IN THE COURT OF THE IN THE COURT OF THE HON'BLE FAMILY JUDGE COURT

JUDGE CUM XV ADDL DISTRICT JUDGE, RANGA REDDY DISTRICT

AT::KUKATPALLY

O.P.NO. OF 2020

Between:

G. Indira, W/o Santosh Gaikwad,

aged about 41 years, occ: Teacher ,
R/o H.No.26, Rail Vihar Colony,
Serilingampally,
Lingampalli, R.R.District
Telangana-500032. … PETITIONER No.1
AND
Santosh Gaikwad, S/o Laxman Gaikwad,
Aged: 50 years, occ: Private Employee,
R/o H.No.26, Rail Vihar Colony,
Serilingampally,
Lingampalli, R.R.District,
Telangana-500032. … PETITIONER No.2

PETITION FILED UNDER SEC.13-B OF THE HINDU MARRIAGE ACT,

1955, FOR DISSOLUTION OF MARRIAGE BY MUTUAL CONSENT.

I DESCRIPTION OF THE PETITIONER NO.1

The description and address of the petitioner for the purpose of service
of summons, notices, process etc is the same as stated above in the cause title.

II DESCRIPTION OF THE PETITIONER NO.2

The description and address of the respondent for the purpose of

service of summons, notices, process etc is the same as stated above in the
cause title.

III The above named petitioners respectfully submitting as follows :

1. It is submitted that, the marriage between the Petitioners was

performed on 24-08-1998, at: _______, at: H.No.5-73, Chitanyapuri
Colony, Dilsukhnagar, Hyderabad, as per Hindu rites and customs. The
said marriage was arranged marriage. The same was attended by the
parents, friends and relatives of either sides. They Immediately, after
the marriage, the Petitioner No.1 accompanied the Petitioner No.2 to the
marital home. Out the said wedlock they were blessed with 2 male
 children namely 1)G.Rohan, aged about 21 years, 2)G.Rashmitha, aged
about 16 years.

2. It is submitted that, even though the Petitioners lived together for a

period of 5 years, after 5 years some they could not able to adjust with
each other one are the other issues raised between each other and they
could not able to live together hence in the year 2003 the petitioner no.2
went to Chenni and stayed there. The petitioner no.1 and her children
were with the parents of the petitioner no.2. the petitioner no.2 used to
come to Hyderabad once in a year to see his parents. The petitioner no.2
stayed there for 15 years and the petitioner no.1 and petitioner no.2
never tried to meet each other for those 15 years, then after the
petitioner no.2 shifted to Pune and he stayed there for 2 years, then the
petitioner no.2 come back to Hyderabad to stay with his parents. Then
also even after the gap of those 17 years the petitioner no.1 and 2 could
not able to live together. This not out of place to mention that For these
17 years both the petitioner no.1 and 2 do not have conjugal
relationship. The petitioners realized that they are incompatible to each
other. As they are unable to adjust with each other and they have
decided to take divorce by mutually. Since then the petitioner no.1
staying at her parent’s home at______________ since first week of January
2019. The children are staying with the grand parents only. The
petitioner no.2 visit frequently to look after her children and in-laws.
The parents and relatives of the Petitioners attempted to reconcile the
petitioners. However all their efforts to reconcile them failed. The
Petitioners refused to live together as husband and wife on account of
incompatibility.

4. It is submitted that, since the petitioners are living separately since 18

years they never tried to live together, both the children were aware of
the said fact.

5. It is submitted that, after the intervention of the elders from both sides
considering the future of the children as well as the petitioner no.1 and
2, both the petitioners came to a compromise that they would take
 divorce mutually on the ground of incompatibility and they have
decided that, the children will stay with the parents of the petitioner
no.2 and petitioner no.1 and it is also undertook that, even after divorce
petitioner no.1 allowed to stay with the parents of the petitioner no.2
and for that the petitioner no.2 do not have any objection.

6. It is submitted that, it is just and necessary to dissolve the marriage of

both petitioners by granting a decree of divorce. It is further submitted
that there is no collusion between the petitioners for filing this divorce
petition.

