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In the Court of Learned Principal Judge,Family Court,Pataudi

Raj Kumar S/o Sh. Ramesh Kumar Aged- 35,years,R/o Ward No.6, Near

Ice Factory,Bala Ji Colony,Farrukh Nagar,Gurugram ...Petitioner No. 1

And

Sonia W/o Sh. Raj Kumar and D/o Sh. Samay Singh Yadav, Aged 34 Years

Resident Of X-Block,RoshanPura,Paprawat Road,Najafgarh,south West

Delhi-110043 ....Petitioner No.2

Petition for dissolution of marriage by a decree of divorce

on the basis of mutual consent, as per the provisions

envisaged U/s. 13-B of Hindu Marriage Act.1955, as

amended till date.

Respected Sir,

The petitioners most respectfully submit as under: -

1. That a marriage was solemnized between the parties on 22.02.2016 at

Raghu Vatika, Najafgarh, Delhi according to Hindu customs and rites.

An affidavit to this effect is enclosed.

2. That the status and place of residence of the parties to the marriage,

before the marriage and at the time of filing of the petition are as

follows:-

a. Status and place of residence of Husband/Petitioner No. 1

before marriage:-

Hindu, Unmarried, R/o Ward No.6, Near Ice Factory,Bala Ji

Colony,Farrukh Nagar,Gurugram

b. Status and place of residence of Wife/Petitioner No. 2 before

marriage:-
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Hindu, Unmarried Sonia W/o Sh. Raj Kumar and D/o Sh.

Samay Singh Yadav, Aged 34 Years Resident Of X-

Block,RoshanPura,Paprawat Road,Najafgarh,south West Delhi-

110043

c. Status and place of residence of husband at the time of filing of

the petition: -

Hindu, Married, Ward No.6, Near Ice Factory,Bala Ji

Colony,Farrukh Nagar,Gurugram

d. Status and place of residence of wife/respondent at the time of

filing of the petition:

Hindu, Married, R/o Sonia W/o Sh. Raj Kumar and D/o Sh.

Samay Singh Yadav, Aged 34 Years Resident Of X-

Block,RoshanPura,Paprawat Road,Najafgarh,south West Delhi-

110043

3. That the present marriage was consummated at Ward No.6, Near Ice

Factory,Bala Ji Colony,Farrukh Nagar,Gurugram and one issues was

born out of this wedlock namely Jayaan Kakroliya Aged around 5

years.

4. That during their stay together, despite keen desire and genuine

efforts, they could not adjust with each other and there is no

possibility of their cohabiting together in future too.

5. That all the efforts to the effect of reconciliation have failed and both

the petitioners have been leading a separated life since September

2020.

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6. That now, since there is no possibility of their living together as

husband and wife, both the parties have mutually agreed to the effect

of dissolution of the marriage between them, and have approached the

Hon’ble Court of your Lordship in this regard.

7. That both the parties have agreed to dissolve their marriage in their

self-interest and in the interest their future lives and both the parties

will withdraw their cases pending between them.

8. That the present petition is being filed after the lapse of statutory

period of one year and there has been no unnecessary delay in filing

of the present petition and the present petition is not being presented

in collusion by the parties. It is not being presented in collusion with

the parties.

9. That the petitioner No. 1 is residing at Ward No.6, Near Ice

Factory,Bala Ji Colony,Farrukh Nagar,Gurugram at the time of filing

the present petition and further the present marriage were

consummated in Gurugram which is well within the territorial

jurisdiction of the Hon’ble Court of your lordship and hence the

Hon’ble Court is competent enough to entertain and dispose of

this petition in accordance with law.

10. That it has been settled to the petition, shall not pay

anything to each other and even in future shall not lay any

monetary claim qua to each other.

11. That it has been mutually settled that the custody of the

child shall be with the petitioner No. 1 and the petitioner

No. 2 shall lay no claim on his custody under any provision

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of law in future. That the petitioner No.2 has no right of

visitation, further it is also mutually settled that all the

medical expenses of the child shall be bear by the petitioner

No.1 because the child is suffering from an disease

Cerebral Palsy by mutual understanding.

12. That none of the parties to this marriage shall lay any

claim against each other of any kind under any provision of

law. The petitioner No. 2 will not claim from petitioner No.

1 any sort of maintenance under the provisions of Hindu

Marriage Act, 1954 or under the provisions of Cr.P.C.or the

Adoption and Maintenance Act, 1956 or the Prevention of

Women from Domestic Violence Act or any other law. All

the cases instituted by the petitioner No.2 shall be

withdrawn by her in view of the mutual settlement. The

parties shall not interfere in each other’s life after the

dissolution of marriage.

13. That proper court fees has been affixed on the petition as

per the requirements of law.

14. That the parties to the petition do not seek any relief as to

costs of the petitioner against each other.

Prayed

It is, therefore, humbly prayed that marriage between the

parties be dissolved by a decree of divorce on the basis of

mutual consent as provided for in the provisions of Section

13 [B] of the Hindu Marriage Act. 1955.

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PETITIONER NO. 1 PETITIONER NO. 2

Raj Kumar S/o Ramesh Kumar Sonia W/o Sh. Raj Kumar and

Ward No.6, Near Ice D/o Sh. Samay Singh Yadav,

Factory,Bala Ji Colony,Farrukh Aged 34 Years Resident Of X-

Nagar,Gurugram Block, Roshan Pura, Paprawat

Road, Najafgarh, south West

Delhi-110043
Through: - Through: -

Rahul Dhankhar,Advocate Dinesh Kumar,Advocate

Verification: -
Verified that the contents of this petition have been read over and explained

to us and the same are true and correct to the best of our knowledge and

belief and nothing has been concealed therein.

