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IN
THE COURT OF LD. PRINCIPAL JUDGE, FAMILY COURT; TIS HAZARI COURTS, DELHI.
H.M.A.
CASE NO. ________ OF 2022.
……………………., :
PETITIONER
VERSUS
S.NO. PARTICULARS PAGES
1. MEMO OF
PARTIES + C.F.
2. PETITION FOR DISSOLUTION OF MARRIAGE BY A
DECREE OF DIVORCE A AMENDED BY THE MARRIAGE LAWS (AMENDMENT) ACT, 1976 UNDER
SECTION 13(1)(ia) OF HINDU MARRIAGE ACT, 1955. SUPPORTING AFFIDAVIT.
3. LIST OF
DOCUMENTS.
4. VAKALTNAMA.
Through (NAME)
Advocate
ADDRESS,
Mob.No,
Email,
IN
THE COURT OF LD. PRINCIPAL JUDGE, FAMILY COURT; TIS HAZARI COURTS, DELHI.
H.M.A.
CASE NO. ________ OF 2022.
……………………., :
PETITIONER
VERSUS
P.S. …………….,
MR. …………………...,
S/o Sh. ……………….,
R/o…………. : PETITIONER
VERSUS
MRS. ……………..,
D/o Sh. …………..,
Through (NAME)
Advocate
IN
THE COURT OF LD. PRINCIPAL JUDGE, FAMILY COURT; TIS HAZARI COURTS, DELHI.
H.M.A.
CASE NO. ________ OF 2022.
MR. …………………...,
S/o Sh. ……………….,
R/o ……………………, : PETITIONER
VERSUS
MRS. ………………….,
D/o Sh…………………,
P.S. …………….
A
PETITION UNDER SECTION 13 (1)(ia) OF THE HINDU MARRIAGE ACT, 1955 ON BEHALF OF
THE PETITIONER FOR DISSOLUTION OF MARRIAGE BY A DECREE OF DIVORCE AS AMENDED BY
THE MARRIAGE LAWS (AMENDMENT) ACT 1976.
MOST
RESPECTFULLY SHOWETH :-
1.
That a marriage between the
parties hereto was duly solemnized at Hotel Radisson Blue, Dwarka, Delhi,
according to the Hindu Customs, Rites and ceremonies on dd.mm.yyyy without any
exchange of dowry.
2.
That petitioner is a law
abiding citizen of India and has always maintained peace and tranquility, given
rapt attention to the discharge of social, moral obligation and liability in a
fair way and up till now there is not any redressal of grievances against the
petitioner at any forum.
3.
That, the status and place of
residence of the parties to the marriage before and at the time of filing the
petition are given below: -
|
|
Status
|
Age
|
Place of residence
|
Before Marriage
|
Bachelor Hindu
|
……. Years
|
R/O ………………,
|
At the time of filing the present petition.
|
Married Hindu
|
……
years
|
-do-
|
|
|
Status
|
Age
|
Place of residence
|
Before Marriage
|
Spinster Hindu
|
…… Years
|
House No. ……………,
|
At the time of filing the present petition.
|
Married Hindu
|
…… years
|
-do-
|
4.
That the petitioner and
respondent were Hindu at the time of solemnization of their marriage and they
continue to profess the same religion till the date of filing the present
petition.
5.
That after the marriage, the
parties lived as husband and wife and cohabited with each other. There is no child
born out of the said wedlock. Respondent is currently staying at her parental
home and never desired to discharge her matrimonial duties.
6.
That
the marriage of the petitioner and respondent was solemnized without any
exchange of dowry and in a low profile manner.
7.
That
the petitioner and his wife lived last together in her matrimonial home on Dec.
yyyy she left the house of the petitioner with all her belonging and valuables
which also includes jewellery from her matrimonial home.
8.
That since after the few days of
their marriage, the respondent used to fight with the petitioner by throwing
unnecessary tantrums and mental torture the petitioner by using harsh words on
almost every conversation.
9.
It is submitted that the
petitioner was always giving love and affection to the respondent. While
petitioner away, everything in the home was under her custody and there was no
one to stop her and taking the advantage of this liberty, Respondent went away
with all articles.
10.
That the petitioner and the
respondent had met each other in the year………, and the relationship which
started as casual friend, changed to lovers and ultimately, they decided to
marry each other.
11.
