ROLL NO.

2001052

CASE MOOT SEM X, 2025

BEFORE THE HON’BLE FAMILY COURT OF DELHI

CASE NO. 10/2025

ORIGINAL JURISDICTION

UNDER SECTION 7 OF THE FAMILY COURTS ACT, 1984

IN THE MATTER OF

Mrs. JANVI K. ………………………………………………PETITIONER

v.
Mr. SIDHARTH M. …………………………………………RESPONDENT

MEMORIAL ON THE BEHALF OF RESPONDENT

DRAFTED AND FILED BY COUNSEL FOR THE RESPONDENT

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 TABLE OF CONTENTS

S.NO TOPIC PAGE NO.

1. LIST OF ABBREVIATION………………………….3
2. REFERENCES……………………………………….4
3. TABLE OF CASES…………………………………..5
4. STATEMENT OF JURISDICTION………………...6
5. STATEMENT OF FACTS……………………...........7
6. STATEMENT OF ISSUES…………………………..8
7. SUMMARY OF ARGUMENTS…………………….9
8. ARGUMENTS ADVANCED…………………..…10-16
9. PRAYER……………………………………………..17

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 LIST OF ABBREVIATIONS
AIR All India Reporter

BNSS Bhartiya Nagrik Suraksha Sanhita

HAMA Hindu Adoptions and Maintenance Act

HMA Hindu Marriage Act

HMGA Hindu Minority and Guardianship Act

Hon’ble Honorable

N. Delhi New Delhi

s. Section

SC Supreme Court

SCC Supreme Court Cases

SLP Special Leave Petition

v. Versus

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 REFERENCES
BOOKS:
1. Dr. Paras Diwan, Modern Hindu Law (Pg 273, 25th ed., Allahabad Law Agency, 2022)
2. Ishan Mihir Patel, Hindu Law of Divorce, Maintenance and Child Custody (2nd ed.,

Law and Justice Publishing Co.,)

3. Prashant Chandra, Laws Relating to LIBERTY, CHILD CUSTODY AND

4. Prof. (Dr.) Rakesh Kumar Singh, Modern Hindu Law (Thomson Reuters)
5. Prof. Kusum, Family Law Lectures Family Law I (6th ed., LexisNexis)

LEGAL DATABASES:
1. Bar & Bench
2. Indian Kanoon
3. Manupatra
4. SCC Online

STATUTORY PROVISIONS:
1. Bharatiya Nagarik Suraksha Sanhita, 2023.
2. Family Courts Act, 1984.
3. Hindu Adoption And Maintenance Act, 1956.
4. Hindu Marriage Act, 1955.
5. Hindu Minority and Guardianship Act, 1956.

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 TABLE OF CASES
CASE LAWS PAGE NO.

1. Bhushan Kumar Meen Vs. Mansi Meen AIRONLINE 2009 SC 407…………..15-16

2. In Mc Grath Re (1893) 1 Ch 143……………………………………………………14
3. Mamta Jaiswal Vs. Rajesh Jaiswal II(2000)DMC170……………………………...16
4. Manushree Vs. Sachin (case no.26/2016 decided on 15.01.2019
ADJ Saket District Court N. Delhi)………………………………………………...16
5. Saraswathibai Shripad v. Shripad Vasanji AIR 1941 BOMBAY 103………………14
6. Savitri Pandey v. Prem Chandra Pandey AIR 2002 SC 591……………………..…11
7. Thrity Hoshie Dolikuka v. Hoshiam Shavaksha Dolikuka, (1982) 2 SCC 544…14-15
8. Vishwanath Agrawal v. Sarla Vishwanath Agrawal (2012) 7 SCC 288……….……11

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 STATEMENT OF JURISDICTION
The counsel on the behalf of the Respondent has endorsed the pleadings in response to the
petition filed by the petitioner under the aegis of Section 7 the Family Courts Act, 19841. The
Respondent will humbly contest the grounds that have been invoked under the aegis of
aforementioned section of the Family Courts Act, 1984.

