IN THE COURT OF THE DISTRICT JUDGE AT DELHI

H.M.A. PETITION NO. 177 0F 1777

IN THE MATTER OF:

MRS.. YUNA SINGH w/o MR. YUVA SINGH

r/o of Vasant vihar, A13, New Delhi PETITIONER

Versus

MR. YUVA SINGH s/o Natwar Singh

r/o of Vasant vihar, A13, New Delhi RESPONDENT

PETITION FOR DISSOLUTION OF MARRIAGE BY A DECREE OF DIVORCE

UNDER SECTION 13 (1) (i-a) AND (i-b) OF THE HINDU MARRIAGE ACT, 1955

MOST RESPECTFULLY SHOWETH :

The petitioner, above named states as under:

1. That marriage of the Petitioner and the Respondent was solemnized on 1st April, 2018
at Delhi according to Hindu rites and ceremonies. The marriage was registered with
the Registrar of marriage at Delhi. Certified copy of the extract from the concerned
register is attached herewith as Annexure P-1.

2. That the status and place of residence of the parties to the marriage before the
marriage and at time of filing of this petition is given as under:

HUSBAND

i) Before Marriage
Age- 28 years
Residence- A13, Vasant vihar, New Delhi
Status- Single

ii) At the Time of Filing the Petition

Age -32years
Residence- A13, Vasant Vihar, New Delhi
Status- Married
WIFE

i) Before Marriage
Age- 27 years
Residence- A15, Dlf Phase 1, Gurugram
Status- Single

ii) At the Time of Filing the Petition

Age- 31years
Residence- A13, Vasant vihar, New Delhi
Status- Married

3. That out of the wedlock, the Petitioner gave birth to one son named Ashu Singh aged
3 years.

4. That after the marriage, both the parties lived together at the matrimonial house in
Delhi for sometime and thereafter the Respondent moved to Bangalore for a new job
on 2nd april 2020, leaving the Petitioner behind and her young son to live with his
parents.

5. That ever since the Respondent moved to Bangalore, he physically deserted the
Petitioner and has not taken care of her and her young son and she had to make out a
living for herself and for the maintenance of her son.

6. That the parents of the Respondent are also unable to maintain the Petitioner and her
children due to their old age and meager resources.

7. That soon after the wedding the Petitioner found out that the Respondent is a habitual
drunkard and spends most of his earning on his drinks and on several occasion the
Respondent even took some of the Petitioner’s jewellery and disposed them off
without her permission and used the proceeds for his such pleasures.

8. That soon after the wedding day the Respondent and his parents started demanding
expensive presents from the Petitioners family including a new car and a new
apartment as the Respondent wanted to acquire as much comforts for himself and his
parents . They continued to pester the Petitioner to fulfil such demands.

9. That since the Parents of the Petitioner were not able to fulfil such demands of the
Respondent, the Respondent always ill-treated and abused her as well as her parents
by calling them abusive names and also used unparliamentary language in presence of
his friends , relations and neighbours, causing the Petitioner mental harassment .
10. That the Respondent has, in spite of repeated phone calls and messages from the
Petitioner never cared to send a single rupee for maintenance of herself or her son
ever since he moved to bangalore.

11. That for the last year the Respondent has started making false allegations of adultery
and infidelity towards the Petitioner, although the petitioner herself feels that the
Respondent has not been faithful to her and neither cares or wants to keep her as his
spouse anymore. He has even send messages to that effect to his parents and relations,
which have degraded and defamed the Petitioner.

12. That after repeated request by the Petitioner ,the Respondent took her to his rented
residence in Bangalore to live with him and thereafter the Respondent again
mal-treated her and slapped her on several occasions.

13. That after staying 3 weeks with the Respondent in Bangalore, the Petitioner had to
leave and return to Delhi as she could not bear such maltreatment anymore.

14. That while at Bangalore , the Petitioner also learnt that the Respondent was interested
in some other women from his office and therefore suspected the reason for
maltreatment towards her.

15. That for last more than two years, the parties have not cohabited at any place and even
though the Respondent has met the Petitioner for some days at Delhi, he never invited
the Petitioner for cohabitation.

16. That in these circumstances, the Petitioner has been deserted by the Respondent for
the last more than 2 years and has been treated with cruelty for even a longer time.

17. That all efforts by the Petitioner to rehabilitate the marriage between the parties have
been frustrated and there is now no more chance of the parties living together or
uniting as a happy married couple.

18. That the Petitioner has not in any manner been accessory to or connived at or
condoned the acts of cruelty complained of.

19. That the Petition is not presented in collusion with the Respondent.

20. The Petition is being presented without any unnecessary or improper delay on the part
of the Petitioner.

21. That there is no legal ground as to why the decree prayed for should be not granted in
favour of the Petitioner.

22. That no litigation has taken place between the parties to the Petition earlier.
23. That the marriage between the parties was solemnized at Delhi. The Hon’ble Court
therefore has jurisdiction to entertain and try this Petition.

24. In the facts and Circumstances of case mentioned herein above this Hon’ble Court
may graciously be pleased to :

PRAYER

The Petitioner, therefore prays:

a) For grant of decree of Divorce in favour of Petitioner and against the Respondent; and

b) Any other relief or reliefs which the court may deem proper under the circumstances
be also awarded to the Petitioner .

PETITIONER THROUGH
 VERIFICATION

I, Yuna Singh, the petitioner above named, residing at A13, Vasant vihar, Delhi , do hereby
solemnly declare and say that what is stated in paragraphs 1 to 17 is true to my knowledge
and what is stated in the remaining paragraphs 18 to 24 is stated on information and belief
and i believe the same to be true.
Signed and verified at Delhi on this 4th day of April 2023.

Petitioner
 AFFIDAVIT

I, Yuna Singh, the Petitioner above named, do hereby solemnly declare and affirm as under:

1. That iam the petitioner in the above-noted petition which has been drafted under my
instruction. The contents of the Petition are true and correct.

2. That i and Respondent’s marriage was solemnized on 1st april 2018 at Delhi .

3. That i say that i was single before my marriage to the Respondent and my address at
the time of filing of this petition is A13, Vasant vihar, New Delhi.

4. That i have gone through the contents of the accompanying Petition , i reaffirm the
contents of the Petition, which are not repeated here for the sake of brevity.

5. That the Petition is not being presented in collusion with the Respondent.

6. That the Petitioner has not in any manner been accessory to or connived at or
condoned the acts of cruelty complained of.

Petitioner