IN THE COURT OF HON’BLE PRINCIPAL JUDGE, FAMILY COURT

DWARKA COURTS, SOUTH WEST DISTRICT, NEW DELHI

HMA No. _____/ 2025

IN THE MATTER OF:

SRIJAN SINGH …PETITIONER NO 1

AND
AARYAA RAAJ ...PETITIONER NO 2

INDEX

S.NO. PARTICULARS PAGE COURT

NO. FEE

1. Memo of Parties

2. First Motion Petition under Section 13-B(1) of

Hindu Marriage Act, 1955 for the dissolution
of Marriage by Mutual Consent along with
supporting affidavits of the Petitioners
3. Specific Affidavit of both the Petitioners in
terms of Judgement as passed by the Hon’ble
High court of Delhi in the matter titled as Rajat
Gupta Vs Rupali Gupta in Cont. Case (C) No.
772/2013

4. List of documents along with documents

5. Annexure - A - Certificate of the counsel

6. Annexure - B - Certificate of both the

Petitioners

7. ANNEXURE – D Proof of residence for

Petitioner No. 2 – Copy of the rent agreement.
8. Undertaking on behalf of the counsel

9. Vakalatnamas
 PETITIONER No. 1.

THROUGH
(XXXXX)
Advocate for Petitioner no.1
CH.XXX LAWYERS CHAMBER
DWARKA COURTS
MOB-XXXXXXXX

PETITIONER NO.2

THROUGH

(XXXXX)
Advocate for Petitioner NO. 2
CH.XXX LAWYERS CHAMBER
DWARKA COURTS
MOB- XXXXXXXX
NEW DELHI
DATED:
IN THE COURT OF HON’BLE PRINCIPAL JUDGE, FAMILY COURT
DWARKA COURTS, SOUTH WEST DISTRICT, NEW DELHI
HMA No. _____/ 2025

IN THE MATTER OF:

SRIJAN SINGH …PETITIONER NO 1

AND
AARYAA RAAJ ...PETITIONER NO 2

MEMO OF PARTIES
SRIJAN SINGH
C/O S.D. SINGH
R/O :Flat No 804 C WING 8TH FLOOR
SAI VIHARCHS LTD.
PLOT NO 78 79AND 80 SECTOR
CBD BELAPUR.
SUB DIST: THANE
MAHARASTHRA 400614 ….PETITIONER NO 1

AND

AARYAA RAAJ

D/O: ABHAY SINGH

R/O: NAV DURGA SHIVJI DHAM
THADI DULAMPUR
WARD NO 17 DEOGHAR
JHARKHAND 814114
ALSO AT -
R/O, 141 UG BHAGWATI
GARDEN UTTAM NAGAR 110059 …PETITIONER NO
2
 PETITIONER No. 1.

THROUGH
(XXXXX)
Advocate for Petitioner no.1
CHXXX LAWYERS CHAMBER
DWARKA COURTS
MOB-XXXXXXX

PETITIONER NO.2

THROUGH

(XXXXX)
Advocate for Petitioner NO. 2
CH.XXX LAWYERS CHAMBER
DWARKA COURTS
MOB- XXXXXXXX
NEW DELHI
DATED:
IN THE COURT OF HON’BLE PRINCIPAL JUDGE, FAMILY COURT
DWARKA COURTS, SOUTH WEST DISTRICT, NEW DELHI
HMA No. _____/ 2025

IN THE MATTER OF:

SRIJAN SINGH
C/O S.D. SINGH
R/O :Flat No 804 C WING 8TH FLOOR
SAI VIHARCHS LTD.
PLOT NO 78 79AND 80 SECTOR
CBD BELAPUR.
SUB DIST: THANE
MAHARASTHRA 400614 ….PETITIONER NO 1
AND
AARYAA RAAJ
D/O: ABHAY SINGH
R/O: NAV DURGA SHIVJI DHAM
THADI DULAMPUR
WARD NO 17 DEOGHAR
JHARKHAND 814114
ALSO AT -
R/O, 141 UG BHAGWATI
GARDEN UTTAM NAGAR 110059 ...PETITIONER NO 2

P.S:UTTAM NAGAR

FIRST MOTION PETITION UNDER SECTION 13-B(1) OF THE HINDU

MARRIAGE ACT, 1955 FOR THE DISSOLUTION OF MARRIAGE BY
A DECREE OF DIVORCE BY MUTUAL CONSENT

The Petitioners above named most respectfully submits :