7. The petitioners are constrained to approach this Hon’ble Court seeking

decree of divorce by mutual consent :

a) That the marriage between the Petitioners performed on 24-08-1998

be dissolved by way of mutual consent.

b) That the petitioners do not have any kind of claim against each other.

IV Jurisdiction: This Court has Territorial Jurisdiction to entertain this

petition as the petitioners are the residents of above said address, which is
within the territorial Jurisdiction of this Hon’ble court.

V Cause of Action: The cause of action arose for the first time in the year
2003 when the petitioner left the company of the petitioner no.1 stayed at
Chenni, the cause of action arose on the first week of January 2019 when both
the petitioners decided to take divorce and ever since the cause of action is
continuing as they are staying separately.

VI Court Fee: The court fee of Rs______/- is paid under proper schedule of
Hindu Marriage Act.

VII Prayer: The petitioner and the respondent therefore pray that this
Hon’ble Court may be pleased to pass a decree of
 a) Divorce between the parties by dissolving their marriage dated 24-8-
1998

b) And such other order or orders as this Hon’ble Court may deem fit and
proper in the circumstances of the case.

Date: 14/12/2020 PETITIONER No.1

PLACE: KUKATPALLI
PETITIONER No. 2

VERIFICATION

We, G. Indira, W/o Santosh Gaikwad, aged about 41 years, occ: Teacher, R/o H.No.26, Rail
Vihar Colony, Serilingampally, Lingampally, R.R.District, Telangana-500032, Santosh
Gaikwad, S/o Laxman Gaikwad, Aged:50 years, occ:Private Employee, R/o H.No.26, Rail
Vihar Colony, Serilingampally, Lingampalli, R.R.District, Telangana-500032, petitioner Nos.1
& 2 herein, do hereby declare that the contents of the above paras are true and correct to the best
of my knowledge, belief and hence verified on this the day of November, 2020

Date: PETITIONER No.1

Place: KUKATPALLY
PETITIONER No. 2
LIST OF DOCUMENTS

1. Marriage Photo with pen drive.

2. Wedding card
3. Copy of aadhar card of petitioner nos. 1 and 2
4. Copy of aadhar cards of children

Date: PETITIONER No.1

Place: KUKATPALLY
PETITIONER NO.2
 IN THE COURT OF THE HON'BLE
FAMILY JUDGE COURT JUDGE CUM
XV ADDL DISTRICT JUDGE,
RANGAREDDY DISTRICT ::
AT::KUKATPALLY

O.P.NO. OF 2020

Between:

G. Indira
PETITIONER No.1

AND

Santosh Gaikwad

PETITIONER No.2

PETITION FILED U/ SEC.13-B OF THE

HINDU MARRIAGE ACT, 1955, FOR
DISSOLUTION OF MARRIAGE BY
MUTUAL CONSENT.

FILED ON:

FILED BY:

JAMPANI.SRIDEVI,
V. Geetha
C. Praveen Kumar,
P.V. Tirumala Kumar,

,
R/o:H.No.6-3-634, Green Channel
Complex, Near NASR School, Khairatabad,
Hyderabad, Telangana.

COUNSEL FOR PETITIONERS No.1 & 2

IN THE COURT OF THE HON’BLE FAMILY JUDGE COURT JUDGE CUM
XV ADDL DISTRICT JUDGE, RANGA REDDY DISTRICT
AT::KUKATPALLY

I.A.NO. OF 2020

IN

FC OP No. OF 2020
Between:
G. Indira, W/o Santosh Gaikwad,
aged about 41 years, occ:Teacher,
R/o Hno.26, Rail Vihar colony,
Serilingampally,
Lingampalli R.R.District.,
Telanagana-500032
... Petitioner
No.1

And
Santosh Gaikwad, S/o Laxman Gaikwad,
Aged: 50 years, occ: Private Employee,
R/o H.No.26, Rail Vihar Colony,
Serilingampally,
Lingampalli, R.R.District,
Telangana-500032. .... Petitioner No.2

AFFIDAVIT

I, G. Indira, W/o Santosh Gaikwad, aged about 41 years, occ: Teacher, R/o H.No.26, Rail
Vihar Colony, Serilingampally, Lingampalli, R.R.District, Telangana-500032., do hereby
solemnly affirm on oath and submit as follows;

1. That I am the petitioner herein and as such, I know the facts of the case.

2. I submit that, we have filed the above O.P. seeking mutual Divorce. I submit
that I am not well acquainted with the legal formalities and as such, I seek the
assistance of JAMPANI.SRIDEVI, V. Geetha, C. Praveen Kumar, P.V.
Tirumala Kumar, Advocates, R/o H.NO.6-3-634, Green channel complex,
Near Nasr school, Khairatabad, Hyderabad, Telangana.

