PETITION FOR DIVORCE BY MUTUAL CONSENT

Draft a Petition
UNDER SECTION 28 OE THE SPECIAL MARRIAGE
for divorce by ACT, 1954.
mutual consent. TO
THE HON'BLE PRINCIPAL JUDGE
AND OTHER JUDGES OF THIS
HON'BLE COURT
 Specimen of Matrimonial Petitions 191
PuE HUMBLE PETITION OF THE PETITIONER ABOVENAMED
uOsT RESPECTFULLY SHEWETH:
On 1st April 20..., the First Petitioner, a Hindu by religion, was
1. lawfully married to the Second Petitioner, a Jew by religion, under
the provisions of the Special Marriage Act, 1954. Hereto annexed
and marked Exhibit 'A' is a copy of the Marriage Certificate dated
tst April 20.... evidencing the said marriage between the Petitioners.
After the said marriage, the Petitioners cohabited at the First
Petitioner's house. However, within a few weeks after the said
mariage, constant quarrels and altercations began to take place
between the Petitioners, and ultimately on or about the 10th day of
Aoril 20... the Second Petitioner left the First Petitioner's home,
and went to reside separately at Oak Lane, Mumbai, where the
Second Petitioner continues to reside at the date of filing this Petition.
The Petitioners submit that, in the circumstances, the Petitioners
have been living separately for a period of more than one year.
3. The PetitionerS say and submit that they have not been able to live
together and they have mutually agreed that their said marriage be
dissolved by this Hon'ble Court.
4 There are no issues of the said marriage between the Petitioners.
5. There are no collusion or connivance between the Petitioners in
filing this Petition.
6. The Petitioners were married in Mumbai and last cohabited in Mumbai
within the territorial limits of the jurisdiction of this Hon'ble Court.
This Hon'ble Court has jurisdiction to entertain, try and dispose of
this Petition.
7. No other proceedings with respect to the marriage between the
Petitioners have been filed in this Hon'ble Court or in any other
Court in India.
8. The Petitioners have paid the fixed court fees of Rs. .... on this
Petition.
9. The Petitioners will rely on documents a list whereof is annexed hereto.
The Petitioners therefore pray:
(a) That this Hon'ble Court be pleased to decree a dissolution of
the marriage between the Petitioners;
(b) That the costs of and incidental to this Petition be provided for;
and
(c) For such further and other reliefs as the nature and circumstances
of the case may require.
Petition drawn by:
Mr. POR Sd/- ABC
Advocate Sd/- X A C
High Court, Mumbai (Petitioners)
VERIFICATION
(Yerification Clause as in Form No. 1above with necessary alterations)
 VERIFICATION
I, Shakuntala Krishna Sawant, the Petitioner abovenamed, do hereby
solemnly declare and say that what is contained in paragraphs ...to
is true to my knowledge and what is stated in paragraphs..to
stated on legal advice and I believe the same to be true.
Solemnly declared at Mumbai, this
day of November 20 Sd/- S.K. Sawant
Before me,
Registrar/Superintendent,
X & Co.
Family Court, Mumbai.
Advocates for the Petitioner.