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Divorce Petition by Hindu Wife on the Grounds of Cruelty

IN THE FAMILY COURT BANDRA, MUMBAI

M.J. PETITION NO. ___ of ____

Smt. ___________,

daughter of ___________,

aged _______ years, residing at ___________ Petitioner.

Versus

XYZ, son of _________,

_______ years of age,

residing at _________,

carrying on __________ business...... Respondent.

In the matter of dissolution of marriage under Section 13 of the Hindu Marriage Act, 1956:

And

In the matter of the Family Courts Act, 1954;

And

In the matter of Divorce of the Petitioner with the Respondent on grounds of cruelty.

TO,

THE HON''BLE PRINCIPAL JUDGE

AND OTHER JUDGES OF THIS

HON''BLE COURT.

THE HUMBLE PETITION OF

THE PETITIONER ABOVENAMED

MOST RESPECTFULLY SHEWETH:

1. That the Petitioner and the Respondent were lawfully married according to traditional Hindu Vedic
rites on the ______ day of __02 at the ______ in Mumbai. Hereto annexed and marked Exhibit 'A' is a
copy of the marriage certificate evidencing the said marriage.

2. The Petitioner and the Respondent are Hindu by birth and they continue to be so.

3. After the said marriage, the Petitioner and the Respondent cohabited and lived together at the
Petitioner's house for about six years. There were two issues out of this marriage viz. LML (son of
________ years of age) and HIJ (daughter of ___ years of age).

4. The Petitioner states that from the month of ___ 02, the Respondent began to ill-treat the
Petitioner, and from the month of _____02, began to physically assault the Petitioner without any cause
whatsoever. For some time, the Petitioner made no complaint and underwent such ill-treatment, hoping
that the Defendant would see better sense. However, on or about ____month of 02, the Respondent
attacked the Petitioner with a stick and inflicted serious injuries leading to multiple fractures in hand and
leg of the Petitioner. The Petitioner thereupon lodged a complaint at the ____ Police Station, being
complaint No. ___. The Petitioner craves leave to refer to and rely upon a copy of the said complaint
when produced.

5. The Petitioner says that as a result of the aforesaid injury inflicted on the Petitioner by the
Respondent, the Petitioner had to be hospitalized for six days. The Petitioner craves leave to refer to and
rely upon the Medical Certificate issued by Dr. ____ who treated the Petitioner at ______ Hospital.

6. The petitioner says that even thereafter, the Respondent continued to treat the Petitioner in a
cruel and violent manner. The Petitioner says that such cruelty has cause an apprehension in the mind
of the Petitioner that it will be harmful and injurious for the Petitioner to continue to live with the
respondent.

7. There is no collusion or connivance between the Petitioner and the Respondent in filing this
Petition.

8. The Petitioner is claiming alimony @ Rs. ---- per month from the Respondent.
9. No other proceedings with respect to the marriage between the Petitioner and the Respondent
have been filed in this Honorable Court or in any other Court in India.

10. The Petitioner and the Respondent were married in Mumbai and last cohabited in Mumbai within
the territorial limits of the jurisdiction to entertain, try and dispose of the present Petition.

11. The Petitioner being a lady is exempt from payment of Court fees.

12. The Petitioner will rely on documents, a list whereof is annexed hereto.

The Petitioner therefore prays:

· That this Honorable Court be pleased to decree a dissolution of the said marriage between the
Petitioner and the Respondent;

· That the Petitioner be granted alimony @ Rs. _______/- per month;

· That the Respondent be ordered and decreed to pay to the Petitioner the costs of this Petition;
and

· In the alternate to prayer (c) above, the Respondent be directed to give the Petitioner a sum of Rs.
________/- so as to enable her to purchase suitable accommodation for herself;

· That pending the hearing and final disposal of this petition, the Respondent be directed to provide
the Petitioner with a monthly allowance of Rs. ____/- to meet her personal expenses and the expenses
of running the matrimonial home;
· For such further and other reliefs as the nature and circumstances of the case may require.

Petition drawn by:

Mr. ABC,

Advocate, Sd/- Petitioner

High Court, Mumbai.

VERIFICATION

I, ___________, the Petitioner above named, do hereby solemnly declare and say that what is contained
in paragraphs _________ to __________ is true to my knowledge and that what is state in paragraphs
_______ to _______ is stated on legal advice and I believe the same to be true.

______ day of ____02. Sd/-

Before me,

Registrar/Superintendent,

222222222

Bail Application
IN THE COURT OF ____________, ADDITIONAL DISTRICT AND SESSION JUDGE, _____________ COURTS,
____________

IN THE MATTER OF:

LMN, ___________, Son of _________________ Years of Age, Working as _____ Residing at __________

........... Petitioner

Versus

State of_________ Through PQR, Son of _________, ____ Years of age, Working as __________ Residing
at _______________

...........Respondent

FIR No.: ___________

U/s: ___________

P.S.: ___________

APPLICATION UNDER SECTION 439 OF THE CODE OF CRIMINAL PROCEDURE 1973 FOR GRANT OF BAIL

Most Respectfully Show:

1. That the present application under section 439 of the Code of Criminal Procedure 1973 is being
filed by the Petitioner for seeking grant of bail in FIR No. _________ registered at Police
Station_______________. The present petition is being moved as the Petitioner has been arrested on
_________ (give date) in connection with the said FIR. The petitioner is now in judicial/police custody.

2. That the Petitioner is innocent and is being falsely implicated in the above said case as he has
nothing to do with the matter.

3. That the Petitioner is a law abiding citizen of India. The petitioner is gainfully carrying on the
business of ________ at ________. (Give details).

4. That the Petitioner is a responsible person and is living at the above mentioned address.

5. (Give all other relevant facts, which have led to the arrest or which show the petitioner's innocence
or disassociation with the alleged offence supposed to have been committed)

6. That the Petitioner is innocent and no useful purpose would be served by keeping him under
custody and this is a fit case for grant of bail. (It would be pertinent to mention as to the stage of
investigation or in case the charge sheet has been filed, whether charges have been imposed, evidence
has started, the length of the list of witnesses cited by the prosecution etc. as these would all be
mitigating circumstances)

7. That the Petitioner undertakes to abide by the conditions that this Honorable Court may impose at
the time of granting bail to the Petitioner and further undertakes to attend the trial on every date of
hearing.

8. That the Petitioner has not filed any other similar petition before this or any other Honorable Court
for grant of bail in case of the present FIR. (Or give details and results of earlier applications)

PRAYER:
In view of the above stated facts and circumstances it is most respectfully prayed that this Honorable
Court may be pleased to

a. Grant bail to the Petitioner in connection with FIR No. ________ registered under section
________, for the offence of ________ (give sections) at Police Station _________ (give place).

b. Pass any other such order as this Honorable Court may deem fit and proper in the interest of
justice.

LMN........Petitioner

Through

ABC.........Counsel

Place:

Dated:

33333

In the Court of Civil Judge Class – I at Delhi

Suit No. ………… / 20…….

A. B. s/o B. C.

123, A B Road, Delhi

………………………………….. Plaintiff

Vs.

M. N. s/o O. P.

456, A B Road,Delhi

………………………………….. Respondent

Suit for Specific Performance of Contract to sell a residential plot

The plaintiff respectfully states as follows : –

Inducement:

(1) Plaintiff is a Govt. Servant working in Delhi. and so on

(2) Respondent is a property broker having an office at …

Material Facts of the case:

(3) The plaintiff agreed with the respondent on 10 Aug 2008 to purchase the Plot No 123 at Rani Bagh
Colony,Delhi. A copy of the contract is attached with the petition.

(4) The boundaries of the plot is as under:

East: Road

West: Plot number 12

North: Road

South: Colony wall

(4) The total value of the plot to be paid by the plaintiff to the respondent, as agreed upon in the
contract, is Rs. 40,000/-.

(5) The respondent accepted a payment of 10,000/- though Check No. 123 of SBI,CP Branch at the time
of making the contract and promised to do registry upon payment of remaining amount of 30,000/-

(5) The plaintiff tried to pay the remaining amount on several occasions by cash as well as check but the
respondent refused to take the payment.

(6) The plaintiff also sent a notice about the same to the respondent on 10/10/2009.

(7) The plaintiff is ready to pay the remaining amount of Rs 30,000/- but the respondent is not willing to
transfer the said plot.

Cause of Action and Limitation

(8) The cause of action for the present suit first arose on 10/10/2009, when the respondent refused to
convey the said property as per the terms of the agreement and hence, the suit filed today is within
time.
Valuation:

9 The suit is valued for the purpose of jurisdiction and court-fee at Rs. 30000/-.

Jurisdiction:

(10) The plot is located in Indore, which is within this court's territorial jurisdiction.

(11) The value of the contract is 40,000/- which is within this court's pecuniary jurisdiction.

Relief Claimed:

(12) The plaintiff, there fore prays that the court be pleased to order the respondent to perform his part
of the contract by accepting the remaining payment and conveying the said plot to the plaintiff be
permitted to deposit the balance of consideration in this Hon'ble Court.

the respondent be ordered to pay compensation for mental harrasment, loss of wages, and cost of this
litigation.

(Signature of the plaintiff)

YYY

Advocate

Place: ………………….

Date: …………………..

Verification
I, ______, do hereby solemnly verify that the contents from paras 1 to 4 are correct and true to the best
of my knowledge and contents from para 5 to 12 are based on legal advice, which I believe to be correct.
Affirmed at Delhi this 4th Day of September 2015.

(Signature)

Plaintiff

You can get the help of lawyers in India to write a suit for specific performance of a contract.

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