1. That the marriage between the Petitioner No.1 and the Petitioner No.2
was solemnized on 06.07.2018 at SHIV NAGAR ,DEOGHAR
JHARKHAND 814114 as per Hindu rites and ceremonies.
2. That after the marriage parties have not co-habitated with each other
since 01.07.2023 and due to disputes and differences between the parties
they started to live separately. That no children are born from the said
wedlock .
3. That the age, status and place of residence of the parties to the marriage,
before the marriage and at the time of filing of the present petition were/
are as follows:
PETITIONER NO. 1/ HUSBAND
Status Age Place of Residence
Before the Hindu 29 Years Flat No 804 C WING 8TH
Marriage
Bachelor FLOOR
SAI VIHARCHS LTD.
PLOT NO 78 79AND 80
SECTOR
CBD BELAPUR.
SUB DIST: THANE
MAHARASTHRA 400614
At the time of Hindu 36years Flat No 804 C WING 8TH
filing the
Married FLOOR
present petition
SAI VIHARCHS LTD.
PLOT NO 78 79AND 80
SECTOR
CBD BELAPUR.
SUB DIST: THANE
MAHARASTHRA 400614
 PETITIONER NO. 2/ WIFE
Status Age Place of Residence
Before the Hindu 26 years NAV DURGA SHIVJI
Marriage
Spinster DHAM
THADI DULAMPUR
WARD NO 17 DEOGHAR
JHARKHAND 814114
At the time of Hindu 33 years R/O: NAV DURGA SHIVJI
filing the DHAM THADI
present petition Married DULAMPUR
WARD NO 17 DEOGHAR
JHARKHAND 814114
ALSO AT -
R/O, 141 UG BHAGWATI
GARDEN UTTAM NAGAR
110059

That the Parties to the petition could not adjust with each other due to their
indifferent temperaments and despite of the keen efforts, put by the well-wishers
and the relatives of the Parties, the parties to the marriage could not reconcile
their differences and since 01.07.2023, the Parties have been living separately at
their respective residences as mentioned in the petition. Both the Petitioners are
convinced that it is impossible to live with each other and that no purpose would
be served by prolonging their matrimonial differences. The Parties are not even
on talking terms and there is no possibility of reconciliation.

That the petitioners could not reconcile their differences and there is no
possibility of their living together and as such they have mutually decided to
dissolve their marriage by a decree of divorce by mutual consent.
That the Parties have agreed that after the dissolution of their marriage, the Parties
shall act and perform according to the mutual settlement under the Memorandum
of understanding dated 08.04.2025 arrived at between the parties. The copy of the
said MOU dated 08.04.2025 is annexed herewith.

That the Parties have settled their respective claims and nothing remains due to
them from each other, under all heads. The Petitioners have mutually agreed to
the following condition set out under the Memorandum of understanding dated
08.04.2025:

