District : North 24 Parganas

In the Court of Ld. Addl. District Judge - I at Bongaon,

Ref. Mat Suit No : / 2025
IN THE MATTER OF :-
An application U/S- 13 of Hindu Marriage Act
of 1955.
AND

IN THE MATTER OF :
Sri. Priyanshu Das, aged about 23 years,
Son of Madan Das, by faith Hindu, by oc-
cupation - Day Labour, of Vill. & P.O. -
Khamarkalla, P.S.- Gopalnagar, Dist. - North
24 Parganas, Pin - 743262, Mobile No. -
9800552163.
..........Petitioner / Husband

VS

IN THE MATTER OF :
Smt. Keya Das, aged about 22 years, W/O.
- Priyanshu Das, D/O - Uttam Das, by faith -
Hindu, by occupation - House Wife, at
present residing at Vill - Bairampur, P.O. -
Gopalnagar, P.S.- Gopalnagar, Dist. - North
24 Parganas, Pin - 743262.
........ Respondent/Wife
 (2)

MOST RESPECTFULLY SHEWETH :-

1. That both of the petitioner and respondent atr Hindu by religion and
as such they are governed by Hindu laws and customs and the marriage in
between parties was solemnised on 26.02.2024 according to the Hindu rites
and customs at the house of the father of the respondent situated at Vill. &
P.O. - Khamarkalla, P.S.- Gopalnagar, Dist. - North 24 Parganas, Pin -
743262.

2. That since after marriage both the parties started living together as
husband and wife in the house of the petitioner at Vill. & P.O. - Khamarkalla,
P.S.- Gopalnagar, Dist. - North 24 Parganas, Pin - 743262

3. That out of their wedlock during their unpleasant conjugal where the
marriage was duly consumated and they started living together as husband
and wife under the same roof, no child was born.

4. That your humble petitioner is a very simple, honest and law abiding
person with strict principle, high morality as well as keen sence of duty and
responsibility. On the other hand the respondent is a woman of completely
opposite quality i.e. she is very ill-tempered, whimsical, demanding, obsti-
nate, adament having no care and regard to the petitioner and she does not
care and bother the petitioner as her husband. She also does not bother or
respect petitioner’s family members as her relatives. That the respondent
never done any house hold works and always ordared her in-laws to do the
same.

5. That the petitioner has been living in joint family with his aged par-
ents, and others, but after few days of said marriage the respondent has
been creating pressure upon the petitioner for living in a separate mess or
stay in her paternal house as “Ghar Jamai” because she does not want to
live in the joint family of the petitioner.

6. That the respondent used to humiliate the petitioner in presence of

third person always because the respondent is much beautiful than the peti-
 (3)

tioner. The respondent left your petitioner’s house without any consent of the
petitioner or the family members of the petitioner here and there and also
went to her paternal house.

7. That the petitioner when came to know such untoward behaviour of

the respondent, he took several attempts to restrain her with the help of the
relatives of both the parties, but all comes in vain.

8. That the respondent was very much cruel to the petitioner from the
very inception of their cojugal life and also the respondent cruel to the peti-
tioner by beaten him several times and abuse him by filthy languages.

9. That the petitioner came to know that the respondent had an illicit
relation with another person of her paternale locality and for that the respon-
dent asked the petitioner to take her paternal house and the respondent ex-
pressed her desire to stay for some days in her paternal house, so the peti-
tioner came back to his house without the respondent. After some days when
the petitioner went to the father’s house respondent to come back the respon-
dent, then the respondent refused to return back to her matrimonial house
without any rhyme and reason. Thereafter the petitioner and his family mem-
bers made several attempts to bring the respondent back to their house, but
ultimately it was failed and the respondent openly declared to the petitioner
for giving her divorce. Since 15.04.2024 i.e. more than nine months both the
petitioner and the respondent living separately.

10. That inspite of the above facts and circumstances the petitioner con-
sidering the fate and future as well as his prestige and position in the society
tried his best for reconciliation but all comes in vain.

11. That the cause of action arose on 15.04.2024 when the respondent left
the house of the petitioner at Vill. & P.O. - Khamarkalla, P.S.- Gopalnagar,
Dist. - North 24 Parganas, Pin - 743262 the jurisdiction of this Ld. Court.

12. That the present petition is a bonafide one and accordingly the peti-
 (4)

tioner is entitled to get the decree of divorce on the ground of desertion as

well as cruelty to the petitioner.

13. That there is no collussion in between the parties in the matter of

presenting this petition before this Ld. Court and no other petition is pending
for the same in any court of law.

14. That a fixed court fee of Rs. 100/- is paid herewith as per law.

Under the above circumstances, it is humbly

prayed that your Honour would graciously be
pleased to pass a decree of divorce by way of
dissolution of marriage held on 26.02.2024 in
between the parties to met the ends of justice.

And for this act of kindness your humble petitioner as in duty bound shall
ever pray.
Verification

I, Sri. Priyanshu Das, aged about 23 years, Son of Madan Das, by

faith Hindu, by occupation - Day Labour, of Vill. & P.O. - Khamarkalla,
P.S.- Gopalnagar, Dist. - North 24 Parganas, Pin - 743262 do hereby state
and verify that the above made statements are true to the best of my knowl-
edge and belief and I sign this verification at my advocate’s office on
07.01.2025
District : North 24 Parganas
In the court of the Addl. District Judge - I at Bongaon,

Ref. Mat Suit No : / 2025

Affidavit

I, Sri. Priyanshu Das, aged about 23 years, Son of Madan Das,

by faith Hindu, by occupation - Day Labour, of Vill. & P.O. - Khamarkalla,
P.S.- Gopalnagar, Dist. - North 24 Parganas, Pin - 743262 do hereby
solemnly affirm and declare as follows :-

1. That I am the petitioner of this Suit and as such I am well conversant

with the facts and circumstances of this Suit and so also competent to swear
this Affidsavit.

2. That the statements made in paragraph 1-14 are true to the best of my
knowledge and belief and remaining are my information and my humble
submission before this Ld. Court of Law.

3. That the statements made in this Affidavit are true to the n best of
myknowledge and belief and I sign this Affidavit on the 07.01.2025 at my
Advocate’s sherista.

Deponent
Identified by me

Advocate