IN THE COURT OF HON’BLE COURT OF PRINCIPAL JUDGE

FAMILY COURT, DWARKA, NEW DELHI

H.M.A. CASE NO. _______ OF 2018

Pawan Kumar
S/o Sh. Ram Sarup
R/o 25/1, Ground Floor
Khasra No. 21/23, Block-P,
Dharampura, Najafgarh,
New Delhi – 110043 …………… Petitioner

Versus

Asha Yadav
W/o Pawan Yadav
D/o Shiv Ram Yadav
R/o H. No. – 176, G – Block,
Gali No. – 8, Prem Nagar,
Najafgarh, New Delhi – 110043 …………… Respondent

PETITION FOR DISSOLUTION OF MARRIAGE BY DECREE OF

DIVORCE UNDER SECTIONS 13(1) (i-a) OF THE HINDU MARRIAGE
ACT, 1955 AS AMENDED UP-TO DATE

IT IS MOST RESPECTFULLY SHOWETH:

1. That the Petitioner is a law abiding and peace loving citizen of India,

aged about 29 years and is presently residing in Najafgarh, New

Delhi. The Petitioner has been already expelled from his parental

home by his parents due to continuous misbehavior of the

Respondent towards the parents of the Petitioner.

2. That the Respondent is the wife of the Petitioner aged about 27

years and was living in the house of parents of the petitioner with

her husband till 02.03.2018 (Holi). Currently the respondent is

living with her parents at the above mentioned address from

02.03.2018 onwards till date.

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3. That the marriage between the Petitioner and the Respondent was

an arranged marriage and was solemnised according to Hindu Rites

and Ceremonies on 28.03.2015, at MR GREEEN VATIKA, Prem

Nagar, Najafgarh, at New Delhi-110043. The parties to the petition

being Hindu by religion are governed by the Hindu Marriage Act,

1955. An affidavit of the Petitioner duly attested in this regard is

being filed herewith. Marriage Card of the Petitioner showing date of

marriage as 28.03.2015 is annexed herewith as Annexure: PW-1

4. That the Respondent, ever since the marriage did not adjust herself

neither with petitioner nor with parents of petitioner because of

highly egoistic, arrogant, violent and dominating personality having

no regard for husband and his family members and so being of

completely different and opposite nature and temperament from the

Petitioner.

5. It is submitted that the Respondent has caused great hardships,

mental trauma and highest level of disappointment and frustration

to the Petitioner on personal as well as on social levels and as such

there is complete irretrievable breakdown of marriage and no

chance of reconciliation between the Petitioner and the Respondent

in the future.

6. That out of this wedlock, one boy named Mr. Yash, is born on

19.02.2016.

7. That the status and place of residence of the parties to the marriage

before the marriage and at the time of filing the petition were/are as

follows: -

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 BEFORE MARRIAGE:

WIFE

STATUS AGE PLACE OF RESIDENCE

Spinster About 24 C/o Sh. Shiv Ram

years R/o H. No. – 176, G – Block, Gali No. –
8, Prem Nagar, Najafgarh, New Delhi –
110043

HUSBAND

STATUS AGE PLACE OF RESIDENCE

Bachelor About 26 C/o Sh. Ram Sarup

Years R/o RZ – 68, Sudan Garden, New
Roshanpura, Najafgarh, New Delhi –
110043

AT THE TIME OF FILING THIS PETITION:

WIFE

STATUS AGE PLACE OF RESIDENCE

Married About C/o Sh. Shiv Ram

27 years R/o H. No. – 176, G – Block, Gali No.
– 8, Prem Nagar, Najafgarh, New
Delhi – 110043

HUSBAND

STATUS AGE PLACE OF RESIDENCE

Married About R/o 25/1, Ground Floor, Khasra No.

29 years 21/23, Block-P, Dharampura,
Najafgarh, New Delhi-110043.

