In the court of learned District Judge,

Ferozepur.

Sourab Arora aged 3_ years son of Shri

Surinder Kumar Arora, resident of 266, Gali
no.2, Kundan Nagar, Ferozepur City.
Petitioner.
Versus
Karamjeet Kaur wife of Sourab Arora and
daughter Maan resident of village Redwan
Tehsil Shahkot, District Jallandhar.
Respondent
Petition under section 13 of Hindu
Marriage Act for dissolution of
marriage of the petitioner and
respondent by decree of divorce.
**
Sir,
The petitioner submits as under:-
1. That a marriage had taken place between
the petitioner and respondent on 16.4.2017 at
village Rewaran according to Sikh Rites in the
presence of common relatives of both the
parties. An Affidavit of the petitioner, duly
attested in this regard is attached herewith.
 2. That the status and place of residence
of the parties before the marriage and at
the time of filing of the petition were as
follows:
HUSBAND WIFE
Status Place Status Place
of of
Residen Residen
ce ce
Before Unmarri Ferozep Before Unmarri Redwan
marriag ed ur City marriag ed
e e
At the Married Do At the Married Do
time of time of
filing filing
the the
petitio petitio
n n

3. That the marriage of the petitioner with

the respondent was very simple marriage and no
dowry was given or taken in the said marriage
as both the parties are handicapped and met
each other as per mercy of God. Both the
parties are from different caste as the
respondent belongs to Majbi Sikh family wereas
the petitioner belongs to Arora
family. However after the marriage, the
petitioner and his family engaged one family
function in Harish Hotel in Ferozepur City
where the relatives and both the parties
joined the said party.

4.That the marriage between the parties was

solemnized through mediator namely Goyal Sahab
and thereafter the roka ceremony was fixed for
16.4.2017 but the respondent and her parents
compelled to solemnize the marriage on
16.4.2017 and only two sisters of petitioner
alongwith his mother joined the said marriage.

5.That after the marriage, the parties lived

together and co-habited with each other as
wife and husband and out of this wed-lock, the
respondent conceived one child on 20.5.2017
but later on she aborted the same without the
consent of the petitioner. The copy of the
report issued by Radhey Radhey Welfare Society
Ferozepur dated 20.5.2017 is enclosed
herewith.

6. That the respondent, after the

solemnization of marriage, treated the
petitioner with legal, mental and physical
cruelty, which has caused a reasonable
apprehension in the mind of the petitioner
that it will be harmful and injurious for him
to reside with the respondent.
7. It is worth to submit here that the
respondent is lady of hot temperaments,
nagging attitude and never ready to hear
proper advice. The petitioner is deaf and dumb
whereas the respondent is handicapped from
right leg (Polio affected). During the stay of
the respondent with the petitioner after the
marriage, she never paid any respect to the
petitioner and his family members and has also
not performed the duties of wife. The behavior
and attitude of the respondent was totally
changed and she used to treat the petitioner
like a slave and always gave taunts.

8. The petitioner and his mother tried to

persuade the respondent several times, not to
illtreat the petitioner but the respondent
used to insult the petitioner and his mother
and relatives. The father of the petitioner
had already died long back. The mother of the
petitioner retired as a Vice Principal from
Kendriya Vidyalya. She is a pensioner and has
very ordinary style of living and carries
immense respect in society.

9. The respondent is in the habit of leaving

the matrimonial house frequently and spent
days together in her parental house or outside
and whenever the petitioner objected to the
same, she created scene in the family. The
petitioner is studied upto 6th standard whereas
the respondent is studied upto 10th class and
know the work of stiching etc. and she also
possess course from Government institute of
School of stiching in village. The petitioner,
is also trained in tailoring. The mother of
the petitioner knowing this skill of
petitioner and respondent, invested her meagre
savings and opened stiching centre for them in
the name of Sourab Boutique in Ferozepur City
for the betterment of both the parties where
petitioner used to sit with respondent. She
desserted both the Boutique and the
petitioner, there by wasting all the meagre
savings the poor mother of the petitioner had,
further aggrevating the misery of the family
of the petitioner.
The respondent has now left the society
of the petitioner on 13.7.2017 alongwith her
sister.

10.That the marriage is based on love and

trust between the parties and the
respondent has totally broken the same and
there is complete love lost between both the
parties and now there is no chance of their
re-habilitation and marriage between the
petitioner with the respondent has
irretrievably broken down. The marriage has
caused the illeffects on the health, economic
condition, lifestyle and mental condition of
the petitioner and any further continuation
may cost petitioner his life. The petitioner
is continuosly facing the barbs in society and
anecdotes like “ISKI BIWI BHAAG GAYI”, “YE
IMPOTENT HOGA” etc. Though petitioner is
hearing impaired but is sound enough to
understand these words which is further adding
to his mental agony. The parties to the
petition are not in matrimonial relations.
The marriage is irretrievably
broken down and the mental peace of the
petitioner has always remained disturbed as a
result of abnormal behavior of the respondent.
The petitioner had thus suffered grave mental
pain, agony, which has made impossible for him
to live with respondent. The feeling of deep
anguish, disappointment, frustration always
remain in the mind of the petitioner that he
infact is left with no desire to live with the
respondent and have thus decided to get her
marriage dissolved.
That due to abovesaid facts and
circumstances, the respondent is guilty of
cruelty. Now there is complete love lost
between the parties. The petitioner also
convened several panchayat in order to re-
habilitate the matter, but the respondent
refused to join the company of the petitioner.
The petitioner is thus entitled to decree of
divorce.

9.That the petitioner has not connived at or

condoned the acts of cruelty of the respondent
and his parents. The respondent also deserted
the petitioner for continuous period of more
than 2 years.

10.That the petition is not presented in

collusion with the respondent.

11.That there has not been any unnecessary or

improper delay in filing this petition.

12.That there is no other legal ground why

the relief should not be granted.

13.That there is no other litigation pending

between the parties so far.

14.That the marriage between the parties took

place at _________________within the local
limits of the ordinary original Civil
Jurisdiction of this Hon'ble court and as
such this Hon'ble court has got the
territorial jurisdiction to entertain
, try and decide the present petition.

P R A Y E R

It is most respectfully prayed that the court

may accept the present petition and grant a
decree of divorce between the parties thereby,
dissolving the marriage between the parties
Submitted by:-
 Sourab Arora son of Shri Surinder
Kumar Arora, resident of 266, Gali
no.2, Kundan Nagar, Ferozepur City.
Petitioner.
Through counsel
Naveen Puri Advocate
Verification
Verified that the contents of the petition are
true and correct to the best of my knowledge
and belief.
Verified at Ferozeupr on Petitioner