3. In the circumstances, it is prayed that this Hon’ble Court may be pleased to

permit the petitioner to engage the services of JAMPANI.SRIDEVI, V.
Geetha, C. Praveen Kumar, P.V. Tirumala Kumar Advocates, in the
interest of justice.

Sworn & signed in my presence DEPONENT

on this the day of December, 2020
identified by Sridevi Jampani, Advocate

Advocate::Kukatpally
IN THE COURT OF THE HON’BLE FAMILY JUDGE COURT JUDGE CUM
XV ADDL DISTRICT JUDGE, RANGA REDDY DISTRICT
AT::KUKATPALLY

I.A.NO. OF 2020

IN

FC OP No. OF 2020
Between:

G. Indira, W/o Santosh Gaikwad,

aged about 41 years, occ:Teacher,
R/o Hno.26, Rail Vihar colony,
Serilingampally,
Lingampalli R.R.District.,
Telanagana-500032
... Petitioner
No.1

And
Santosh Gaikwad, S/o Laxman Gaikwad,
Aged: 50 years, occ:Private Employee ,
R/o H.No.26, Rail Vihar Colony,
Serilingampally,
Lingampalli, R.R.District,
Telangana-500032. .... Petitioner No.2
AFFIDAVIT

I, Santosh Gaikwad, S/o Laxman Gaikwad, Aged: 50 years, occ: Private Employee,
R/o H.No.26, Rail Vihar Colony, Serilingampally, Lingampalli, R.R.District,
Telangana-500032., do hereby solemnly affirm on oath and submit as follows;

1. That I am the petitioner herein and as such, I know the facts of the case.

2. I submit that, we have filed the above O.P. seeking mutual Divorce. I submit
that I am not well acquainted with the legal formalities and as such, I seek the
assistance of JAMPANI.SRIDEVI, V.Geetha, C. Praveen Kumar, P.V.
Tirumala Kumar, Advocates, R/o H.NO.6-3-634, Green channel complex,
Near Nasr school, Khairatabad, Hyderabad, Telangana.

3. In the circumstances, it is prayed that this Hon’ble Court may be pleased to

permit the petitioner to engage the services of JAMPANI.SRIDEVI,
V.Geetha, C. Praveen Kumar, P.V. Tirumala Kumar, Advocates, in the
interest of justice.

Sworn & signed in my presence DEPONENT

on this the day of December, 2020
identified by Sridevi Jampani, Advocate

ADVOCATE :: KUKATPALLY
 IN THE COURT OF THE IN THE COURT OF THE HON'BLE FAMILY JUDGE
COURT JUDGE CUM XV ADDL DISTRICT JUDGE, RANGA REDDY DISTRICT ::
AT::KUKATPALLY

FC OP No. OF 2020
Between:

G. Indira, W/o Santosh Gaikwad,

aged about 41 years, occ:Teacher
R/o Hno.26, Rail Vihar colony,
Serilingampally,
Lingampalli R.R.District.,
Telanagana-500032
... Petitioner
No.1

And
Santosh Gaikwad, S/o Laxman Gaikwad,
Aged: 50 years, occ: Private Employee,
R/o H.No.26, Rail Vihar Colony,
Serilingampally,
Lingampalli, R.R.District,
Telangana-500032. .... Petitioner No.2

PETITION FILED U/SEC.13 OF THE FAMILY COURT ACT

For the reason state in the accompanying affidavit it is prayed that this Hon’ble
Court may be pleased to permit me seek the legal assistance of of JAMPANI.SRIDEVI,
V. Geetha, C.Praveen Kumar, P.V. Tirumala Kumar, Advocates, R/o H.NO.6-3-634,
Green channel complex, Near Nasr school, Khairatabad, Hyderabad, Telangana as an
Advocate, otherwise the petitioner’s would sustain loss and injury.