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8. That it is the painful story of a husband, who has always cared,

loved and supported his wife in every sphere and at every stage, but

in return, unfortunately the wife has not only betrayed him but has

also caused him extreme mental agony and pain by her numerous

insensitive and unjustified acts and comments. The Respondent has

not only treated the Petitioner with extreme mental cruelty, mental

stress and harassment but has also deliberately used choicest of

slangs and abuses in day-to-day life not only against the

Petitioner but also against the family members of the Petitioner

especially against the sister and mother of the Petitioner.

9. That the Respondent also wants to extort the property of the

Petitioner’s father and has attempted to commit suicide on 2-3

occasions, when the threat to transfer the property in the name of

Respondent was not adhered. That due to mental harassment by

the Respondent, parents of the Petitioner has thrown him out of

their home and also dis-owned him from all his properties and now

the Petitioner is forced to live on a rented accommodation, therefore,

the Petitioner left with no other option except to file the present

petition for the dissolution of the marriage on the ground of cruelty.

In view of the prolonging and present circumstances, the Petitioner

is now unable to bear the mental torture any more.

10. That the marriage between the parties has broken down

irretrievably and it has become harmful and injurious both

mentally and physically for the Petitioner to continue to remain

the husband, only in name, of the Respondent. It is respectfully

stated that the marriage between the parties is liable to be dissolved

by a decree of divorce.

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11. That the Respondent and her parents left no stones unturned to

degrade and demoralize the Petitioner at each and every stage and

the Petitioner, however, to save the marriage, the Petitioner did not

take any action against the Respondent in the past three years of

the marriage and became a punching bag for the Respondent

and her parents upon whom she and her parents used to spell out

her regular quota of anger by way of choicest of slangs which

sometimes coupled with hitting on the rib cage and on the back and

humiliated on day to day basis which the Petitioner cannot tolerate

anymore.

12. That the Petitioner has been treated with mental and physical

cruelty by the Respondent and her parents. It is no longer possible

for the Petitioner to live with her as living with Respondent has

been very traumatic and humiliating. The Petitioner fears for his

wellbeing and also of his family members and apprehends danger to

their life and limbs.

13. It is significant to mention that the Respondent and her parents in

day-to-day life used to slang and humiliate the petitioner by saying

“Haramkhor, Haramzada, Bewkoof, Idiot, Ghatiya insaan, Teri

Behan ka affair kai ladko ke saath, Tu drink krta hai, Tu smoke

bi karta hai or pata nahi kaise kaise nashe karta hai, Tu ek bura

admi hai, Teri maa khud khana ni bna sakti abi vo jawan padi

hai, main to use goo (excreta) khilaungi, Tu agar meri baat nahi

manega to main suicide kar lungi, Gadha, Ekdum zero, Aukaat

nahi hai,” etc..

The acts on the part of the Respondent resulting in the said extreme

mental cruelty, harassment, torture and defamation from the date

of marriage are, in brief, stated hereinafter.

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14. That after solemnization of the marriage on 28.03.2015, both the

Petitioner and the Respondent cohabited in the house of petitioner

parents situated at R/o RZ – 68, Sudan Garden, New Roshanpura,

Najafgarh, New Delhi – 110043, but for name sake only, as the

Respondent started her tantrums immediately after marriage. The

level of ill-treatment by the Respondent and her parents gradually

increased with the passage of time.

15. That just after one month of the marriage around May, 2015, when

the Petitioner went to the Respondent’s parents home for taking

back to her matrimonial home, her parents threatened the

Respondent by saying that they would beat him if he does not fulfill

their daughter’s demands and also embarrassed the petitioner in

front of their relatives.

16. That soon after the aforesaid un-forgettable incident which was

happened at Respondent House, the Respondent started using

filthy and abusive language to the Petitioner and his family.

The Respondent stopped the Petitioner from spending time with his

family. Respondent also started to apply restrictions on the

Petitioner from meeting his family and friends; she also started to

demand all the money that the Petitioner was earning.