That the childhood friend Utkarsh
had close relationship with the respondent and both of them were having an
affair with each other. The petitioner had met with the respondent at the birth
day party of Utkarsh common friend in May, yyyy and there was just a formal
introduction between each other and thereafter they had met with each other on
couple of occasions. Utkarsh family members got to know about the relationship and
they were against the said relationship, which resulted in breaking of
relationship of Utkarsh and respondent.
12.
Utkarsh felt bad about
breaking of relationship, however did not had courage of going against wishes
of his family members and thereby requested petitioner to console respondent
and giver her some company. The petitioner only at the instance of Utkarsh met
respondent on couple of occasions. The petitioner and the respondent over the
period of time and after couple of meetings became friend with each other and
started liking each other’s company.
13.
That the petitioner fell in
love with the respondent over the period of time and petitioner and respondent went
to Rajaji National Park for a day on dd.mm.yyyy and ckecked out on dd.mm.yyyy.
Thereafter, petitioner and respondent went to VP Resorts Mumukshu Pauri
together to be with each other and stayed from dd.mm.yyyy to dd.mm.yyyy. The
respondent’s cousin also came to the said premises along with his friends. The
informant met her cousin but she did not introduce the petitioner with her
cousin and stated that she has come along with many other friends and they are
not alone.
14.
That the petitioner was
shocked that the respondent was not willing to introduce him to his family
members and she was keeping their relationship a secret from her family and
friends.
15.
That the petitioner and the
respondent had decided to spend New Year together at Goa. The petitioner booked
airways ticket and hotel bookings, were together at Goa from dd.mm.yyyy to dd.mm.yyyy
and stayed together. The petitioner at Goa in full public glare proposed the
respondent and gave her ring as token of his love. The respondent accepted his
proposal. A true copy of the flight tickets is annexed as Annexure P1.
16.
That the petitioner further
asked the respondent, whether she will be able to inform her family members
about their relationship, to which she said there is no urgency in informing her
parents about relationship and she does not wish to get married any time soon.
The petitioner on the other hand, wanted to get married to the respondent as
the mother of the petitioner was medically unfit and has been suffering from
numerous medical problems. The father of the petitioner was suffering from
uncontrolled sugar, pulmonary edema (a condition caused by excess fluid in the lungs
making it difficult to breathe), coronary artery disease (narrowing or blockage
of the coronary arteries) and various other ailments and mostly confined to
bed, wanted petitioner, being elder son to get married, as she had uncertain
future due to medical complication.
17.
That the petitioner and thus
wanted to respondent to commit to marriage, as their relationship could be
taken to next stage. The respondent on the other hand, wanted her complete
freedom, did not want to commit in relationship, she was happy to have
relationship with no baggage of commitment, family pressure and not answerable
to anyone.
18.
That the respondent was
staying at Delhi in PG stating that she was doing some post-graduation, but in
fact she was not doing any post-graduation and doing job at night shift.
Respondent on the pretext of post-graduation, was happy to stay away from her
family and clutches of relationship.
19.
That the respondent used to
regularly ask for money from the petitioner which was either transferred by the
petitioner or requested his brother to transfer funds to the account of the
respondent which is evident from the receipt / email for transferring the
amount in the bank account of the respondent by the brother of the petitioner
is annexed as Annexure P2.
20.
That the family members of the
petitioner came to know about his relationship with the respondent and the
petitioner was questioned about his relationship. The petitioner has clearly
told his parent that he will marry the respondent and no one else. The mother
of the petitioner, had agreed and stated that if he is so much in love with
her, there is no harm in getting them married. The parents of the petitioner had
agreed for the marriage of the petitioner and the respondent belong to
different caste as the family of the petitioner is Punjabi by caste and the
respondent is Brahmin by caste.
21.
That the petitioner had
discussed the issue with the respondent, who was unwilling to marry him but at
the insistence of the petitioner, she had agreed to discuss the issue with her
parents. Thereafter, the respondent and her mother visited the office of the
father of the petitioner and her mother clearly stated that they do not have
much of the money and thus they could not spend much on marriage. The
respondent’s mother further told that they do not have any relations at Delhi
who can arrange things at Delhi, thus entire arrangements have to be made by
the parents of the petitioner.
22.
That the engagement between
the petitioner and the respondent took place on dd.mm.yyyy at Janakpuri and
entire arrangement for the engagement ceremony was made by the petitioner’s
parents and his family members, there was never any contribution from the
respondent or her family members.
23.