COUNSEL FOR THE PETITIONER NO.1 AND 2

Date:
Place: KUKATPALLY
 IN THE COURT OF THE HON'BLE
FAMILY JUDGE COURT JUDGE CUM
XV ADDL DISTRICT JUDGE,
RANGA REDDY DISTRICT ::
AT::KUKATPALLY

I.A.No. OF 2020

IN

O.P.NO. OF 2020

Between:

G. Indira
PETITIONER No.1

AND

Santosh Gaikwad

PETITIONER No.2

PETITION FILED U/SEC.13 OF THE

FAMILY COURT ACT

FILED ON:

FILED BY:
JAMPANI.SRIDEVI,
V. Geetha
C. Praveen Kumar,
P.V. Tirumala Kumar,

R/o H.NO.6-3-634, Green Channel

Complex, Near NASR School, Khairatabad,
Hyderabad, Telangana 500004.

COUNSEL FOR PETITIONERS No.1 & 2

 IN THE COURT OF THE IN THE COURT OF THE HON'BLE FAMILY
JUDGE COURT JUDGE CUM XV ADDL DISTRICT JUDGE, RANGA REDDY
DISTRICT :: AT::KUKATPALLY

O.P.No. OF 2020
(Under Hindu Marriage Act)
BETWEEN:

G. Indira
PETITIONER No.1
AND

Santosh Gaikwad

PETITIONER No.2

1. Particulars of Marriage:

1. Name, Sex, Religion & ordinary residence of G. Indira, W/o Santosh Gaikwad,
the Petitioner no.1 aged about 41 years, occ: Teacher
R/o Hno.26, Rail Vihar colony,
Serilingampally, Lingampalli
R.R.District., Telanagana-500032

2. Name, Sex, Religion & ordinary residence of Santosh Gaikwad, S/o Laxman Gaikwad,
the Petitioner No.2 Aged: 50 years, occ: Private Employee,
R/o H.No.26, Rail Vihar Colony,
Serilingampally,
Lingampalli, R.R.District,
Telangana-500032.

3. Place & Date of the solemnization On:11-02-2000, at H.No.2-2-152,

of marriage Budidagadda, Kothagudem, AP

Place where the Petitioner Nos. 1 & 2 G. Indira, W/o Santosh Gaikwad,
4. resided together after Marriage aged about 41 years, occ:Teacher
Santosh Gaikwad, S/o Laxman Gaikwad,
Aged: 50 years, occ:Private Employee,
R/o H.No.26, Rail Vihar Colony,
Serilingampally,
Lingampalli, R.R.District,
Telangana-500032.
 5. Where the Petitioner No. 1 & 2 last Do
resided together

6. Where the Petitioner No.2 was residing at

the time of presentation of the Petition As mentioned in the cause title
and
As mentioned in the cause title
where the Petitioner No.2 is residing at the
time of presentation of the Petition

7. Whether any children born out of the 1. G.Rohan, aged about 21 years, date
Said Wedlock
of birth _____ 1999,
2. G. Rashmitha, aged abour 16 years,
date of birth ______ 2004.

8. Whether marriage photo enclosed YES

9. Whether any previous application has

been made to the Court or any other court --NO –
with the reliefs claimed in this
petition

10. Whether there is any agreement or collusion

between the parties in --NO –
Presenting this Application

11. Grounds on which Divorce is sought Mutual Divorce

Petitioner No.1 Petitioner No.2

 Form No.7 List of Document (Rule 9,10 & 62)
(Under Order VII, R.14 or Order XIII, R.1 of Code of Civil Procedure)

IN THE COURT OF THE IN THE COURT OF THE HON'BLE FAMILY JUDGE

COURT JUDGE CUM XV ADDL DISTRICT JUDGE, RANGA REDDY
DISTRICT :: AT::KUKATPALLY

O.P.No. of 2020

Between:

G. Indira
Petitioner No.1

AND
Santosh Gaikwad
Petitioner No.2

List of Documents filed by- Petitioner/Petitioner

Date if any of
documents
S.No Parties to the Document Description of Document
vernacular in
English
Marriage Photo with pen drive.
1. 11-2-2000 Petitioner no.1 and 2