i. That the parties have agreed to dissolve their marriage by a Decree

of Divorce by Mutual Consent in accordance with the provisions
of the Hindu Marriage Act, 1955. The Joint Petitions for obtaining
the decree of divorce by mutual consent shall be filed at Dwarka
Courts in Delhi. The parties shall file the petitions under Section
13B(1) and 13B(2) of the Hindu Marriage Act in terms of this
Memorandum of Understanding.
ii. That it has been mutually agreed that the Petitioner no.1 shall pay
a total sum of Rs.30,50,000/- (Rupees Thirty Lakhs fifty thousand
Only) and, the above detailed consideration will be paid to the
PETITIONER NO 2 towards full and final settlement of all the
claims in every manner (past, present and future) of the
PETITIONER NO 2 arising out of the matrimonial disputes
between the parties including claim on account of stridhan,
maintenance, permanent alimony, expenses, ancestral claims of
children etc..
iii. That the parties shall file a joint petition for divorce by mutual
consent under section 13B (1) of HMA (First Motion) on or before
29.04.2025 days of the signing of the present Memorandum of
 Understanding. The PETITIONER NO 01 shall pay a sum of
Rs.10,00,000/- (Rupees Ten Lakhs Only) to the PETITIONERNO
2 at the time of recording of the statement of the parties under
section 13B (1) of HMA (First Motion). The said amount shall be
paid by Cheque/bank draft/pay order/RTGS made in favour of
PETITIONER NO 2.
iv. That the parties if they mutually agree shall move an application /
petition for waiving of the statutory period of six months between
the first motion and second motion. In case, for any reason, the
petition for waiving of the statutory period of six months between
the first motion and second motion is declined by the Hon’ble
Court or the said application/petition for waiving the statutory
period of six months is not filed, the parties shall file the petition
under Section 13 B (2) of HMA within 15 days of the expiry of the
statutory period of six months.
v. That the PETITIONER NO 1 shall pay another sum of
Rs.20,50,000/- (Rupees Twenty Lakhs fifty thousand Only) to the
PETITIONER NO 2 at the time of recording of the statement
under section 13B(2) of HMA (second motion). The said amount
shall be paid by Cheque/bank draft/pay order/RTGS made in
favour of PETITIONER NO 2.
vi. That it is mutually agreed between the parties herein that neither
the PETITIONER NO 1 nor the PETITIONER NO 2 shall visit
each other at their place of residence, occupation or otherwise,
substantially ejusdem generis without any prior information or
consultation with / to each other, emergencies are always
excluded. The burden and legal fee/court fee for the mutual
divorce will be borne by the PETITIONER NO 1.
vii. That Both the parties assure each other that no complaints (Civil
 and Criminal) and representation have been filed or letters sent to
any authority, Tribunal, Court, Police Station or any other body
against each other and if, there are any, then these shall be
disclosed and withdrawn by both the parties with the signing of the
present settlement. In future neither of the parties shall file any
litigation, complaint (Civil and Criminal) or any case against each
other pertaining to any dimension of the dispute that is part of the
present settlement. Both parties also undertake that they will not
in any manner involve or cooperate with any third person with
respect and pertaining to any dispute between the parties qua the
present conciliated agreement. That the PETITIONER NO2 after
Second motion/ Petition undertake to withdraw all or any
complaints pending, Domestic Violence Case detailed as; MC-
652/2024 pending before Ms. Divya yadav JMIC, South West
Dwarka, Maintenance case detailed as case no-647/2024 pending
before Family judge dwarka court Mr. VK RAI and HMA
SECTION 9 case detailed as case no-3382/20245 pending before
Family judge dwarka court Mr. VK RAI further the PETITIONER
NO 2 will cooperate for the same.
viii. That it is understood to the parties herein that by executing this
Memorandum of Understanding the parties hereto, state that they
have no further claims or demands against each other of any kind
or dimension and all their disputes and differences have amicably
been settled. Both the parties agree to remain bound in spirit and
words with the terms and conditions as mentioned in this
settlement.
ix. That the terms and conditions set out hereinabove in this
Memorandum of Understanding are irrevocable in nature and
cannot be mutually altered / amended / varied verbally. The same
 shall be binding on both the parties and breach of any of the terms
and conditions shall make parties liable for contempt of Court.
That further in case of any default of the conditions stated herein
if the defaulting party is PETITIONER NO 1 than the amound
paid will be forfeited plus penalty of 2,00,000 rs (two lakh rupees)
and if PETITIONER NO 2 is defaulting party than PETITIONER
NO 2 shall return the double amount of amount paid by first party
along with 2,00,000 rs (two lakh rupees) penalty to another party.
x. That both the parties herein shall be jointly and severally liable for
performance of this Memorandum of Understanding and shall be
personally liable in case of any default and it is understood that
each party to this Memorandum of Understanding shall have the
right under the law and even otherwise to get this Memorandum
of Understanding enforced in any manner they want, limited and
otherwise the covenants of this Memorandum of Understanding
and it is at the same time understood between the parties that each
and every covenant of the present Memorandum of Understanding
is independent and dependent to each other simultaneously in the
same breath.
xi. Both the parties agree and undertake not to interfere in the life of
each other in any manner and also undertake not to make any
allegations, defamatory or derogatory statements against each
other and their respective family members personally or on any
public forum or through social media i.e. whatsapp, facebook,
twitter, instagram, etc. or in any other manner. None of the parties
shall tap/record each other phones or any instrument in future.
That there is no possibility of the Petitioners cohabitating together
as husband and wife. That there has been an irretrievable breakdown
of the marriage and it is beyond repair. That no party shall withdraw
 his/ her consent for divorce on mutual consent and they will extend
full cooperation to each other in filing of the joint petitions for
divorce on the basis of mutual consent.
That the Petitioners have settled the terms and conditions of the
divorce and there are no pending issues which require further
settlement. That there are no other legal grounds why the relief
should not be granted.
That this Petition is not made in collusion between the Parties and
neither is there any threat, coercion or undue influence upon any of
the Petitioners and is within time as per law.
That the marriage between the Petitioner No.1 and the Petitioner
No.2 was solemnized on 06.07.2018 at SHIV NAGAR ,DEOGHAR
JHARKHAND 814114 as per Hindu rites and ceremonies after the
marriage .
That this Hon’ble Court has the jurisdiction to try and entertain the
present petition, as Petitioner No. 2 is a resident within the
jurisdiction of P.S. Uttam Nagar. Proof of residence for Petitioner
No. 2 is annexed herewith as ANNEXURE-D (copy of the rent
agreement)."
PRAYER

It is, therefore, most respectfully prayed that this Hon’ble Court may kindly be
pleased to allow the present petition to dissolve the marriage of the petitioners by
a decree of divorce by mutual consent.
 PETITIONER No. 1.

THROUGH
(XXXXX)
Advocate for Petitioner no.1
CH.XXX LAWYERS CHAMBER
DWARKA COURTS
MOB-XXXXXX

PETITIONER NO.2

THROUGH

(XXXXX)
Advocate for Petitioner NO. 2
CH.XXX LAWYERS CHAMBER
DWARKA COURTS
MOB- XXXXXX
NEW DELHI
DATED:

VERIFICATION
We, the above-named Petitioners do hereby state on solemn affirmation that the
contents of Para 1 to 14 of the petition, are true and correct to the best of our
knowledge and belief and the last Para is the prayer to this Hon’ble Court.
Verified at New Delhi on this __ day of APRIL, 2025.