That the petitioner and his
family members were happy and showed their emotions of love and care towards
the respondent and her family members, but on the other hand, the respondent
and her family members showed no enthusiasm and emotions and were sitting in
huddle without much cheer or expression on their faces.
24.
That after engagement, the
behavior of the respondent was completely changed towards the petitioner and
she was not allowing the petitioner to spend much of time with her. However,
the petitioner was not alerted by all this change of attitude and only
subsequently he has realized that there was change in her attitude immediately
after marriage.
25.
That the petitioner and his
parents were so excited about marriage being first in their family, they took the
respondent for shopping, purchased her lehnga, her bridal makeup, booked for
venue of marriage, booked place for the respondent and her family members to
stay, made arrangements for their guest etc.
26.
That the petitioner and his
family members made entire expenditure towards marriage and the respondent and
her family members made very little contribution towards marriage expenses. As
the family of the respondent had informed the petitioner that they will not be
in a position to manage anything at Delhi so it was the petitioner and his
family members who have to arrange everything.
27.
That the respondent family
transferred some amount towards sharing of expenditure, however when they came
to Delhi, they took cash from the petitioner and his family members for
purchasing their own clothes and articles, thus there was no contribution or
very little contribution from the end of respondent or her family members
towards marriage. The respondent had taken some personal loan for marriage and
the petitioner had paid the principal and interest amount towards the repayment
of loan. A true copy of the receipts
received in electronic form towards the repayment of loan taken by the respondent
is annexed as Annexure P3.
28.
That the marriage of the
petitioner with the respondent was solemnized as per Hindu rites and ceremonies
on dd.mm.yyyy at Hotel Radisson Blue, Dwarka, Delhi without any exchange of
dowry. The expenses in the marriage were borne by the petitioner. A true copy
of the bank statement and cheque towards the said expenses of Rs…………………./- are
annexed as Annexure P4(colly).
29.
That it is hereby submitted
that the father of the petitioner has paid some amount in cash towards the rest
of the payment in the marriage are being searched by the father of the
petitioner and he undertakes to file the same as soon as he finds the same.
30.
That after marriage, the
respondent was completely reluctant from creating any physical relationship
with the petitioner, though earlier they have enjoyed each other company, but
now the respondent did not allow the petitioner to come close to her. The petitioner
was not even once allowed to have any physical relationship with the respondent
after marriage.
31.
That the respondent further
disrespected the parents of the petitioner on several occasions and she was
never willing to talk to them. Respondent would sit in her room for long hours
without trying to talk to them, parents of the petitioner treated her like
their own daughter and bought things for which could appease her be it clothes,
jewellery, food etc., however the respondent was least responsive.
32.
That the petitioner also
showered all his love and affections, but the same was reciprocated.
33.
That within few days of
marriage, the respondent regularly picked up fight with the petitioner on each
and every point of issue. Respondent was looking for an opportunity to fight
with the petitioner. The respondent used to raise issue to fight on smallest of
the issue and never made any effort to adjust to family life. The red will always
be on her mobile and used to be awake at night chatting on phone etc.
34.
In the middle of night, the
respondent started fighting with petitioner on meager issues and disturbed
peace of the entire family. The mother of the petitioner was always on
medication and any such disturbance would wake her up and she would not be in a
position to sleep any further. The petitioner made all his effort to persuade
the respondent but she on the other hand, had asked the petitioner that she did
not want to reside with the parents of the petitioner and demanded a separate
house for herself.
35.
That the petitioner had told
the respondent that he can’t leave his parent as both are suffering various
ailments especially the mother of petitioner who was suffering from
uncontrolled sugar, pulmonary edema, coronary artery disease etc. and need a
constant care but the respondent had remained adamant to her demand.
36.
That the petitioner having
left with no other option and for the sake of his matrimonial life, had agreed
the demand of the respondent and thereafter he along with the respondent arranged
the rented accommodation in …….,. The rent agreement was prepared in name of
both the petitioner as well as the respondent, at the monthly rent of Rs…./-
per month. A true copy of the rent agreement is being annexed herewith and Annexure P5.
37.
That the petitioner and the respondent
had shifted to rental accommodation and started living separately from the father
and mother of the petitioner as per the demand of the respondent.
38.
That even shifting of parties
to separate accommodation did not changed the attitude of the respondent and
she kept on fighting with the petitioner, she was not even once loving, caring
and emotional towards the petitioner.
