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CHECK-LIST
1. VALUATION OF SUIT JURISDICTION

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3. NATURE OF SUIT
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4. AGE OF PARTIES · ; Plaintiff
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Defendant
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s. CAVEAT

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6. WHETHER ANYT EARMARKED COURT
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7.! COURT FEE AFFIXED

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51
No.
Relief
Sought
Valuation
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for the
Valuation
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' purpose of purpose individually
jurisdiction of court
fee
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8. CONNECTED CASES IF ANY & NAME OF THE
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S.NO. PLAINTIFF I PETITIONER/ COMPLAINANT I APPELLANT I DECREE HOLDER ETC

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6. Date ofBirth ~~~ ~-~ l£lq·.ry.. *Age i8J Yoilr'

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9. Valuation of Suit Court Fee ascertained:

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Court Fee paid/deposited:

10. * Police Station ______... ,-

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S.NO. DEFENDANT/ACCUSED/RESPONDENT/APPELLANT/JUDGMENTDEBTORETC

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CONNECTED MATIER, IF ANY CASE DETAILS (viz. CIS REGISTRATION No.I CASE TITLE) PENDING IN TilE COURT OF

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FRESH MATIER 0 C.\Sl': TlTLE

S.No. . ADVOCATE FOR PLAINTIFF I COMPLAINANT I PETITIONER I DECREE HOLDER ETC.

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IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT PATIALA
HOUSE COURTS NEW DELHI

HMA Petition No. /2025

In the matter of:-

Inder Dev Petitioner

Versus
Mrs. Preeti Respondent
INDEX

s. Particulars Page Court

No. No. Fee
1. Memo of parties 1

2. Petition U/S 13 (1) (ia) of Hindu

Marriage Act 1955 along with affidavit 2.~ 1"1.

3. List of documents along with

documents ~~~~

4. Vakalatnama
19
Delhi

Dated: 25.07.2025

Through:

Counsel -

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r
 !'"
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.
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-
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT PATIALA {j)
HOUSE COURTS NEW DELHI "c

HMA Petition No. /2025 i

~

In the matter of:-

Inder Dev Petitioner

Versus
Mrs. Preeti Respondent
MEMO OF PARTIES

Inder Dev
S/0 Sh. Arjun
R/0 H. No. B-255
JJ Colony, Inderpuri
New Delhi-1100 12

Versus
Mrs. Preeti
W /0 Sh. Sh. Inder Dev .•-
D/0 Shri Ram Kumar Baitha
R/0 Ward-1, Lakhmipur,
Mahesh Patti, P.S. Ujjaiar Pur
Distt. Samastipur, ..
-

Bihar-848132 Respondent
!

Petitioner
Through:

Counsel

New Delhi
Dated:3f .07.2025
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""""'".- . . . _ ..........
.n. o. D/3036115 --l.L-~J:(_
Chamber No. 701, Pa!iala Advocc.te
.N~~~ O;:;/hi-11Qo~ouse Courr.
'··oor/e. 981 . 1
E-mail: arnilb~i I 0!95280
ns aBO@gmail.com
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT PATIALA
HOUSE COURTS NEW DELHI

HMA Petition No. /2025

~·--

In the matter of:-

Inder Dev
S/0 Sh. Arjun
R/0 H. No. B-255
JJ Colony, Inderpuri
New Delhi-110012 Petitioner

Versus
Mrs. Preeti
W /0 Sh. Sh. Inder Dev
D/0 Shri Ram Kumar Baitha
R/0 Ward-1, Lakhmipur,
Mahesh Patti, P.S. Ujjaiar Pur
Distt. Samastipur,
Bihar-848132 Respondent

PETITION FOR DISSOLUTIUON OF MARRIAGE BY DECREE OF

DIVORCE UNDER SECTION 13 (1) (ia) OF HINDU MARRIAGE
ACT AS AMENDED UPTO DATE ON BEHALF OF THE
PETITIONER •
Most respectfully showeth:-

1. That the marriage of the petitioner was solemnised with the

respondent according to Hindu rites and ceremonies on

20.112021 at Ward-1, Lakhmipur, Mahesh Patti, P.S. Ujjaiar

-
Pur Distt. Samastipur, Bihar-848132'.

I
2. That the marital status, age and place of residence of the

parties to the petition were and are as under:-

PETITIONER/HUSBAND

Status Age Place of Residence

Before Marriage Hindu 27 House No. B-255,

Unmarried Years
Inder Puri, J.J.

Colony, New Delhi-

110012.

AT THE TIME Hindu 28 House No. B-255,

OF FILING Married years
PETITION Inder Puri, J.J.