17. That the Respondent throughout the period from beginning i.e.

March 2015 to March, 2018 continued to harass the Petitioner

mentally by picking fights on every petty issues and showing her

unsupportive nature on each and every spare of the marital life

without fulfilling any obligation of a wife. There are numerous

instances where the Petitioner was harassed and humiliated by the

Respondent and her parents on regular basis. Some of the instances

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where the Petitioner was subject to abusive language, humiliation,

mental torture, violence and mental cruelty by the Respondent and

her parents are followings:

a.) Unpredictable and Angry Nature:

That the Respondent used to show abusive and unpredictable

nature. The Respondent at various occasions acted recklessly

and created a scene if the Petitioner didn’t fulfill her demands. In

the month of May, 2015 when the Petitioner refused to fulfill her

illegitimate and unjustified demands, she threw utensils and

other objects on the Petitioner and her mother. The Respondent

in fit of rage didn’t even care about the Petitioner and her mother

who might have sustained injury.

b.) Suicidal Tendency:

That in the month of August 2015, after only five months of the

marriage, the Respondent cut her wrist with the blade when the

Petitioner refused to fulfill her illegitimate and unjustified

demands of transferring the property in her name. Furthermore,

the Respondent on several occasions had hit her head and hand

on wall and broke all her bangles. On numerous occasions,

Respondent had cut her wrist with blade just to dominate the

petitioner and forced him to follow her instruction and also

threatens to commit suicide or file a complaint against the

petitioner in police station. In-fact, When the Respondent

attempted to commit suicide on 07.10.2017, Petitioner called the

parents of the Respondent and narrated the complete incident

regarding committing suicide. Parents of Respondent along with

Respondent assured the Petitioner that this type of incident will

not happened again in future and also gave an undertaking duly

7
 signed and acknowledged by the parents of Respondent that

Respondent will not repeat this in future and in case Respondent

repeat this then Respondent and their parents will be solely

responsible for that. The copy of the letter dated 07.10.2017

signed by the Respondent and her parents is attached as

Annexure PW-2

c.) Abuse and Threat to Leave:

That the respondent used to threat to leave the Petitioner and go

back to her parental home. In-fact, every time Respondent

without even informing anyone in the family of Petitioner

including the Petitioner went to her parent’s home. Petitioner

always went to the residence of the Respondent to get her back

and by persuading the parents of the Respondent to send the

Respondent with him. When Petitioner confronted the

respondent about leaving his home without infrming any one,

then respondent replied in a very arrogant manner and told that

“Mein kisi se nahi puchungi or na hi kisi ko btaungi. Jab

mera man karega tab main apne ghar jaungi or jab mera

man krega tab mein yaha aa jaungi.”

Consequently, the Respondent used to go to her parent’s home

whenever she desired and she never cared about the concerns of

the Petitioner. When the Petitioner informed the parents of the

Respondent about their daughter’s irresponsible and abusive

behavior, they threatened the Petitioner and said that the

Respondent would do whatever she wants and the Petitioner

can’t do anything about this and again threaten the petitioner

that he has to follow the instruction of the respondent.

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d.) Creating ruckus and embracing in front of everyone:

That after nine months of the marriage, on 19.02.2016 a sweet

baby boy Mr. Yash was born out the wedlock. However, the

Respondent and her parents were not happy after birth of the

child. The Respondent and her parents ruined the celebration as

in front of all the relatives and neighbors and they commented,

“Ye itne kanjoos log ha ki hamari beti ko government

hospital main le ke gaye hain, private hospital main le ke

kyo nahi gaye”.

Afterwards, the Respondent and her parents continued

embracing the Petitioner on all social events. Once, when the

Petitioner and his family were celebrating the “Kua Pujan” festival

of their son, the Respondent called her brother and other

relatives to create ruckus. The brother of the Respondent and her

other relatives of Respondent after getting drunk, entered in the

premises of the Petitioner, shouted at the Petitioner and created

ruckus in front of all the respected member of the society.

