H.M.A. NO.    OF 20XX

  IN RE -:

 SH. XXXX                                                             PETITIONER


  SMT. XXXX                                                         RESPONDENT





I, XXXX aged – XXXX years S/o. Sh.  XXXX R/O XXXX, New Delhi, do hereby solemnly affirm and declare as under-:





1.   That marriage between the deponent & Respondent was solemnized on XXXX at XXXX, according to Hindu rites, custom and ceremonies.

2.    That the marriage was solemnized in a very simple manner with the presence of 80-90 people from the respondent’s family i.e some relatives from the deponent’s family and some relatives are from the deponent’s family and few friends of the deponent were also present and the marriage was solemnized according to Hindu rites and customs.

3.   That after the marriage deponent and respondent lived and cohabited and consummated the marriage and the parties had resided together at Delhi, with each other, out of this wedlock one child has been born to the parties who is at present about 4 years named Baby XXXX.                                         

4.   That after the marriage, deponent alongwith respondent resided at deponent’s home at Delhi for about 18 months and during the said period of 18 months, the deponent used to go 5 days in a week to her parent’s home at XXXX because the respondent is working with PGI XXXX as Computer Operator and the deponent is working in the same organization prior to the marriage and during the visits at Delhi deponent came to know certain new things about the respondent that she is not well and she used to suddenly get angry without a justified cause with frequent panic, unexplainable phobias with mental health problem including depression and anxiety in the family and also experienced the dramatic change in the behavior when the respondent is in the stress, when the plaintiff asked about all the symptoms then the respondent alongwith her mother said this happened usually so nothing worry about it.

5.   That deponent alongwith his mother were residing at Delhi with the respondent and the deponent’s mother presented one saree, gold ring to the respondent but the respondent refused to accept the gift of the deponent by saying “XXXX” The respondent put a condition before the deponent that she wanted to stay at XXXX and she wants to settle at XXXX, the petitioner will have to arrange one separate house at XXXX at any condition. When the petitioner told the respondent that he has not enough money to bring these things and assured the respondent that the above said house would be arranged at XXXX after few years for the respondent but the respondent clearly refused to accept this of the respondent and whole night the respondent did not talk properly with the petitioner and fought with the other family members. Next day again the respondent misbehaved with the parents of the petitioner and said “XXXX” by this behavior of the respondent, the entire family was so astonished but could narrate anything to others, and after so many request by the family members of the petitioner’s then only the respondent’s conduct became normal towards the petitioner and other family members and in the house the petitioner was residing with his parents.

6.   That after three or four days of the marriage, the petitioner and the respondent went to relative (Mama ji) of the petitioner at Rohini, Delhi while coming from the relative’s (Mama ji) house, the respondent asked the petitioner to purchase valuable gifts for her mother, sisters and her brother in law but the petitioner had informed her that he had not brought adequate funds to purchase something,  The respondent became so anxious about her family members that what they would thought about and so many distressing, persistent and intrusive thoughts and images are coming, and felt so inferior with all her relatives and so many other things the respondent shared with the petitioner as a result the respondent did not behave properly with petitioner.

7.   That after their return from relatives’ (Mama Ji) house the respondent did not talk properly with the petitioner. The petitioner tried his best to convince the respondent that the petitioner is Priest (Pujari) at Delhi in a temple and the petitioner cannot spent lavishly still the petitioner assured the respondent that the petitioner would make all possible efforts for the happiness of the respondent. Only after the assurance of the petitioner the respondent started behaving properly with the petitioner.

9.   That respondent’s attitude towards the petitioner and his other family members remained worst for the whole day and the respondent said that she is suffering from headache and wants some rest and at that moment she had taken out some pills from her purse and taken that pills and gone to sleep and no cohabitation had taken place between the parties, from the appearance It appeared to the petitioner and his mother that the respondent was suffering from some such problem which related to depression. From that the entire day the petitioner and his mother took great care of the respondent and showered all love & affection upon the respondent, That in the morning hours when the respondent woke up, she was offered tea but she was not behaving properly, however the said matter was ignored being the lovable bahu of the family in the matrimonial house.

10.      That after 4-5 days respondent went to her parent’s house at XXXX and after two days, the petitioner and his family came to know that the respondent is admitted in the hospital and seriously ill there with the problem of some psychiatry problem, because the doctor of the hospital found some activity which is not in normal person and she always fainted during the hospitalization. The respondent got all these information from the relatives of the respondent. The petitioner stayed the complete day and night for taking care of the petitioner, because of this incident the petitioner was so much  worried that he could not have his meal for the complete day, and from there the respondent was diagnosed with  Dissociate disorder.