Wedding card
2. 11-2-2000 Petitioner no.1 and 2

Copy of aadhar card of

3. Petitioner no.1
petitioner no. 1
Copy of aadhar card of
4. Petitioner no. 2
petitioner no.2
Copy of aadhar card of the
5. Petitioner no.1 and 2
first son
Copy of aadhar card of the
Petitioner no.1 and 2
second son

Date: /12/2020
Place: Kukatpally Advocate for Petitioner
 IN THE COURT OF THE HON'BLE
FAMILY JUDGE COURT JUDGE CUM
XV ADDL DISTRICT JUDGE, RANGA
REDDY DISTRICT :: AT::KUKATPALLY

O.P.No. OF 2020

BETWEEN:

G. Indira
PETITIONER No.1

AND

Santosh Gaikwad

PETITIONER No.2

LIST OF DOCUMENTS

FILED ON: /12/2020

FILED BY:
JAMPANI.SRIDEVI,
V. Geetha
C. Praveen Kumar,
P.V. Tirumala Kumar,

R/o H.NO.6-3-634, Green Channel

Complex, Near NASR School, Khairatabad,
Hyderabad, Telangana.

COUNSEL FOR PETITIONERS No.1 & 2

 IN THE COURT OF THE IN THE COURT OF THE HON'BLE FAMILY
JUDGE COURT JUDGE CUM XV ADDL DISTRICT JUDGE, RANGA REDDY
DISTRICT :: AT::KUKATPALLY

O.P.No. OF 2020

BETWEEN:

G. Indira
PETITIONER No.1
AND

Santosh Gaikwad
PETITIONER No.2

We,
1) G. Indira, W/o Santosh Gaikwad, aged about 41 years, occ:Teacher, R/o.H.No.26,
Rail Vihar colony, Serilingampally, Lingampalli R.R.District., Telanagana-
500032

2)Santosh Gaikwad, S/o Laxman Gaikwad, Aged: 50 years, occ: Private Employee,
R/o H.No.26, Rail Vihar Colony, Serilingampally, Lingampalli,
R.R.District,Telangana-500032. do hereby appoint and retain

M/s JAMPANI.SRIDEVI
V Geetha
C. Praveen Kumar,
P.V. Tirumala Kumar,
Advocates

Advocate/s to appear for me/us in the above Suit/Appeal/Petition/Case and to conduct

and prosecute or defend the same and all proceedings that may be taken in respect of any
application for execution of any decree or order passed therein. I/We empower my/our
Advocate/s to appear in all miscellaneous proceedings in the above suit or matter till all
decrees or order are fully satisfied, or adjusted, to compromise and obtain the return of
documents and draw any money that might be payable to me/us in the said suit or matter
and I/We do further empower my/our Advocate/s to accept on my/our behalf service of
notice of all or any appeal or petition filed in any court or appeal Reference or Revision
with regard to the said suit or matter before disposal of the same in Honourable Court.

I certified that the executant who is well acquainted with English, read this
Vakalatnama that the contents of this Vakalatnama were read out and explained in
Urdu/Hindi/Telugu to the executant he/she/they being unacquainted with English, who
appeared perfectly to understand the same and signed or put his/her/their name or mark in
my presence.

Identified by Sri Sridevi Jampani

Executed on day of December, 2020 ADVOCATE

At Kukatpally
 IN THE COURT OF THE HON'BLE
FAMILY JUDGE COURT JUDGE CUM
XV ADDL DISTRICT JUDGE, RANGA
REDDY DISTRICT :: AT::KUKATPALLY

O.P.No. OF 2020

BETWEEN:

G. Indira
…. PETITIONER No.1
AND

Santosh Gaikwad

.. PETITIONER No.2

VAKALAT
ACCEPTED

FILED ON:

FILED BY:
JAMPANI.SRIDEVI,
V. Geetha
C. Praveen Kumar,
P.V. Tirumala Kumar,,

R/o H.NO.6-3-634, Green Channel

Complex, Near NASR School, Khairatabad,
Hyderabad, Telangana.

COUNSEL FOR PETITIONERS No.1 & 2