It is significant to mention that the Respondent didn’t even care

about her infant son. That in the month August, 2016,

Respondent left her infant son (8 months) with the Petitioner

despite of the fact that the infant required a biological mother

during initial days but without in contrary to that Respondent

neither cared about his infant son nor enquired about his son

from the Petitioner and in fact Respondent absolutely forgot that

she has a 9 month old infant baby. The Respondent came back

to the Petitioner after almost Five months on 26.01.2017. During

this period the infant boy was craving for his mother, however

somehow, the Petitioner and their parents took care of the infant

boy and fulfilled his parental obligation unlike the Respondent.

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e.) Threat to commit suicide if the property is not transferred

to the Respondent’s name:

That the Respondent is a greedy person who wishes to grab the

property of the Petitioner and his parents. From the inception of

marriage, Respondent is asking the Petitioner or his parents to

transfer some property in her name. The height of greediness

was crossed, when the Respondent gave birth to boy and after

the birth, Respondent intimidated the mother of the Petitioner

and said, “ab to maine tuj ko ladka de diya hai, ab to tu

mere naam ye ghar kar de warna mein tere ko tere pote se

alag kar dungi or phir tadapte rehna apne pote ke bina”.

Furthermore, the Respondent many times cut her wrist and hit

her head at the wall and broke all her bangles in order to get the

property transferred on her name. She also said, “Tum sab meri

baat maan jao or ye ghar mere naam kara do warna me

aisa hi karungi or tum sab ko jail bhijwa dungi”.

f.) Disrespecting the mother and sister of the Petitioner by

using utmost filthy and abusive language:

The Respondent and her parents disrespected the mother and

sister of the Petitioner as in when they got the opportunity. In the

month of July, 2017, Respondent harassed the sister and mother

of the Petitioner by saying, “Teri Behan ka affair kai ladko ke

saath hai” and “Teri maa khud khana nahi bana sakti abi

vo jawan padi hai, main to use goo khilaungi”. Afterwards,

the abovementioned incident became part of the regular activity

of the Respondent and her Parents. Respondent constantly

harassed the mother and sister of the Petitioner throughout the

period of stay.

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g.) Threat to file fake case of dowry against the Petitioner and

his family:

The Respondent and his family have adopted all the measures to

harass the Petitioner including threat to file fake case of dowry

against the Petitioner and his family. Furthermore, on

26.01.2016, when the Petitioner requested the Respondent and

her family to stop their illegitimate demand and reckless

behavior, the father of the Respondent said, “Tum logo ki

property ko apne bete ke naam kara do nahi to tum sab ko

dehaj ke case main jail main sadne ke liye andar kara

dungi.”

The above incident shocked the conscience of the Petitioner and

made the believe to the Petitioner that the Respondent and her

parents is after the property of the Petitioner and his family and

they can even file fake case of dowry against the Petitioner and

family to grab the property.

h.) Abortion of the Child without the consent of The Petitioner:

That in any matrimonial relationship, both the husband and wife

have equal right over the birth of the infant who is in womb.

However in the month of _____, 201_ the Respondent, without

even informing the Petitioner, aborted the child by taking a

medicine which was given by the parents of the Respondent.

When the Petitioner and his parents got to know about this cruel

act, they protested against the same but the Respondent said,

“mane pehla bachha to bhool se kar liya tha ….isliye maine

medicine le ke bachha gira diya.”

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 The aforesaid incident caused the Petitioner huge pain and

distress as his unborn child was murdered by its own mother

(Respondent).

i.) Indifferent towards the matrimonial obligations and duties:

That the Respondent never cared about her matrimonial

obligations and duties. The Petitioner had a met with an accident

in the month of March _______ and doctor advised him to rest

because of injuries. The parents of the Petitioner are old, thus, it

was the matrimonial obligation of the respondent to look after

her husband. However, to the utter shock and surprise of the

Petitioner, the Respondent didn’t perform her obligation towards

her husband, even refused to give medicine and also failed to

assist in performing daily routines after the accident, in-fact,

after a week of the accident when the Petitioner was still on bed

rest, parents of the Respondent came to the home of the

Petitioner and started creating scene over there with no reason.

