A PETITION FOR DIVORCE ON THE GROUND OF CRUELTY US 13 (l)(ia) OF THE HINDU MARRIAGE ACT 1955
IN THE COURT OF THE CIVIL JUDGE, SENIOR DIVISION, PUNE
AT PUNE
Marriage Petition No.	/ 200_
Smt.	W		)
age 30 years, occupation - service,	)        Petitioner
resident of C/o Shri DAD,	)
At/PO Rajgurunagar, Taluka Khed,	)
District Pune.
Versus
Shri	.. H		)
age 35 years, occupation - business,
resident of At/PO Manchar,	)        Respondent
Takuka Ambegaon,	)
District Pune.	)
A PETITION FOR DIVORCE U/S 13 (1) (ia) OF THE HINDU MARRIAGE ACT 1955
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The petitioner abovenamed submits this petition, praying to state as follows:
1. That the petitioner is the wife of the respondent, their marriage having been solemnised at Pune on___according to the Hindu religion, vaidic rites and ceremonies.
2. That the petitioner, prior to the marriage, was known by her maiden name as Kumari Sonali, while there is no change resulted in the name of the respondent.
3. That after the marriage, the parties hereto cohabited and resided together for about two years.   However, out of their wedlock, the petitioner begot no child.
4. That at the time of the settlement of the marriage, the respondent and the elders from his family concealed from this petitioner and her parents that the respondent was neither in any service, nor had he been doing any particular business, and the petitioner and her parents realised it too late when the time has already been passed by, and there was then nothing which could have been done in the matter.
5. That this petitioner even prior to her marriage had been in Central Government working as a Telephone Operator in the Telephone Exchange, Rajgurunagar, and since the respondent was earning nothing, all the household expenses of the family of the respondent had been required to be met out of the salary of this petitioner alone.
6. That despite the fact that the whole amounts of salary of this petitioner had always been handed over to the respondent every month, the respondent and the other members of his family started to make some tall claims and huge demands through this petitioner from her parents, and with view to meeting one such demand, the petitioner purchased a colour TV set on hire-purchase basis from the shop of M/s Jai Hind Agency, Laxmi Road, Pune, and all the principal amount as well as interest due thereon to the tune of Rs. 20,000/- has already been paid by the petitioner alone.
7. That even though immediately after her marriage to the respondent, the petitioner learnt that the respondent had been a careless man doing nothing in life, the petitioner being brought up in a cultured family and of a respectable clan, she stayed on and cohabited with him and mutely suffered all the tensions,  tortures and cruelty caused by the respondent.
8. That the respondent has also been in the habit of consuming alcohol, and  under the influence of drink and  his parents particularly mother, he used to beat the petitioner up mercilessly and thereby he not only ill-treated the petitioner but also caused her mental and physical cruelty to a great extent, and hence, this petition.
9. That the petitioner submits for the kind information and consideration of this Hon'ble Court that there have been quarrels caused by the respondent, and every time, he made out a very poor show, without caring for the prestige of the family and the character and reputation of this petitioner.
10. That this petitioner also submits that with a view to saving the married life of the parties, she tried her best to bring about improvement on the part of the respondent, but instead of any positive response, the things have gone from bad to worst, and the petitioner became only unhappy.
11. That on account of severe mental cruelty, the petitioner was finally compelled to leave the house of the respondent against her wish, and she has now been residing with her parents also against their wish since December 200_
12. That the parties hereto reside within the local limits of the jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to try and decide this petition
13. That the parties hereto have been residing separately for the last more than two years, and hence, this petition is maintainable.
14. That this petition being chargeable with a fixed rate of court fee, the same is paid herewith.
15. That the petitioner, therefore, prays that -

(a) The marriage between the parties hereto be dissolved by a decree of divorce;
(b) The petitioner be paid her costs from the respondent, and
(c)  Any other orders in the interest of justice be kindly passed.
Pune,
Sd/- W
Dated: __..	.	PETITIONER
Sd/-   xXx ADVOCATE FOR PETITIONER