1
Jurisdiction. -
(1) Subject to the other provisions of this Act, a Family Court shall-
(a) have and exercise all the jurisdiction exercisable by any district court or any subordinate civil court under
any law for the time being in force in respect of suits and proceedings of the nature referred to in the
Explanation; and
(b) be deemed, for the purposes of exercising such jurisdiction under such law, to be a district court or, as the
case may be, such subordinate civil court for the area to which the jurisdiction of the Family Court extends.
Explanation. - The suits and proceedings referred to in this sub-section are suits and proceedings of the
following nature, namely:-
(a) a suit or proceeding between the parties to a marriage for a decree of nullity of marriage (declaring the
marriage to be null and void or, as the case may be, annulling the marriage) or restitution of conjugal rights or
judicial separation or dissolution of marriage;
(b) a suit or proceeding for a declaration as to the validity of a marriage or as to the matrimonial status of any
person;
(c) a suit or proceeding between the parties to a marriage with respect to the property of the parties or of either
of them;
(d) a suit or proceeding for an order or injunction in circumstances arising out of a marital relationship;
(e) a suit or proceeding for a declaration as to the legitimacy of any person;
(f) a suit or proceeding for maintenance;
(g) a suit or proceeding in relation to the guardianship of the person or the custody of, or access to, any minor.
(2) Subject to the other provisions of this Act, a Family Court shall also have and exercise-
(a) the jurisdiction exercisable by a Magistrate of the First Class under Chapter IX (relating to order for
maintenance of wife, children and parents) of the Code of Criminal Procedure, 1973 (2 of 1974); and
(b) such other jurisdiction as may be conferred on it by any other enactment.

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 STATEMENT OF FACTS
1) Sidharth M. and Janvi K. got married in 2020 through Hindu rites and ceremonies in a
temple in Delhi. Both had well-paying IT jobs, and their marriage started on a happy
note. They lived harmoniously for the first six months, supporting each other in both
personal and professional capacities.
2) After six months of marriage, Sidharth made a bold career decision by leaving his high-
paying job (₹1,10,000 per month) to pursue a business venture, aiming for long-term
financial stability. Janvi, being a supportive wife, stood by him during this transition.
Through immense hard work over the next two years, Sidharth’s business flourished,
and he began earning more than his previous salary.
3) Since Janvi’s salary was relatively lower (₹60,000 per month), Sidharth suggested that
she leave her job and pursue a better opportunity that aligned with her intellectual
capabilities and offered higher pay. Trusting their financial security, she voluntarily
resigned.
4) In the early years of the business struggle, Sidharth became involved in drinking and
gambling, which had a significant impact on both his financial and emotional stability,
as well as that of his family. However, this phase lasted for only 1.5 years. As he began
to achieve success, he regained control of himself and made every effort to mend the
emotional distress his wife had endured during this period. Throughout this time, Janvi
remained the backbone of the family, playing a crucial role in keeping it together.
5) In January 2022, they welcomed their baby girl, Era. This milestone transformed
Sidharth into a more responsible family man, as he prioritized spending time with his
daughter despite his business commitments. Whenever possible, he took Era to parks
and shopping malls and ensured her emotional well-being, thereby sharing a significant
responsibility.
6) Despite Sidharth’s efforts to maintain harmony, Janvi often scolded Era for minor
issues, exhibited rapid mood swings, and frequently raised her voice at her, fully aware
that such behavior could have a lasting impact on their young daughter. Her attitude
toward Sidharth also showed no inclination toward reconciliation, despite
understanding the delicate future of their child. Instead of addressing the situation
through discussion or counseling, Janvi filed for divorce in January 2025, seeking
custody of Era and demanding ₹70,000 per month in maintenance.

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 STATEMENT OF ISSUES

ISSUE 1

 WHETHER EMOTIONAL AND FINANCIAL DISTRESS/ CHALLENGE FOR A BRIEF

PERIOD BETWEEN HUSBAND AND WIFE CONSTITUTE SUFFICIENT GROUNDS
FOR DIVORCE UNDER SECTION 13 OF THE HINDU MARRIAGE ACT, 1955.
FURTHERMORE, SHOULD THE EFFORTS MADE TOWARDS RECONCILIATION
BE FACTORED INTO THE COURT'S CONSIDERATION?
ISSUE 2
 WHETHER PETITIONER’S (JANVI'S) CURRENT STATE OF DISTRESS RENDER
HER UNFIT TO PROVIDE A STABLE AND NURTURING ENVIRONMENT FOR THE
CHILD, THEREBY RAISING QUESTIONS ABOUT HER SUITABILITY FOR
CUSTODY?
ISSUE 3
 WHETHER THE PETITIONER (JANVI K.) ENTITLED TO MAINTENANCE, GIVEN
THAT EVENTS IN THE MARRIAGE HAVE NOT YET ESTABLISHED VALID
GROUNDS FOR DIVORCE?

