Mediation Script — ADR PSDA Presentation
Case Title: Mohit Suri v. Sameera Suri
Forum: Family Court, Delhi (Referred for Mediation)
Team: Tamanna (Mediator 1), Asavari (Mediator 2), Ankush (Counsel for Petitioner),
Chetan (Client Mohit), Vanshika (Counsel for Respondent), Himanshu (Client Sameera)
Duration: 15–20 minutes
I. Opening & Ground Rules (2:30 mins)
TAMANNA (Mediator 1):
Good afternoon, everyone. I’m Tamanna, serving as the lead mediator for this session, and
this is my co-mediator, Ms. Asavari. We welcome both parties to today’s mediation, which
has been referred by the Family Court, Delhi, in the matter of Mr. Mohit Suri versus Ms.
Sameera Suri.
Before we begin, I’d like to remind everyone that mediation is a voluntary, confidential,
and non-adjudicatory process. Our role as mediators is not to decide who is right or wrong,
but to facilitate communication so that both sides can arrive at a mutually acceptable
resolution.
This process is governed by the principles laid down under Section 89 of the Code of Civil
Procedure and the Mediation Rules, 2005. Nothing discussed here will be admissible in
court without the consent of both parties.
Please remember: there should be no interruptions or personal remarks. Speak only when
recognized, and all communication shall be directed through the mediators.
ASAVARI (Mediator 2):
We request both counsels to ensure that their submissions remain professional and concise,
allowing their clients’ voices to be heard. The counsels’ role is advisory; the clients are the
primary participants in this process.
Before we proceed, can both parties confirm their understanding and consent to these ground
rules?
ANKUSH (Counsel for Mohit): Confirmed, Mediators.
VANSHIKA (Counsel for Sameera): Confirmed.
CHETAN (Mohit): Yes, agreed.
HIMANSHU (Sameera): Agreed.
II. Introductions (1:30 mins)
ASAVARI:
Let’s begin with brief introductions. Counsel for the petitioner, please introduce yourself and
your client.
ANKUSH:
Good afternoon. I am Ankush, Counsel for the petitioner, Mr. Mohit Suri, who has filed for
Restitution of Conjugal Rights under the Hindu Marriage Act, 1955.
CHETAN (Mohit):
Good afternoon. I am Mohit Suri, a fashion designer based in Mumbai and New Delhi. I’m
here voluntarily, hoping that this process will help restore understanding and possibly our
marriage.
TAMANNA:
Thank you. Counsel for the respondent, please introduce yourself and your client.
VANSHIKA:
Good afternoon. I’m Vanshika, Counsel for Ms. Sameera Suri, the respondent. She has
initiated divorce proceedings in England but is here in good faith to explore settlement
possibilities.
HIMANSHU (Sameera):
Good afternoon. I am Sameera. My priority is our daughter’s welfare and a peaceful
resolution that ensures emotional and financial security for both of us.
III. Opening Statements (4:00 mins)
TAMANNA:
We will now hear the opening statements from each side, beginning with the petitioner.
Please note, no interruptions will be allowed.
Petitioner’s Side
ANKUSH (Counsel for Mohit):
Thank you, Mediators. My client, Mr. Mohit Suri, is a reputed fashion designer who has
contributed significantly to the respondent’s business during its initial setup in India.
Unfortunately, certain financial losses and professional pressures led to misunderstandings in
their marriage.
The key issues are:
• Mr. Mohit’s financial liability due to a ₹1.25 crore loss,
• The alleged defamation by Ms. Sameera, which damaged his reputation,
• And her relocation to England with their minor daughter, leaving the petitioner
emotionally isolated.
My client seeks reconciliation and is willing to undergo counseling, abstain from gambling,
and take steps for mutual healing. His primary interest is to rebuild his family life and secure
the emotional well-being of his child.
CHETAN (Mohit):
I accept that I’ve made mistakes. But I’ve taken corrective measures — I’ve stopped
gambling and joined therapy. I just want my family back, or at least a fair chance to show that
I’ve changed.
Respondent’s Side
VANSHIKA (Counsel for Sameera):
Mediators, my client, Ms. Sameera, is an accomplished psychologist and businesswoman
who has supported her husband through thick and thin. However, persistent gambling and
emotional instability have left her with no option but to seek divorce.