PETITIONER No. 1 PETITIONER No. 2

IN THE COURT OF HON’BLE PRINCIPAL JUDGE, FAMILY COURT
DWARKA COURTS, SOUTH WEST DISTRICT, NEW DELHI
HMA No. _____/ 2025

IN THE MATTER OF:

SRIJAN SINGH …PETITIONER NO 1

AND
AARYAA RAAJ ...PETITIONER NO 2
AFFIDAVIT

I, SRIJAN SINGH, aged about 36 years, S/O SH. S.D SINGH, R/O Flat No 804 C
WING 8TH FLOOR SAI VIHARCHS LTD.PLOT NO 78 79AND 80 SECTOR CBD
BELAPUR.SUB DIST: THANE MAHARASTHRA 400614, do hereby solemnly affirm
and declare as under:
1. That I am the petitioner No.1/Husband of the Petitioner no. 2 in the above noted
petition and am well conversant with the facts and circumstances of the case and
as such fully competent to swear and depose the present affidavit.

2. That the accompanying petition under section 13(B)(1) of the Hindu Marriage
Act, 1955, has been drafted by my counsel under my instructions. I have read
and understood the contents of the petition and hereby state that the averments
made in the petition are true to my knowledge and the said contents of the
petition may kindly be read as part and parcel of this affidavit and the same are
not being repeated herewith for the sake of brevity.

DEPONENT
VERIFICATION

Verified at New Delhi on this __ day of APRIL, 2025 that the contents of the above
affidavit are true and correct to the best of my knowledge and belief.

DEPONENT

IN THE COURT OF HON’BLE PRINCIPAL JUDGE, FAMILY COURT

DWARKA COURTS, SOUTH WEST DISTRICT, NEW DELHI
HMA No. _____/ 2025
IN THE MATTER OF:
SRIJAN SINGH …PETITIONER NO 1

AND
AARYAA RAAJ ...PETITIONER NO 2
AFFIDAVIT

I, Ms. AARYAA RAAJ, D/O SH. ABHAY SINGH Aged About 33 Years R/O: nav
durga shivji dham thadi dulampur ward no 17 deoghar jharkhand 814114 also at
R/O, 141 UG BHAGWATI GARDEN UTTAM NAGAR 110059 do hereby solemnly
affirm and declare as under:

1. That I am the petitioner No.2/wife of the Petitioner no. 1 in the above noted
petition and am well conversant with the facts and circumstances of the case and
as such fully competent to swear and depose the present affidavit.

2. That the accompanying petition under section 13(B)(1) of the Hindu Marriage
Act, 1955, has been drafted by my counsel under my instructions. I have read
and understood the contents of the petition and hereby state that the averments
made in the petition are true to my knowledge and the said contents of the
petition may kindly be read as part and parcel of this affidavit and the same are
not being repeated herewith for the sake of brevity.

DEPONENT
VERIFICATION

Verified at New Delhi on this __ day of APRIL, 2025 that the contents of the above
affidavit are true and correct to the best of my knowledge and belief.

DEPONENT

IN THE COURT OF HON’BLE PRINCIPAL JUDGE, FAMILY COURT

DWARKA COURTS, SOUTH WEST DISTRICT, NEW DELHI
HMA No. _____/ 2025
IN THE MATTER OF:

SRIJAN SINGH …PETITIONER NO 1

AND
AARYAA RAAJ ...PETITIONER NO 2

AFFIDAVIT OF THE PETITIONER NO. 2 AS PER JUDGEMENT DATED

15.5.2018 PASSED BY THE HON’BLE HIGH COURT OF DELHI IN THE
MATTER OF RAJAT GUPTA VS RUPALI GUPTA IN CONT. CASE (C)
772/2013

I, Ms. AARYAA RAAJ, D/O SH. ABHAY SINGH Aged About 33 Years
R/O,R/O: NAV DURGA SHIVJI DHAM THADI DULAMPUR WARD NO 17
DEOGHAR JHARKHAND 814114 ALSO AT R/o 141 UG BHAGWATI
GARDEN UTTAM NAGAR 110059 do hereby solemnly affirm and declare as
under:

1. The deponent says that she is Petitioner No.2/wife of the Petitioner no. 1 in the
above noted petition and well conversant to the facts and circumstances of the
case and as such fully competent to swear and depose the present affidavit.
2. The deponent says that marriage between the Petitioner No.1 and the
Petitioner No.2 was solemnized on 06.07.2018 at SHIV NAGAR
,DEOGHAR JHARKHAND 814114 as per Hindu rites and ceremonies.
3. That after the marriage parties have not co-habitated with each other
since 01.07.2023 and due to disputes and differences between the parties
they started to live separately. That no children are born from the said
wedlock .
4. That the Parties to the petition could not adjust with each other due to their
indifferent temperaments and despite of the keen efforts, put by the well-
wishers and the relatives of the Parties, the parties to the marriage could
not reconcile their differences and since 01.07.2023, the Parties have been
living separately at their respective residences as mentioned in the petition.
 Both the Petitioners are convinced that it is impossible to live with each
other and that no purpose would be served by prolonging their matrimonial
differences. The Parties are not even on talking terms and there is no
possibility of reconciliation.
5. That the petitioners could not reconcile their differences and there is no
possibility of their living together and as such they have mutually decided
to dissolve their marriage by a decree of divorce by mutual consent.
6. That the Parties have agreed that after the dissolution of their marriage, the
Parties shall act and perform according to the mutual settlement under the
Memorandum of understanding dated 08.04.2025 arrived at between the
parties. The copy of the said MOU dated 08.04.2025 is annexed herewith.
7. That the Parties have settled their respective claims and nothing remains
due to them from each other, under all heads. The Petitioners have mutually
agreed to the following condition set out under the Memorandum of
understanding dated 08.04.2025:

