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1.

That after the marriage, the parties could not pull on well owing to various differences and temperamental
incompatibility, and have decided to live separately from each other for more than 2 year i.e from X1 st Aug
20XX till today and both are staying separately in their respective parental homes. There is no chance of
reconciliation of marriage between the parties or resumption of normal marital relationship in future. The well
wishers, friends, relatives and elders of both the families tried to reconcile the relation between the parties but
all attempts went to vain

2. That the present petition is being preferred by the petitioners seeking dissolution of their
marriage by mutual consent. That the petitioner No. 1 is working as ____ and petitioner
no. 2 is working as _______ . The marriage of petitioners was solemnized on ____
according to Hindu rites at _____ . The certificate issued by the Registrar of Marriages
__________ and the joint affidavit of the petitioners is annexed with this petition. There
is one girl child out of this wed lock. She is major, aged ______ .
3.

4. That the parties since have realized that it will be futile to continue the marital relationship, as such have
decided to file instant application praying for a Decree of Divorce on mutual consent on the following terms
and conditions

a. That any other complaint / all other complaints / cases filled by party of the First Part against party
of the second part and his family members shall be treated as withdrawn / closed.
b. That it has been further mutually agreed that both the parties are hereby applying before District
and Session court at Pune for Decree of Dissolution of Marriage by mutual consent and complete
all the formalities till the final order of Decree of Dissolution of Marriage by mutual consent.
c. That both the Parties shall assist each other in prudently pursuing the petition for dissolution of
marriage by mutual consent and shall appear in the concerned Court as and when necessary and
required to record necessary statements as per law in getting the decree of Divorce by mutual
consent.
d. 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 / agreement will be liable
for legal action.
e. That this compromise / agreement is being executed voluntarily and with mutual consent without
any Fear, Pressure, Force, Fraud, Undue Influence, Coercion in the presence of members of the
family / relative.
f. That the parties have now decided to dissolve the marriage legally through a decree of divorce on
mutual consent. The parties have settled all their claims, counter claims etc. and the respondent
wife has received her entire Stridhan, Permanent alimony, maintenance etc. and there is no due
with regard to any other claim between the parties now.

g. that the petitioner no 1 will get and retain the bank accounts which are in joint
names and will be sole holder of the amounts lying in those accounts
h. That the petitioner no 1 will get and retain all the household goods and
furnishings and petitioner no 2 will have no right or entitlement in those goods
and furnishings

5. On XX/XX/2011 both petitioner started living separate and there is no matrimonial relationship between
them, from XX/XX/2011both petitioner not sharing any house or not in any kind of husband and wife
relationship.
6. That the above petition is bona fide and not presented in collusion between the parties.
7. That all the efforts of reconciliation between the parties to continue the present marriage has failed and there
are no further chances of reconciliation between the parties any more
8. That the party has decided to withdraw all the complaints, counter complaints against each other
9. That the present petition is not being filed in collusion.
10. That there are no legal impediments in grant of the decree of divorce to the parties on the
basis of mutual consent.
11. That there is no legal impediment for which relief prayed for should not be granted to the
parties.
12.

That after solemnization of marriage, the petitioners lived together as husband and wife at Chandigarh.
Unfortunately, after marriage, they both realized that there are serious differences in their attitude and
living style, which created no compatibility. Consequently, both the parties to the petition parted their
company from each other since ____ DATE _______ (minimum separation to show – one year and a few
months before filing of petition

The parties have mutually settled their disputes regarding all the stridhan, maintenance,
permanent alimony and all other matters.and also have agreed on following terms and
conditions

A. That petitioner no 1 will get and retain the present flat (MY PRESENT ADDRESS)
and petitioner no 2 will have no right title intrest possession inheritance succession
or claim over this property and future earning of the wife i.e. petitioner no 1. forfeits
all his claim against petitioner no 1. towards full and final settlement .There is no
past, present or future claim against each other.The flat mentioned above so
received by petitioner no 1, forfeits all her claim against the husband.and is towards
full and final settlement of permanent alimony.

That both the petitioner nos. 1 and 2 will not claim any type of maintenance or any
right upon the property of each other or in-laws in future

That, Petitioner no. 1 has no right, title, interest, possession, inheritance, succession
or claim over the immovable properties and future earnings of the husband. and
forfeits all her claim against petitioner no. 2 towards full and final settlement .There is
no past, present or future claim against each other
that petitioner no 2 will not be entitled to claim any Maintenance from petitioner no 1 and
will earn for himself

That both the petitioner nos. 1 and 2 undertake not to file any civil or criminal case
including maintenance proceedings against each other.
that these conditions are towards full and final settlement of permanent alimony.There is
no past, present or future claim against each other.and none of the both parties will
subsequently make any claim for maintenance , rights of reisdence etc .

That except as hereunder stated there were no other proceedings between parties.
The consent has not been given by either party by fear, force, fraud, coercion or undue
influence

That, as prayed in application filed under section 151 CPC the period of six months for
moving second motion under section 13-B (2) of the Hindu Marriage Act may be waived
off condoned in the circumstances of the case.

did not pull together being of different ideas,habits, testes, thoughts and increasing
incompatibility

not to claim for any maintenance alimonyeither for her or for the girl child from her husband,
that is, theSecond Petitioner

That, both the petitioners states that there is no impediment to the dissolution of the
marriage.

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