Matrimonial Causes under Hindu Marriage Act 1955
Petition of Divorce
                         In the Court of……..at…………
           Matrimonial Jurisdiction
In the matter of s. 13 of the Hindu Marriage Act 1955
In the matter of………..
AB………….Petitioner
versus
CD………..Respondent
EF………..Co-respondent
The humble petition of……… (full
name and address)
Most Respectfully Sheweth:
1. That at all material times the parties to proceedings were and are Hindus governed by the Hindu Marriage Act 1955.
2. That on the…….day of……….your petitioner was duly married to CD at etc.,……….and the said marriage was solemnised according to Hindu rites and customs. (An extract from the Marriage Register or an affidavit duly attested to be filed.)
3. That ever since the said marriage your petitioner and the said CD lived together as husband and wife at……..until the…….day of….(state reasons of separation).
4. That the following are the issues of the said marriage (state name, address, date of birth, age and sex).
5. ……………..That on diverse occasions between…………and…..the respondent committed adultery with………………..at……………against the wish of your petitioner and in spite of her protests.
6…………………….That your petitioner has come to know of the same on…………….and since then she has not in any manner been accessory to or connived at or condoned such adultery.
7. (When the applicant is the wife.) That the said CD had married on the…………..day of………Sm……..and she is now living at……………
Or
That the said CD has, since the solemnization of the marriage, been guilty of rape (or sodomy or bestiality) on……………
8. That there is no collusion or connivance between the parties with
respect to the subject-matter of the present petition.
9. That there were no previous proceedings between the parties relating
to their marriage.
10. The marriage was celebrated at…………….or the parties last lived and resided at………………………..within the jurisdiction of this Court.
Your petitioner therefore prays that the court might be pleased to pass a decree dissolving the marriage of your petitioner with CD.
Signed                                                                                                   AB
Verification
I, AB, wife of CD aged about………..years by occupation service residing
At………..do hereby solemnly affirm and say as follows:
I am the petitioner above-named and I know and I have made myself acquainted with the facts and circumstances of this case.
The statements in paragraphs 1 to 10 are true to my knowledge and belief.
I sign this verification on this………..day of……………at the Court
House at………………
Signature of AB
Before me                                                    Signature of Advocate
Notary