I. That the parties have agreed to dissolve their marriage by a Decree of

Divorce by Mutual Consent in accordance with the provisions of the
Hindu Marriage Act, 1955. The Joint Petitions for obtaining the decree
of divorce by mutual consent shall be filed at Dwarka Courts in Delhi.
The parties shall file the petitions under Section 13B(1) and 13B(2) of
the Hindu Marriage Act in terms of this Memorandum of
Understanding.
II. That it has been mutually agreed that the Petitioner no.1 shall pay a
total sum of Rs.30,50,000/- (Rupees Thirty Lakhs fifty thousand Only)
and, the above detailed consideration will be paid to the PETITIONER
NO 2 towards full and final settlement of all the claims in every manner
(past, present and future) of the PETITIONER NO 2 arising out of the
matrimonial disputes between the parties including claim on account of
 stridhan, maintenance, permanent alimony, expenses, ancestral claims
of children etc..
III. That the parties shall file a joint petition for divorce by mutual
consent under section 13B (1) of HMA (First Motion) on or before
29.04.2025 days of the signing of the present Memorandum of
Understanding. The PETITIONER NO 01 shall pay a sum of
Rs.10,00,000/- (Rupees Ten Lakhs Only) to the PETITIONERNO
2 at the time of recording of the statement of the parties under
section 13B (1) of HMA (First Motion). The said amount shall be
paid by Cheque/bank draft/pay order/RTGS made in favour of
PETITIONER NO 2.
IV. That the parties if they mutually agree shall move an application /
petition for waiving of the statutory period of six months between
the first motion and second motion. In case, for any reason, the
petition for waiving of the statutory period of six months between
the first motion and second motion is declined by the Hon’ble
Court or the said application/petition for waiving the statutory
period of six months is not filed, the parties shall file the petition
under Section 13 B (2) of HMA within 15 days of the expiry of the
statutory period of six months.
V. That the PETITIONER NO 1 shall pay another sum of
Rs.20,50,000/- (Rupees Twenty Lakhs fifty thousand Only) to the
PETITIONER NO 2 at the time of recording of the statement
under section 13B(2) of HMA (second motion). The said amount
shall be paid by Cheque/bank draft/pay order/RTGS made in
favour of PETITIONER NO 2.
VI. That it is mutually agreed between the parties herein that neither
the PETITIONER NO 1 nor the PETITIONER NO 2 shall visit
each other at their place of residence, occupation or otherwise,
 substantially ejusdem generis without any prior information or
consultation with / to each other, emergencies are always
excluded. The burden and legal fee/court fee for the mutual
divorce will be borne by the PETITIONER NO 1.
VII. That Both the parties assure each other that no complaints (Civil
and Criminal) and representation have been filed or letters sent to
any authority, Tribunal, Court, Police Station or any other body
against each other and if, there are any, then these shall be
disclosed and withdrawn by both the parties with the signing of the
present settlement. In future neither of the parties shall file any
litigation, complaint (Civil and Criminal) or any case against each
other pertaining to any dimension of the dispute that is part of the
present settlement. Both parties also undertake that they will not
in any manner involve or cooperate with any third person with
respect and pertaining to any dispute between the parties qua the
present conciliated agreement. That the PETITIONER NO2 after
Second motion/ Petition undertake to withdraw all or any
complaints pending, Domestic Violence Case detailed as; MC-
652/2024 pending before Ms. Divya yadav JMIC, South West
Dwarka, Maintenance case detailed as case no-647/2024 pending
before Family judge dwarka court Mr. VK RAI and HMA
SECTION 9 case detailed as case no-3382/20245 pending before
Family judge dwarka court Mr. VK RAI further the PETITIONER
NO 2 will cooperate for the same.
VIII. That it is understood to the parties herein that by executing this
Memorandum of Understanding the parties hereto, state that they
have no further claims or demands against each other of any kind
or dimension and all their disputes and differences have amicably
been settled. Both the parties agree to remain bound in spirit and
 words with the terms and conditions as mentioned in this
settlement.
IX. That the terms and conditions set out hereinabove in this
Memorandum of Understanding are irrevocable in nature and
cannot be mutually altered / amended / varied verbally. The same
shall be binding on both the parties and breach of any of the terms
and conditions shall make parties liable for contempt of Court.
That further in case of any default of the conditions stated herein
if the defaulting party is PETITIONER NO 1 than the amound
paid will be forfeited plus penalty of 2,00,000 rs (two lakh rupees)
and if PETITIONER NO 2 is defaulting party than PETITIONER
NO 2 shall return the double amount of amount paid by first party
along with 2,00,000 rs (two lakh rupees) penalty to another party.
X. That both the parties herein shall be jointly and severally liable for
performance of this Memorandum of Understanding and shall be
personally liable in case of any default and it is understood that
each party to this Memorandum of Understanding shall have the
right under the law and even otherwise to get this Memorandum
of Understanding enforced in any manner they want, limited and
otherwise the covenants of this Memorandum of Understanding
and it is at the same time understood between the parties that each
and every covenant of the present Memorandum of Understanding
is independent and dependent to each other simultaneously in the
same breath.
XI. Both the parties agree and undertake not to interfere in the life of
each other in any manner and also undertake not to make any
allegations, defamatory or derogatory statements against each
other and their respective family members personally or on any
public forum or through social media i.e. whatsapp, facebook,
 twitter, instagram, etc. or in any other manner. None of the parties
shall tap/record each other phones or any instrument in future.