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 SUMMARY OF ARGUMENTS

1. Whether Emotional and Financial Distress/ Challenge for a Brief Period Between
Husband and Wife Constitute Sufficient Grounds for Divorce under Section 13 of the
Hindu Marriage Act, 1955. Furthermore, Should the Efforts Made Towards
Reconciliation Be Factored into the Court's Consideration?

May it please this Hon’ble Court, it is humbly submitted that the petitioner lacks locus standi
to seek a decree of divorce before the Hon’ble Family Court of Delhi, as no valid grounds have
been established under Section 13 of The Hindu Marriage Act, 1955. Furthermore, the
petitioner has failed to produce any substantive proof of misconduct on the part of the
respondent or any evidence of an irretrievable breakdown of marriage, which are essential
considerations for granting divorce. In the absence of such legally recognized grounds, the
present petition is devoid of merit and does not warrant consideration by this Hon’ble Court.

2. Whether Petitioner’s (Janvi's) Current State of Distress Render Her Unfit to Provide
a Stable and Nurturing Environment for the Child, thereby Raising Questions about
her Suitability for Custody?

It is humbly submitted before this Hon’ble court that the petitioner’s emotional instability raises
concerns under Section 6(a) of the Hindu Minority and Guardianship Act, 1956, which, while
favoring maternal custody for children below five, is subject to the child’s best interests. Given
the petitioner’s distress, the respondent’s emotional and financial stability makes him more
suitable for custody as per section 13 of the Hindu Minority and Guardianship Act, 1956.

3. Whether the Petitioner (Janvi K.) Entitled to Maintenance, given that Events in the
Marriage have Not Yet Established Valid Grounds For Divorce?

May it please this Hon’ble Court, the petitioner’s claim for maintenance under Section 25 of is
entirely unsustainable. As a well-educated, financially independent ex-IT professional, the
petitioner does not qualify under Section 24 of The Hindu Marriage Act, 1955, which is
designed to provide maintenance only to financially dependent spouses. Furthermore, no valid
grounds for divorce or matrimonial offenses have been established against the respondent. In
the event that the respondent is granted custody of the child, the petitioner’s claim for
maintenance loses any legal foundation, as the need for such support would be further
diminished by the respondent’s willingness and ability to fulfill the child’s financial needs.

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 ARGUMENTS

1. WHETHER EMOTIONAL AND FINANCIAL DISTRESS/ CHALLENGE FOR A

BRIEF PERIOD BETWEEN HUSBAND AND WIFE CONSTITUTE SUFFICIENT
GROUNDS FOR DIVORCE UNDER SECTION 13 OF THE HINDU MARRIAGE
ACT, 1955. FURTHERMORE, SHOULD THE EFFORTS MADE TOWARDS
RECONCILIATION BE FACTORED INTO THE COURT'S CONSIDERATION?

[1.1] May it please this Hon’ble Court, it is most respectfully submitted that the present petition
seeking divorce under Section 13 of the HMA, 1955 fails to establish any legally sustainable
grounds for the grant of a divorce decree by the Hon’ble Family Court of Delhi.

[1.2] Absence of Valid Grounds Under Section 13 of the HMA, 1955

The petitioner has failed to substantiate the claim for divorce under any recognized ground
stipulated under s. 13 of the Act. The Act primarily provides for three categories of divorce:

A. SECTION 13 (DIVORCE ON SPECIFIED GROUNDS);

a) Marital Infidelity & Sexual Misconduct
b) Cruelty & Mental/Physical Health Issues
c) Abandonment & non-coexistence
d) Religious & Spiritual Renunciation
e) Death & Presumption of Death
f) Special Grounds for Wife
B. SECTION 13A (ALTERNATE RELIEF IN DIVORCE PROCEEDINGS); &
C. SECTION 13B (DIVORCE BY MUTUAL CONSENT).

A meticulous examination of the present case reveals that neither Section 13A nor Section
13B of the HMA, 1955 is applicable. The essential conditions for invoking these provisions—
such as an irretrievable breakdown of marriage or mutual consent—are absent. Consequently,
the only applicable provision to consider is s.13, which operates under the offence/fault theory,
requiring proof of specific matrimonial offence/fault by the respondent.

