In the Court of Family Judge (I), Bhubaneswar

C.P No-_______/2023

Mrs Mukti Biswas, aged 68 years

W/O-Drbabrata Manadal,At/Po-Ramchak, P.S-Khairi
Dist- East Medinipur. Last marital residing place
Qtr no- type 2/2,kendriya Vidyalaya
Staff quarter, Satya Nagar, B.B.S.R
At present Rashmi Enclave ,Plot no. 66/146
Subudhi pur,P.S-Tamando, B.B.S.R,PIN-751028
Dist-Khordha,Contact no-8328819829 ……petitioner
V/S
Debabrata Mondal, aged about 65 years
S/o-Lt. Satish Chandra Mondal,Po-Ramchak,
P.S- Khejurivia Janka, Dist- East-medinipur
Presently residing Debyotinagar college palli
Po-Tetenipara sewli, P.S- Titagarh
Dist-North 24parganas, west Bengal ,
PIN-700121…Respondent …….Respondent

Petition U/S 27(a) (d) of Special marriage Act - 1954 for grant of divorce
The humble petition of
Above named petitioner
Most Respectfully Sheweth,
1. That this is an application for dissolution of marriage held between
parties in 12/06/1987 before the marriage officer West Bengal vide
marriage certificate issued bearing number 165 on dated 12/06/1987.
2. That it is pertinent to mention here that prior to said registration of
marriage, the marriage of the parties had also solemnized at 20 central a
road Anandapury, Barrackpur west Bengal as per their tradition and
customs in presence of their well-wishers, relatives and family of the
respected parties on dt.19/05/1987.
3. That the parties are Hindus and they governed by Hindu law.
4. That while the marriage performed between the parties at that the
petitioner was working as a musical teacher in Kendriya Vidyalaya
Khorda and the respondant working in Ministry of Agriculture
department Central Government, India at Bhubaneswar.

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5. That soon after solemnization of marriage, the parties resided together
as husband and wife at first Khorda in a rented house taken by
petitioner at her service place. The parties happily consummated their
marital relation, belonging to members of Bengali community.
6. That thereafter, due to transfer of the petitioner from khordha to
Kendriya Vidyalaya-1 at satya nagar Bhubaneswar, she allotted her
official type 2 quarter bearing no.2/2 where the parties resided together
as husband and wife. The petitioner gave birth a male child namely sanit
which now 33 year already married and their residing with the petitioner
at her present residence.
7. That in the year 2002, the respondant transfer to the west Bengal. From
2002 to 2007, the repondant coming to Bhubaneswar and keeping his
marital relation with petitioner but since year 2007 they have separated
from each other having no marital relation till today.
8. That the official residiental quarter bearing no.2/2 satya nagar
Bhubaneswar was the last residing place of the parties have separated
from each other finally in the year of 2007.
9. That the respondant was not paying a single pai to the petitioner even
from date of her marriage, rather always extracting money from her
demanding she being his wife should give all of her money and income
to him although respondant getting more salary than the petitioner.
10.That apart from the salary of income, the respondant as lot of residential
and commercial properties at west Bengal whose income is more than
three lakhs per month. The repondnat spending all of his money for
their brother and sister but was not spending any money for petitioner
and her son. The respondant always torturing mentally by showing his
cruel behavior that the petitioner is ugly looking and she is aged than
him . while the respondant transferred from Bhubaneswar to west
Bengal, he was regularly keeping his extra marital relation with other
ladies by showing their photos to the petitioner. He also demanding
divorce from the petitioner for his remarriage. The well-wishers of the
parties several times attempted to settle the disputes between the
parties and for their re inion but it was in vain.
11.That even after separation residing of parties since year 2007 having no
conjugal relation between parties, the respondant through several
communication harassing to the petitioner by giving her mentally
torture with utmost cruel behavior
12.That the petitioner is a retired person and her son not got his job but
maintaining herself and family with all hardship from her little pension

