IN THE COURT OF HON’BLE CIVIL JUDGE
DISTRICT COURT
(NAME OF PLACE)
CASE NO. _________/______________
Smt._____________________(Name),
Daughter of________(Father’s Name),
Wife of Shri ______(Husband’s Name),
Aged_____________________(Years),
Residing of _____________(Address),
………………….PETITIONER
VERSUS
Shri._____________________(Name),
Son of ____________(Father’s Name),
Aged_____________________(Years),
Resident of ______________(Address),
Carrying on_____________ (Business),
…………………RESPONDENT
OBJECTION RAISED ON BEHALF OF PETITIONER
Most respectfully submitted-
Preliminary Objections:
- Admitted the fact of marriage of petitioner and respondent on (__/__/____) in _______________ (name of the place). (If the fact of marriage and date/ place are true).
- Here in point no. (2), the petitioner objects the respondent here, is trying to get away from his words, respondent never informed me that he was going abroad for his studies and the petitioner comes to know about it by one of the respondent’s friend, so here the fact is very clear that he wants to leave her wife and went abroad and started leaving thereitself.
- In point no. (3), the petitioner objects points stated where the respondent talks about that he was trying to contact the petitioner, but her number changed, so here the respondent can make a call to any family member as everyone was worried about the respondent and he not even try to contact the family members at landline number, and as the respondent left away from the petitioner fir the period of 23 years, thus it is a valid point to take a divorce from the respondent, as it becomes a very clear issue for the ground of divorce.
- In point no. (4) Of the written statement drawn from the side of the respondent talks about that the other wife was already having her children before the marriage, but was not having any proof? Thus, Adultery proved by unrebuttable evidence is a ground for divorce and where the circumstantial evidence does not denote to what the respondent is filing the written statement.
VERIFICATION
I,___________________, the Petitioner above named, do hereby solemnly declare and say that what is mentioned in paragraph ___ to __is true to my knowledge and that what is contained in paragraph ____ to _____ is stated on legal advice and I believe the same to be true.
Day of ______ (year)
Before me,
Sd/-
Registrar/Superintendent,
AFFIDAVIT
BEFORE THE HON’BLE DISTRICT COURT OF (NAME OF THE PLACE)
BENCH AT (NAME OF THE PLACE)
Petitioner:____________________________ (Name)
Versus
Respondent:____________________________(Name)
- That I am the petitioner in the present case and I am well conversant with the facts and circumstances of the case, hence competent to file this affidavit.
- That, I am filing an application under Section 13 of the Hindu Marriage Act, 1956 and the Family Court Act 1954 on the ground of committing Adultery before this Hon’ble Court. The contents of the application have been read over, translated and explained to me in Hindi and in English also. The content of the application related to the facts are true from my personal knowledge and that related to law are true to the information received by me from my advocate, which I believe to be true and this affidavit is sworn in support thereof. Nothing contained therein is false and nothing has been concealed.
Place: __________________
(Signature)
Date: __/__/____
Deponent
VERIFICATION
I solemnly affirm that what is stated above is true from my personal knowledge, nothing contained herein is false and nothing has been concealed.
Verified by me on (__/__/____)
Place:____________________
(Signature)
Date:__/__/_____
Deponent
Identified by
(Signature)
(Name of the Advocate)