[1.3] Failure to Establish Matrimonial Offense or Fault Under Section 13

It is humbly submitted that no substantial evidence has been presented to indicate any culpable
act by the respondent that would warrant a divorce decree under s. 13. The provision mandates
the existence of a legally recognized matrimonial offense or fault that fundamentally impairs

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the marital relationship. However: there is no indication of any physical or mental incapacity
on the part of the respondent that would prevent the continuation of a healthy marital
relationship.

In the case of:

Savitri Pandey v. Prem Chandra Pandey2 the Supreme Court has held that: marriage between
the parties cannot be dissolved only on the averments made by one of the parties that as the
marriage between them has broken down and no useful purpose would be served to keep it
alive.

The respondent’s alleged actions, even if admitted as momentarily irresponsible and subjected
to the highest level of scrutiny, do not meet the threshold of severity or gravity required to
establish grounds for divorce under s.13 of the HMA, 1955. The brief and temporary nature of
the alleged behavior must be considered in the context of the respondent’s professional and
personal circumstances at the time. Notably, the respondent's actions occurred during a
challenging phase wherein he was striving to achieve greater financial stability and security for
the welfare of his wife and future child. Such efforts, even if they inadvertently led to certain
temporary strains in the relationship, cannot be construed as intentional misconduct or an act
aimed at harming the spouse or the marital bond.

In Vishwanath Agrawal v. Sarla Vishwanath Agrawal 3, wherein it was observed that the
expression ‘cruelty’ has an inseparable nexus with human conduct or human behaviour. It is
always dependent upon the social strata or the milieu to which the parties belong, their ways
of life, relationship, temperaments and emotions that have been conditioned by their social
status.

It is respectfully submitted that due consideration must be given to the educational and social
background of both spouses, which can be objectively categorized as mature and literate.
Given their educational qualifications and exposure, both parties possess the capacity for
reasoned decision-making and responsible conduct. This Hon’ble Court may, therefore, assess
their claims in light of their intellectual maturity and social standing, ensuring that legal
remedies are not misused in a manner contrary to the principles of equity and justice.

2
AIR 2002 SC 591
3
(2012) 7 SCC 288

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 Furthermore, it is pertinent to highlight the respondent’s sincere and proactive efforts to restore
harmony in the marriage and ensure the well-being of the child, immediately upon regaining
stability in his professional and personal life. The respondent made genuine attempts to
reconcile with the petitioner, thereby demonstrating his commitment to preserving the marital
bond. Additionally, the respondent displayed profound empathy and affection towards his
daughter, who, during her tender years, suffered neglect at the hands of the petitioner. While it
is acknowledged that marital discord caused strain on both sides, it was the respondent who
took the initiative to ensure the child's care and welfare. His actions reflect a responsible
and devoted approach to parenting, which must be duly considered while assessing the
overall merits of the present case.

2. WHETHER PETITIONER’S (JANVI'S) CURRENT STATE OF DISTRESS

RENDER HER UNFIT TO PROVIDE A STABLE AND NURTURING
ENVIRONMENT FOR THE CHILD, THEREBY RAISING QUESTIONS ABOUT
HER SUITABILITY FOR CUSTODY?

It is a humble submission before this Hon’ble court that the petitioner should not be granted
the right to custody of the child (Era) under the HMGA, 1956.

[2.1] Applicability

I. According to s. 3(1)(a) of the HMGA, 1956, the act is applicable to any person who is a
Hindu by religion. In the present case, both the parties are Hindus by religion married
under Hindu rites.
II. According to s. 6(a) of the HMGA, 1956, in the case of a boy or an unmarried girl—the
father, and after him, the mother will be the natural guardian: provided that the custody
of a minor who has not completed the age of five years shall ordinarily be with the mother,
also;
III. According to the s.13 of the HMGA, 1956, the welfare of the minor is the primary
concern when appointing a guardian for a Hindu minor. No one has an automatic right to
guardianship if the court finds that their guardianship would not be in the minor’s best
interest.

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[2.2] Petitioner’s Emotional Stability and Its Impact on the Child, Era

It is respectfully submitted that while the petitioner’s mental distress may not have originated
from her own volition, she nonetheless had the responsibility to manage and regulate it in a
manner that would not adversely affect the well-being of the child. In the present case, the
petitioner’s demeanor and approach toward Era raise serious apprehensions regarding the
potential negative impact on the child’s emotional and psychological development. The
petitioner’s mood swings, frustration, and emotional distress should not become a burden on
the child, as a minor cannot be expected to bear the responsibility of managing or enduring a
parent’s instability. It is, therefore, imperative for this Hon’ble Court to examine whether such
an environment aligns with the paramount principle of the child’s best interests and welfare.

