFARE FUND THEREFORE

STAMP OF RS 2/- IS NOT AFFIXED HEREWITH

VAKALATNAMA

---------------------------------

Advocate’s Signature

IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ )


SnehalShamraoSawant )
aged 29 years, Occ.: - Service )
Residing at G-1, KokanKinara Building No.9, )
Near Ganesh Mandir ,Kokan Nagar , )
Jogeshwari (East ),Mumbai-400060, )
Contact No. 9769991993 )
Email.:- _______________________ ) …Petitioner No. 1

And

Manoj Manohar More )


aged 38 years, Occ.: - Service )
Residing at Room No. 66, E Wing , )
NandadeepCHS., Municipal Colony, )
GovandiDeonar, Mumbai-400043. )
Contact no. 9821628587 )
Email:-Snehalsharma@gmail.com ) …Petitioner No. 2
To,
The Registrar,
Family Court Bandra,
Mumbai.
------------

Respected Sir / Madam,

We, Snehal Manoj More @ SnehalShamraoSawant, the Petitioner No. 1 &Manoj


Manohar More Petitioner no. 2 above named, do hereby appoint Shri.Virkant C.
Deshpande, Mrs.Vanita Y. Orpe, Mrs.Shilpa A.
Jadhav,Mrs.SabhayataRajpurohit&Mr.Devendra C. ParabAdvocates High
Court to act appear and plead on our behalf in the above matter.
In witness whereof, we have set and subscribed our hand to this writing at
Mumbai.

Dated this______ day of 2019

Accepted :-

(Shri. Vikrant C. Deshpande)


Bar Council of Maharashra& Goa
Roll No. MAH/2361/1999

(Mrs. Shilpa A. Jadhav)


Bar Council of Maharashra& Goa
Roll No. MAH/5912/2013

(Mrs. SabhyataRajpurohit)
Bar Council of Maharashra& Goa
Roll No. MAH/5626/2006

(Shri. Devendra C. Parab)


Bar Council of Maharashra& Goa
Roll No. MAH/4078/2014

(Mrs. Vanita Y. Orpe)


Bar Council of Maharashra& Goa
Roll No. MAH/3565/2008
Advocates for Petitioner No. 1 & 2

Office Address:-

Shop no. 03, Cancer Pisces CHS Ltd.,


Janakalyannagar, Malwani – 01,
behind fire brigade, Malad (W),
Mumbai :-  400 095.
 Contact nos.:-7738793982 & 022-40142937

(Snehal Manoj More @ SnehalShamraoSawant)


Petitioner No. 1

(ManojManohar More)
Petitioner no. 2
IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2

MARRIAGE PHOTOGRAPHS

IN THE FAMILY COURT MUMBAI AT, BANDRA


M. J. PETITION NO. OF 2019

Snehal Manoj More @ SnehalShamraoSawant .… Petitioner No. 1

And

ManojManohar More ...… Petitioner No. 2


WEDDING CARD
==============.

IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2019

Snehal Manoj More @


SnehalShamraoSawant )
aged 29 years, Occ.: - Service )
Residing at G-1, KokanKinara Building No.9, )
Near GaneshMandir ,Kokan Nagar , )
Jogeshwari (East ),Mumbai-400060, )
Contact No. 9769991993 )
Email.:- _______________________ ) …Petitioner No. 1

And

Manoj Manohar More )


aged 38 years, Occ.: - Service )
Residing at Room No. 66, E Wing , )
NandadeepCHS.,MunsipalColony, )
GovandiDeonar, Mumbai-400043. )
Contact no. _______________ )
Email:-_____________________________ ) …Petitioner No. 2
CLAIM AFFIDAVIT

OF PETITIONER NO. 2

------------------------------------

I Manoj Manohar More, aged 38 years, Occupation:- unemployed, Residing at


Room No. 66, E Wing ,Nandadeep CHS., munsipal colony, GovandiDeonar,
Mumbai-400043, Maharashtra., the Petitioner no. 2 above named, do hereby on
solemn declared as under:-

MOST RESPECTFULLY SHEWETH:


 
29. I state that I am Hindu by religion, Indian inhabitant, citizens of India and
domiciled in state of Maharashtra and residing at address mentioned in the title
herein above. I do not belonging to Schedule Tribe as per section 2 (2) of Hindu
Marriage Act.

