Plaint
Plaint
Plaint
VERSUS
Mr Arjun Yadav,
#123, TMA Pain Road, Bengaluru,
Karnataka. ..........DEFENDANT
1. Petitioner got into marriage with the defendant on.11th may 2014 according to Hindu rites and customs
2. both the Plaintiff and Defendant belong to Hindu religion and both were in a relationship prior to getting
married.
3. Petitioner and the Defendant thereafter lived and cohabited as husband and wife at the residence of
4. The plaintiff and the defendant have two Children from the said marriage named Rahul Yadav ( son )
5. The defendant although started of well in their marital life, but 3 years later turned Abusive, consistently
subjecting the plaintiff to both mental and physical abuse in an inebriated state.
6. The plaintiff who works at a reputable Multinational Company has a monthly remuneration of Rs
80,000/- where as the defendant after covid affected his business rendering him to earn a monthly
remuneration of Rs 45,000/- which manifested his envy in the form of abuse both physical and mental.
7. The defendant also turned alcoholic and frequently in his state of inebriation feud with the plaintiff,
creating an unsafe and toxic environment for not only the plaintiff but also the kids.
8. The parents of the Defendant who at the start of the marriage were caring and loving after this phase
only added to the Mental torture on my client by constantly demanding more dowry.
9. The Defendant at every attempt at communication and resolution never reciprocated in any productive
manner continuing the abuse and the subjugation of the plaintiff to his whims and fancies which is
10. Plaintiff states that since it had become very difficult for the Plaintiff to continue to live with the
11. The Plaintiff seeks to get Divorced to the defendant under Section 13 of the Hindu Marriage Act, 1955.
12. Plaintiff states that it is the duty of the Respondent to maintain his child. Plaintiff is entitled for an order
from this Hon’ble Court directing the Respondent to pay interim and permanent maintenance of Rs. Rs
50,000/- per month to the son of the Plaintiff and Defendant Under Section 24 and Section 25 of the
13. The Plaintiff has never once condoned this behaviour of the Plaintiff and his parents and has
undergone this subjugation only for the sake of stability for her children, but now is seeking the
14. There is no suit pending in any Court of India between the Plaintiff (Mrs Riya Yadav) and Defendant (Mr
16. Petitioner submits that this Hon’ble Court has jurisdiction to try and entertain this Petition.
19. Petitioner will rely on the documents a list whereof is annexed herewith.
Plaintiff therefore, Prays :-
(a) that this Hon'ble Court be pleased to pass a decree of divorce dissolving the marriage of the
(b) that this Hon'ble Court be pleased to direct the Respondent to pay permanent maintenance
of Rs. Rs 20,000/- per month to the Children of the Plaintiff and defendant;
And
that such other and further reliefs as the nature and circumstances of the case may require be
granted.
I, Riya Yadav of Bengaluru, Indian Inhabitant, the Plaintiff abovenamed do hereby solemnly
declare that what is stated in the foregoing paragraphs 1 to 19 is true to my knowledge and what is stated in
the rest of the Plaint is on the information and belief and I believe the same to be true.
VERSUS
AFFIDAVIT OF MRS RIYA YADAV, W/O MR ARJUN YADAV AGED ABOUT 26 YEARS
I, Mrs Riya Yadav, the deponent hereinabove do hereby solemnly affirm and state hereunder:
1. I am an adult citizen of Bengaluru, Karnataka, competent to make this affidavit, and have personal
knowledge of the matters stated herein.
2. The statements made in this affidavit are true and correct to the best of my knowledge, information,
and belief.
3. I say that the accompanying Suit has been drafted and filed by my counsel upon my
instructions and contents of the same are true and correct.
4. I say that the documents filed along with plaint are true copies of originals.
DEPONENT
VERIFICATION:
I, Riya Yadav, do hereby verify on this 17 day of March, 2024 at Delhi that the contents of the
above said affidavit are true and correct to my knowledge and information and nothing
material has been concealed therefrom.
DEPONENT