8.The deponent says that there is no possibility of the Petitioners cohabitating

together as husband and wife.
9.The deponent says that the deponent undertakes to abide by the stipulation
as contained in the Judgment dated 15/05/2018 passed by the Hon’ble the
deponent says that High Court of Delhi in the matter of Rajat Gupta vs.
Rupali Gupta in Cont. Case (C)772/2a013.

DEPONENT
VERIFICATION
Verified at Delhi on this ___ day of______ 2025 that the contents of the aforesaid
affidavit are true and correct. No part of it is false and nothing material has been
concealed therefrom.

DEPONENT

IN THE COURT OF HON’BLE PRINCIPAL JUDGE, FAMILY COURT

DWARKA COURTS, SOUTH WEST DISTRICT, NEW DELHI
HMA No. _____/ 2025

IN THE MATTER OF:

SRIJAN SINGH …PETITIONER NO 1

AND
AARYAA RAAJ ...PETITIONER NO 2
AFFIDAVIT OF THE PETITIONER NO. 1 AS PER JUDGEMENT
DATED 15.5.2018 PASSED BY THE HON’BLE HIGH COURT OF DELHI
IN THE MATTER OF RAJAT GUPTA VS RUPALI GUPTA IN CONT.
CASE (C) 772/2013

I, SRIJAN SINGH, aged about 36 years, S/O SH. S.D SINGH, R/O Flat No 804
C WING 8TH FLOOR SAI VIHARCHS LTD.PLOT NO 78 79AND 80
SECTOR CBD BELAPUR.SUB DIST: THANE MAHARASTHRA 400614,
do hereby solemnly affirm and declare as under:

1. The deponent says that he is Petitioner No.1/Husband of the Petitioner no.

2 in the above noted petition and well conversant to the facts and
circumstances of the case and as such fully competent to swear and depose
the present affidavit.
2. The deponent says that marriage between the Petitioner No.1 and the
Petitioner No.2 was solemnized on 06.07.2018 at SHIV NAGAR
,DEOGHAR JHARKHAND 814114 as per Hindu rites and ceremonies.
3. That after the marriage parties have not co-habitated with each other since
01.07.2023 and due to disputes and differences between the parties they
started to live separately. That no children are born from the said wedlock
.
4. That the Parties to the petition could not adjust with each other due to their
indifferent temperaments and despite of the keen efforts, put by the well-
wishers and the relatives of the Parties, the parties to the marriage could
not reconcile their differences and since 01.07.2023, the Parties have been
living separately at their respective residences as mentioned in the petition.
Both the Petitioners are convinced that it is impossible to live with each
other and that no purpose would be served by prolonging their matrimonial
 differences. The Parties are not even on talking terms and there is no
possibility of reconciliation.
5. That the petitioners could not reconcile their differences and there is no
possibility of their living together and as such they have mutually decided
to dissolve their marriage by a decree of divorce by mutual consent.
6. That the Parties have agreed that after the dissolution of their marriage, the
Parties shall act and perform according to the mutual settlement under the
Memorandum of understanding dated 08.04.2025 arrived at between the
parties. The copy of the said MOU dated 08.04.2025 is annexed herewith.
7. That the Parties have settled their respective claims and nothing remains
due to them from each other, under all heads. The Petitioners have mutually
agreed to the following condition set out under the Memorandum of
understanding dated 08.04.2025:

