IN THE HON’BLE FAMILY COURT AT GURGAON
DIVORCE PETITION NO. 101 OF 2025
IN THE MATTER OF:
Mrs. Anjali Sharma
W/o Mr. Rajeev Sharma,
Aged about 32 years,
Currently residing at:
H. No. 245, Sector 46, Gurgaon – 122003, Haryana
… Petitioner/Wife
VERSUS
Mr. Rajeev Sharma
S/o Mr. Harish Sharma,
Aged about 35 years,
Presently residing at:
Flat No. 703, Emerald Residency,
Bandra West, Mumbai – 400050
… Respondent/Husband
PETITION UNDER SECTION 13(1)(ia) AND 13(1)(ib) OF THE HINDU MARRIAGE ACT, 1955
FOR DISSOLUTION OF MARRIAGE BY A DECREE OF DIVORCE
The Petitioner respectfully submits as under:
1. That the marriage between the Petitioner and the Respondent was solemnized on 15
December 2018 in Gurgaon, Haryana, according to Hindu rites and ceremonies. A certified
copy of the marriage certificate is annexed herewith as Annexure A.
2. That after marriage, the parties lived together as husband and wife at the Petitioner’s
matrimonial home located in Sector 46, Gurgaon, and cohabited as such until 2022.
3. That a male child was born out of the wedlock on 4 June 2020, who is currently residing
with the Petitioner and is solely dependent on her for his care, education, and maintenance.
4. That after the birth of the child, the behavior of the Respondent drastically changed. He
began to subject the Petitioner to verbal abuse, often insulting her in front of family, friends,
and neighbors. He continuously cast unfounded aspersions on her character and accused
her of infidelity without any proof or cause.
5. That the Respondent physically assaulted the Petitioner on multiple occasions, causing
her mental agony and physical pain. The repeated cruelty has caused the Petitioner extreme
emotional trauma and undermined her dignity.
6. That in or about March 2022, the Respondent abruptly left the matrimonial home without
any reasonable cause or justification and started living in Mumbai. Since then, he has
refused all communication, has not visited his child, and has completely failed to provide
any financial support to the Petitioner or the minor child.
7. That despite repeated attempts by the Petitioner and her family members, and efforts by
elders to mediate, the Respondent has shown no inclination to resume cohabitation or fulfill
his marital obligations.
8. That the Petitioner has been deserted by the Respondent for a continuous period of over
two years, without her consent and without any reasonable cause, thereby satisfying the
requirement of Section 13(1)(ib) of the Hindu Marriage Act.
9. That the continued mental cruelty, physical violence, and deliberate desertion by the
Respondent have made it impossible for the Petitioner to continue the marital relationship,
and the marriage has irretrievably broken down.
GROUNDS FOR DIVORCE
The Petitioner seeks dissolution of the marriage on the following grounds:
Cruelty as defined under Section 13(1)(ia) of the Hindu Marriage Act, due to verbal and
physical abuse, character assassination, and emotional trauma.
Desertion as defined under Section 13(1)(ib) of the Hindu Marriage Act, due to continuous
abandonment by the Respondent for more than two years without cause.
PRAYER
In view of the foregoing facts and circumstances, the Petitioner respectfully prays that this
Hon’ble Court may be pleased to:
Pass a decree of divorce in favour of the Petitioner and against the Respondent by
dissolving the marriage solemnized on 15 December 2018;
Grant permanent custody of the minor child to the Petitioner with liberty to the Respondent
to seek visitation, if so advised;
Direct the Respondent to pay monthly maintenance and child support, as deemed
appropriate by this Hon’ble Court;
Pass any other order(s) as this Hon’ble Court may deem just, fit and proper in the interest of
justice.
AND FOR THIS ACT OF KINDNESS, THE PETITIONER AS IN DUTY BOUND SHALL EVER
PRAY.
Gurgaon
Date: 11 June 2025
Sd/-
(Mrs. Anjali Sharma)
Petitioner
Through Counsel:
Smriti Raj