Colony, New Delhi-

110012.

•
RESPONDENT /WIFE

Status Age Place of Residence

Before Hindu 24 Years Ward-1,

Marriage Unmarried
Lakhmipur,

Mahesh Patti, -
P.S. Ujjaiar Pur
I
 Distt. Samastipur,

Bihar-848132

At the time Hindu 25 Years Ward-1,

of filing Married
petition Lakhmipur,

Mahesh Patti,

P.S. Ujjaiar Pur

Distt. Samastipur,

Bihar-848132

3. That the marnage was consummated/there is cohabitation

between the petitioner and the respondent and out of this

wedlock one female child was born.

4. That the said marriage of the petitioner was arranged marriage

and simple marnage and attended by at least 200 persons •

from both the sides and no dowry was exchanged m this

marnage.

5. That after the marnage, the respondent taken to the

matrimonial home, where the marriage between the petitioner

-
and the respondent was consummated.

I
6. That aftr marriage respondent lived happily at the residence of

the petitioner at his native place in Bihar for one month and

after some time, respondent and petitioner shifted to Delhi at

his parents house and later on due to paucity of space, to

maintain privacy petitioner taken a rented accommodation of

one room near his parents house in the month of January

2023 at H. No. E-432, Third Floor, Inder Puri, JJ Colony, New

Delhi and shifted there.

7. That in the first week of February, 2022 respondent's mother

& father has made a call to petitioner and said that they want

to settle his son in Delhi and said that they want to adjust his •
son in the rented accommodation with petitioner, but

petitioner said that for few days it is possible but for

•
permanently is not possible as the rented accommodation is

only one room. On this parents of respondent became

aggressive and insulted the petitioner.

8. That after that respondent's father and mother started

interfering in the petitioner's peaceful and happy married life

and instigating to respondent against the petitioner. On this

several time respondent quarrelled with the petitioner.

r
 However, petitioner manages the respondent and removes the

doubt created by the respondent's parents in the mind of the

respondent.

9. That several times respondent told to the petitioner that

respondent's parents are pressurizing her to give the divorce to

the petitioner and they will again remarry her in a well settled

family.

10. That on 02.04.2022, suddenly respondent brother Sonu

Kumar came to the petitioner's house in the absence of the

petitioner and told to respondent that mother's medical

condition is serious and urgently they want to see her. On this

respondent took all the belonging and jewellery with her and

left the house without informing to petitioner. When in the

evening, when petitioner came and he does not find

respondent at home then petitioner made a call on respondent

mobile, then petitioner came to know that respondent is along

with her brother is in the train and she is going to see her

ailing mother as told to her by her brother. In this regard

petitioner gave written complaint to the local police station

Inder Puri on 28.06.2022.

I
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11. That on 12.04.2022 parents of petitioner visited to the !
j,
residence of respondent at Bihar and asked about the health :.1
!

of respondent mother and requested to respondent parents to

send petitioner wife back along with them, but respondent

parents refused for not sending back and then on this, father

of respondent said that respondent did not want to go back to

her husband house. On this petitioner parents insisted to talk

to the respondent, but respondent parents and brother did not

allow petitioner to talk to the respondent.

12. That on this petitioner parents call some respectable person

from the nearby, but respondent parents remained adamant

that they will not send the respondent back neither disclosed

any reason fornor sending the respondent back and further

•
threaten to petitioner parents that he will file a false complaint

for demand of dowry in Bihar against petitioner as well as

against the whole family member of the petitioner, if petitioner

insist for respondent to come back to the petitioner house.

13. That petitioner contacted to respondent, then petitioner came

to know that respondent parents are angry on the issue of

refusal by petitioner in Feb 2022 regarding nor to adjust his

 brother-in-law in his rented accommodation and make this

issue as a prestige issue. Respondent shows her willingness to

come back, but respondent parents are stopping her to come

back. They had threatened to the respondent that if

respondent insist for going to petitioner house then they will

break there all the relation and now under the pressure of

parents, respondent is refusing to come back to the petitioner

house.

14. That the conduct of the respondent, will show her

unwillingness to stay in her matrimonial home, and her

indifferent, non cooperative and un-adjustable

attitude/behaviour towards the petitioner as well as her

matrimonial home.
•
15. That the respondent has withdrawn herself from the company

of the petitioner on 12.04.2022 without any cause or reason

on the part of the petitioner and has refused to live with

petitioner, in her matrimonial home.

I
16. That the parties have not cohabited with each other since the

date of separation.
17. That the petitioner has treated with mental, physical,

therefore, the petitioner has been compelled to file the present

divorce petition.

18. That the petitioner has not condoned the acts of the cruelty

committed upon him by the respondent.

19. That the petition has not been filed in collusion with the

respondent.

20. That the present petition has not filed any Improper or

· unnecessary delay.

21. That no other allegation regarding marriage of petitioner and

respondent is pending in any court of law.

22. That there is no other ground as to why the relief sought for is

not granted.
•
23. That the cause of action for filing present petition to petitioner

arose when the respondent left the matrimonial home on her

own and against the wishes of petitioner to· rejoin her

matrimonial home inspite of all best efforts made by the

petitioner. The cause of action again arose on several times -

when the petitioner tried to contact the respondent to join her

matrimonial home the cause of action finally arose on

I
 12.04.2022 when the petitioner finally left the matrimonial

home and received threatening call with lodging false criminal

case of dowry demand and black mailing the petitioner and his

family, cause of action still continued till the relief claim is not

granted. Hence this petition.

24. That the petitioner is residing at the above mentioned address

on rent, cause of action for filing present petition also occurred

at Delhi, Hon 'ble Court has jurisdiction to try and entertain

the present petition.

25. That the requisite court fees for the purposes of court fee and

jurisdiction is fixed, and the same is paid. •

PRAYER
I

It is, therefore, most respectfully prayed that a decree of

•
divorce may kindly be passed in favour of the petitioner and

against the respondent dissolving the marriage between the

parties by decree of divorce under section 13 (1) (ia) of the

Hindu Marriage Act, 1955, in the interest of justice.

 Any other relief which this Hon ble Court deems fit and
proper, in the facts and circumstances of the case be also
passed in favour petitioner.

Through:

Counsel

New Delhi
A lvc::::-.c" '_:_: I:JJvC_f\.R
D t d 25 07 2025
Chcrnbcr i·lo. 701, ''ziio/a House Co~ne
r:n. No. D/J03J/15 Acll'oc-t
a e : . .
i~c~·,., o.::::-.i-110001 .

Verification:- E-m<.:r ;-;,~:,::~:-~:~-:~~;~i~~~~~ail.corn

Verified at Delhi on this 25th day of July 2025 that the

contents of paras No. 1 to 15 are true and correct to my knowledge
and these of paras No. 16 to 25 are believed to be true on the
information received and last para is prayer to this Hon ble Court.

Petitioner

,_
IN THE COVRT OF PRINCIPAL JUDGE FAMILY COURT PATIALA
HOUSE COURTS NEW DELHI

HMA Petition No. /2025

In the matter of:-

Inder Dev Petitioner

Versus
Mrs. Preeti Respondent

AFFIDAVIT

I, Inder Dev aged about 28 years S/0 Sh. Arjun R/0 H. No.

B-255 JJ Colony, Inderpuri New Delhi-110012, do hereby

solemnly affirm and declare as under:- ·

1. That I am the petitioner in the above noted petition and fl,llly

conversant with the facts and circumstances of the case,

hence competent to swear this affidavit. •

2. That I was married with the respondent above named on

20.11.2021 in accordance with Hindu rites and ceremonies at

Bihar and lastly resided in New Delhi within the jurisdiction of

this Hon'ble Court.

 4. That the petition Is not being filed m collusion with

respondent.

5. That the accompanying petition under section 13 (1) (ia) of

Hindu Marriage Act has been drafted by my counsel under my

instructions and the contents of the same have been read over

and explained to me in my vernacular and the same have been

understood by me and same may be read as part and parcel of

this affidavit as the same are not being repeated herein for the

sake of brevity.

Deponent

Verification:-
7 5 JUL 202S "'
Verified at New day of July 2025 that the

contents of my above affidavit are correct and true to my knowledge

and belief and nothing material has been concealed there from.
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List of Document Produced by ·PLAINTIFF
DEFENDANT
Order XIII Rule of. the order of Civil Procedure form prescribed by the High Court
in the Court of
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· List of documents produced with the plaint (or the first Hearing
on behalf of the flaintlft or Defendant) ·.
Date of hearing; This list as filed by· This _day of 20
1 2 3 4 5 6
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lnderDev
'if"'f ft!f>t/ DOB: 26/03/1997
·:~/MALE

9237 9019 4683

~'ftmq~'ftj1.;!'1qt'<il~ Q~ij)(DI
tif.I!OOEclD~NnfiCAIION AUTHORITY OF INDIA

'f<IT: Address:
S/0 Arjun, B-819, J.J. Colony.
S/0 ar¥. oft-819, ;it.;lt. Jnd e rp uri, lnd e rp uri, Central

~. -~('l(l,
Delhi,
Dalh1·110012
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~-110012

9237 9019 4683

MERAAADHAAR,MERIPEHACHAN
 ,_
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"!tiT: ~~pit~ Address: 0/0: Ram Kumar

Baitha, ward 1, Lakhmipur
'"' 1' """"F """"'r.rm
ll<f.t;Q'I",qit, ~-
'"" Maheshpatli Deal,
Samaslipur, L.m.patti, Bihar,
848132 848132

6909 3405 9079

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1800 300 1947 halpCuldl!.l.gov.ln www.uldal.gov.ln
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C.C.No .................................. .
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2S.JUL-2025 FIR No ................................... .

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INTHECOURTOF_~+UUu~nb~C~~~al~-tJr~r~0~~pO~-~Fll~j~/yT-~(~O~\~~GJJ_____
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------
Suit f Appeal No. _ _ _ _ _ _ _ _ _ _ _ _ _ ___.:._ _ _ _ _ _ ..cv=-- JURISDICTION OF 202
In re :-
Plalntlfl(s) Or Petltloner(s)
Appellant(s) Complalnant(s)
'
VERSUS
________ £1,--C,JiJ.lle;;;e._~
.....o---------~Delendant(s) /Respondent(s) I Accused

,_ _ _ _ _ _ _ _ _ _ _ _ _:::.__ _ _ _ _ _ _ _ _ _ _ do hereby appoint

4J>V :,. ~M~a KC#JC\r · ;: cSW1;.J J'lv-ttd¥ 4tt~} .i><W'1a.tr

f:~j~~~\,~1~~0:~. Cit -No- 1-ot ch -(Jo - 21:3
Mo~- Cfct6~266282.
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E-n :~.:i : 31 ~-::,:_,:;: 1,s 1:_:r:.r :r rn1:: :.co11l
(herein afler called the advocate/s to be my/our Advocate in the above-noted case authorize him:-
To act, appear and plead in the above-noted case in this court or in any other rourt in which lh: ·.- '"'-j
or heard and also in the appellate court including High court subject to payment of fees separately for
To sign file, verify and present r:-leadings, appeals cross-objections or petitions for
executions review, revision, withdrawal, compromise or other petitions or affidavits or other
documents as may t:.e deemed necessary or proper for the prosecution of the said case in all its
stages subject to payment of fees for each stage.
To file and take back documents, to admit and/or deny the documents or opposite party.
To withdraw or compromise the said case or submit to arbitration any differences or
disputes that may arise touching or in any manner relating to the said C8Se.
To take execution proceedings on paying separate fee.
To deposit, draw and receive money, cheques, case and grant receipts hereof and to
do all other acts and things which may be necessary to be done for the progress and in the
course of the prosecution on the said case.

To appoint and instruct any other Legal Practitioner authorizing him to exercise the power and authority hereby
conferred upon the Advocate whenever he may think fit to do so and to sign the power of attorney on our behalf.
And 1/ We the undersigned do hereby agree to ratify and confirm all acts done by the Advocate or
his substitute in the matter as my/our own facts, as if done bY: me/us to all intents and purpose.
And IM/e undertake that 1/ We or my/our duly authorised agent would appear in court and all hearings
inform the Advocate for appearance when the case is called.
And JM/e undersigned do hereby agree not to hold the advocate of his substitute responsible for the result of
~ ~s 0 case.The adjournment costs whenever ordered by the court shall be of the Advocate which he shall receive
\ V/ retain for himself.
And IM/e undersigned do hereby agree that in the event of the whole or part of the fee agreed by me/us to be
paid to the advocate remaining unpaid he shall be entitled to withdraw from the prosecution of the said case L·ntil the
same is paid up. The fee setlle is only for the above case and above Court. IM/e hereby agree that once the fee is
paid,I/We will not be entitled for the refund of the same in any case whatsoever and if the case prolongs for
(\ me._ethan 3years the original fee shall be paid again by me/us
V/ IN WIT NESS WHERE OF 1/We do hereunto set my/our hand to these presents the contents of which ~ave

~~~:~~~~j' lh:r::~:~:~st~~ ;~~~ d to ~.~ 20~

..... ,........................... dayof .. ..

Al'v~
~ rl-T }<('_UlVI./:-..R
Advocc.te
Client Client
r=.n. No.
35
0130 ~~ Patiala House Court,
7 I Identify the Slgnature{Thumb Impression of the Below Mentioned Person,
Ch"mber No. , 01
'"' New Oelhi-1100 Who Has been Signed In my presence. The Client.
Advomare: 9810'195280 ..
.. , I SO@!lm~li.COtn
E.-maii: am;iba1ns a -