Furthermore, human behavior can be regulated with the realization of responsibility. This is
evident from the respondent’s mature and proactive approach in attempting to reconcile with
both the petitioner and his daughter, demonstrating emotional stability and parental
commitment. However, the petitioner’s emotional distress, particularly its infliction upon the
child during her tender years, indicates a state of psychological strain that presently renders her
unfit for custody.

In light of the foregoing, it is submitted that the welfare of the child must remain the primary
consideration, and the petitioner’s current disposition must be thoroughly assessed before
granting custody.

[2.3] Petitioner’s Instability Acts as A Counter to Perpetual Financial Stability and

Emotional Development of The Child

It is respectfully submitted that the petitioner’s current period of instability and frustration is
inversely proportional to the continuous financial stability and emotional security essential for
the child’s well-being, particularly during her formative years. An environment marked by
uncertainty and distress may not be conducive to the child’s overall development, as financial
and emotional stability are fundamental components of a healthy upbringing.

While it may be argued that financial support for the child can be provided by the respondent
even if she remains in the petitioner’s custody, mere financial assistance does not suffice to
ensure the child’s welfare. In this regard, attention is drawn to an article published in the Indian

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Journal of Social Psychiatry4, which underscores the interrelation between financial security,
parental mental health, and family relationship stability as key determinants of child
development. The study reinforces the principle that financial support alone cannot compensate
for an emotionally strained parent-child relationship. In Mc Grath Re5, Lindely, L.J. observed;
The dominant matter for the consideration of the court is the welfare of the child. But the
welfare of the child is not to be measured by money only nor merely physical comfort. The
word ‘welfare’ must be taken in its widest sense. The moral or religious welfare of the child as
well as its physical well-being. Nor can tie of affection be disregarded.

The respondent, recognizing the importance of both financial and emotional stability, has
actively taken steps to ensure the child’s well-being. Despite professional commitments, he has
consistently engaged in activities that foster emotional security, such as taking Era to parks,
shopping malls, and attending to her emotional needs. These efforts highlight his capability to
provide a stable, nurturing, and financially secure environment for the child, which must be
duly considered when determining custody. Therefore, in the present case, the specific legal
grounds under s. 13 of the HMGA, 1956 must take precedence over the general presumption
that a mother should retain natural guardianship of a child below five years of age. The
principle of maternal guardianship, while recognized under s. 6 of the HMGA, 1956, is not an
absolute right but is always subject to the paramount consideration—the best interests and
welfare of the child.

[2.4] Rebuttal to the Presumption in Favor of the Mother

While the HMGA, 1956 favors the mother for custody of a child below five years, this is not
an absolute rule. The welfare of the child is the primary concern.

In Saraswathibai Shripad v. Shripad Vasanji6 the Hon’ble court observed, "It is not the welfare
of the father, nor the welfare of the mother that is the paramount consideration for the Court. It
is the welfare of the minor and the minor alone which is the paramount consideration."

In Thrity Hoshie Dolikuka v. Hoshiam Shavaksha Dolikuka7, the Court reiterated that the
only consideration of the Court in deciding the question of custody of minor should be the
welfare and interest of the minor. And it is the special duty and responsibility of the Court.

4
Gaspar, T., Cerqueira, A., Guedes, F.B. et al. Parental Emotional Support, Family Functioning and Children's
Quality of Life. Psychol Stud 67, 189–199 (2022).
5
(1893) 1 Ch 143
6
AIR 1941 BOMBAY 103
7
(1982) 2 SCC 544

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Mature thinking is indeed necessary in such situation to decide what will ensure to the benefit
and welfare of the child. In view of the foregoing, it is respectfully submitted that the present
case establishes strong grounds for the respondent’s suitability in ensuring the welfare of the
child. The respondent’s consistent efforts have been centered on reconciliation with his wife,
primarily to prevent any adverse impact on the child’s well-being. This demonstrates a
responsible and child-centric approach, prioritizing the stability and emotional security of the
child over personal differences.

Accordingly, this Hon’ble Court is urged to consider the respondent’s disposition, maturity,
and commitment to the child’s welfare while determining custody. His proactive stance in
fostering both financial and emotional stability unequivocally aligns with the paramount
consideration principle—that the best interests of the child must prevail in all custody matters.

