In the Court of the Learned Principal Judge,
Family Court, Bulandshahr
Divorce Petition Case No. 1247 of 2023
Ajay, aged about 23 years, son of Ramesh,
Resident of Village Rasoolabad, Parana Pahasu,
Tehsil Shikarpur, District Bulandshahr,
Aadhaar Card No.: 3707 7875 5353,
Mobile: 9389292328
… Petitioner/Husband
Versus
Smt. Vandana @ Surti, aged about 20 years,
Wife of Ajay, daughter of Jabar Singh,
Resident of Village Aflasa, presently residing at:
House of Jitendra Singh, Rajput,
Phase–2, Sector–24, Gurugram, Haryana – 122001,
Aadhaar Card No.: _________,
Mobile: 8860305716
… Respondent/Wife
Petition under Section 13 of the Hindu Marriage Act, 1955
The Petitioner most respectfully submits as follows:
1. That the marriage between the Petitioner and the Respondent was solemnized on
16.06.2020 according to Hindu rites and ceremonies. At the time of marriage, no
dowry was given or taken except customary articles and household items worth
approximately Rs. 8,000–10,000. The marriage was duly consummated.
2. That after marriage, the Respondent stayed at her matrimonial home for some days
but did not behave properly with the Petitioner and his family. She often quarreled
and expressed disinterest in cohabitation with the Petitioner. The Petitioner and his
family members made every possible effort to counsel her, but despite all, she did not
mend her behavior.
3. That the Respondent left the matrimonial home on her own without any reasonable
cause. The Petitioner’s father tried to persuade her and her parents several times, but
she did not return.
4. That on 05.08.2020, the Respondent’s father came to the Petitioner’s house with some
relatives and took her away to her parental home in Shikarpur, Bulandshahr, assuring
that she would be sent back. However, despite repeated efforts, the Respondent did
not return.
5. That thereafter, the Petitioner’s parents and relatives made several attempts to bring
the Respondent back and advised her parents also. However, the Respondent
categorically refused to come and resume matrimonial life.
6. That on 20.05.2023, a panchayat was convened between both families, wherein elders
of both sides advised the Respondent to return to her husband’s home and live with
him peacefully. However, the Respondent refused in the presence of all and
misbehaved with the Petitioner’s family.
7. That the Petitioner has continuously made sincere efforts to bring the Respondent
back and maintain matrimonial harmony, but all efforts have gone in vain.
8. That on 24.09.2023, once again, in presence of respectable members of the society,
the Respondent was advised to return to her matrimonial home, but she openly
refused and instead insulted the Petitioner and his family. Thereafter, she permanently
left the Petitioner’s company.
9. That the Respondent has deserted the Petitioner for more than one year without any
reasonable cause, and the Petitioner has been left without matrimonial
companionship.
10. That the marriage between the parties was solemnized according to Hindu rites and
ceremonies and is governed by the provisions of the Hindu Marriage Act, 1955.
11. That the Petitioner is left with no option but to seek dissolution of marriage by a
decree of divorce on the ground of desertion under Section 13 of the Hindu Marriage
Act.
12. That the Petitioner has not filed any other petition for divorce earlier between the
same parties in any Court of law.
13. That the last cohabitation between the Petitioner and the Respondent was on
05.08.2020 at Village Rasoolabad, Parana Pahasu, Tehsil Shikarpur, District
Bulandshahr. Thereafter, on 24.09.2023, in presence of relatives, the Respondent
finally refused to live with the Petitioner and made her intention clear to separate
permanently.
14. That the cause of action for the present petition arose within the jurisdiction of this
Hon’ble Court when the marriage was solemnized and when the Respondent deserted
the Petitioner. Therefore, this Hon’ble Court has territorial jurisdiction to entertain
and decide this petition.
15. That the valuation of the present petition for the purpose of Court Fees and
jurisdiction is fixed at Rs. 1000/- upon which appropriate court fee has been affixed.
Prayer
It is, therefore, most respectfully prayed that this Hon’ble Court may kindly:
(a) Pass a decree of divorce under Section 13 of the Hindu Marriage Act, 1955, thereby
dissolving the marriage between the Petitioner and the Respondent solemnized on
16.06.2020.
(b) Grant any other relief(s) which this Hon’ble Court deems fit and proper in the interest of
justice.
Verification
I, the Petitioner above named, do hereby verify that the contents of paragraphs 1 to 16 of the
petition are true and correct to my knowledge and belief, and nothing material has been
concealed.
Verified at Bulandshahr
On this 05th day of October, 2023.
Sd/-
(Petitioner – Ajay)
Sd/-
(Advocate – Anil Kumar Gautam)
Affidavit
I, Ajay, aged about 23 years, son of Ramesh, resident of Village Rasoolabad, Parana Pahasu,
Tehsil Shikarpur, District Bulandshahr, do hereby solemnly affirm and state as under:
1. That I am the Petitioner in the accompanying petition under Section 13 of the Hindu
Marriage Act, 1955, and am fully conversant with the facts of the case.
2. That I have read and understood the contents of the petition from paragraphs 1 to 16,
which are true and correct to my personal knowledge and belief.
3. That no part of the contents is false and nothing material has been concealed therein.
4. That whatever stated hereinabove is true and correct to my knowledge and belief.
Verified at Bulandshahr
On this 05th day of October, 2023.
Sd/-
(Petitioner – Ajay)
Sd/-
(Advocate – Anil Kumar Gautam)
