IN THE COURT OF THE PRINCIPAL JUDGE FAMILY COURT , DHANBAD.

ORIGINAL SUIT NO. / 2020

IN THE MATTER OF:-

MR.SANJAY SINGH PETITIONER

VERSUS

MRS. GUNJAN SINGH RESPONDENT

PS. MADHUBAN
Distt. DHANBAD

INDE
X

SRL. NO. PARTICULARS PAGES

1. Petition for Decree of Divorce along with Declaration

2. Address of the parties
3. List of Witnesses
4. List of document along
with Documents
5. Vakalatnama

FILED BY

PETITIONER
THROUGH

PAWAN KUMAR OJHA , Advocate(s)

(Counsel for the Petitioner)
Enrolment No: 571/2011
Chamber/ Office at: LAHBANI DHAIYA
DHANBAD
DHANBAD
DHANBAD
Contact No: 9534129333
E-mail: dhanbad3@gmail.com
Dhanbad:
Dated:
 IN THE COURT OF THE PRINCIPAL JUDGE FAMILY COURT , DHANBAD.

ORIGINAL SUIT NO. /2020

IN THE MATTER OF:-

Mr.SANJAY SINGH ,
S/O PREM KUMAR SINGH ,
R/O PULWARITAND
KHARKHAREE P.S-MADHUBAN
KATRAS-DHANBAD PETITIONER

VERSUS

Mrs. GUNJAN SINGH ,

D/O Shri KAMAKHYA SINGH ,
W/O SANJAY SINGH ,
R/O CHITROLLY
P.O-KANAR
P.S-KHARIA-DIST-CHAPRA(BIHAR_ RESPONDENT

PS. Madhuban
Distt. Dhanbad

PETITION U/S 13(1)(ia) OF THE HINDU MARRIAGE ACT, 1955 (AS

AMENDED UPTO DATE) FOR DECREE OF DIVORCE / DISSOLUTION OF
THE MARRIAGE BETWEEN THE PARTIES.

It is respectfully submitted as under.

1. That the marriage between the parties was solemnized on

20.05.2013 as per Hindu rites and ceremonies, in a very simple
ceremony being held at Vill-Chitrolly P.O- Kanar P.S-Khariya Dist
Siwan Bihar.

2. That the status, age and the place of residence of the parties before /
at the time of marriage and at the time of filing of this Petition were /
are as follows:-

Before the marriage

Husband Wife
Status & Age Residence Status & Residence
Age
Hindu Bachelor R/O Phulwaritand, Hindu Virgin R/O D/o-
Widower Karkharee 21 Years Kamakhya Singh
-41 Years Madhuban, Chitrolly p.o-
(Approx.) Dhanbad Kanar p.s-Khariya
Dist-Chapra
 At the time of filing of petition
Husband Wife
Status & Age Residence Status & Residence
Age
Hindu Married R/O Hindu R/o Kamakhya
46Years Katras Bazar Married Singh Chitrolly
(Approx.) Dhanbad Years p.o-Kanar p.s-
Khariya
Dist-Chapra

3. That the parties have no child, but the three Childeren with the bed
lock with previous wife Priyanka .Previous wife died during
pregnancy. The child/ children is/ are currently residing with the
Petitioner.

4. That the parties have been residing separately since last one year.

5. That the marriage between the parties was without any dowry. The
Petitioner, his parents and/ or any other relative had not taken any
dowry in the marriage, in Cash or kind.But bear the expenses of all
rituals.

6. That the Respondent has already taken away her entire STRIDHAN,
given to the Respondent by both, the Petitioner’s side and/ or the
Respondent’s side and house jewelary, including jewelry, of gold and/
or silver, as also the artificial ones, dresses, sarees worth
10,00,000(Ten Lakhs). She took it away on 16.10.2019 . She has
kept her entire stridhan items at her parents’ house at Chapra(Bihar)
. The jewelry was meager/ small items like nose pin, etc. All the
Jewelry and valuables are with the Respondent as on the date of filing
of this Petition.

7. That the marital relations between the parties have not been very
pleasant and compatible since the day of marriage till the date filing of
this Petition. The reasons for disharmony and non-compatibility are
squarely attributable to the Respondent.

