District:
South 24 parganas
IN
THE COURT OF THE LEARNED DISTRICT JUDGE
AT ALIPORE
Matrimonial
suit no. Of 2014
In the matter of:
An
application under section 28 of the Special
Marriage act, 1954.
AND
In the matter of:
SOUMYA GHOSH
Son of Swapan
Ghosh
Residing at Ghosh Para,
Shyampur,
P.S. Maheshtala
Kolkata-700137
……………. PetitionerNo.1/Husband
-Versus-
BABY GHOSH (Das)
Wife of
Soumya Ghosh
Daughter of Kartick Das
Residing at
Kolkata-
……………. PetitionerNo.2 /Wife
The Humble petition
on behalf of the above
named
Petitioner/Husband.
Most Respectfully Sheweth:-
1.
That your
petitioners are the husband and wife by relation and they are the bonafide
citizen of India.
2.
That the marriage
in between your petitioner no.1 and petitioner no.2 was solemnized on 22th
December 2010 by the Special Marriage Act, 1954 by Md.Rabiul Islam Molla,
Marriage Registrar and on the same a social ceremony also took place at
petitioner no.2/wife’s house i.e.
The xerox copy of the marriage Certificate is annexed
herewith as annexure – ‘A’
3. That after the petitioner no.1 and
petitioner no.2 were lived together as husband and wife at petitioner’s no.1
house i.e. Ghosh Para, Shyampur, P.S. Maheshtala, Kolkata-700137,District-24
Parganas(South) and the said marriage was consumated there.
4. That the petitioner no.1 and
petitioner no.2 got married on 22.12.2010 and got separated on 12/03/2013 and till they said separation
continuing. They do not have any issue in their relationship.
5. That after marriage, as the day
passed, there were differences in tempermant, habits, tastes, thoughts, ideas,
ideologies etc. Frequent quarrels were
going on every- day. Several reconciliation from friends, parents, did not work
out.
6. That after a very serious quarrel and
in order to avoid further deterioration in relationship both of them willfully
agreed to be mutually separated. So they are living separately since March,
2013 and decided to be separated forever by way of mutual Divorce.
7. That your petitioners tried their
best and even some well-wishers of both of the petitioner tried their best to reconcile
the matter but all the efforts were in vain.
8. That it should be mentioned here that
there is no issue of the parties out of their wedlock and there is no demand of
any shorts of things against each other at present or never will grow in future.
9. That the cause of action arose on
12/03/2013 i.e. the date of separation of the house of petitioner no.1 under
P.S.Maheshtala, Kolkata-700137, District- South 24 Parganas from each other.
10.
That there is no demand on further demand
against each other in any manner.
11.
That there is no collusion on connivance in
between the parties in respect of subject of this proceeding.
12.
That there is no chance of their re-union.
Yours petitioners therefore pray before
Honour to pass a Decree of dissolution
of marriage by mutual consent U/S 28 of
Special Marriage Act, 1954 and further and other
order or orders as your Honur may deem fit and
proper for the ends of
justice.
And for this act of kindness, as your
petitioner in duty bound, shall over pray.
VERIFICATION
I, SOUMYA GHOSH the petitioner no.1/
husband do hereby declare that the statements made in the foregoing paragraphs
are true to my knowledge and belief and I sign this verification this the day of , 2014.
VERIFICATION
I, BABY GHOSH (Das) the petitioner
no.2/ wife do hereby declare that the statements made in the foregoing
paragraphs are true to my knowledge and belief and I sign this verification
this the day of , 2014.
AFFIDAVIT
I, SOUMYA GHOSH son of Swapan Ghosh ,
aged about 36 years, by faith- Hindu, by occupation- Service, residing at Ghosh
Para, Shyampur, P.S. Maheshtala, Kolkata-700137, District- Soth 24 Parganas , do
hereby solemnly affirm and declare as follows :-
1.
That
I am the petitioner no.1/ husband of the instant application and am well
conversant with the facts and circumstances of this petition.
This is true to my knowledge.
2.
That
the statements made in the foregoing paragraphs nos. 1 to 12 are all true to my
knowledge and belief and the rest thereof are my humble submission before this
learned Court.
-----------------------------
DEPONENT
Read over, explained in Bengali
and Identified by me.
Advocate
AFFIDAVIT
I, BABY GHOSH (Das) wife of Soumya Ghosh ,
daughter of Kartick Das,aged about
years, by faith- Hindu, by occupation- House wife, residing at Ghosh
Para, Shyampur, P.S. Maheshtala, Kolkata-700137, District- Soth 24 Parganas , do
hereby solemnly affirm and declare as follows :-
1.
That
I am the petitioner no.2/ wife of the instant application and am well
conversant with the facts and circumstances of this petition.
This is true to my knowledge.
2.
That
the statements made in the foregoing paragraphs nos. 1 to 12 are all true to my
knowledge and belief and the rest thereof are my humble submission before this
learned Court.
-----------------------------
DEPONENT
Read over, explained in Bengali
and Identified by me.
Advocate
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