30. I state that I got married to each other on 27/06/2012 and the marriage was
solemnized at SantGhadgeMaharaj Hall , Jari Mari Temple , Near Lack, S.V.
Road, Bendra (West ) Mumbai-400051, The wedding took place according to
hindu rites and by following the prevailing customary rituals in the
presence of the near relatives and well wishers.

31. I states that prior to the marriage Petitioner no.1 was spinster and her
maiden name was Ms. SnehalShamraoSawant and I was bachelor.

32. I submit that on the date of marriage, Petitioner no.1 was 22 years and I was
31 years old, thus we had attained majority and were of marriageable age as
prescribed under the law.

33. I submits that the marriage between me and petitioner no.1 was a valid
marriage under The Hindu Marriage Act 1955 and none of us had any
spouse living at the time of the marriage and the relationship of mine and
Petitioner no. 1 also do not fall within the prohibited degrees.

I submits that, after marriage we were last residing as a husband and wife at
Room No. 66, E Wing ,Nandadeep CHS., munsipal colony, GovandiDeonar,
34. Mumbai-400043, Maharashtra.,, Maharashtra and thus this is treated as our
matrimonial home.

35. I states that out of the said wedlock we do not have any child.

36. I state that we were leading a normal married life, however for the last 1
year, our views and opinions differ on many trivial issues concerning our
life style and behaviour. Our temperament, likes and nature totally
mismatch and we could not arrive on any mutual decision relating to our
daily family issues.

37. I state that now the relationship between us has come to such a stage that it
is not at all possible to live as husband and wife any more. We both have
tried to reconcile our differences by seeking the intervention of the family
members, friends and elderly relatives, but in vain and the efforts made by
us proved futile.

38. I state that we both have decided to live separately in different homes and
from 05/10/2017 we are living separate till date. I state that we do not have
any physical or mental relationship between us and thus never treated
ourselves in relationship of husband & wife.

39. We have exchange all our jewellery, goods, articles and other exchangeable
items with each other on final hearing of the present petition and after that
no party has any kind of claim over any other item or property, as per the
consent terms herein.

40. I confirm and declare that presently there is no joint property both movable
and immovable, investment or any other asset. However if any found in
future than I will co-operate Petitioner no. 1 in deletion of name, separation
or distribution of the same mutually and peacefully.

41. I confirm and declare that presently there is no joint debt / loan / liability or
due of whatsoever nature in whatsoever manner. However if any found in
future than I shall bear / pay such debt / loan / liability/ dues and keep
harmless and free the Petitioner no.1.

42. I hereby agree, confirm and declare that I will never claim any kind of legal
right on Petitioner no.1’s property both movable and immovable, bank
account, investment or any other asset, which was hold or acquired in her
individual name before, during, after marriage and now after mutual
divorce herein, in future.

43. I agree and declare that I will not file any complaint or adopt any Civil
and/or Criminal proceedings against Petitioner no.1 regarding any act done
by him during the existence of marriage, separation and in future after
mutual divorce herein. Further I agree, confirm and declare that if there is
any complaint or Civil / Criminal case pending in any of the Court of Law
in India or out of India, then the same now stands withdrawn
unconditionally and voluntarily against each other after mutual divorce
herein. Also we should not adopt any malpractices to defame each other or
our families and in no circumstances use any such documents or material
acquired during the existence of marriage & after mutual divorce herein.

44. I agrees and confirms that petitioner no.1 will not use the name and
surname of mine after mutual divorce herein, for any purpose in future. I
agree and confirm herein that petitioner no. 1 is free to re-marry and I will
create any obstacle in Petitioner no.1’s re-marriage.

45. I agrees and confirms Petitioner no.1 will never hold me responsible or liable
for any maintenance or alimony in future forever.
46. I state that there has been irretrievable break down of marriage and the
same has become totally dead and beyond any hope of salvage.

47. I state that In view of the above circumstances, I have now mutually agreed
that there is no point for the continuance of the marital relationship between
us and we have decided to settle the matter amicably by seeking legal means
by filing a Mutual Consent Petition under the provision of section 13-B of
the Hindu Marriage Act, 1955, by which the we are governed.

48. I have mutually agreed upon certain terms and conditions more specifically
set out in the consent terms.

49. I state that it is desirable and necessary under the facts and circumstances of
the present case, that the marriage should be dissolved in the mutual
interest of us.

50. I state that the mutual consent to the present divorce has not been obtained
by any force, fraud or under influence.

51. I state that the cause of action for filing this instant petition arose from
05/10/2017 and we have now agreed to seek a divorce by mutual consent.