Place: Gurugram. Petitioners

Date:

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In the Court of Learned Principal Judge,Family Court,Gurugram

Raj Kumar ...Petitioner No. 1

and

Sonia ...Petitioner No.2

Petition for dissolution of marriage by a decree of divorce

on the basis of mutual consent, as per the provisions
envisaged U/s. 13-B of Hindu Marriage Act.1955, as
amended till date.
AFFIDAVIT

I, Raj Kumar and S/o Ramesh Kumar Aged 35 Resident of Ward No.6,Near

Ice Factory,Farrukh Nagar, Gurugram do hereby solemnly affirm and

declare as under:

1. That the deponent is the one of the parties to the above captioned petition

and has made himself acquainted with the facts and circumstances of

the case.

2. That a marriage was solemnized between the deponent and the petitioner

No. 2 Sonia according to Hindu customs and rites on

22.02.2016 at Raghv Vatika, Najafgarh, Delhi That the contents of

the petition may kindly be read as piart and parcel of this affidavit.

Dated
Place :Pataudi Deponent
Verification:
Verified that the contents of the affidavit have been read over and explained
to me, and the same are true and correct to best of my knowledge and belief.

Date:
Place :Pataudi Deponent

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In the Court of Learned Principal Judge,Family Court,Pataudi

Raj Kumar ...Petitioner No. 1

and

Sonia ...Petitioner No.2

Petition for dissolution of marriage by a decree of divorce

on the basis of mutual consent, as per the provisions
envisaged U/s. 13-B of Hindu Marriage Act.1955, as
amended till date.
AFFIDAVIT

I, Sonia W/o Sh. Ne Raj Kumar and D/o Sh. Somay Singh Yadav, Aged 34

do hereby solemnly affirm and declare as under:

1. That the deponent is the one of the parties to the above captioned

petition and has made herself acquainted with the facts and

circumstances of the case.

2. That a marriage was solemnized between the deponent and the

petitioner No. 1 Raj Kumar according to Hindu customs and rites on

22.02.2016 at Raghv Vatika, Najafgarh, Delhi

3. That the contents of the petition may kindly be read as part and parcel

of this affidavit.

Date:
Place : Pataudi Deponent
Verification:
Verified that the contents of the affidavit have been read over and explained
to me, and the same are true and correct to best of my knowledge and belief.

Date:
Place : Pataudi Deponent

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In the Court of Learned Principal Judge,Family Court,Pataudi

Neeraj Kumar ...Petitioner No. 1

and

Sonia ...Petitioner No.2

Petition for dissolution of marriage by a decree of divorce on the basis

of mutual consent, as per the provisions envisaged U/s. 13-B of Hindu

Marriage Act.1955, as amended till date.

INDEX

Sr.No. Particulars Page No.

1. Application U/S 13 of Family Court Act

2. Petition U/s 13-B Of H.M.Act Along

Affidavits
3. Photographs Of Marriage, Invitation Card

Copy OF ID Proofs
4.
5. Vakalatnama
Place:- Gurugram
Dated:-

PETITIONER NO. 1 PETITIONER NO. 2

Sonia W/o Sh. Raj
Raj Kumar S/o Ramesh Kumar
Kumar and D/o Sh.
Ward No.6, Near Ice
Samay Singh Yadav,
Factory,Bala Ji Colony,Farrukh
Aged 34 Years Resident
Nagar,Gurugram
Of X-Block, RoshanPura,
PaprawatRoad,
Najafgarh, south West
Delhi-110043
Through: - Through: -
Rahul Dhankhar,Advocate Dinesh Kumar,Advocate

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In the Court of Learned Principal Judge,FamilyCourt,Pataudi

Raj Kumar ...Petitioner No. 1

And

Sonia ...Petitioner No

Petition for dissolution of marriage by a decree of divorce on the

basis of mutual consent, as per the provisions envisaged U/s. 13-B

of Hindu Marriage Act.1955, as amended till date.

Application Under Section 13 OF Family Court Act

Respected Sir,

The petitioners/ Applicants most respectfully submit as under:

1. That the applicant is petitioner No.1 in the above titled petition.

2. That there are several legal & technical issues involved in the present

case and the applicant being rustic about the procedures of law is not

in a position to contest the proceeding before this Hon’ble Court

without help of a legal practitioner.

Prayer

It is therefore prayed that in the interest of justice, this Hon’ble

court be pleased to allow the applicant to engage a legal practitioner to

present her in the present proceedings.

APPLICANT/PETITIONER NO.1

Through Counsel

Rahul Dhankhar,Advocate

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In the Court of Learned Principal Judge,Family Court,Gurugram

Raj Kumar ...Petitioner No. 1

And

Sonia ...Petitioner No

Petition for dissolution of marriage by a decree of divorce on the

basis of mutual consent, as per the provisions envisaged U/s. 13-B

of Hindu Marriage Act.1955, as amended till date.

Application Under Section 13 OF Family Court Act

Respected Sir,

The petitioners/ Applicants most respectfully submit as under:

1. That the applicant is petitioner No.1 in the above titled petition.

2. That there are several legal & technical issues involved in the present

case and the applicant being rustic about the procedures of law is not

in a position to contest the proceeding before this Hon’ble Court

without help of a legal practitioner.

Prayer

It is therefore prayed that in the interest of justice, this Hon’ble

court be pleased to allow the applicant to engage a legal practitioner to

present her in the present proceedings.

APPLICANT/PETITIONER NO.2

Through Counsel

Dinesh Kumar,Advocate

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