When the parents of the Petitioner requested them not to make

noise as the Petitioner was still in not in healthy condition, they

said they don’t care about him. The Respondent also completely

ignored her husband’s poor condition and without bothering

about the wellbeing of the Petitioner, she left the home despite of

repeated requests to stay at home by the Petitioner himself.

Furthermore, it is pertinent to mention that it has been more

than two years since the Petitioner had physical relationship

with the Respondent as whenever the Petitioner tried to have

intercourse with the Respondent, she reacted impassively and

categorically told the Petitioner that unless the property is not

transferred to her name, she would not even let him touch her.

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 In addition to the above, one of the matrimonial obligations of

any wife is to take care of home in the absence of husband,

however, the Respondent never even tried to get involved in

family activity. She also refused to cook the food stating that the

Petitioner’s parents have to cook food and they would feed her as

well.

j.) Threatening the Petitioner on regular basis and beating him

in the Police Station:

That whenever the Petitioner tried to make the Respondent

understand about her matrimonial obligations, she and her

parents threatened the Petitioner and his family to imprison

them in jail on account of false cases using their influence in

police and political circles in Delhi. In-fact on 07.04.2018 when

father of the Petitioner went to his village to supervise the

farming on his agricultural land, he was suddenly surrounded by

the father of Respondent and one Mr. Hetram who were carrying

pistol. They tried to grab father of the Petitioner and even tried to

beat him; however, father of the Petitioner somehow escaped

from their grip and saved his life.

Furthermore, the Respondent and her parents don’t even respect

the law and its institutions as on 15.04.2018 the Respondent

and her mother called the Petitioner into Najafgarh Police Station

for the settlement, however, as in when the Petitioner reached

the Police Station, he was beaten by the mother of the petitioner

in merciless manner in front of the Police Officials that also in

the Najafgarh Police Station only. The lady police constable

somehow saved the Petitioner from the grasp of the mother in

law. That after being beaten by the mother of Respondent in

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 Police Station and also in front of Respondent and other Police

Officials, Petitioner decided that now he cannot have any relation

with the Respondent anymore and lost all his hope for revival of

his matrimonial life. Petitioner also filed a written complaint on

15.04.2018 having Diary No. 21A against the mother of the

respondent for beating the petitioner mercilessly. The copy of the

complaint dated 15.04.2018 having Dairy No. 21A against the

mother of the Respondent in Najafgarh Police Station is attached

as Annexure PW-3.

k.) Forcing the Petitioner to stay away from family members:

That when the marriage took place, it was agreed by both the

parties that the Respondent would stay with the parents of the

petitioner along with Petitioner in order to take care of the old

aged parents of the Petitioner as the Petitioner is the only male

child of their parents and he remains occupied on his job

throughout. However, soon after the marriage, the Respondent

started pressurizing the Petitioner to stay away from his family

members or transfer the property in her name. Whenever the

mother of the petitioner asked the Petitioner to bring some

household articles from the market then the Respondent started

fighting that why the Petitioner is obeying the instruction of his

mother. The Respondent crossed all the lines when she said,

“tum apne maa baap ko kahi virdha ashram mein chodke

aa jao, phir hum aaram se rehenge, ab ye boodhe ho gaye

hai or in se sari property mere naam karva do phir main

tumare liye khana bi bnaungi or tum ko apni saath bhi

sone dungi.”

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 The Respondent always hated the family of the Petitioner and

does not wanted to live with them and always tried to convince

the Petitioner to stay away from his family or else seek transfer

the property on her name.

18. That the above mentioned incidents broke all the hopes of Petitioner

to have a good, peaceful and respectable family life with the

Respondent. Despite Respondent’s several verbal assurances in the

past, the Respondent had never treated petitioner with dignity and

respect which he deserved as a husband and also as a human

being. The Respondent and her parents’ have habit of behaving in

utter disrespect towards the Petitioner in the presence of the

families from both the sides. The Respondent used to constantly

fight, disrespect and rebuke him in front of his family members. Her

lack of empathy and consideration towards Petitioner’s basic need

demonstrating total callousness towards him.

