........................
Petitioner
versus
CD
.........................
Respondent
The humble petition of
.......
of
....
No
............
(full name and address)
Most Respectfully Sheweth:
1.
That at all material times and at present the parties to the proceedings
were and are Hindu and so governed by the Hindu Marriage Act 1955.
2.
That on the
..........
day of
...........
the applicant was duly
married to CD at
..............
and the said marriage was solemnised according
to Hindu rites. (An extract from the Marriage Registrar or an affidavit duly
attested to be filed).
3.
That the following are the issues of the said marriage (name, date of
birth, age and sex).
4.
That ever since the said marriage and until the
..........
day of
...........
the applicant and the said CD lived and cohabited as husband and
wife at etc
......
when he withdrew himself from the society of the
applicant without any reasonable or probable cause and thereby deserted her to all intents and purposes.
5.
That from and shortly after the marriage the said CD habitually and
with very few exceptions conducted himself towards the applicant with
severe harshness and cruelty and at times abused her in most filthy language
(state particulars of cruelty).
6.
That the applicant has not in any manner been accessory to or connived
at or condoned any of the said acts of CD.
7.
That the said CD further falsely, maliciously charged the applicant as
having committed adultery, abused the applicant in various ways and treated
the applicant with such cruelty as to cause a reasonable apprehension in
the mind of the applicant that it will be most harmful or injurious for the
petitioner to live further with the said CD.
8.
That there were no previous proceedings between the parties and
there is no collusion between the applicant and CD with respect to the
subject-matter of the present petition.
9.
That the applicant has come to court with the greatest promptitude
and least delay (in case of delay the same must be explained).
10.
That this court has jurisdiction to entertain this application as the
marriage was celebrated at
(the parties reside
or
last resided within the
jurisdiction of this court).
............
day of
.....................
at the Court
House at
...............
Signature of AB
Before me
Signature of Advocate
Notary