39.
That so much quarrel and
fighting started taking toll over the petitioner on the petty issue and petitioner
started suffering from depression.
40.
That the aforesaid mental
condition of the petitioner was easily understandable by the respondent but she
did not care about the petitioner at all.
41.
That the petitioner had lack
of sleep and he used to be awake all the time at night, being disturbed by the
entire situation. His love for the respondent was abundant, however he was not
getting the same response from the respondent and that hurted him more.
42.
That one day, the father of
the petitioner received a call from the landlord of the petitioner, who had
informed him about the mental condition of the petitioner.
43.
That the father of the
petitioner rushed to the house of the petitioner and found him in acute state
of depression. The petitioner was in very bad condition and the father of the
petitioner took him to hospital for treatment. On the other hand, the respondent
showed no emotion, respect toward the petitioner and in the month of December, yyyyy
she left the house.
44.
That the respondent while
leaving from house took all the belongings and valuables along with her. The respondent
being wife of petitioner, should have taken care of petitioner, but respondent never
showed any love and respect and when he needed the respondent by her side, she
was nowhere.
45.
That the petitioner wrote
numerous messages to respondent and wanted her to give some response, but the respondent
showed no reciprocation and acted like hard stone. The petitioner shared their
photographs of good time spent together, shared voice messages while crying and
begging her to be at his side, to come back and be with him, but the respondent
failed to do so.
46.
That the petitioner sent mail
to informant bringing his heart out and requesting respondent to come back, but
the respondent again failed to respond. As on dd.mm.yyyy, the petitioner sent
e-mail to the respondent which is reproduced herein blow which clearly shows
love of the petitioner for the respondent and his state of mental condition due
to respondent leaving his company without any reason:-
“Tum mujse pyar nhi Karti thi tbi chali Gayi. Tumhe pta nhi
tha ki mai kitna karta hu. Tumne avoid kia muje no reply nothing kisne brain
wash kia tumhara. Life mein Problems Kitne Aati hai, main aane Wala tha par nhi
tumhare jiju ne batmizi se bt ki mere dad se Meri mom se Up down chalte hain
par ye nhi chhod do. Main baggage ban gya tha ki yr kya hogya hai or tumhe pta
side effects or withdrawal symptoms hai par nhi tumhe life enjoy Karni thi
right. Socho shaadi ke 6-7 saal health issue hote tumhe toh main chodh deta
bolo. Tumhari mom ne tumhare dad ko chhod diya tha nhi na. Meri mom ko 30 ki
age mein heart problem or diabetes hogyi chhodh diya tha mere dad ne. Tumhe
freedom chahiye thi toh bol deti ki liven rahenge no shaaadi . Meri galti hai
mene pyr kia . Selfish ho tum or tumhara ex sharma sab selfish. Delhi mein reh
ke b kahi or reh rhi ho PG mein. Reason dena please.
47.
That the petitioner is still
madly in love with the respondent and wants her to be by his side. The respondent
has left the petitioner in December, without
any rhyme and reason and at time when he was unwell and under depression.
48.
That all the sincere efforts
of the petitioner and his family and friends, to bring the respondent back to
matrimonial home to resume her matrimonial obligations have bore no fruit and
the petitioner is being made to suffer.
49.
That the respondent has thus
left the matrimonial home, withdrawn from the society of the petitioner and
deserted the petitioner and the aforesaid acts of the respondent are without
any just or reasonable cause and without the consent and against the wishes of
the petitioner.
50.
That the petitioner thereafter
having left with no other option, was forced to file a petition under Section 9
of the Hindu Marriage Act, 1956 before the court of Ld. Principal Judge, Family
Courts, West District, Tis Hazari Courts, Delhi. A true copy of the petition
under Section 9 of the Hindu Marriage Act, 1956 is annexed as Annexure P6.
51.
That when the respondent came
to know about the filing of the aforesaid petition, she thereafter in order to
safeguard herself, has lodged the false and frivolous F.I.R. bearing Crime No………/2021
U/s 498A/323/504 of IPC r/w Section 3 & 4 of Dowry Prohibition Act, with
Police Station ………………, against the petitioner and his family members. The
entire F.I.R. is based on assumption and does not say even a single word about
the commission of any offence whatsoever.
52.
That the respondent is the
legally wedded wife of the petitioner and thus legally and morally bound to
perform her marital obligations. It is thus incumbent upon her to fulfill her
matrimonial obligations including cohabiting with the petitioner which
obligations she has miserably failed in discharging without any just or
reasonable cause.