She has maintained dual responsibilities in India and England, but after repeated
disappointments, she moved back to England for emotional and financial stability.
Her primary interests are:
1. Ensuring complete financial autonomy from Mr. Mohit’s debts,
2. Protecting the future of their minor child, and
3. Maintaining dignity and safety in any communication or settlement.
HIMANSHU (Sameera):
I loved Mohit deeply, but repeated breaches of trust broke the relationship. My only concern
now is peace, stability, and raising our daughter in a safe environment. I’m not against
dialogue, but reconciliation seems very difficult right now.
IV. Issue Identification & Clarification (3:00 mins)
ASAVARI:
Thank you for your openness. The main issues emerging are:
1️⃣ The conflict between Restitution of Conjugal Rights and the Divorce Proceedings abroad;
2️⃣ The ₹1.25 crore debt and questions of liability;
3️⃣ Alleged defamation affecting reputation;
4️⃣ Custody and parental access for the minor child.
TAMANNA:
Both parties have expressed concern for their child, which gives us a strong foundation for
constructive dialogue. Let’s now explore these issues through interest-based discussion rather
than positional arguments.
V. Interest Exploration (4:00 mins)
TAMANNA:
Mr. Mohit, apart from reconciliation, what matters most to you at this stage?
CHETAN (Mohit):
I want to be part of my daughter’s life — to see her grow, make decisions for her education,
and not be treated like an outsider. Also, I want to clear my name from these defamatory
remarks that have hurt my professional image.
ANKUSH:
Yes, his core interests are parental participation and reputation protection. We are not here
to litigate but to build a framework for trust restoration.
ASAVARI:
Ms. Sameera, what do you expect from this process?
HIMANSHU (Sameera):
I want assurance that I will not be financially liable for any of Mohit’s debts or future loans.
I’m also willing to discuss joint parenting, provided it doesn’t compromise my daughter’s
security.
VANSHIKA:
My client’s interests are financial independence, emotional stability, and clear legal
safeguards against future liabilities. She is not opposed to communication, but she cannot
return under emotional pressure.
VI. Negotiation Phase (3:30 mins)
ASAVARI:
Given these interests, let’s explore a balanced settlement framework. Would both parties be
open to a three-month reconciliation period through family counseling, followed by a
review session?
CHETAN:
Yes, I’m willing to participate in counseling.
HIMANSHU:
I can agree, provided the sessions are neutral and in India during my short visits.
TAMANNA:
Good. Regarding finances, would it be acceptable that Ms. Sameera’s business assets in India
remain solely under her control, while Mr. Mohit undertakes a personal moratorium on large
borrowings for 90 days?
ANKUSH:
That’s reasonable.
VANSHIKA:
Agreed, with an undertaking that the gambling habit is permanently discontinued.
ASAVARI:
Lastly, to ensure dignity, both sides shall cease any negative communication or defamation
publicly or privately.
CHETAN:
Agreed.
HIMANSHU:
Agreed.
VII. Interim Settlement Summary (1:30 mins)
TAMANNA (reading the draft aloud):
Let the record show that both parties have agreed to the following:
1️⃣ Both parties will attend family counseling sessions for a period of three months under a
neutral counselor in India.
2️⃣ Mr. Mohit will abstain from gambling and will undertake financial counseling.
3️⃣ Ms. Sameera’s Indian business assets shall remain under her sole management.
4️⃣ Both parties shall co-parent their child, jointly deciding on her education, health, and
travel.
5️⃣ Both parties agree to non-defamation and respectful communication.
6️⃣ Upon review after three months, if reconciliation fails, they may proceed with mutual
consent divorce under Section 13B of the Hindu Marriage Act, with shared custody rights.
VIII. Closing (1:30 mins)
ASAVARI:
Both parties have shown maturity and respect throughout today’s proceedings. These interim
terms reflect sincerity and a shared desire for peace.
TAMANNA:
We will now prepare the Mediation Settlement Report and forward it to the Family Court,
Delhi.
We thank both counsels and clients for their cooperation. The session is now concluded.