3. WHETHER THE PETITIONER, JANVI K., ENTITLED TO MAINTENANCE,

GIVEN THAT EVENTS IN THE MARRIAGE HAVE NOT YET ESTABLISHED
VALID GROUNDS FOR DIVORCE?

[3.1] It is submitted before this Hon’ble court that the petitioner is not entitled for
maintenance from the respondent under s. 25 of HMA 1955, s.18 of HAMA, 1956 & s.144
of BNSS, 2024.

[3.2] Non-Sustainability of the Petitioner’s Claim for Maintenance

May it please this Hon’ble Court, it is humbly submitted that the petitioner’s claim for
maintenance does not satisfy the conditions prescribed under the HMA, 1955, particularly
under s. 24, which emphasizes the financial standing and capability of either spouse. In the
present case, the petitioner is a well-educated ex-IT professional who has been employed both
before and after the marriage. Given her professional background and financial independence,
she falls outside the purview of s.24, which is intended to provide relief to a financially
dependent spouse.

In Bhushan Kumar Meen Vs. Mansi Meen8, while reducing the maintenance amount from
Rs.10000/- to Rs.5000/- granted by the lower court to the wife, the Supreme Court observed
that " we cannot also shut our eyes to the fact that at present the respondent wife is not employed
or at least there is nothing on record to indicate that she is employed in any gainful work.

8
AIRONLINE 2009 SC 407

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However having regard to the qualifications that she possesses, there is no reason why she
ought not to be in a position to also maintain herself in the future.

In the case of Mamta Jaiswal Vs. Rajesh Jaiswal 9, Madhya Pradesh High Court Civil
Revision No.1290 of 1999 decided on 24.03.2000 the Hon'ble High Court of Madhya Pradesh
has held that well qualified spouses desirous of remaining idle, not making efforts for purpose
of finding out a source of livelihood, have to be discouraged. It is further held that a lady, who
is fighting matrimonial litigation filed for Divorce, cannot be permitted to sit idle and to put
her burden on the Husband for demanding pendente lite alimony from him during pendency of
such matrimonial petition.

Also, in the case of Manushree Vs. Sachin (case no.26/2016 decided on 15.01.2019 ADJ Saket
District Court N. Delhi) while rejecting the maintenance petition filed by the wife who is well
qualified has also observed that Court should not be allowed to be used to extort money.

Furthermore, if this Hon’ble Court seeks to analyze other relevant provisions such as s. 18(2)
- (a), (b), (d), (e), (f), (g) of the HAMA, 1956, and s, 144 (4) of the BNSS, 2023 it becomes
evident that these provisions apply in cases where the wife is justified in living separately or in
seeking maintenance due to the husband’s fault. However, in the present case:

 No legally recognized grounds for divorce have been established.

 No matrimonial offense has been committed by the respondent.

The respondent has consistently provided both emotional and financial care for the child, unlike
the petitioner, whose course of care has been inadequate.

As a result, if this Hon’ble Court grants custody of the child (Era) to the respondent, the
petitioner’s claim for maintenance for the child’s upbringing holds no legal basis. Additionally,
as an educated and financially capable individual, the petitioner cannot claim maintenance on
the same footing as a deserted or financially/educationally destitute spouse lacking sufficient
means for survival.

Moreover, the respondent remains willing to provide financial assistance for a reasonable
period should the petitioner wish to reconcile and settle the matter amicably without divorce.
His insistence on this course of action stems from his genuine intent to preserve the welfare of
the child and safeguard the sanctity of the marital relationship.

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II(2000)DMC170

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 PRAYER

Wherefore, in light of the facts stated, the arguments advanced, and the authorities cited, the
respondent most humbly prays that this Hon’ble Court be graciously pleased to:

1. Declare that the petitioner is not entitled to a decree of divorce.

2. Declare that the petitioner is not entitled to custody of the child, as the welfare and best
interests of the child are best served in the respondent’s care.
3. Declare that the petitioner is not entitled to any sum of maintenance, as she is financially
independent and capable of maintaining herself.

AND/OR

Pass any such further orders as this Hon’ble Court may deem just, equitable, and
appropriate in the interests of justice, equity, and good conscience.

For this act of kindness, the respondent, as duty-bound as ever, shall remain eternally
grateful.

Date: 20.02.2025 RESPECTFULLY SUBMITTED

COUNSEL ON BEHALF OF THE RESPONDENT

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