19. That the Petitioner from the day of marriage is not happy with the

Respondent and always subject to the abusive language and metal

torture by the Respondent and her parents which make the life of

Petitioner as hell or even worse than hell. The Petitioner has lost all

his self-respect because of the aforesaid incidence and character

assassinating allegation on him-self and on his sister.

20. That the Petitioner tolerated acts of cruelty of the Respondent with a

view to save their marriage but it was all in vain. The Respondent

and her Parents did not mend her ways and were persistent in

making the Petitioner’s life miserable. In-fact her conduct was

thoroughly supported by her parental family members.

15
 21. That the Respondent, without any just and reasonable cause and

has further utterly failed to fulfill to perform her matrimonial

obligations and duties towards the Petitioner, being his Soul Mate.

The Respondent has further failed and avoided to cooperate with

the petitioner during his rough patch of life, being the legally

wedded wife of the Petitioner, and is thereby depriving him of the

comfort of matrimonial ties. The incident in which the mother of

the Respondent beat the Petitioner mercilessly was the final straw

on the camel’s back and it has forced the Petitioner to seek legal

remedy against her. Therefore, there is no alternative but to

approach this Hon’ble Court for the relief as prayed for in the

petition.

22. That all efforts of persuasion by the Petitioner to rehabilitate the

marriage between him and his wife i.e. Respondent, have been

frustrated and there is no more chance of them living together or

uniting as a happy married couple.

23. That there is no collusion between the Petitioner and the

Respondent regarding this divorce petition.

24. That there has not been any unnecessary or improper delay in filing

this petition.

25. That there have not been any previous proceedings with regard to

the marriage by or on behalf of any party.

26. That there is no other legal ground that why relief sought should

not be granted to the petitioner.

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27. That the Petitioner and Respondent resides within the territorial

limits of the original matrimonial jurisdiction of this Hon’ble Court

and the Petitioner and the Respondent have last resided as

husband and wife at Najafgarh and at the time of filing of the

present petition the Petitioner and Respondent are still the

resident of Najafgarh, New Delhi and the same comes within the

jurisdiction, ambit and scope of this Hon’ble Court, therefore, this

Hon’ble Court has got the jurisdiction to entertain, try and dispose

of this petition and to grant the appropriate relief.

28. That the court fee of this petition is Rs. ----/- for the purposes of

the jurisdiction and the same has been affixed here on the petition

by the Petitioner.

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 PRAYER:

The petitioner, most humbly and respectfully, prays in the interest of

justice:

A. That the Hon’ble Court may be pleased to grant a decree of divorce

to the petitioner;

B. That the costs of the petition may kindly be awarded to the

petitioner;

C. That any other relief, which this Hon’ble Court may deem fit &

proper in the interest of justice, may kindly be granted in the favour

of the petitioner.

Place: New Delhi. Petitioner

Dated: __.04.2018 (Pawan Kumar)

Filed Through:

Suraj Kumar Singh

SKS & Partners
Advocates & Legal Consultant

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 IN THE COURT OF HON’BLE COURT OF PRINCIPAL JUDGE

FAMILY COURT, DWARKA, NEW DELHI

H.M.A. CASE NO. _______ OF 2018

Pawan Yadav
S/o Sh. Ram Sarup
R/o 25//1, Ground Floor
Khasra No. 21/23, Block-P,
Dharampura, Najafgarh
New Delhi – 110043 …………… Petitioner

Versus

Asha Yadav
W/o Pawan Yadav
R/o H. No. – 176, G – Block,
Gali No. – 8, Prem Nagar,
Najafgarh, New Delhi – 110043 …………… Respondent

AFFIDAVIT

I, Pawan Yadav, S/o Sh. Ram Niwas aged – 29 years S/o Sh. Ram Sarup

present residing at Flat No. 25/1, Ground Floor, Khasra Number-21/23,

Block-P, Dharampura, Najafgarh, New Delhi-110043 do hereby solemnly

affirm and declare as under:-

1. That I am legally wedded husband of the Respondent Mrs.

Asha Yadav and well conversant with the facts of the petition

and thus competent to depose this affidavit. The marriage was

solemnized on the 28.03.2015, according to Hindu rites,

customs and ceremonies.