53.
That the respondent has also caused
various acts of mental and physical cruelty against the petitioner and his
family members and has also severally damaged his reputation and goodwill.
54.
The respondent further with an
intent of her travelling to new destinations out of India, has forced the petitioner
to indulge in numerous misadventures, which has let the petitioner financially,
mentally exhausted and the petitioner has also suffered immensely in his job
prospects and options.
55.
That the petitioner has tried
to fulfill all the demands of the respondent, with the sole hope of bring the
happiness and togetherness of family, however the respondent has never bothered
for any such issues and has deserted the petitioner without any rhyme or
reasons.
56.
That the respondent was never
in love with the petitioner. Respondent used to pretend that she is in love
with the petitioner in order to extract money from him. The respondent got
married with the petitioner just because she was after his money and nothing
else.
57.
That it is also trite to
mention here that the petitioner and his family are the financially quite
capable having their own house and a car and as such there is no need to demand
a sum of Rs. ………….,/- and a car from the respondent and her family members.
58.
That the petitioner was
suffering from depression due to the torture and harassment made by the respondent
and was under treatment in the hospital for a long period of time. A true copy
of the documents with regard to the medical treatment of the petitioner is
annexed as Annexure P7.
59.
That the petitioner and his
family fully cooperated with the financial condition of the respondent even
than making false allegations which shows that respondent wanted to exert
pressure upon the petitioner and his family and to harass them to meet their
illegal demands.
60.
The marriage of petitioner was
never consummated, as the respondent refused to have relationship and start
family. Respondent didn’t allow him to touch her. And even respondent has
refused to have any relationship.
61.
It is submitted that no one
from her family, her parents, her brother and sister, ever visited his
home till date, to spend time with them as part of family. Her family was never
keen to build a family‐to‐family bond. There was no
regular communication except for occasional greetings on birthday/anniversary
etc.
62.
The petitioner had adjusted
with her rudeness, reckless attitude, ill‐treatment and harassment all times,
because petitioner’s family believes in marriages are made in heaven, secondly
petitioner did not want to trouble and disturb his parents further as already
they are spending their life in very painful circumstances for the reason
stated above. Petitioner took up issue related to her behavior, attitude etc
with her family, petitioner was threatened that petitioner and his parents will
be implicated in false cases of dowry and harassment and will be put behind
bars petitioner had stopped visiting his in‐laws place after that.
63.
That during the marriage,
neither petitioner nor anyone from his family had asked anything from
respondent /her family as gift/dowry etc. petitioner was having a good salary,
so petitioner never expect and never think of demanding anything from
respondent or her family. It is against the culture of petitioner family.
64.
That with time the respondent
made these fights a routine affair and subjected the petitioner to a lot of
mental agony and stress by creating a ruckus at their house, which also
resulted in the petitioner falling sick frequently and also damaging his health
in every way possible.
65.
That the petitioner being
affectionate did all acts to make the respondent feel comfortable and loved but
in return the respondent just fought with the petitioner and made him sick
because of the fights. That the respondent refused to help the petitioner with
any household work and cribbed all the time, and also harassed the petitioner
for not having enough money to fulfill the whims and fancies of the respondent.
The respondent did not respond to the love showered by her husband in an
ordinary way, rather she complained about the weak economic condition of the
hardworking petitioner.
66.
That the respondent started
enjoying this inhuman habit of hers to fight and mentally torture the
petitioner, and would get sadistic pleasures out of the sorry condition of the
petitioner, like no mentally stable person would.
67.
That the petitioner somehow
managed to come out of this trauma given to him by the respondent and did not
tell anyone about this habit of the respondent, not even his own family
members, and also requested the respondent to avoid this kind of behavior so
that the sanctity of marriage could be maintained.
68.
That any sane spouse after
getting to know of such dark and disturbing facts about the intentions of his
partner would be mentally shattered. The petitioner went through the same
ordeal and further suffered great deal of difficulty in thinking straight for a
couple of months. In these two months the petitioner tried to convince the
respondent not to end the marriage, but the respondent always turned a deaf ear
to his requests and fight on petty issues.
69.
That the petitioner having
tried everything possible to make the marriage work tried to find out about the
whereabouts of the respondent. The failure of the respondent to revert back to
the petitioner made him lose all hope of leading a normal married life.