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 income whereas the respondant’s present income is more than three
lakhs per month from his all source income i.e from income of house
property, agriculture property and pension income. Considering the
income of the present respondant, his family should have maintain
equal status but the respondant always neglecting petitioner and her
son.
13.That the petitioner after her retirement having no house to take shelter
has purchased a 2 BHK residential flat in Rashmi Enclave of plot no-
66/146 subudhipur apart from she purchased a small plot at Rajarhatta,
Koikhali. Due to old age of the petitioner she bequeath an will in favor of
her son apprehending danger from respondant
14.That the last residing marital place of the parties of official quarter of the
petitioner bearing no.2/2 satya nagar Bhubaneswar under territorial
jurisdiction of Hon’ble court. The parties have also separated from each
other since from year 2007
15.That there is no necessity to continue the marital relation between the
parties in future, hence this divorce petition filed before Hon’ble court.
16.That there is no collusion between the parties to file this application
17.That on 20/09/2018, 13/11/2018 and 1/12/2018, the respondnat
through her advocate issued several pleader notice threatening to
petitioner. She also gave his reply to the said letters of the respondant
through her advocate. The repondant filed O.A no1731/2022 in central
administration tribunal west Bengal against the petitioner
18.That the cause of action arose on 24/06/2007 when the parties
separated from each other from their resident quarter no.2/2 satya
nagar Bhubaneswar, on 1/12/2018 respondant send advocate notice to
petitioner and lastly when the petitioner received the summon of case
filed by respondant against her of O.A no. 1731/2022.
19.That for purpose of jurisdiction of Hon’ble court, this being the petition
for dissolution of marriage of parties valued of Rs 1000 /-only and this
being the family dispute no court fee required to pay.
20.That therefore the petitioner pray the following reliefs :-
(a) Let an order and decree be passed dissolving the marriage of the
parties held before marriage officer west Bengal on dt 12/06/2007
vide marriage certificate bearing no 165 (under section 13 of Act XLIII
of 1954) along with customary marriage held at 20 central A road,
Anandapury, Barrackpur, west Bengal.
(b) Let permanent alimony of Rs 50 lakhs (fifty lakhs) only be granted in
favor of petitioner against respondent.
 (c) Let the cost of the suit of the proceeding be passed in favor of the
petitioner and against respondent.
(d) Let any other relief’s be passed in favor of the petitioner as deem fit
by Hon’ble court as petitioner is entitle.

B.B.S.R By the petitioner

Date :-

Documents Relied on
1. Marriage invitation card (original).
2. Joint photo of marriage.
3. Marriage certificate bearing no.165 on dt. 12/06/1987.
4. Pleader notice issued by respondant as pleaded.
5. Reply notice of the petitioner.
6. Copy of the case filed by respondent against against petitioner in
west Bengal central administrative tribunal.
7. Electricity bill of the residential flat of the petitioner.
8. Any other document as per pleadings.
9. Oral evidence.

Verification
I, Mrs Mukti Biswas, aged 68 years, W/O-Drbabrata
Manadal,At/Po,Ramchak, P.S-Khairi,Dist- East Medinipur.
Last marital residing place-Qtr no- type 2/2,kendriya Vidyalaya Staff
quarter, Satya Nagar, B.B.S.R At present Rashmi Enclave ,Plot no. 66/146
Subudhi pur,P.S-Tamando, B.B.S.R,PIN-751028, Dist-Khordha,do hereby
solemnly affirm and state that the contents of the above said petition are
correct and I have verified the same and put my signature on
this_____day of _____2023 at court premises.

Bhubaneswar Verificant
Dt:-

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 Affidavit
I, I, Mrs Mukti Biswas, aged 68 years, W/O-Drbabrata
Manadal,At/Po,Ramchak, P.S-Khairi,Dist- East Medinipur.
Last marital residing place-Qtr no- type 2/2,kendriya Vidyalaya Staff
quarter, Satya Nagar, B.B.S.R At present Rashmi Enclave ,Plot no. 66/146
Subudhi pur,P.S-Tamando, B.B.S.R,PIN-751028, Dist-Khordha,, do hereby
solemnly affirm and state as follows:
1. That I am the petitioner in this case.
2. That the facts stated above are true to the best of my knowledge
and on record.

Identified by me Deponent
Advocate