11.      That the entire day the petitioner gave the best possible way to keep the respondent happy but the petitioner could not enjoy all marital bliss for a long time and his marriage with the respondent very soon ran into rough weather because of the behavior of the respondent. The respondent started to harass the petitioner on one pretext or the other. The respondent started compelling the petitioner that the petitioner should leave the job of priest (Pujari) and starts his own business as the respondent fells humiliated among her friends and relatives when the respondent tells them that her husband is Pujari in a temple. Due to continuous pressure of the respondent, the petitioner assured the respondent that he would do his own business.  Even then there was no change in the attitude of the respondent. The respondent used to pick up quarrels with the petitioner, his mother. Not only this the respondent started insulting the petitioner and mother in the presence of their relatives and friends, though, the petitioner discharged all his obligations as husband.

12.      That the relatives of the respondent came to meet the petitioner and the respondent. The petitioner and his mother gave some clothes as gift to the respondents. After seeing the gifts the respondent became very furious and started shouting at the petitioner and his mother in the presence of their relatives. The respondent threw the gifts and insulted the petitioner and his parents by saying that “ XXXX Thus the respondent humiliated the petitioner and mother in the presence of their relatives, and the respondent fainted on the earth after all this in front of the relatives, and after this incident & insult in front of the relatives the mother of the petitioner went to native place of the petitioner at Village-XXXX, and all this done by the respondent in one month and the mother of the petitioner was very much sad about this fact.

13.      That the respondent use to leave the matrimonial home and used to spend hours in the temples and ashrams without intimation to the petitioner at Delhi whenever the respondent used to come to Delhi, the petitioner used to bring her back with great persuasion and difficulty and this became regular feature of the respondent in very less time, as she was not normal in her behavior.

14.      That one day on XXXX in the morning the respondent went to her parental home as on XXXX is the birthday date of the respondent and when the respondent did not return back on XXXX to celebrate her birthday with petitioner to her then the petitioner went to the parental home of the respondent at XXXX and requested the respondent to return back to her matrimonial house. After so many requests the respondent was ready to come with the petitioner on XXXX and the petitioner along with respondent came to the home and after coming to the home she was so furious in every things & the petitioner realized that respondent has absolutely changed in her behavior and became so much restless in her demand that cannot explain, The petitioner also requested the mother of the respondent through phone to give proper advice to the respondent but she also favoured the respondent. The respondent told the petitioner that in case the petitioner leaves Delhi shift to XXXX, then everything will be normal, the petitioner showed his inability to do so but the respondent paid no heed to the request of the petitioner and remained adamant on her demand. The respondent’s mother proposed the petitioner that the petitioner and the respondent would behave like this, if the demand new house at XXXX was not fulfilled.

15.      That the petitioner repeatedly requested the respondent to shift from XXXX to Delhi because the petitioner is suffering loss in everything as the petitioner is not able to attend properly to his Puja Path while living in such a environment where the respondent was not giving a single day for peace and the every day the respondent gave abuses to the parents of the petitioner.

16.      That with the passage of time, the behaviour of the respondent towards the petitioner became from bad to worse. One day in the morning hours, the respondent felt severe headache so she telephoned to her mother and whispered something and after some time a telephone was received by the petitioner from respondent’s mother that since she is having a severe headache, two tablets in the name of OLEANZ 5 Mg and NEXITO 10 Mg, available in her purse may please be given to her and she will be all right.  Even the offer of the petitioner to take the respondent to the Doctor if the need be was declined forcefully and it was informed that the said medicines will make her all right, after taking the said medicines, she had again gone for sleep and in the evening she woke up and now I am all right, after being amazed with the attitude and behavior with the respondent, her mother was called and discussed and she admitted that the respondent is suffering from Depression and at times she is having severe attack of depression etc. and she is under medication.

17.      That being disturbed with the attitude and behavior of the respondent, the petitioner had discussed the matter with respondent’s mother and also informed them about the said tablets, whereas it was informed that the said medicines are being given to the patients suffering from Schizophrenia (a medical term), since she was suffering from depression as such she was medically treated and the medicines in the name of RIVOTRIL 0.5 MG, OLEANS 5 mg and NEXITO 10 mg were being given for about 15 days to cure the diseases and at this juncture the petitioner  had requested that is why the said matter was not informed to the petitioner  before marriage or at the time of marriage whereas he informed that she did not find the matter much important as such she did not informed and further informed to leave the respondent at the parents house and will be taken back later on.

