.....................
(or to the Judge of
.................
)
AB
........................................
Petitioner
versus
CB
...........................................
Respondent
XY
...............................................
Co-respondent
The humble petition of AB of (full name
and address)
Sheweth:
1. That the parties to the petition were and are domiciled in India and
Christian by faith and religion.
2. That on the
...........
day of
.................
your petitioner was lawfully
married to CB, then CD, a spinster aged about
................
years at...................
and the said marriage is still subsisting.
3.
That ever since his said marriage, your petitioner lived and cohabited
with his said wife from time to time at various places, viz
....
and lastly
at
............
in or about
.........
and that your petitioner and his said
wife have had several issues of their said marriage, viz.,..........children
named
.......
who are aged.......respectively
and
............
years,
the respective dates of their birth being..........
day of
............
and ..............
day of.............
4.
That during the
............
years immediately preceding the day of ..........XY was constantly, with few exceptions, residing in the house of
your petitioner at...................
aforesaid and that on diverse occasions during
the said period, the dates of
w
hich are unknown to your petitioner, the said
CB in your petitioner's said house committed adultery with the said XY.
State briefly the circumstances from which the petitioner came to the
conclusion as to adultery.
(If the marriage was solemnised out of India, the adultery must be shown to
have been committed in India.
That there was never nor is at present any collusion or connivance
between the petitioner and his said wife for the purpose of obtaining a
dissolution of their said marriage or for any other purpose.)
5.
That your petitioner has not condoned any of the acts of adultery on
the part of the respondent.
..................
by occupation service residing
At
...........
do hereby solemnly affirm and say as follows.