Model Divorce Petition

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  • Tuesday, October 22, 2013
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  • IN THE COURT OF  C1:: PL1
    O.P.No.      of y1
    Between:
    p1
    ... Plaintiff
    A n d

    d1
    ... Defendant

    PETITION FILED UNDER SECTION 13 OF HINDU MARRIAGE ACT.

    1. PETITIONER:

    p2

    2. RESPONDENT:

    d2



    1.           The address for service of all notices on the petitioner is that of his advocates Sri. Add7 Add8  Advocates, Pl1 and that of the respondent is as stated above.
    2.           The petitioner and the respondent are the husband and wife and the marriage in between the parties took as per Hindu rights and Caste Customs on dt1 at place.
    3.           There are no children due to the wedlock in between the petitioner and respondent.
    4.           There is no collusion in between the petitioners and they have not filed any application seeking dissolution of the marriage previously before any Court.
    5.           The cause of action for the petition arose on dt1 when the marriage in between the petitioner and respondent took place within the jurisdiction of the Hon'ble Court.
    6.           A court fee of Rs.10/- is paid under Schedule (II) Article (I) (vii) of Andhra Pradesh Court Fees and Suits Valuation Act.
    7.           The petitioners therefore prays that the Hon'ble Court may be pleased to grant a decree for divorce dissolving the marriage that took place in between the petitioner and respondent on Dt1 at place and award such other relief as the Hon'ble court deems fit and proper in the circumstances of the case.
                                        Be pleased to consider,
                    Petitioners:         

    The contents stated above are read over and explained to us in Telugu and having perfectly understood the same and we declare that the contents stated above are true to best of our knowledge, information, belief and we signed/affixed thumb mark on this petition at Pl1 on D5.

                    Petitioners:

    LIST OF DOCUMENTS FILED:

    S.No.
    Date
    Description of the document









                                  Advocate for the petitioner.








    Add6
                





    IN THE COURT OF C1:: PL1
    O.P. No.        of y1
    BETWEEN
    p1 
              .. Petitioner
    A n d
    d1 
              .. Respondent






    COURT FEE PAID: Rs.10/-



    PETITION FILED UNDER SECTION 13 OF HINDU MARRIAGE ACT



                          
    List of Papers Submitted:

    1.Petition
    2.Vakalat
    3.Process with copies
    4.Documents filed: As per List.


                     Advocate.



             





    ADDRESS FOR SERVICE:

    Add7

    Advocate
    Pl1.






    IN THE COURT OF  C1:: PL1
    O.S.No.      of y1
    Between:
    p1
    ... Plaintiff
    A n d

    d1
    ... Defendant

    We p2 do hereby appoint and retain

    Add7            

    Add 8
    Advocate               
    Pl1.

    to appear for us in the above original petition and to conduct and to prosecute or defend the same all proceedings that may be taken in respect of any applications for execution of any decree or order passed therein. I empower my advocate to appear in all miscellaneous petitions in the above suit or matter till the decrees or orders are fully satisfied or adjusted and to obtain the return of documents and draw any moneys that might be payable to me in the suit or matter and I do further empower my advocate to accept on my behalf, service of notices of all any appeals or petitions filed in any Court of appeal, reference or revision with regard to the said suit or matter before the disposal of the Same in this Hon’ble court.


    Petitioner:








    The contents stated above are explained in Telugu to the deponent having perfectly understood the same and admitted the contents are true, solemnly affirmed and signed/affixed thumb mark in my presence at Pl1 on D5. 


                                                             Advocate








































    Add6
                 





    IN THE COURT OF C1:: PL1
    O.P. No.        of y1
    BETWEEN
    p1 
              .. Petitioner
    A n d
    d1 
              .. Respondent











    VAKALAT FILED ON BEHALF OF THE PETITIONER




























    ADDRESS FOR SERVICE:
    Add7
    Add8
    Advocates
    Pl1


    IN THE COURT OF C1 :: PL1
    O.S.No.      of y1
    Between:
    p1 
    ...  Petitioner
    A n d

    d1 
    ... Respondent

    PROCESS MEMO FILED BY THE PETITIONER

    S.No.
    Name of the party Address
    On What Account
    Process
    Remarks
              
    d2
    30.00

    T.C.


    Urgent


    Total





    Pl1                        
    Dated: d5
                                    Advocate for the Petitioner  





    IN THE COURT OF C1:: PL1
    O.P. No.        of y1
    Between:
    P1
    ... Petitioner
    A n d

    d1
    ... Respondent

    To
    d2.

    Whereas the petitioner has instituted a petition against you under Section 13 of Hindu Marriage Act. You are hereby summoned to appear in this Court on        day of                y1 at 10.30 A.M. to answer the claim and you are directed to produce  all evidences and produce all documents on that day all documents upon which you intend to rely in support of the defence    
    Take notice that in default of your appearance on the day afore mentioned the suit will be heard and determined in your absence.

    Given under my hand and the seal of the Court.
    This    day of       y1


    Add7

    Advocate                                 Central Nazir.   






    IN THE COURT OF C1:: PL1
    I.A.No.    of y1
    O.P. No.    of y1
    Between:
    P1
    ... Petitioner
    A n d

    d1
    ... Respondent

    AFFIDAVIT FILED BY THE PETITIONER

          I, p2 do hereby solemnly and sincerely affirm and state as follows: -

    1. I am the petitioner herein and well acquainted with the facts of the case.
    2. Hence I submit and pray that the Hon'ble court may be pleased to Else I suffer serious and irreparable loss.             
                                  Be pleased to consider,

                            Deponent:

    The contents stated above are explained in Telugu to the deponent having perfectly understood the same and admitted the contents are true, solemnly affirmed and signed in my presence at Pl1 on d5.

                                     Advocate






    IN THE COURT OF C1:: PL1
    I.A.No.        of y1
    O.P. No.       of y1
    Between:
    P1
    ... Petitioner
    A n d

    d1
    ... Respondent

    PETITION FILED UNDER ORDER  RULE AND SECTION 151 CIVIL PROCEDURE CODE

            For the reasons stated in the accompanying affidavit the petitioner prays that the Hon'ble court may be pleased to 

                                                            Be pleased to consider,
    Pl1,
    D5.                                          
                                            Advocate for petitioner.








    Add6
     IN THE COURT C1:: PL1
    O.P.No.     of y1
    I.A.No.     OF y1





















    PETITION FILED UNDER
    SECTION 151 OF C P C


















    ADDRESS FOR SERVICE:
    ADD7
    ADVOCATE
    PL1

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