MEMORANDUM OF UNDERSTANDING (MOU) /

SETTLEMENT AGREEMENT

This Memorandum of Understanding is made and executed on this …….

day of March 2025 between:

Sanjay Kumar (Aadhar card no.4694 7494 5479) Son of Sh. Jiwan lal, aged 32

years, a Resident of V.P.O. Bilaspur, Tehsil Haripur District- Kangra, H.P.

(hereinafter referred to as “FIRST PARTY”)

AND

VARSHA (Aadhar card no. 4319 9629 6720) W/O Sh. Sajany Kumar, Daughter

of Sh. Kuldeep Chand aged 27 years old, a Resident of ward no.5, Hanuman

Nagar Narwana, Tehsil Narwana Distt-Jind Haryana.

AND WHEREAS;

1. The marriage between the First Party and Second Party was solemnized on

04.05.2021 as per Hindu rites, customs and ceremonies. No child is born

from the above said marriage.

2. That the marital life of the parties could not run happily and due to

temperamental differences, difference of opinion and incompatibility between

the parties, disputes and differences have been arose as such they could not

continue their relationship happily for long time and in result thereof, both of

them started living separately since 07/11/2021.

3. That the second party has filed a domestic violence case (DV ACT) complaint

is registered case no. COMA/34/2022 BEFORE THE Sub-Divisional Judicial

Magistrate, Narwana Jind Haryana against the first party and his other family

members. The second party has also filed a case under section 125 Cr.P.C vide

Mt. Case No.352/2022 against the first party, which is pending adjudication

before additional district and sessions judge, NARWANA designated as the

principal judge of the family court, NARWANA HARYANA. The first party

has filed a Divorce Case U/S 13 (1) (i-a) of the Hindu Marriage Act 1955 vide

HMA Case No.140/2023 against the second party, which is pending

adjudication before The Principal Judge of the Family Court at Kangra,

Parties requested to transfer petition no. 2120/2024 to the Apex Court for above

said case.

4. AND WHEREAS, with the efforts of the respective family members/ relatives

and respectable counsels of both the parties, the matter has been amiably settled

between the parties on the following terms and conditions:-

A. That both the parties have settled all their disputes, and differences with each other

with the certain terms and conditions and further both the parties have decided

to get their marriage dissolved by way of a decree of divorce by mutual consent

under Section 13(B) of Hindu Marriage Act, 1955 from the Hon’ble Family

Court, Narwana at Jind Haryana.

B. That it has been mutually settled that the first party will pay a sum of Rs.

11,50,000/-) to the second party as full and final settlement towards all her

claims i.e., maintenance (past, present and future), permanent alimony, stridhan,

Jewellery, movable and immovable properties etc.

C. That the Second party/wife has already received all her articles, istridhan and

jewellery from the First Party/Husband and his family member. The Second

party will be left with no claim of marriage expenses, litigation expenses,

maintenance (Past, Present and Future), permanent alimony, movable or

immovable properties from the First Party/ Husband and his family members.
D. That the full and final amount of Rs. 11,50,000/- will be paid by the first party

to the second party in two instalments. First instalment of Rs. 4,00,000/-) will

be paid at the time of recording of statement on the first motion petition by way

of demand draft or Cheque no…………. in the name of second party. The

second instalment of Rs.7,50,000/-) will be paid, at the time of recording of

statement on the second motion petition by way of demand draft or cheque

no……… in the name of second party,

E. That after the recording of the statement of the first motion petition, Second party

will withdrawal of all registered cases against the First Party and his family

members, before the appropriate authority and the both parties will cooperate

and make necessary statements before the court for withdrawal of the above-

mentioned cases.

F. That it has been settled between the parties that both the parties will file joint

mutual divorce petition under section 13B of Hindu Marriage Act to dissolve

their marriage by a decree of Divorce by mutual consent as early as possible

preferably within a period of 15 days from the signing of the present MOU. The

second motion petition u/s 13 B (2) of HMA along with an application for

waiving of statutory period of six months will be filed soon thereafter,

preferably within 2 months from the grant of first motion petition. It is also

agreed that the petition for withdrawal of all registered cases and his other
 family members before the Second Motion will be filed soon after the first

motion.

G. That both parties have agreed that they will cooperate with each other for filing

the first motion petition u/s 13 B(1) HMA, second motion petition 13-B (2)

HMA and quashing petition and will appear before the respective courts to

make necessary statements.

H. That both the parties have agreed that after receiving the full and final settlement

amount, grant of divorce and quashing of the case, either party will not interfere

in the personal and professional life of each other and they will also not file any

type of case, complaint, petition against each other or their respective family

members qua this marriage.

I. That after signing of this MOU the respective parties shall withdraw their cases

from the concerned court as soon as possible irrespective of their dates of

hearing. The parties have undertaken that they will file an application in their

respective cases to postpone the dates in order to withdraw the cases.

J. That it has been mutually agreed between the parties that after receiving the full
and final amount i.e. Rs.11,50,000/-, neither Party or their family members shall
have any claim left against the other Party or their family members of any kind
whatsoever and they will not claim any type of maintenance, alimony etc. as it
 is a full and final settlement which covers all the claims of the respective
parties.

K. That it is further agreed between the parties that in case of breach/violation or

L. That it is also agreed between the parties that any case, complaint, claim or
appeal filed against each other whether known or unknown where
summon/notice has been issued or not would be null and void and will be
treated as withdrawn/quashed after grant of decree of divorce to the parties.

M. That if either of the party has filed any complaint which is not in the knowledge of
either of the parties in court of law, police or any other authority, either in
Haryana or in any territory of India then it shall be deemed to be considered as
compromise and withdrawal and not shall any effect.

N. The First Party/ Husband and Second Party/Wife have agreed and undertake not
to use any documents Aadhar Card, Pan Card, Passport, Ration Card, electricity
bill, Digital Signature and electronic data or whatsoever) related to each other in
present, and the future. That in case any of the parties violate this clause then
the aggrieved party shall have the right to enforce criminal proceedings against
the other party.

O. That the above said settlement and its terms and conditions have been entered
and executed between the parties with their free consent and the consent of their
respective family members with their sweet will and without any force, undue
pressure, influence, misrepresentation or mistake (both law and fact) in any
 form, and statement, agreement has been correctly recorded the said agreed
terms are without any inducement or coercion from any corner whatsoever.

P. That as per the terms and conditions of the MOU, both the parties undertake that
after execution of this MOU and after taking divorce by mutual consent from
the concerned family court, then both the parties will be in contact with each
other in any way, like WhatsApp and any other way. It is further agreed
between the parties, that both parties will not misuse any photographs, and
videos of each other. The Second Party also undertake not to visit the office of
the First Party and the home in future after executing the MOU.

IN WITNESS WHEREOF, the parties here to have signed this MOU on the
day, month and year first herein above mentioned in presence of the following
Witnesses:

First Party

(SANJAY KUMAR)
WITNESSES

1.

Second Party

(VARSHA)

2.