DIVORCE SETTLEMENT AGREEMENT

THIS DEED OF SETTLEMENT has been executed on this 24 th Day of February 2023
between Mr.D. Aijay, S/o Mr.V.Dinesh ,resident in No. 52/77, Star lane papapuram,
Agasteesaram(T.k),Kanyakumari District-629401
FIRST PART
AND
Mrs. R.Usha, D/o Mr.S.Rohit , resident in No.36/21,2nd Main road, Silkpuram,Thirunelveli
District -627111 SECOND PART
WHEREAS by statement of plaint filed on 1st February 2023 in the District Court of
Nagercoil under court file number 2023/SD, as amended by an amended Statement of Plaint
therein on effective date 7th February 2023 , Mr.D.Aijay instituted proceedings as plaintiff
against Mrs.R.Usha as defendant in Dissolution of Marriage.

The Parties

1. The Parties will attempt to settle their dispute in good faith. The Parties, their duly
authorised representatives and the Mediator will attend Mediation meetings.. All
communications relating to, and at, the mediation will be without prejudice and confidential

2. Representatives will have the necessary authority to settle the Dispute. The procedure at
the Mediation will be determined by the mediator after consultation with the Representatives.

The Mediator

3. The Mediator will abide by the terms of the mediation Agreement and will be responsible
for:
a)Attending any meetings with any or all of the Parties and their representatives preceding the
Mediation, if requested or if the mediator decides this is appropriate;
b)Drawing up the mediation Agreement, and ensuring that it is signed after the initial
consultation.
c) Organizing a suitable venue and dates;
d) Organizing exchange of the Summaries and Documents;
e) Reading before the mediation each Summary and all the Documents sent to the Parties in
accordance with para 6
f) Determining the procedure after consultation (see paragraph 2 above)
• Assisting the parties in drawing up any written principles of settlement, if so requested;
•Conducting general administration in relation to the mediation as requested by the parties.

4. The mediator will not act for any of the Parties individually in relation to the subject
matter of the mediation in any capacity either during currency of the Agreement or at
any time thereafter.

Other participants
5. Each Party will notify the other Party of the names of those people, witnesses, etc. in
addition to the representatives that in intends will be present on its behalf at the mediation.
Each party, in signing the mediation Agreement, will be deemed to be agreeing on behalf of
both itself and all such persons to be bound by the confidentiality provisions of the Model
Procedure.

Exchange of Information

6. Each Party will simultaneously exchange with the other and send to the mediator at least
two weeks before the mediation or such other date as may be agreed between the

Parties:

A concise summary ("the Summary")stating its case in the Dispute and the relief requested:
Copies of all the documents to which it refers in the Summary and to which it may want to
refer in the mediation ("the documents"). 7. The Parties will try to agree on a joint set of
documents from their respective Documents.

Disclosure and Confidentiality

8. The Parties will make full disclosure to each other and to the mediator during the
mediation of all information and documentation relevant to the issues being mediated.The
mediator shall hold the information and/or documentation so designated in confidence.
9. The Parties agree and understand that the mediation discussion and any documents created
for the mediation process are without prejudice and for the purposes of reaching a mutually
acceptable agreement.

10. The Mediator will not produce any report or testify in any court or arbitration with respect
to what was said in mediation. The Parties will not call the mediator as a witness in any legal
or adjudicative proceeding and will not subpoena any notes or records made by the mediator
in relation to the mediation.

11. The Parties acknowledge that no statutory privilege exists for mediators and that the
Mediator may be required by the Courts to testify despite this Agreement to the contrary.

12. Nothing in this Agreement shall prevent the discovery or admissibility of any evidence
that is otherwise discoverable or admissible, merely because the evidence was presented in
the course of mediation

The Mediation

13. No formal record or transcript of the Mediation will be made, unless otherwise agreed by
the Parties.

14. If the Parties are unable to reach a settlement in the negotiations at the Mediation and
only if all the Representatives so requested and the mediator agrees, the mediator will
produce for the Parties a non-binding written recommendation on terms of settlement. This
will not attempt to anticipate what a court might order but will set out what the mediator
suggests are appropriate settlement terms in all of the circumstances.

Settlement Agreement
1. The Parties declare and approve that they were married on 23/01/2021 at Nagercoil and
that after the Marriage they lived together as Husband and Wife at the residence of The First
Party .
2. The Parties Declare and approve that their Marriage was consensual and Solemnized and
Entered into with the approval of the Parents of Both Parties.
3. The Parties declare and approve that no dowry was taken or given by either party in the
said Marriage .
4. The parties Declare and approve that they have been living separately from each other
Since 20/11/2021
5. The parties Declare and approve that they cannot continue to live as Husband and Wife
under a same Roof .
6. The Parties declare and approve that they have decided to dissolve their Marriage by way
of filing of Petition under Section 13 of the Hindu Marriage act , 1955 for Dissolution of the
marriage by mutual consent .
7.The Parties declare and approve that both the parties have settled all their disputes amicably
through mediation.
8.The parties declare and approve that it has been settled that the Second Party will not claim
any amount on account of maintenance herself from the first Party in future nor will she file
any such claim against the First party in any court of law for grant of maintenance nor file
any criminal case against the first Party.
IN WITNESSES WHEREOF, Both the parties have signed this deed of settlement at
Nagercoil.

Termination

16. Any of the Parties may withdraw from the Mediation at any time and shall immediately
inform the Mediator and the other Representatives in writing upon withdrawal. The
Mediation will terminate when:

a) a breach of the mediation Agreement Party withdraws from the Mediation: or

b) written principles of settlement are concluded and initiated by the representatives: or

in the opinion of the Mediator, it is in the best interests of the Parties that the Mediation be
terminated.

17. The Parties undertake not to take any further steps in any legal proceedings regarding the
issues being mediated while the Mediation is in progress unless the same are required to
preserve rights..

Fees, Expenses and Costs

18. The mediator's fees and other reasonable expenses of the mediation will be borne equally
by the Parties. Payment of these fees and expenses will be made directly to the mediator in
accordance with the mediator's fee schedule and term and conditions of business.
19. Each Party will bear its own costs and expenses of its participation in the mediation,
unless otherwise agreed.

Waiver of Liability

20. The Mediator shall not be liable to the Parties for any act or omission in connection with
the services provided in relation to the Mediation, unless the act or omission is

Signed Party A

NAME Party B

SIGNATURE

NAME

SIGNATURE

MEDIATOR