NOTICE TO A WIFE ON BEHALF OF HER HUSBAND

B. E. AVHAD,                                                                16/1 Siddharth Chambers,
B. Com. (Hons);                                                               LL. M., Erandwana, Karve Road,
ADVOCATE.                           Phones: 5431424,5431434
                                                                                         PUNE 411 004
                                                                                          Dated
To
NOTICE(BY REGISTERED A.D.)
Smt. 
C/O Shri B............A........
Nehrunagar, M. G. Road, SURAT, GUJARAT STATE.
Madam,
Under instructions from and on behalf of my client, Shri YES, of 55 Amrut Apartments, Shivajinagar, Pune 411005, I have to address you as follows: 
1. That you are a legally wedded wife of my client, your marriage having been solemnised at Surat on 31st December 200.. according to Hindu religion, vaidic rites and ceremonies.
2. That after your marriage to my client, you resided and cohabited with my client for about one and a half years, in the beginning at Mumbai and lastly at Pune.
3. That out of the said wedlock, you have begotten a daughter named Buzy, on....
4. That during the period of your cohabitation with my client, you were always in the habit of going away from my client and staying with your parents against the wish of my client and at your own sweet will.
5. That during the said period of cohabitation, you always insisted upon my client that he should live apart from the other members of his family, and you also used to detest not only the parents of my client and the other members of his family, but also my client in person, and such an attitude on your part was antisocial and inhumane, too.
6. That on........, when your uncle had come to Pune, you left the house of my client under the pretext of attending the betrothal ceremony of your cousin, and at that time, you had put on your person all the gold and other ornaments and jewellery of the family of my client.
7. That while leaving the house of my client, you also told my client and his parents that you would return back within a couple of days, and you had accordingly asked the mother of my client to let the baby with the family of my client, and when you did not turn up to Pune for about a fortnight, my client and his parents came to a tacit conclusion that on..... Itself, you had in mind your ulterior motive to leave the company and society of my client and never to resume cohabitation anytime thereafter, and leaving a nine-month old baby at the mercy of nobody, it was cruelty on the part of your motherhood, and by such an act, you have brought not only a bad name to the whole of your clan but also cursed the womanhood, as a whole.
8. That my client has no words to describe such very indifferent attitude and nature on your part, which is simply disgusting.
9. That since the time you have left the company and society of my client and the young baby, my client, his parents and relatives made all possible and sincere efforts to bring you back for cohabitation with my client, but you have paid no respect to your own conjugal relationship with my client, and it appears that after passing all these days away from my client and the young innocent soul, you have been careless and indifferent towards the domesticity of my client, and my client, while bringing up the child and looking after her welfare and health, has lost all his hopes to have a wise thought on your part for resuming cohabitation with him.
10. That my client my client also further says that the act of leaving the society of my client without any reasonable ground amounts to cruelty and desertion, which is illegal on your part, and you are really answerable for the same.
11. That taking into consideration the very delicate relationship between my client and yourself and also giving a second thought to the future of the baby, my client does hereby call upon you to resume cohabitation with him WITHIN TEN DAYS from the receipt hereof, failing which my client shall take it for granted that you are no more sincere and interested in cohabitation with my client, and my client would then be constrained to take against you an appropriate legal action including filing a petition for divorce and recovering from you gold ornaments and jewellery, and in that event, you shall have to thank none but yourself for all the faults and follies on your part alone, which please note.
                                                                                                              
                                                                                                                Yours faithfully,
                                                                                                                (B. E. AVHAD)
                                                                                                                 ADVOCATE