52. I submit that our marriage was solemnised at SantGhadgeMaharaj Hall , Jari
Mari Temple , Near Lack, S.V. Road, Bendra (West ) Mumbai-400051,
Maharashtra. Therefore the present honourable court has got the
jurisdiction to try & entertain this Petition filed u/s 13 (B) of The Hindu
Marriage Act, 1955.

53. I submits that there is no other case pending before any court of law for
dissolution of marriage between both the Petitioners.

54. I have submitted the court fee of Rs. 100 /- is paid.

55. I submits that there is no collusion and connivance between us, while filing
this Petition.

56. I state that we have read and understood the contents of this claim affidavit
and the same are as per our instructions only.

Place : - Bandra, Mumbai.

Dated this _____ day of March, 2019


[Vikrant C. Deshpande] [Snehal Manoj More @ SnehalShamraoSawant]
Advocate for Petitioner No. 1 & 2 Petitioner No.
2

VERIFICATION

I, ManojManohar More, the Petitioner no. 2 do hereby solemnly affirm and


state that whatever stated hereinabove is true and correct to the best of my
knowledge and I believe the same to be true.

Solemnly affirmed at Mumbai )

Dated this _____ day of March 2019 )

Identified by me

[ManojManohar More]
Petitioner no. 2

[Vikrant C. Deshpande]
Advocate for Petitioner no. 1 &2

IN THE FAMILY COURT MUMBAI AT, BANDRA

M. J. PETITION NO. OF 2018

Snehal Manoj More @


SnehalShamraoSawant )
aged 29 years, Occ.: - Service )
Residing at G-1Kokan KinaraBuilding ,
No.9, Near ganeshMandir ,Kokan Nagar ,
Jogeshwari (East ),Mumbai-400060,
Maharashtra.
Contact No. 9920892220 )
Email.:- _______________________ ) …Petitioner No. 1

And
Manoj Manohar More )
aged 38 years, Occ.: - Service )
Residing at Room No. 66, E Wing ,
Nandadeep CHS., munsipal colony,
GovandiDeonar,
Mumbai-400043, Maharashtra. )
Email:-_____________________________ ) …Petitioner No. 2
CLAIM AFFIDAVIT OF
PETITIONER NO. 1

----------------------------------------

I Snehal Manoj More @ SnehalShamraoSawant, aged 29years, Occupation:-


Housewife, Residing G-1Kokan Kinara Building ,No.9, Near ganeshMandir ,
Kokan Nagar ,Jogeshwari (East ),Mumbai-400060,Maharashtra.the Petitioner no. 1
above named, do hereby on solemn declared as under:-

MOST RESPECTFULLY SHEWETH:


 
57. I state that I am Hindu by religion, Indian inhabitant, citizens of India and
domiciled in state of Maharashtra and residing at address mentioned in the title
herein above. I do not belonging to Schedule Tribe as per section 2 (2) of Hindu
Marriage Act.

58. I state that I got married to each other on 27/06/2012 and the marriage was
solemnized at SantGhadgeMaharaj Hall , Jari Mari Temple , Near Lack, S.V.
Road, Bendra (West ) Mumbai-400051. The wedding took place according to
hindu rites and by following the prevailing customary rituals in the
presence of the near relatives and well wishers.

59. I states that prior to the marriage I was spinster and my maiden name was
Ms. SnehalShamlalSawant and Petitioner no. 2 was bachelor.

60. I submit that on the date of marriage, I was 22 years and Petitioner No. 2
was 31 years old, thus we had attained majority and were of marriageable
age as prescribed under the law.

61. I submits that the marriage between me and petitioner no.2 was a valid
marriage under The Hindu Marriage Act 1955 and none of us had any
spouse living at the time of the marriage and the relationship of mine and
Petitioner no. 2 also do not fall within the prohibited degrees.
62. I submits that, after marriage we were last residing as a husband and wife at
at Room No. 66, E Wing ,Nandadeep CHS.,
munsipalcolony,GovandiDeonar,
Mumbai-400043, Maharashtra., Maharashtra and thus this is treated as our
matrimonial home.

63. I states that out of the said wedlock we do not have any child.

64. I state that we were leading a normal married life, however for the last 1
year, our views and opinions differ on many trivial issues concerning our
life style and behaviour. Our temperament, likes and nature totally
mismatch and we could not arrive on any mutual decision relating to our
daily family issues.