I. That the parties have agreed to dissolve their marriage by a

Decree of Divorce by Mutual Consent in accordance with
the provisions of the Hindu Marriage Act, 1955. The Joint
Petitions for obtaining the decree of divorce by mutual
consent shall be filed at Dwarka Courts in Delhi. The parties
shall file the petitions under Section 13B(1) and 13B(2) of
the Hindu Marriage Act in terms of this Memorandum of
Understanding.
II. That it has been mutually agreed that the Petitioner no.1
shall pay a total sum of Rs.30,50,000/- (Rupees Thirty
Lakhs fifty thousand Only) and, the above detailed
consideration will be paid to the PETITIONER NO 2
towards full and final settlement of all the claims in every
manner (past, present and future) of the PETITIONER NO
2 arising out of the matrimonial disputes between the parties
 including claim on account of stridhan, maintenance,
permanent alimony, expenses, ancestral claims of children
etc..
III. That the parties shall file a joint petition for divorce by
mutual consent under section 13B (1) of HMA (First
Motion) on or before 29.04.2025 days of the signing of the
present Memorandum of Understanding. The
PETITIONER NO 01 shall pay a sum of Rs.10,00,000/-
(Rupees Ten Lakhs Only) to the PETITIONERNO 2 at the
time of recording of the statement of the parties under
section 13B (1) of HMA (First Motion). The said amount
shall be paid by Cheque/bank draft/pay order/RTGS made
in favour of PETITIONER NO 2.
IV. That the parties if they mutually agree shall move an
application / petition for waiving of the statutory period of
six months between the first motion and second motion. In
case, for any reason, the petition for waiving of the statutory
period of six months between the first motion and second
motion is declined by the Hon’ble Court or the said
application/petition for waiving the statutory period of six
months is not filed, the parties shall file the petition under
Section 13 B (2) of HMA within 15 days of the expiry of the
statutory period of six months.
V. That the PETITIONER NO 1 shall pay another sum of
Rs.20,50,000/- (Rupees Twenty Lakhs fifty thousand Only)
to the PETITIONER NO 2 at the time of recording of the
statement under section 13B(2) of HMA (second motion).
The said amount shall be paid by Cheque/bank draft/pay
order/RTGS made in favour of PETITIONER NO 2.
VI. That it is mutually agreed between the parties herein that
neither the PETITIONER NO 1 nor the PETITIONER NO
2 shall visit each other at their place of residence,
occupation or otherwise, substantially ejusdem generis
without any prior information or consultation with / to each
other, emergencies are always excluded. The burden and
legal fee/court fee for the mutual divorce will be borne by
the PETITIONER NO 1.
VII. That Both the parties assure each other that no complaints
(Civil and Criminal) and representation have been filed or
letters sent to any authority, Tribunal, Court, Police Station
or any other body against each other and if, there are any,
then these shall be disclosed and withdrawn by both the
parties with the signing of the present settlement. In future
neither of the parties shall file any litigation, complaint
(Civil and Criminal) or any case against each other
pertaining to any dimension of the dispute that is part of the
present settlement. Both parties also undertake that they will
not in any manner involve or cooperate with any third
person with respect and pertaining to any dispute between
the parties qua the present conciliated agreement. That the
PETITIONER NO2 after Second motion/ Petition
undertake to withdraw all or any complaints pending,
Domestic Violence Case detailed as; MC-652/2024 pending
before Ms. Divya yadav JMIC, South West Dwarka,
Maintenance case detailed as case no-647/2024 pending
before Family judge dwarka court Mr. VK RAI and HMA
SECTION 9 case detailed as case no-3382/20245 pending
 before Family judge dwarka court Mr. VK RAI further the
PETITIONER NO 2 will cooperate for the same.
VIII. That it is understood to the parties herein that by executing
this Memorandum of Understanding the parties hereto, state
that they have no further claims or demands against each
other of any kind or dimension and all their disputes and
differences have amicably been settled. Both the parties
agree to remain bound in spirit and words with the terms
and conditions as mentioned in this settlement.
IX. That the terms and conditions set out hereinabove in this
Memorandum of Understanding are irrevocable in nature
and cannot be mutually altered / amended / varied verbally.
The same shall be binding on both the parties and breach of
any of the terms and conditions shall make parties liable for
contempt of Court. That further in case of any default of the
conditions stated herein if the defaulting party is
PETITIONER NO 1 than the amound paid will be forfeited
plus penalty of 2,00,000 rs (two lakh rupees) and if
PETITIONER NO 2 is defaulting party than PETITIONER
NO 2 shall return the double amount of amount paid by first
party along with 2,00,000 rs (two lakh rupees) penalty to
another party.
X. That both the parties herein shall be jointly and severally
liable for performance of this Memorandum of
Understanding and shall be personally liable in case of any
default and it is understood that each party to this
Memorandum of Understanding shall have the right under
the law and even otherwise to get this Memorandum of
Understanding enforced in any manner they want, limited
 and otherwise the covenants of this Memorandum of
Understanding and it is at the same time understood
between the parties that each and every covenant of the
present Memorandum of Understanding is independent and
dependent to each other simultaneously in the same breath.
XI. Both the parties agree and undertake not to interfere in the
life of each other in any manner and also undertake not to
make any allegations, defamatory or derogatory statements
against each other and their respective family members
personally or on any public forum or through social media
i.e. whatsapp, facebook, twitter, instagram, etc. or in any
other manner. None of the parties shall tap/record each
other phones or any instrument in future.