2. That an accompanying petition under Section 13 (ia) of The

Hindu Marriage Act, 1896 has been drafted under my

instructions and the contents whereof may be read as part

and parcel of this affidavit.

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 3. That the contents in the petition are true and correct to my

knowledge and belief and nothing has been concealed therein.

DEPONENT

VERIFICATION

I, Pawan Yadav, deponent do hereby solemnly verify that the contents

of my above affidavit are true and correct to the best of my knowledge,

no part of it is false and nothing material has been concealed therein.

Verified on ____ April, 2018 at New Delhi.

DEPONENT

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 IN THE COURT OF HON’BLE COURT OF PRINCIPAL JUDGE

FAMILY COURT, DWARKA, NEW DELHI

H.M.A. CASE NO. _______ OF 2018

Pawan Yadav …………… Petitioner

Versus
Asha Yadav …………… Respondent

VAKALATNAMA
KNOW ALL to whom these present shall come that I, Pawan Kumar, the Authorized
Representative of the above named Petitioner, do hereby appoint……
SKS & Partners
Advocates & Legal Consultants
Chamber No.565, Saket Court Complex, New Delhi-17
Suraj Kr. Singh (D-1861-2008), Abhay Singh (D-4524/2016), Bharat Singh (D-2359/2017)
& Navin Kumar (D-6311/2017)
Ph.:-9810329829
(herein after called the advocate/s) to be my/our Advocate in the above noted case authorised his :-
To act, appear and plead in the above-noted case in this Court or in any other Court,
Tribunal in which the same may be tried or heard and also in the appellate Court including High
Court subject to payment of fees separately for each court by me/us.
To sign, file, verify and present pleading, appeals, cross-objections or petitions for
executions review revision, withdrawal, compromise or other petitions or affidavits or other
documents as may be deamed necessary or proper for the prosecution of the said case in all its
stages subjects to payment of fees for each stage.
To file and take back documents, to admit and/or deny the documents of opposite party.
To withdraw or compromise the said case or submit to arbitration any differences or
disputes that may aries touching or in any manner relating to the said case.
To take execution proceedings.
To deposit, draw and receive monthly cheques, cash and grant receipts thereof and to do all
other acts and things which may be necessary to be done for the progress and in the course of the
prosecution of the said case.
To appoint and instruct any other Legal Practitioner authorizing him to exercise the power
and authority hereby conferred upon the Advocate whenever he may think fit to do so and to sign
the power of attorney on our behalf.
And I/We the undersigned do hereby agree to ratify and confirm all acts done by the
Advocate or his substitute in the matter as my/our own acts,, as if done by me/us to all intents and
proposes. And I/We the undertake that I/We or my/our duly authorized agent would appear in
Court on all hearings and will inform the Advocate for appearance when the case is called. And
I/We the undersigned do hereby agree not to hold the advocate or his substitute responsible for the
result of the said case. The adjournment costs whenever ordered by the Court shall be of the
Advocate which he shall receive and retain for himself. And I/We the undersigned do hereby agree
that in the event of the whole or part of the fee agreed by me/us to be paid to the advocate
remaining unpaid he shall be entitled to withdraw from the prosecution of the said case until the
same is paid up. The fee settled is only for the above case and above Court. I/We hereby agree that
once fee is paid, I/We will not be entitled for the refund of the same in any case whatsoever and if
the case prolongs for more than 3 years the original fee shall be paid again by me/us.
IN WITNESS WHEREOF I/We do hereunto set my/our hand to these presents the
contents of which have been understood by me/us on this _rd day of April 2018.
Accepted subject to the terms of the fees.

Suraj Kumar Singh, Abhay Singh, Pawan Yadav

Bharat Singh & Navin Kuma Client

Advocates

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