65. I state that now the relationship between us has come to such a stage that it
is not at all possible to live as husband and wife any more. We both have
tried to reconcile our differences by seeking the intervention of the family
members, friends and elderly relatives, but in vain and the efforts made by
us proved futile.

66. I state that we both have decided to live separately in different homes and
from 05/10/2017 weare living separate till date. I state that we do not have
any physical or mental relationship between us and thus never treated
ourselves in relationship of husband & wife.

67. Wehave exchange all ourjewellery, goods, articles and other exchangeable
items with each other on final hearing of the present petition and after that
no party has any kind of claim over any other item or property, as per the
consent terms herein.

68. I confirm and declare that presently there is no joint property both movable
and immovable, investment or any other asset. However if any found in
future than I will co-operate Petitioner no. 2 in deletion of name, separation
or distribution of the same mutually and peacefully.

69. I confirm and declare that presently there is no joint debt / loan / liability or
due of whatsoever nature in whatsoever manner. However if any found in
future than I shall bear / pay such debt / loan / liability/ dues and keep
harmless and free the Petitioner no.2.

70. I hereby agree, confirm and declare that I will never claim any kind of legal
right on Petitioner no.2’s property both movable and immovable, bank
account, investment or any other asset, which was hold or acquired in his
individual name before, during, after marriage and now after mutual
divorce herein, in future.

71. I agree and declare that I shall not file any complaint or adopt any Civil
and/or Criminal proceedings against Petitioner no.2 regarding any act done
by him during the existence of marriage, separation and in future after
mutual divorce herein. Further I agree, confirm and declare that if there is
any complaint or Civil / Criminal case pending in any of the Court of Law
in India or out of India, then the same now stands withdrawn
unconditionally and voluntarily against each other after mutual divorce
herein. Also we should not adopt any malpractices to defame each other or
our families and in no circumstances use any such documents or material
acquired during the existence of marriage & after mutual divorce herein.

72. I agrees and confirms that I will not use the name and surname of Petitioner
No. 2 after mutual divorce herein, for any purpose in future. I agree and
confirm herein that petitioner no. 2is free to re-marry and I will create any
obstacle in Petitioner no.2’s re-marriage.

73. I will never hold petitioner no.2 responsible or liable for any maintenance or
alimony in future forever.

74. I state that there has been irretrievable break down of marriage and the
same has become totally dead and beyond any hope of salvage.

75. I state that In view of the above circumstances, I have now mutually agreed
that there is no point for the continuance of the marital relationship between
us and we have decided to settle the matter amicably by seeking legal means
by filing a Mutual Consent Petition under the provision of section 13-B of
the Hindu Marriage Act, 1955, by which the we are governed.

76. I have mutually agreed upon certain terms and conditions more specifically
set out in the consent terms.

77. I state that it is desirable and necessary under the facts and circumstances of
the present case, that the marriage should be dissolved in the mutual
interest of us.

78. I state that the mutual consent to the present divorce has not been obtained
by any force, fraud or under influence.

79. I state that the cause of action for filing this instant petition arose from
05/10/2017 and we have now agreed to seek a divorce by mutual consent.
80. I submit that our marriage was solemnised at SantGhadgeMaharaj Hall , Jari
Mari Temple , Near Lack, S.V. Road, Bendra (West ) Mumbai-
400051Maharashtra. Therefore the present honourable court has got the
jurisdiction to try & entertain this Petition filed u/s 13 (B) of The Hindu
Marriage Act, 1955.

81. I submits that there is no other case pending before any court of law for
dissolution of marriage between both the Petitioners.

82. I have submitted the court fee of Rs. 100 /- is paid.

83. I submits that there is no collusion and connivance between us, while filing
this Petition.

84. I state that we have read and understood the contents of this claim affidavit
and the same are as per our instructions only.

Place : - Bandra, Mumbai.

Dated this _____ day of March , 2019

[Vikrant C. Deshpande] [Snehal Manoj More @


SnehalShamraoSawant]
Advocate for Petitioner No. 1 & 2 Petitioner No.
1

VERIFICATION

I, Snehal Manoj More @SnehalShamraoSawant]


the Petitioner no. 1 do hereby solemnly affirm and state that whatever stated
hereinabove is true and correct to the best of my knowledge and I believe the same
to be true.

Solemnly affirmed at Mumbai )

Dated this _____ day of March 2019 )


Identified by me

[Vikrant C. Deshpande][Snehal Manoj More @ SnehalShamraoSawant]


]Advocate for Petitioner No. 1 & 2 Petitioner No.
1

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