8 .The deponent says that there is no possibility of the Petitioners

cohabitating together as husband and wife.
9. The deponent says that the deponent undertakes to abide by the
stipulation as contained in the Judgment dated 15/05/2018 passed by
the Hon’ble the deponent says that High Court of Delhi in the matter of
Rajat Gupta vs. Rupali Gupta in Cont. Case (C)772/2a013.

DEPONENT
VERIFICATION
Verified at Delhi on this ___ day of______ 2025 that the contents of the
aforesaid affidavit are true and correct. No part of it is false and nothing
material has been concealed therefrom.
 DEPONENT

IN THE COURT OF HON’BLE PRINCIPAL JUDGE, FAMILY COURT

DWARKA COURTS, SOUTH WEST DISTRICT, NEW DELHI
HMA No. _____/ 2025

IN THE MATTER OF:

SRIJAN SINGH …PETITIONER NO 1

AND
AARYAA RAAJ ...PETITIONER NO 2

LIST OF DOCUMENTS
 S.NO PARTICULARS PAGE NO.
.

1. Annexure-A (Colly.)
Photograph of Marriage of Petitioner No. 1 and 2
along with copy of their wedding card
2. Annexure-B (Colly.)
Copies of the Aadhar cards of the Petitioner No. 1 and
2
3. ANNEXURE – C
Copy of Memorandum of Understanding dated
20.09.2024
4. ANNEXURE – D
Proof of residence for Petitioner No. 2 – Copy of the
rent agreement.

PETITIONER No. 1. PETITIONER No. 2

Through
XXXXXXXXX XXXXXXXX
Counsel for the Petitioner No.1 Counsel for the Petitioner no.2
Ch.XXX,Lawyer ChamberBlock Ch.XXX,lawyer chamber Block
Dwarka Court Complex ,New Delhi Dwarka Court ,New Delhi
Mob: XXXXXXX Mob: XXXXXX

ANNEXURE-‘A’

CERTIFICATE

I, XXXXXX, Advocate, Enrolment No. XXXX/2024 (copy attached) do hereby

certify that I have personally verified the copies of the documents of the
Petitioner No. 1 enclosed with the petition with the originals and that same are
true copies of their respective originals. I also undertake to submit the duly
signed and attested petition, in original in the court and to make up the
deficiency, if any, in the court fee as and when directed by the Hon’ble Court.

SUDHANSHU SINGH
Counsel for the Petitioner No. 1
Ch.no 847 LAWYERS BLOCK
DWARKA COURT COMPLEX DELHI
MOB NO: 7011295463
MAIL: sudhanshu.dullb@gmail.com

ANNEXURE-‘A’

CERTIFICATE

I, MANAS RAO, Advocate, Enrolment No. D/4791/2023 (copy attached) do

hereby certify that I have personally verified the copies of the documents of the
Petitioner No. 2 enclosed with the petition with the originals and that same are
true copies of their respective originals. I also undertake to submit the duly signed
and attested petition, in original in the court and to make up the deficiency, if any,
in the court fee as and when directed by the Hon’ble Court.

MANAS RAO
Counsel for the Petitioner No.2
Ch.847 Lawyers Chamber Block,
Dwarka Courts Complex, New Delhi
Mob: 9911327246
Email: manasrao7@gmail.com.com

Annexure-‘B’

CERTIFICATE

I, SRIJAN SINGH, aged about 36 years, S/O SH. S.D SINGH, R/O Flat No 804
C WING 8TH FLOOR SAI VIHARCHS LTD.PLOT NO 78 79AND 80 SECTOR
CBD BELAPUR.SUB DIST: THANE MAHARASTHRA 400614, do hereby
solemnly affirm and declare as under:
The Petitioner No.1 in the present petition, do hereby certify that the documents
annexed to the petition are true copies of their respective originals. The
documents so annexed are self-attested and if the same are found to be false or
fabricated, I shall make myself liable for civil and criminal legal action.

I undertake to submit the duly signed and attested petition, in original in the Court
and to make up the deficiency, if any, in the court fee as and when directed by the
Hon’ble Court.

SRIJAN SINGH
S/O SH. S.D SINGH
THANE MAHARASTHRA 400614

Annexure-‘B’

CERTIFICATE

I, Ms. AARYAA RAAJ, D/O SH. ABHAY SINGH Aged About 33 Years R/O:
NAV DURGA SHIVJI DHAM THADI DULAMPUR WARD NO 17
DEOGHAR JHARKHAND 814114 also at R/O, 141 UG BHAGWATI
GARDEN UTTAM NAGAR 110059 do hereby solemnly affirm and declare as
under:

The Petitioner No.2 in the present petition, do hereby certify that the documents
annexed to the petition are true copies of their respective originals. The
documents so annexed are self-attested and if the same are found to be false or
fabricated, I shall make myself liable for civil and criminal legal action.

I undertake to submit the duly signed and attested petition, in original in the Court
and to make up the deficiency, if any, in the court fee as and when directed by the
Hon’ble Court.

AARYAA RAAJ
D/O SH. ABHAY SINGH
R/O, 141 UG BHAGWATI GARDEN
UTTAM NAGAR 110059