IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT, JIND
Rajkumar son of Kawar Singh Resident of Village Kalwa Tehsil Pillukhera District
Jind …Petitioner
VERSES
Ritu Wife of Rajkumar daughter of Raj Singh resident of Village Matloda District
Panipat …Respondent
PETITION UNDER SECTION 13 OF THE HINDU
MARRIAGE ACT, 1955 FOR DISSOLUTION OF
MARRIAGE BY A DECREE OF DIVORCE ON THE
GROUND OF ADULTERY AND CRUELTY.
Most Respectfully Submitted:
1. That the marriage between the Petitioner and the Respondent was solemnized on
04.02.2014 at village Matloda District Panipat according to Hindu rites and
ceremonies, and thereafter the parties cohabited as husband and wife.
2. That the status and place of residence of the parties of the marriage before the marriage and at the
time of filing the petition were as follow:-
HUSBAND WIFE
Place of Place of
Status Status
Residence Residence
BEFORE Hindu Village Kalwa Hindu Village Matloda
MARRIAGE Unmarried District Jind Unmarried District Panipat
AT THE TIME OF
Hindu Hindu
FILING THE Do -do-
Married Married
PETITION
3. That the parties were blessed with two children, a son born on 21.11.2016 and a
daughter born on 30.05.2018.
4. That soon after marriage, the conduct of the Respondent changed, and she started
behaving in an indifferent and inconsistent manner towards the Petitioner.
5. That in June 2019, the Petitioner personally witnessed the Respondent signaling
and communicating with one Sumit, a neighboring youth, in an objectionable
manner. Subsequently, the Respondent was found engaged in continuous
telephonic and online communication with the said Sumit.
6. That during Diwali of 2019 at Bhatinda, the Respondent was found indulging in
repeated telephonic conversations and behavioral intimacy with Sumit, ignoring
her marital obligations towards the Petitioner.
7. That in August 2025, the Petitioner recovered WhatsApp and Instagram chats,
photographs, and videos from the Respondent’s mobile phone, which clearly
indicated adulterous relations between the Respondent and the said Sumit. The
same were corroborated from Sumit’s mobile phone as well. Even the minor
daughter of the Petitioner once disclosed that Sumit made video calls to the
Respondent, who instructed the child not to reveal the same to the Petitioner’s
mother.
8. That the Respondent has consistently denied conjugal relations to the Petitioner,
has frequently threatened divorce, and has subjected the Petitioner and his family
members to mental cruelty. Her family members also assaulted the Petitioner’s
parents and relatives and issued threats of dire consequences.
9. That by reason of the aforesaid adulterous and cruel conduct of the Respondent,
the Petitioner has suffered extreme mental agony, harassment, and humiliation,
and the matrimonial bond between the parties has irretrievably broken down.
[Link] the respondent never cared the petitioner never fulfilled her
matrimonial duties toward the petitioner and she was never proved as good
wife for petitioner and dutiful lady for the family and due to aforesaid
reasons it is not possible for the petitioner to live with the respondent under
one roof.
[Link] there is no reason as to why there lie claimed by the petitioner should
not be granted to the petitioner.
[Link] no other similar petition was ever filed by the petitioner in any court of
law.
[Link] the present petition is not being instituted in collusion with the
respondent.
14. That the parties to the petition lastly resided together as husband and wife
at Jind within the territorial jurisdiction of this Hon’ble Court and hence
this Hon’ble Court has got jurisdiction to try and decide the present
petition.
[Link] a Court fee has been affixed hereon.
[Link] an affidavit is attached.
GROUNDS
The present petition is being filed on the following statutory grounds under Section 13 of
the Hindu Marriage Act, 1955:
a. Adultery (Section 13(1)(i), HMA): The Respondent has, after solemnization of the
marriage, voluntarily engaged in sexual and/or illicit relations with one Sumit, a
person other than the Petitioner, which amounts to the matrimonial offence of
adultery.
b. Cruelty (Section 13(1)(ia), HMA): The Respondent has subjected the Petitioner to
cruelty by:
• Denying conjugal relations,
• Maintaining secret and objectionable communications with another man,
• Abusing and threatening the Petitioner with divorce,
• Allowing her relatives to assault and humiliate the Petitioner’s family,
• Creating constant mental agony and harassment.
CAUSE OF ACTION
The cause of action first arose in June 2019 when the Petitioner witnessed the
Respondent in objectionable communication with Sumit and has continued thereafter
with repeated acts of adultery, threats, and cruelty, the latest being in August 2025 when
illicit chats, photographs, and videos were discovered.
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble Court may kindly be pleased
to:
1. Pass a decree of divorce thereby dissolving the marriage between the Petitioner
and the Respondent solemnized on 04.02.2014, on the grounds of adultery and
cruelty under Section 13 of the Hindu Marriage Act, 1955.
2. Grant any other relief which this Hon’ble Court may deem fit and proper in the
interest of justice.
Petitioner
Rajkumar son of Kawar Singh Resident of
Village Kalwa Tehsil Pillukhera
District Jind
VERIFICATION
Verified at Jind that the contents of para nos. 1 to 16 of the plaint above are true and
correct to the best of ours knowledge, belief and information.
Petitioner
Rajkumar son of Kawar Singh Resident of
Village Kalwa Tehsil Pillukhera
District Jind
Through Counsel:
Dinesh Kumar Deswal, Advocate Jind
IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT, JIND
Rajkumar VERSES Ritu
Petition u/s 13 of Hindu Marriage Act.
AFFIDAVIT
I Rajkumar son of Kawar Singh Resident of Village Kalwa Tehsil Pillukhera District
Jind, do hereby solemnly affirm and state on oath as under:
1. That the marriage between the petitioner and respondent was solemnized on
04.02.2014 at Village Matloda District Panipat as per Hindu rites and
ceremonies by way of Sapatpadi. Thus the respondent is legally wedded
wife of the petitioner. The marriage between the petitioner and respondent
was very simple without any pomp and show. The marriage is still substance
and has not been dissolved by any competent court of law.
2. That the facts stated in Paras 1 to 16 of the petition are true to my personal
knowledge and belief and no part thereof is false and nothing material has
been concealed.
PLACE: JIND
DATED: …………. DEPONENT
VERIFICATION : Verified at Jind that contents of Para No. 1 to 2 of above
affidavit of mine are true and correct to the best of my knowledge, no part of it is
false and nothing material has been kept concealed or suppressed therein.
PLACE: JIND
DATED: …………. DEPONENT