70.
That for more than a year the
petitioner tried to contact the respondent but eventually gave up hope of
getting back with the respondent.
71.
That the respondent had left
the matrimonial home on her own volition as her nefarious demands, transfer the
property in the name of the respondent, etc. had not been met with.
72.
That thereafter, as there was
no chance for re-conciliation between the parties as the Petitioner had
categorically expressed her intention to separate from the Respondent.
73.
That the respondent and
petitioner were Hindu by religion at the time of solemnization of their
marriage and they continue to profess the same religion till the date of filing
the present petition. That after the marriage, the parties never lived as
husband and wife and did not cohabit with each other. There is no issue out of
the said wedlock. Petitioner is currently staying at her parental home and
never desired to discharge her matrimonial duties. That the aforesaid series of
incidents has resulted in the deterioration of the mental health of the
respondent and has seriously impaired his self-confidence and self esteem.
74.
That it is trite to mention
that the conduct and behavior of the respondent and the circumstances were
intentionally created by the respondent against the petitioner and are such
that the respondent has caused immense mental cruelties, torture and agony to
the petitioner without any fault of his part. Since the respondent, after their
marriage has treated the petitioner with utmost cruelty and has willfully
deserted the Petitioner, as detailed in the foregoing paras, therefore the
petitioner is entitled to dissolution of marriage by decree of divorce under
section 13(1)(ia) of the Hindu Marriage Act, 1955 as amended by marriage laws
up to date.
75.
That the petitioner is left
with no other remedy but to approach this Honorable Court. Hence this petition.
76.
That there has not been any
unnecessary or improper delay in filing this petition.
77.
That there is no legal ground
why the relief should not be granted.
78.
That the marriage was
solemnized and the parties last resided together within the limits of ordinary
original jurisdiction of this Honorable Court. The parties lastly resided
together as husband and wife at Vikas Puri, Delhi. Hence this Honorable Court
has got the jurisdiction to entertain the petition.
79.
That the prescribed court fee
has been paid and affixed on the petition.
PRAYER
:-
It is, therefore, most respectfully prayed
that a decree of divorce be passed dissolving the marriage between the parties under Section 13(1)(ia) of the Hindu
Marriage Act, 1955 as amended by marriage laws up to date.
AND
Any other relief which this Honorable Court deems fit and
proper in the circumstances of the case be also granted in favor of the
petitioner and against the respondent.
PETITIONER
DELHI THROUGH
DATED
Through
(NAME)
Advocate
Mob.No………….,
Email:
VERIFICATION
:-
The above named petitioner states on
solemn affirmation that the paras No.1 to ……. of the petition are true upon
petitioner’s knowledge and paras …… to
……. of the
petition are true upon information received and believed to be true. Last para
is prayer made to this Hon’ble Court. Verified at Delhi on this ___ day of March, 2022.
PETITIONER
IN
THE COURT OF LD. PRINCIPAL JUDGE, FAMILY COURT; TIS HAZARI COURTS, DELHI.
H.M.A.
CASE NO. ________ OF 2022.
GAUTAM
SAHNI :
PETITIONER
VERSUS
AFFIDAVIT
1. That
the marriage between the Petitioner and the respondent was solemnized according
to Hindu Rites and ceremonies on dd.mm.yyyy at ………………., Delhi.
2. That
the contents of the accompanying petition under Section 13(1)(ia) of the Hindu
Marriage Act, has been drafted by my counsel under my instructions, contents of
the same are true and correct to my knowledge and the same may kindly be read
as part and parcel of this affidavit as the contents of the same are not being
repeated herein for the sake of brevity and to avoid repetition.
3. That
the contents of the accompanying petition with regard to cruelties may also be
read as part hereof which are not being repeated here for the sake of brevity.
4.
That the marriage between the
parties has been completely broken down and there is no possibility of the
parties living together.
5.
That the accompanying petition
has not been filed in collusion with the respondent.
6.
That there is no impediment in
granting the relief to the petitioner.
7.
That there has not been any
improper delay in filing the petition.
8.
That the petitioner has not in
any manner been accessory to or connived at and condoned the acts complained
of.
DEPONENT
VERIFICATION :-
I, the above named deponent, do hereby
verify that the contents of the above affidavit are true and correct to my knowledge,
no part of it is false and nothing material has been concealed therefrom.
Verified at Delhi on this ___ day of March, 2022.
DEPONENT