18.      That on XXXX Sunday the petitioner invited his close friends for dinner. When the said dinner was going on, the respondent started shouting at the petitioner by saying “XXXX”.  Thus the petitioner created an ugly scene in the said dinner and humiliated the petitioner and his close friends in the presence of everybody and said  “XXXX”, however since the respondent was not ready to cook food etc. as such the mother of the petitioner had to work though it was the duty of the respondent.

22. That the respondent never took care of the petitioner and the petitioner had to make food for getting breakfast, lunch and dinner. Whenever the petitioner tries to persuade the respondent that after the marriage, it is the duty of the wife to look after her husband and his family members, the respondent got annoyed and started threatening the petitioner that she had close links with some senior police officials, and the respondent would implicate the petitioner and his family in some false criminal case i.e dowry cases and said “XXXX”.

19.      That for few days, the respondent lived peacefully with the petitioner but very soon the respondent again started harassing the petitioner on one pretext or the other. The respondent used to sleep throughout the day and refused to cook food for the petitioner. Sometimes, the petitioner used to provide breakfast & dinner to the petitioner and sometimes the petitioner used to take his breakfast, lunch and dinner outside from the market.

20.      That not only this at about the petitioner’s uncle came to see the petitioner in his house, the petitioner requested the respondent to prepare dinner for him but the respondent flatly refused to prepare dinner for him and asked the petitioner to bring the dinner from the market. When the petitioner tried to request the respondent that this is no fair on the part of the respondent. The respondent kept on shouting and refused to prepare dinner for the uncle of the petitioner. The respondent openly cried that the petitioner’s relatives had no business to come in the matrimonial house of the respondent. Seeing the conduct of the respondent petitioner’s uncle felt greatly humiliated hurt and insulted and left the house of the petitioner without taking dinner.

21.      That on XXXX, few relatives of the petitioner came to the house of the petitioner then respondent did not treat them properly nor asked them to sit. When the petitioner requested the respondent to serve tea etc. to his relatives, the respondent started quarrelling with the petitioner when the petitioner requested the respondent to behave properly the respondent became more violent and abused everybody in a very filthy language. Thereafter, the respondent came in a balcony and started shouting in a very loud voice and giving impression as if the respondent is being treated badly by the petitioner and his family members. The respondent shouted saying that “XXXX” and due to such kind of hue and cry, with the result many neighbours collected on the road and with great difficulty the respondent was brought back inside the room by the petitioner. This was done intentionally by the respondent in order to lower down the prestige of the petitioner in the eyes of the neighbours, the respondent abused and went to the extent of raising her hands on the petitioner in the presence of his friends.  The respondent remarked at the petitioner by saying “XXXX”.  Thus the respondent humiliated the petitioner in the presence of his friend in a very bad manner. Seeing the cruel behavior of the respondent, the petitioner’s friend left the house of the petitioner without even taking the water.  The petitioner had to mellow down and this act and conduct on the part of the respondent caused great mental tension and torture to the petitioner.

22.      That after this incident the respondent left the matrimonial house and threatened the petitioner that she will not come back. The respondent went to her mother’s house. The petitioner went to bring back the respondent and brought to the notice of the respondents’ mother the cruel behavior of the respondent but they favored for the respondent by saying that under the circumstances the respondent was perfectly right. Thereafter the petitioner tried his best to convince the respondent and made her to realize that her conduct was absolutely wrong during the past few days and respondent should not have behaved in the said manner, That due to the requests of the parents of the petitioner the petitioner had agreed to give one more chance to the respondent to mend her ways and started living with her, The respondent realized her mistake and assured the petitioner that in future the respondent would behave in a proper manner and would not repeat such type of activities. That after just 1 day the respondent had started showing her true colours again and the petitioner started feeling cheated as not only the respondent had started humiliating and torturing the petitioner and again started raising hands on him every now and then and started treating her as her servant and using the filthy and abusive language which the petitioner cannot even dare to write in the petition.

23.      That not only this the respondent started quarreling with the friends, relatives and guests whosoever came to the house of the petitioner to ask about the welfare of the family. The respondent went to the extent of telling the relatives of the petitioner that they had no business to come to her matrimonial house.  This happened so many times in the month of XXXX onwards.  The petitioner since not having the proper atmosphere at home and also have to devote time to the misdeeds of the respondent, and the entire money as provided by the father of the petitioner in the demand of the respondent.

