SETTLEMENT AND COMPROMISE DEED

This Settlement and compromise deed is made on this 12th day of October 2011, at

Mediation center Allahabad high court.

BETWEEN

XXXXXXXXXXXXX(S/o Shri ********* ) at present residing at ********, here in after

referred to as the First Party,

AND

Smt. ********* (alias Girls name) D/o Sh. ******** R/O ******* Meerut here in after

referred to as the Second Party.

WHEREAS a marriage took place between the first party and Sh. XXXXXXXXXXXXX,
on 5/2/2007 and a boy named Master Ragav ,was born out on 14/4/2008 of the said
wedlock. But due to the differences in temperament of both the husband and wife, the
marriage could not stand long.

WHEREAS the Second Party has filed various cases/complaints/petitions/suits

against the First Party, the description of which is as follows:

a) Complaint which culminated into an F.I.R. numbered as case crime no. 47of

2009 under Section 498A, 323, 504, 506 and Indian Penal Code and sections 3

and 4 of Dowry Prohibition Act which is pending against the First Party and his

family members.

b) Complaint/Petition under Section 125 Cr. P.C. against the First party and

which is titled as YYYYYYYYYYYYYYYYYYYY versus XXXXXXXXXXXXX

complaint case No. _________ pending before the Family Court Judge,Meerut.

c) Complaint/Petition under Section D.V. Act 2005, case No. _________ against the

First party, pending in Meerut Court.

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 WHEREAS the First Party and his relatives has filed various

cases/complaints/petitions/suits against the Second Party, the description of which is

as follows:

i) Complaint case under titled as Vineet Kucchal Vs. Subhash goyal and

others. Under section ____I.P.C. and the same is pending before the

Muzaffarnagar Court.

And all the aforementioned said cases are pending.

And as it was found by both the parties that it is not possible for them to live together

due to incompatibility between the parties, With the intervention of well wishers,

friends and relatives both the parties discussed their differences at length and with

the intervention of common friends have agreed to settle the dispute amicably and,

they have decided to live separately and agreed to settle the matter amicably by taking

divorce between both the parties by mutual consent under the following terms and

conditions. Moreover, both the Parties are living separately since 13/July, 2011 and

both have mutually agreed that the marriage be dissolved and both the parties are in

sound and disposing mind and under no fear, fraud, influence, coercion or under any

force or compulsion have mutually agreed to end this matrimonial relation.

NOW THIS INDENTURE WITNESSETH AND IT IS HEREBY AGREED, DECLARED,

RECORDED AND CONFIRMED BY BOTH THE PARTIES HERE TO AS FOLLOWS:-

A1) The FIRST PARTY undertakes and agrees and has agreed to withdraw all the cases filed

by him whether Civil or Criminal against the SECOND PARTY, and her relatives.

Likewise the SECOND PARTY agrees to withdraw all the cases both Civil and Criminal

against the FIRST PARTY and his relatives.

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A2] Both the parties agree and undertakes to withdraw/close all cases filed against each

other and pending before the various courts in Meerut , Muzaffar nagar and Purkaji

and anywhere in India.

A3] The SECOND PARTY has no claim left against the FIRST PARTY as regards the

stridhan articles/jewelry or any movable or immovable properties and furthermore

there is no claim left against each other as regards valuable items.

A4] The SECOND PARTY relinquishes the right, title and interest, if any in her matrimonial
home or in any movable or immovable properties of the First Party and his

family/relatives, and hereby relinquishes all the rights of inheritance and maintenance.

A5] The FIRST PARTY has agreed to give by way of Demand Draft in favour of the SECOND

PARTY a sum of Rs 400000/- (Rupees 4 lacs only) towards permanent alimony towards

full and final settlement towards the SECOND PARTY.

A5D] The said amount which in totality comes to Rs. 400000/- (4 lacs) will be regarded as full

and final payment and settlement amount to the Second party in respect of her entire

and all other claims towards cost of maintenance i.e present, past and all future

maintenance also towards all other claims that the Second Party that include claims

with respect to istridhan, alimony, gifts, expenditure, inheritance or any other claim

whatsoever that the Second Party may claim against the First Party and his

family/relatives.

A6] The permanent alimony will be paid in two installments wherein

Rs 200000/- (Rupees two Lacs) will be given by way of demand draft in favour of the

Second Party at the time of quashing of the complaint case No. 47/ 2009 under Section

498-A/323/504/506 Indian Penal Code and section 3 & 4 of Dowry Prohibition Act. The

second installment of Rs 2,00,000/- (Rupees two lac only) will be paid by the First Party

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 by way of demand draft in favour of the Second Party at the time of recording of Second

Motion.

A6B] The Draft number ___________ , dated _______________of Rupees 2.00,000 (2 lacs) has

already been made on the name of Second Party, but as mentioned it will be handed

over after quashing of 498A and other related cases

A6C] That the baby boy master Raghav would be handed over to his father, Sh.

XXXXXXXXXXXXXand Smt YYYYYYYYYYYYYYYYYYYY will have no right on the baby.

A8] That the Second Party and First Party will together file an application under a joint

petition under Section 13(B)(1) of the Hindu Marriage Act, 1955 for a decree of divorce

by mutual consent in Meerut family court

A8B] That master Raghav would be handed over to Sh XXXXXXXXXXXXXat the time of filing

of divorce application.