8. That right from the day-one of the marriage the behavior/ attitude of
the Respondent towards the Petitioner, his mother, father, other family
members and relatives has been very insulting/ disrespectful,
quarrelsome, non-co-operative, suspicious, rude, insulting, adamant,
dominating, high tempered, aggressive, violent and suicidal. The
Respondent has given the Petitioner lots and lot of mental tension
almost every day, by her acts of commission and omission, refusing to
perform any of her matrimonial obligations. She has treated the
Petitioner with cruelty, in the following ways and manner:

INSULTING, DISRESPECTFUL, RUDE, HIGH TEMPERED,

AGGRESSIVE, VIOLENT, WHIMSICAL AND QUARRELSOME
ATTITUDE OF THE RESPONDENT:

That the facts and circumstances of this case leading to the filing
of the present Petition are as under:-

I. That the Respondent would not respect anybody in the house, not
even the mother and father of the Petitioner. On the contrary, she
would quarrel and insult the Petitioner publicly every other day.
She would not spare even his mother. The former used to quarrel
with and insult the latter every now and then for no fault of the
latter. The Respondent used to talk very rudely and would insult
the aged parents of the Petitioner at the drop of the hat. That the
Respondent quarreled with the Petitioner and his mother without
any provocation.

II. That the Respondent was very whimsical. She used to break
house hold items at the drop of hat and without any provocation.

III. That due the rude and insulting behavior of the Respondent
towards the parents of the Petitioner, using physical force towards
petitioner & the Children’s and parents his Parents completely
disowned the Petitioner..

ADAMANT AND DOMINATING ATTITUDE:

IV. That the Respondent was very adamant. She was hell bent on
living separately from the parents of the Petitioner. Not only that,
she demanded from the Petitioner a separate residence, clearly
specifying that the house should be near her mother’s house and
away from the house of the parents of the Petitioner.

V. That the Respondent used to dominate the Petitioner in

everyhouse hold affair, be it small or big, thereby not at all giving
 him any space, clearly leaving him with no other choice but to
suffer and sustain mental torture in silence.

NON-CO-OPERATIVE ATTITUDE:

VI. That the Respondent was thoroughly non-co-operative. She

refused to perform her matrimonial obligations making every trivial
household thing an issue. However, the Petitioner continued to be
supportive and co-operative, discharging all his matrimonial
obligations, thinking that good sense will prevail upon the
Respondent sooner than later.

SUSPICIOUS ATTITUDE:

VII. That just as if what is averred hereinabove was not enough, the
Respondent also used to torture, harass and humiliate the
Petitioner privately and publicly by alleging that he had affairs with
other women. The Respondent used to level this allegation despite
the fact that she knew it very well that the Petitioner had no such
relation, the Petitioner being person of principles and morals.

SUICIDAL/ REVENGEFUL ATTITUDE:

VIII. That at times, and very often, the Respondent used to threaten to
commit suicide by pulling a knife from kitchen and putting it near
her wrist. She also used to threaten on and off that she will kill the
Petitioner she attempted for suicide in year 2013 itself .

IX. That for some time now, the Respondent was scaring the
Petitioner by threatening him that she is going to get his entire
family falsely implicated in false criminal cases, for dowry demand
and domestic violence.
 REFUSED TO PERFORM MATRIMONIAL OBLIGATIONS:

X. That the Respondent has not been performing any of her

matrimonial obligation. She has also been refusing to do any
house hold chorus. She has not been preparing meals, breakfast,
lunch, dinner, for the Petitioner.

ACUTE HABBIT OF TALKING ON PHONE/ MOBILE:

XI. That the Respondent talks to her mother on phone several times in
a day. The mother of the Respondent has also threatened the
petitioner of falsely implicating in false criminal Cases.
-The online purchase habit from Amazon,Flipcard,Maxiso
destroyed the finance balance and ultimately mental stress to
petitioner .

OTHER RELEVENT FACTS

XII. Kalyani Singh Aged about -18 years studing in Allhabad university

XIII. Surya Pratap Singh aged about-16 year studing in Denobili Schoo

XIV. Twinkle singh aged about-09 years studing in Denobili School Dhn

Uses physical and Mental Torture about all children.

9. That the Respondent has committed the above said acts of cruelty on
the Petitioner knowingly, intentionally, willfully and deliberately.

10. That the Petitioner has sought the intervention of the parents and
relatives of the Respondent, however, they have never taken any
interest in the affairs of the parties. The Petitioner has made all efforts
and has exhausted all the avenues to bring normalcy in his married
life, however all has gone in vain.On dated 29.10.2019 the family
members of respondent put the gun on head.
11. That the marital relation of the parties has been damaged beyond
repair. There is no chance of any patch up between them.
Consequently the marriage between the parties is irretrievably broken.

12. That in view of the facts and circumstances, as narrated here-in-

above, the Petitioner has been left with no other alternative but to seek
the remedy through the Court of law. Hence this Petition.

13. That this petition is not being presented in collision with the
Respondent.

14. That no such petition was / has ever been filed by the Petitioner
against the Respondent in this Court or any other court.

15. That the Petitioner has not condoned the above said cruelties
committed by the Respondent on him.

GROUNDS

16. That the Petitioner, seeks from this Hon’ble Court the dissolution of his
marriage with the Respondent on the following grounds amongst
others:-

(a) BECAUSE the Respondent has since solemnization of the

marriage of the parties treated Petitioner with cruelty.

(b) BECAUSE there is a complete breakdown of the marriage

between the parties. There is no chance of any patch up
between them.

FORMAL/ LEGAL AVERMENTS

17. That the above said acts of the Respondent tantamount to Cruelty,
and is very well covered under Section-13(1)(ia) of the Hindu Marriage
Act, 1955.

18. That the cause of action to file the present petition arose on
16.10.2019, since when the parties are living separately. It further
arose on each and every day and date prior and after when the
Respondent subjected the Petitioner to cruelty by her acts of
commission and omission, as mentioned in this Petition.

19. That this Hon’ble Court does have the jurisdiction in the matter to
 adjudicate upon and decide the same.

20. That this Petition is being instituted within the period of limitation, as
the same is filed before this Hon’ble Court without any unnecessary
and/or improper delay.

21. That the Petition has also been filed in compliance of the provisions of
the Hindu Marriage Act, 1955. There is no legal ground or bar to the
grant of relief as prayed for in this petition.

22. That the appropriate court fee has been affixed on this Petition.

It is therefore most respectfully prayed that this Hon’ble Court be pleased to;

a )Pass a decree of Divorce &

g dissolution of the marriage

between the parties.
PRAYER

a) Pass any other and / or further

order(s) in the favour of the
, Petitioner and against the
…... Respondent, which this Hon’ble
gra Court may deem fit and proper in
nt / the interest of Justice and fair
dire play.
ctin
 IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE, NEW DELHI
O.S PETITION NO. / 2020

IN THE MATTER OF:-

MR. SANJAY SINGH PETITIONER

VERSUS

MRS. GUNJAN SINGH RESPONDENT

DECLERATION
SANJAY SINGH, S/O SH PREM KUMAR SINGH AGED ABOUT-

R/O Katras Bazar,Dhanbad,Jharkhand.

I, the Deponent, do hereby solemnly affirm and declare as under:-

1. I am the Petitioner in the above noted / accompanying Petition U/S-

13 of the Hindu Marriage Act, 1955, for decree of divorce/ dissolution
of the Marriage between me and the Respondent, and therefore am
competent to file this Affidavit in support of the Petition.

2. The accompanying Petition has been drafted by my counsel as per

my instructions. I have gone through and understood the contents of
the Petition and found the same to be correct.

3. That I reaffirm that I had married to the Respondent. I have filed the
accompanying Petition, as the Respondent has committed cruelty on
me, as stated by me in the accompanying Petition. She did so
intentionally, willfully and deliberately. The contents of the petition
also form part and parcel of this petition, which have, however, not
been repeated herein for the sake of the brevity.

4. That I affirm that there is a complete breakdown of the marriage

between me and my wife. There is no chance of any patch up
between us.

5. That I affirm that I have not presented this petition in collision with the
Respondent.

6. That I affirm that I have not condoned the cruelties committed by the
Respondent on me.

DEPONENT

VERIFICATION
Verified at New Delhi on 03.03.2020 that the contents of the above noted
Declaration are true and correct to my knowledge and belief and nothing
material has been concealed there from.

DEPONENT