24.      That on XXXX at about 8.00 a.m the respondent again started quarrelling with the petitioner and threatened the petitioner that if the property of the petitioner at his native place is not transferred in her name or give the entire money after selling the said house, she would commit suicide and would hold responsible the entire family of the petitioner for the suicide of the respondent by way of leaving a suicide note. Not only this respondent called her mother who further threatened to teach lesson to the entire family of the petitioner, and after few minutes in the morning at 8.30 AM, the mother of the respondent had telephoned in the morning and unfortunately the said phone was picked up by the petitioner and after hello there was a curse “XXXX” and the phone was disconnected and after about 15 minutes again the phone was connected and now it was picked up by the respondent and had discussion etc. and after the discussion it was quite a hell for the petitioner “XXXX” and after that there was nothing for the petitioner to stay at home and as such the petitioner had left the house without even having the Breakfast, the entire day the petitioner was quite tough and even could had his lunch & dinner.

25.      That the respondent was hospitalized in last week of XXXX at PGI XXXX and the petitioner taken care of the respondent and the respondent gave a birth to the baby girl on XXXX, during the time of hospitalization of the respondent and her family members humiliated so much to the petitioner and during the period of hospital the respondent was quite busy with mobile conversation with somebody and when the petitioner asked that to whom the respondent was chatting during the entire day, then there was a big arguments from the respondent’s side with so much of abuses which cannot explain here and it is also not practically possible to narrate all the abuses in this petition, and after the heated arguments between petitioner and respondent, the family members of the respondent abused the petitioner so much and throw him from the hospital and the petitioner came back to Delhi.

26.      That on XXXX after the gap of 5-6 months and after the birth of the child the respondent came to the Delhi and took her entire jewellery as well as her clothes with the excuse that she was going to final the bride for her younger brother and went to her mother’s house at XXXX.

27.      That in the same evening the mother of the respondent threatened the petitioner and his entire family to implicate in some false dowry case and went to her parents’ house.  The respondent and her mother started giving threats to the petitioner and his parents to implicate the entire family in a dowry case.

28.      That recently on XXXX, the petitioner got a threatening call from the mobile number XXXX, which says to eliminate the petitioner, and threatened if the petitioner will interfere with any of the decision of respondent then the petitioner has to behind the bar alongwith his family member in the false dowry cases.

29.      That the life of the petitioner became hell due to the cruel and inhuman treatment of the respondent and the petitioner was being treated as a stranger in the society. Since the respondent has crossed all the limits of cruelty and mental torture, and separated herself with the company of petitioner from last 4 years.

30.      That the Petitioner now is not in a position to tolerate further any cruelty and mental torture at the hands of the respondent and her family members, that all the aforesaid facts clearly prove that the respondent has treated the petitioner with cruelty and it is harmful and impossible for the petitioner to live with the respondent.

31.      That the petitioner has not condoned the aforesaid acts of cruelty complained of and there is no unnecessary or improper delay in filing the petition, the present petition has not been institute in collusion with the respondent and there is no legal impediment as to why the relief should not be granted to the petitioner.

32.      That the marriage between the parties was solemnized at XXXX and the petitioner and respondent last resided at XXXX  and the petitioner still resides at XXXX, hence, this Hon’ble Court has got jurisdiction to try and entertain the present petition.

That the requisite Court fee has been affixed on the petition.

It is therefore, most respectfully prayed that the petition may kindly be allowed and the marriage between the parties may kindly be dissolved by a decree of divorce on the ground of cruelty.


          It is prayed accordingly,


Dated:                                                                                      Petitioner





           I, the above-named petitioner do hereby state on solemn affirmation that the contents of para 1 to       of the above petition are true and correct to the best of the knowledge of the petitioner and belief while those of para        to      are true on legal information received and believed to be correct.  Last para is prayer to this Hon’ble Court.

           Verified at Delhi on this        day of XXXX.





H.M.A. NO.         OF 20XX

  IN RE -:

 SH. XXXX                                                         PETITIONER


  SMT. XXXX                                                    RESPONDENT


 I, XXXX aged –  years S/o. Sh. XXXX R/O XXXX hereby solemnly affirm and declare as under-:



H.M.A. NO.    OF 20XX


 SH. XXXX                                                               PETITIONER


 SMT. XXXX                                                             RESPONDENT

                                        MEMO OF PARTIES 


NEW DELHI                                                                          PETITIONER






.                                                                                RESPONDENT                 





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