A7] After the filing of divorce the Second party will withdraw/close the following

cases:

a) Case no. 47 of 2009 under Section 498A, 323, 504, 506 and Indian Penal Code

and sections 3 and 4 of Dowry Prohibition Act which is pending against the

First Party and his family members.

b) Complaint/Petition under Section 125 Cr. P.C. against the First party and

which is titled as YYYYYYYYYYYYYYYYYYYY versus

XXXXXXXXXXXXXcomplaint case No. _________ pending before the Family

Court Judge,Meerut.

c) Complaint/Petition under Section D.V. Act 2005, case No. _________ against the

First party, pending in Meerut Court.

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A9] Further more the Second Party will co-operate the First Party fully in quashing of the

FIR No. 47/2009 under Section 498-A/323/504/506 Indian Penal Code and section 3

& 4 of Dowry Prohibition Act and the Second Party will be present before the Honble

High Court at Allahabad at the time of hearing of the case whenever listed before the

Honble High Court for getting the said F.I.R. quashed and any litigation arising there

from or incidental thereto.

A9C] Further more the Second Party will co-operate in obtaining the Divorce and the Second

Party undertakes that she will not wriggle out from her statement and will not claim any
future maintenance for herself under any circumstances whatsoever.

A10] Only after complying with the terms and conditions of the compromised deed and the

averments made herein and withdrawing /quashing of criminal cases as well as

maintenance case and all the aforementioned cases, the Second Party will be entitled for

Rs 400000/- (4 lacs) and if at any stage the Second Party backed out or wriggled out

from the statements made herein than the First Party has every right to recover the

given amount and the Second Party will repay the said amount back to the First Party

along with interest as per market rates, and upon refusal of paying the amount the First

Party has every right to initiate proceedings against the second Party. That both the

parties shall have on satisfaction of aforementioned terms no further claims whatsoever

against each other from this day onwards and terms of the aforementioned deed are

binding on them. Any party who denies the above mentioned compromise will be liable

for legal action.

A11] The SECOND PARTY shall not claim any maintenance or alimony or anything for herself

or her family members in past, present and in future whatsoever from the FIRST PARTY

or his family/relatives.

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A12] The SECOND PARTY or her family members will have no rights or claims to movable or

immovable properties, if any of the FIRST PARTY in past, present or in future and, both

parties agrees and undertake they have no claims, against each other in past, present or

in future whatsoever.

A13] In view of the settlement the parties and their family agree that their shall be no further

claims against each other or scope or litigation both civil and criminal in any part of

India at present or in future. Furthermore, in future neither party nor their family

members will make any claim against each other or their family members.

A14] That both the parties undertake not to turn around from the Settlement and

compromise deed.

A15] That both the parties agree after obtaining the divorce and prior to divorce, shall have

no cause for filing any cases both civil and criminal against each other in any court of

law in any part in India and the parties will lead their lives independently without

interference in each other lives in present or in future.

A16] Both the parties undertake that they will not violate the conditions of the compromise

and settlement deed executed by them and will abide by the terms and conditions and

they will not revoke their stand stated in the compromise and settlement deed and both

the parties agree that they will not revive any cases which they have agreed to withdraw.

A17] Both the parties further undertake to withdraw the legal proceedings initiated against

each other and if any, complaints are made by both the parties to any of the authorities,

same will be withdrawn and both parties will not make any such further complaints.

Furthermore, if there is any complaint or petition pending against each other that shall

be treated as void.

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A18] The SECOND PARTY and the FIRST PARTY shall co-operate with each other in all ways

for obtaining the decree of divorce by mutual consent from the Court of Law.

A19] That both the parties i.e. the SECOND PARTY and FIRST PARTY are mature and fully

understands the terms of the present compromise and settlement deed and hereby

declare that they have obtained independent legal advise from their respective counsels

and they are presenting and executing the present settlement and compromised deed

with free will and volition.

A20] That in case of quashing of criminal proceedings filed by FIRST PARTY, the SECOND

PARTY shall not oppose quashing thereof and will co-operate by being present before the

Honble Court at all time when hearing will take place to give necessary statements for

quashing the F.I.R./criminal proceedings. That parties shall remain bound by the

statements and will not wriggle from their statements and undertakings under any

circumstances whatsoever and also will bound by their statements and will not wriggle

out with regard to giving up their claim with regard to any past, present or future

maintenance against each other. Both the parties undertake that they shall adhere to

the terms of compromise/ settlement deed and that they shall not litigate in future and

have no claim against each other whatsoever in past, present and in future.

A22] That Four sets of the present settlement and compromise

deed are being prepared in original for being kept by each party and their

respective counsel.

AND in view of the settlement deed and the averment made herein and the

amount agreed to be paid by the First Party to the Second party, they will not

claim any present, past or future maintenance or have any claim from the First

Party under any circumstances whatsoever.

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Both the parties further aver that the aforesaid statements and contents are true to the

knowledge of both the parties and nothing material is concealed there from and

there is no collusion whatsoever between the parties and the present petition is

filed with free will and consent and without any coercion undue influence or

threat from anybody and without being influenced by each other.

IN WITNESS WHEREOF the parties here to have appended their signatures on this

agreement on the day, month and year first before written in the presence of the
following witnesses.

First Party Second Party

_________ _________

WITNESSES

1.Signature: 1. Signature:

Name: Name:

Address: Address:

2.Signature: 2. Signature:

Name: Name:

Address: Address:

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3.Signature: 3.Signature:

Name: Name:

Address: Address: