District : South 24 Parganas
In the Court of the Learned
Additional District Judge, Baruipur, South 24 Parganas
Mat Suit no. of 2024
In
the matter of :
Alokparna
Debnath, Wife of Sriraj Goswami, Daughter of Late Subimal Debnath, aged about
33 years, residing at Sunny Dew Complex, Premises being No. 971, Majumdar Para,
Phase – 2, Block 2, 3F, Garia, Police Station Narendrapur, Kolkata – 700084,
Mobile Number : 7980957487, Email : pupundebnath78@gmail.com
_______Petitioner
-
Versus –
Sriraj
Goswami, Son of Late Gautam Goswami, aged about 35 years, residing at Manick
Chand Apartment, Premises being No. 74A, Pratap Enclave, Mohan Garden, 4th
Floor (Middle), Uttam Nagar, New Delhi – 110059, Mobile Number 9123060017,
Email : raj.kolkata.007@gmail.com
__________Respondent
/ Opposite Party
An application for Decree of Divorce
under Section 13(1)(ia) of the Hindu Marriage Act’ 1955;
The
humble petition of the petitioner Alokparna Debnath, most respectfully;
Sheweth as under:
1.
That the Petitioner is a peace loving
and law abiding Citizen of the Country, presently residing at the address given
in the cause title of this application.
2.
That the petitioner marriage was
solemnized on 12th day of October’ 2023, with the opposite party
Sriraj Goswami, at the time of marriage the petitioner and the opposite party
were major and able to give consent for the marriage. The said marriage was
performed in terms of the rituals and customs prevailing under Hindu Marriage.
The said marriage was arranged marriage, occurred at the intervention of the
family members of the petitioner as well as family members of the opposite
party. The marriage was solemnized on Social arrangement in presence of the
family, friends, and relatives. The said marriage happened and taken recourses
of solemnization of the said marriage while in the month of July’ 2023, the
petitioner came across of the said opposite party Sriraj Goswami on Social
media platform i.e. Facebook, who introduced himself as he used to reside in
Delhi having his own flat in Uttam Nagar Area in Delhi, he is a divorcee, and
worked in an IT Company, as a Team Leader, and thereafter in a few days, he
allured the petitioner for marry. The Petitioner was divorcee and therefore
find substance in representation on the opposite party Sriraj Goswami. The
marriage was subsequently registered on 29-10-2023, before the Marriage Officer
Paresh Chandra Mondal, having his Office at Tegharia, Sarada Park, Narendrapur
Station Road, Police Station Narendrapur, Post Office – R.K. Pally, Kolkata –
700150, District South 24 Parganas. The Certificate of Marriage under Schedule
“C’, in terms of Sub-Section (1) of Section 8 of the Hindu Marriage Act, 1955,
being Certificate No. WB343004000102000021205-2023-149590, dated 29-10-2023,
has been given by the said Marriage Officer Paresh Chandra Mondal, which
certify the marriage between the petitioner and the opposite party dule
solemnized in presence of the Sister-in-law Reshma Goswami Panda, having his
residence near Cinema Holl, NSB Road, Post Office – Pandaveswar, Pin – 713346,
Police Station – Pandaveswar, Mother-in-law Papiya Goswami, having her place of
abode the then at Panchmahli, Post Office – Kumardhubi, Pin – 828203, Police
Station – Chirkunda, and the petitioner’s Mother Manashi Debnath, having her
place of residence at BL 1 FL 3E, 971, Majumder Para, Post Office – Garia, Pin
– 700084, Police Station – Narendrapur, District South 24 Parganas.
3.
That the Opposite party Sriraj Goswami
represented about his family comprising of his married sister Reshma Goswami
Panda, who staying at her matrimonial home at Durgapur, West Bengal, his mother
Papiya Goswami, was a School Teacher and then residing at Kumardihi, Maithan,
Jharkhand, in course of her duty. His mother retired in the month of September’
2024 and thereafter She will join him at Delhi residence and will continue to
stay there with him. The petitioner communicated such representation of the
opposite party to her mother Manashi Debnath and asked for arrangement of her
marriage with the opposite party.
4.
That the Petitioner’s mother Manashi
Debnath was not favouring such marriage as she did not see the said opposite
party Sriraj Goswami, however on insisted upon by the petitioner for marriage
with the opposite party, she arranged a visit to Delhi to meet with the
opposite party Sriraj Goswami and to enquire about him, the preliminary aspects
and facts necessary for marriage of the petitioner with the opposite party.
5.
That the petitioner’s mother while
visited Delhi along with the petitioner at the flat of the opposite party and
meeting with him, the opposite party produced a Xerox copy of Deed of
Conveyance in regard to the Flat at Delhi and told that the Original Copy of
the Deed of Conveyance is laying with the Bank as the said Flat has been
acquired on Bank Finance, and the opposite party shown a pay-slip which
described as Sriraj Goswami is getting Salary of Rs. 40,000/- (Rupees Forty
Thousand) only. The opposite party Sriraj Goswami demanded Rs. 25,00,000/-
(Rupees Twenty Five Lakhs) only, from the petitioner’s mother being
pre-requisition of the marriage with the petitioner, as he is bearing Rs.
26,000/- (Rupees Twenty Six Thousand) only, per month EMI towards Housing Loan,
therefore he was not able to run his family.
6.
That However, as the petitioner was
bent upon to marry the opposite party Sriraj Goswami, the petitioner’s mother
agreed to give a sum of Rs. 15,00,000/- (Rupees Fifteen Lakhs) only to the
opposite party Sriraj Goswami, under compelling situations.
7.
That thereafter, the opposite party’s
married sister, her husband and other relatives visited the premises of the
petitioner and having lunch and conversation about the marriage to which they
agreed happily; But on the said visit the petitioner came to know that the
opposite party have one female child from his first wife, which he did not
disclose about to the petitioner. As the petitioner made up her mind to marry
the opposite party. She did not give any importance to such aspect.
8.
That after few days, the opposite
party told the petitioner that his one brother (Son of his Mashi) who residing
at Chandigarh wanted to visit Kolkata and he did not have money for Air Ticket,
which the petitioner arranged, at the cost about Rs. 12,000/- (Rupees Twelve
Thousand) only. The petitioner’s mother was not in any knowledge of such
arrangement of the said Air Ticket incurred by the petitioner for the opposite
party.
9.
That the opposite party also demanded
for Diamond Ring, Blezzer and Titan Watch, at the time of marriage and the
arrangement of staying with foods to all his relatives at the marriage for few
days at Durgapur, where his sister’s matrimonial home abode.
10.
That the marriage between the petitioner and the
opposite party has been solemnized in terms of the Hindu
rituals, on 12th
day
of
October'
2023, at Venue at Kolkata. The marriage solemnized
in presence of friends, relatives, and family
members. After solemnization of marriage, the opposite party Sriraj Goswami take
the petitioner with him at Durgapur on 13th day
of October’ 2023, as his mother's “manat” at Kalyaneshwari
Mandir at
Kulti. The
opposite party Sriraj Goswami and his
family member
did not even arrange “Bou-Bhat” Ceremony at
Durgapur. On 15th
day of
October'
2023,
the opposite party Sriraj Goswami, the
petitioner and her mother in law visited “mandir”. On 17th day of
October'
2023, the
opposite party along with the petitioner and her mother in law back to
Kolkata at
the petitioner’s house. Thereafter on 22nd day of
October'
2023, the opposite party Sriraj Goswami take the
petitioner for Honeymoon at Kerala. On
29th day
of October' 2023, the opposite party and the petitioner back
to Kolkata and
their
marriage has been registered under the Hindu Marriage
Act’ 1955 On 31st October' 2023, thereafter
the opposite party Sriraj Goswami accompany the petitioner with him
for
Asansol,
West Bengal to visit his “mashi
bari” and thereafter on 1st day of
November'
2023, the opposite party along with the petitioner departed for Delhi through Train
from “Asansol”,
with his mother. On 2nd
day of
November' 2023, the petitioner reached Delhi,
with the
opposite party Sriraj Goswami and her mother-in-law.
11.
That the petitioner on reaching
her matrimonial home at Delhi, She tried to
accommodate with the opposite party Sriraj Goswami and her
mother-in-law. The
opposite party Sriraj Goswami compelled the petitioner to
do all house hold work started from early morning
to late night. Her
mother-in-law did
not assist even a little bit in such house
hold work to the petitioner. The opposite party Sriraj Goswami did not allow the
petitioner to go outside the
flat. The
opposite party Sriraj Goswami did not allow the petitioner to have
conversation with any neighbor at
the said premises.
The petitioner is a non-vegetarian therefore she
asked for
Chicken
and fish,
which the opposite party Sriraj Goswami and her mother in
law
refused to give and did not arrange for the same as they all along insisted to
take vegetarian meal only. They insisted the
petitioner to wash clothes by hand only insist of having Washing Machine at
their home. The opposite party Sriraj Goswami
did
not take the
petitioner to tour Delhi even.
While the petitioner asked for any assistance in house
hold
work,
the opposite party Sriraj Goswami used to beaten up
the petitioner following abusive languages, and her
mother-in-law did
not raise any voice to that rather silently supported to
the opposite party Sriraj Goswami.
12.
That on one day, the opposite party Sriraj
Goswami’s brother who reside in
Chandigarh,
visited the
matrimonial
home of the petitioner at Delhi, the petitioner was
asked to
cooked food for him also. While
the petitioner cooked food the pressure cooker burst and her
hand burnt
and
therefore the petitioner suffered a
lot with burn
injury, at her hand which no one did care rather the petitioner
was asked
to arrange for the dinner at restaurant. That was the
first
occasion while the petitioner was at
outside from
the flat of
the opposite party Sriraj Goswami in Delhi. The Cost of
the
dinner was also paid by the petitioner from taking
money from her mother.
13.
That on 19th day of
December'
2023, the petitioner came back to
Kolkata
as her
mother
health was not good. On 21st December' 2023, the petitioner
attended “Annaprasan” Ceremony of one of
the relative of
the opposite party Sriraj Goswami at Behala. The
petitioner continued to be
in Kolkata.
On 11th day of January' 2024,
the petitioner was suffering from Typhoid for three weeks
and more;
But the opposite party Sriraj Goswami did not visit
Kolkata and did not bear any cost and expenses of
the medical
treatment, medicine, etc. However, the petitioner on
her own endavour
recover herself
with due care
and bearing of cost and expenses of medical
treatment, medicine,
etc. by
her old aged
ailing mother.
14.
That the opposite party Sriraj Goswami intimated the
petitioner that he opened a
Restaurant
in
Uttam Nagar in Delhi, namely “Raj
Food Center”, and asked for Rs. 30,00,000/-
(Rupees
Thirty Lakhs) only for working Capital in
running the said
Restaurant.
15.
That the opposite party Sriraj Goswami also
told that he opened the said Restaurant with the help of
his said Mashi’s Son namely Joy Roy.
16.
That the petitioner told the
opposite party that her mother do
not have that much of money,
as the
acquired saved money by
her late father has already been given to him,
the said
sum of
Rs.
15,00,000/- (Rupees Fifteen Lakhs)
only. Her mother
is
a house wife
and do
not have
any source of income. She is dependent on little
savings of her late father. The petitioner expressed her
inability in providing such huge demand of
the opposite party Sriraj Goswami.
17.
That the opposite party Sriraj Goswami used
most abusive languages and shouted on the petitioner, on every
next day and asked for money, also threatened
the
petitioner that unless the petitioner give him such demanded
money,
he will not take her at his house. The opposite party Sriraj
Goswami Continuously
insisted
the petitioner for demanded money.
Still the petitioner is suffering mentally towards demand of
money by
the opposite party Sriraj Goswami and her mother-in-law
did not take care
of
such unlawful demand of the opposite party Sriraj
Goswami.
18.
That in the given facts, the
petitioner is a victim of Domestic Violence and the
opposite party being her greedy husband for money.
The petitioner is still suffering from continuous mental torture
for money and the victim of physical torture at Delhi, at the
behest of the opposite party Sriraj Goswami and her mother-in-law. The
petitioner is in need of protection from such domestic violence, mental
and physical
torture. The
dreams of peaceful
happily matrimonial life of the petitioner have been
shuttered at the behest of the opposite party
Sriraj Goswami and her Mother-in-Law.
19.
That the “Stridhan Articles”
of the petitioner, which are as follows, has not been
given to
her yet, by
the opposite party Sriraj Goswami, and her mother-in-law;
1)
Gold Necklace,
(Two pieces);
2)
Gold
designed pola, (One piece);
3)
Gold
earring, (One pair);
4)
Gold
Green Topset, (One piece);
5)
Dinner Set;
6) Glass
Set;
7)
Foldable
Cloth Organizer;
8)
Selfie Stand;
9)
Cloth
hanging Stand;
10) Two Wall
Hanging
Show piece;
11) Door
hanging toran;
12) Wind
chimes;
13) Several
useable Cloths of mine;
14) Shoes;
15) Original
Passport;
20.
That after few days of the marriage,
the opposite party took custody of all gold ornaments of the petitioner. The
petitioner was not allowed use her personal belonging without the permission of
the opposite party, and the keys of the almirah was taken by the opposite
party.
21.
That the opposite party made the life
of the petitioner a living hell as she was deprived of food, cloth and the
things which are required for day to day uses for the petitioner. The opposite
party forced the petitioner to do all the household work at the matrimonial
house, by removing the maid after marriage. The opposite party treated the
petitioner as a maid for his house and forcibly against her wish compelled to
do all household work including caring of her in-laws. The opposite party
retrenched the maid from her service at in-laws house of the petitioner.
22.
That the petitioner silently did all
the household work, including the command of the opposite party on her, but
still then the opposite party expressed his discomfort and used to perpetrate
immense physical and mental torture upon her if she made any little mistake in
her doing, so far.
23.
That the petitioner being a pious
Hindu lady, take all torture of the opposite party in a hope that a good sense
will prevail on him, and certainly one day the opposite party will behave
fairly.
24.
That the opposite party used to return
at home in drunken condition, and on being asked by the petitioner, he used to
beaten up the petitioner by using most filthy languages. The opposite party did
not stop his activities and continued. The petitioner became victim of beating
up by the opposite party not only in four wall of the matrimonial home, but
also in front of friends and relatives of in-laws, while they used to visit the
matrimonial house of the petitioner. The petitioner was subjected to insult and
physical torture by the opposite party in house and in front of his friends and
relatives.
25.
That the petitioner off and on tried
to make understand the opposite party about the performance married obligation
and duty and peaceful living; But this is the opposite party who all along
refused to take such understanding and continued in his own way, which is not
acceptable at any terms, though the petitioner tried to keep the sacrament of
marriage.
26.
That the opposite party used to earn
more than Rs. 2,00,000/- (Rupees Two Lakhs) only, per month as seen by the
petitioner from the Restaurant at Delhi. The opposite party did not disclose
the sources of his said earning. On being asked by the petitioner, the opposite
party did not response, and changed the topic of conversation at that point of
time, with the petitioner. Thus the petitioner is not in appropriate knowledge
about the exact quantum of his earning.
27.
That the opposite party Sriraj Goswami
since inception of the solemnization of marriage demanded money for doing his
business and running family needs from the petitioner and started inflicting
torture on the petitioner to bring money from her old aged ailing mother. The
petitioner’s mother has been given a sum of Rs. 15,00,000/- (Rupees Fifteen
Lakhs) only, at the time of marriage of the opposite party and the petitioner.
The opposite party Sriraj Goswami tendered the cost of honeymoon from the said
money taken from the mother of the petitioner. The opposite party Sriraj
Goswami started the Restaurant at Delhi from the said money given by the mother
of the petitioner. Though the opposite party again asked for a sum of money
being Rs. 30,00,000/- (Rupees Thirty Lakhs) only, from the petitioner.
Pertinently, the opposite party Sriraj Goswami demanded off and on money from
the petitioner and he even did not bear the cost of the dinner at restaurant at
Delhi, which the petitioner paid by taking money from her old aged ailing
mother. The opposite party Sriraj Goswami all along focused in taking money by
this and that way from the petitioner, and he did not care the petitioner on
any aspects of the matrimonial life and it’s recourses, thereof.
28.
That even after, taking money being a
sum of Rs. 15,00,000/- (Rupees Fifteen Lakhs) only, from the petitioner the
opposite party did not stop his torture on the petitioner. The opposite party
used most filthy languages in the name of the mother of the petitioner and her
other relatives, and used to beaten up the petitioner very frequently.
29.
That the opposite party all along
tried to take financial assistance from the petitioner. The opposite party
instigated his family members to inflict torture on the petitioner in pursuance
to obtain financial assistance from the petitioner.
30.
That the opposite party did not stop
his torture on the petitioner and continued in much aggravated manner, subsequently,
the opposite party did not take the petitioner to her matrimonial home at
Delhi. Such fact has been informed by the petitioner to the Narendrapur Police
Station, by way of Letter of Complaint dated 19th day of July’ 2024,
given by Post.
31.
That the Narendrapur Police Station
did not start any investigation on the receipt of the complaint of the
petitioner. Such an in action of the Narendrapur Police Station give indulgence
to the opposite party Sriraj Goswami, who continued in inflicting mental
torture over phone to the petitioner. The Opposite party Sriraj Goswami and the
mother-in-law of the petitioner even did not give the Stridah article to the
petitioner. The Opposite party did not take any endavour to take the petitioner
at her matrimonial home at Delhi. The Opposite party Sriraj Goswami put demand
of money for a sum of Rs. 30 Lakhs from the petitioner and told that while the
petitioner will give such money to the opposite party, the opposite party
Sriraj Goswami will take the petitioner at her matrimonial home at Delhi to
join the matrimonial tie with the opposite party. The continuous cause of the
opposite party Sriraj Goswami in pursuing money from the petitioner started
since inception of the marriage and now for joining the matrimonial home at
Delhi, compelled much in derogative situation to the petitioner to stay herself
at her mother’s house in the district South 24 Parganas, which fall under the
territorial jurisdiction of the Learned Court.
32.
That Since the 19th day of
December’ 2023, the petitioner is staying at her parental house at Sunny Dew
Complex, Premises being No. 971, Majumdar Para, Phase – 2, Block 2, 3F, Garia,
Police Station Narendrapur, Kolkata – 700084. The opposite party did not take
care of anything. The opposite party did not ask to join the matrimonial tie on
any square for peaceful married life. The opposite party did not give any money
or kind to the petitioner to maintain herself in day to day life.
33.
That the opposite party called the
petitioner on considerable interval in night in a drunken condition and on his
such call he used most filthy languages to the petitioner and asked for money
time and again. This being cause of the opposite party, the opposite party
acted in a perverted manner on the petitioner, continuously, even after the
petitioner staying in her parental house.
34.
That the Opposite party is earning
about a sum of Rs. 2,00,000/- (Rupees Two Lakhs) only, per month from the
business of the Restaurant at Delhi. Though the opposite party is not paying
any single Rupee to the petitioner. The Petitioner is dependent on her old aged
widowed mother for her day to day livelihood.
35.
That the Petitioner has no source of
income to earn money. She is totally dependent on income of the opposite party
who deliberately, refused and neglected to look after the petitioner by any
means and measure, so far, till the day in placing the present petition before
the Learned Court.
36.
That the petitioner has no source of
income of her own and completely dependent upon the charity of her old aged
widowed mother. The mother of the petitioner has already been given a sum of Rs.
15 Lakhs to the opposite party Sriraj Goswami being the demands of the opposite
party.
37.
That the petitioner has right to live
as per the standard of living of her husband. The petitioner need sum of money
as Rs. 1,00,000/- (Rupees One Lakh) only, for a decent living in such present
price hike which includes fooding, clothing, medicine, doctors fees,
toiletries, mobile bill expenses, and conveyance and other necessary expenses
for day to day livelihood.
38.
That the Petitioner’s need another sum
of money as of Rs. 30,000/- (Rupees Thirty Thousand) only, for a standard
tenanted accommodation for herself.
39.
That the opposite party is constantly
threatening the petitioner and her old aged widowed mother, and thus she
apprehends that the opposite party can do anything to her. The opposite party
is very dangerous, more particularly while he is in drunken stage. The opposite
party can do harm to the petitioner at any point of time. All the other family
members are always active supporters of his all misdeeds.
40.
That the Petitioner beg to states that
upon such repeated refusal, the deserted petitioner, trying and finding other
alternative has decided to seek divorce from the respondent as such there is no
chance of reconciliation as between them, hence this suit.
41.
That your Petitioner beg to states
that since after her marriage due to continuous torture mentally as well as
socially by the in laws and the respondent, the petitioner become more
frustrated towards her conjugal life.
42.
That the Petitioner beg to states that
the Respondent being husband never render any care and protection to the
Petitioner and never lends his hands towards the Petitioner nor flowed any love
and affection towards her.
43.
That the Petitioner beg to states that
due to such continuous torture, refusal, negligence, and provocation, pretended
by the respondent on your petitioner to commit suicide. The Petitioner
frustrated upon her life due to such continuous mental torture inflicted by the
respondent.
44.
That the Petitioner beg to states that
the married life of your Petitioner was full to the brimful with misery and
sorrow as the respondent was not satisfied. The respondent and his mother used
to inflicted tremendous mental torture upon your petitioner.
45.
That your petitioner beg to submit that
due to continuous torture mentally as well as socially within the Domestic
Relationship by the respondent after her marriage. The petitioner became more
frustrated towards her conjugal life.
46.
That the dream of happy married life of
the petitioner came to an end due to the negligent attitude of the respondent and
his family member.
47.
That the respondent caused immense cruelty
to the Petitioner.
48.
That the petitioner did not condone the
cruel acts upon the petitioner by the respondent and your petitioner’s
reasonable apprehension in her mind that it would be harmful and injurious for
her to live with the respondent as the respondent inflicted torture upon the
petitioner with any reasonable cause and treated her with immense continuous cruelty
on her.
49.
That your petitioner made attempt to
restore the marital tie; But have no effect and now your
petitioner is not in a position to start with conjugal life again on a clear
state wiping off the unpleasant memories.
50.
That at present it is impossible to
lead a happy conjugal life with the respondent and the petitioner become
panicky and has reasonable apprehension in her mind that it will be harmful or
injurious to live together with the respondent.
51.
That at present the petitioner has been
staying and residing at her parental house at Premises
being Sunny Dew Complex, Premises being No. 971, Majumdar Para, Phase – 2,
Block 2, 3F, Garia, Police Station Narendrapur, Kolkata – 700084, District –
South 24 Parganas.
52.
The Petitioner begs to state that there
is no collusion between the parties in filing this
suit.
53.
That the cause of action of this suit
arose on and from the date of marriage on 12th day
of October’ 2023, between the parties, which
subsequently registered on 29-10-2023, before the Marriage
Officer Paresh Chandra Mondal, having his Office at Tegharia, Sarada Park,
Narendrapur Station Road, Police Station Narendrapur, Post Office – R.K. Pally,
Kolkata – 700150, District South 24 Parganas. The Certificate of Marriage under
Schedule “C’, in terms of Sub-Section (1) of Section 8 of the Hindu Marriage
Act, 1955, being Certificate No. WB343004000102000021205-2023-149590, dated
29-10-2023, has been given by the said Marriage Officer Paresh Chandra Mondal,
which certify the marriage between the petitioner and the opposite party dule
solemnized in presence of the Sister-in-law Reshma Goswami Panda, havinf his
residence near Cinema Holl, NSB Road, Post Office – Pandaveswar, Pin – 713346,
Police Station – Pandaveswar, Mother-in-law Papiya Goswami, having her place of
abode the then at Panchmahli, Post Office – Kumardhubi, Pin – 828203, Police
Station – Chirkunda, and the petitioner’s Mother Manashi Debnath, having her
place of residence at BL 1 FL 3E, 971, Majumder Para, Post Office – Garia, Pin
– 700084, Police Station – Narendrapur, District South 24 Parganas, and thereafter
continuing at the house of the respondent at Premises being no. Manick
Chand Apartment, Premises being No. 74A, Pratap Enclave, Mohan Garden, 4th
Floor (Middle), Uttam Nagar, New Delhi – 110059, and lastly on 19th
day of December’ 2023, while the respondent and his family member compelled by
way of aggravated tortured to leave her matrimonial house, and thereby your
petitioner lodge a complaint at the Narendrapur Police Station. Since 19-12-2023,
your petitioner residing at her parental house at Premises
being Sunny Dew Complex, Premises being No. 971, Majumdar Para, Phase – 2,
Block 2, 3F, Garia, Police Station Narendrapur, Kolkata – 700084, under such
compelling circumstances, and thereafter also the continuous torture has been
inflicted on your petitioner by the respondent by way of making calls at her
present residence, which is within the jurisdiction of the Learned Court.
54.
That the purpose of jurisdiction and
Court Fees the Fixed Court Fees has been affixed according
to the provisions of West Bengal Court Fees Act.
55.
That the petitioner had or has not
filed any other petition for Divorce, before any court of law except
this present application before this Learned Court.
56.
That the petitioner prays for :-
a)
A decree of divorce under section 13(1)(ia) of the Hindu Marriage Act, 1955, dissolving the marriage tie between the
petitioner and the Respondent, which
solemnized on 12th day of October’ 2023;
b)
Any other relief or relieves to which
the petitioner is entitled to get in the eye of law and in equity;
c)
A decree for cost of the suit.
And
for this act of kindness, the Petitioner as in duty bound shall ever pray.
List of Documents RELIED ON BY THE PETITIONER
1. Written Complaint to
the Narendrapur Police Station dated 19th day of July’ 2024, with
Postal receipt and track report;
2. Certificate of
Marriage Registration being Certificate No.
WB343004000102000021205-2023-149590, dated 29-10-2023;
3. Order no. 18, dated
14-03-2022, passed by the Learned 10th Court of the A.D.J. at
Alipore, South 24 Parganas in Mat Suit no. 1778 of 2018 (Alokparna Debnath –
Versus Tarak Debnath);
4. Order No. 26, dated
04-06-2022, passed by the Learned 7th Court of the A.D.J. Barasat,
North 24 Parganas, in Mat Suit No. 1417 of 2017 (Sriraj Goswami – Versus –
Supramita Moulik Goswami);
5. Screenshot of the
payment made by the aggrieved person to the respondent;
6. Screenshot of the
payment towards Air Ticket, made by the aggrieved person;
7. Some Photographs of
the marriage of the aggrieved person with the respondent;
8. Other Documents;
Verification
I,
Alokparna Debnath, Wife of Sriraj Goswami, Daughter of Late Subimal Debnath,
being the legal wedded wife of the Respondent, made this application under
Section 13(1)(ia) of the Hindu Marriage Act, 1955. I am acquainted and
conversant with the material facts, stated in the foregoing paragraphs. I
verify & sign this application on this _______the day of December, 2024, at
the Baruipur Court Premises.
AFFIDAVIT
I,
Alokparna Debnath, Wife of Sriraj Goswami, Daughter of Late Subimal Debnath,
aged about 33 years, residing at Sunny Dew Complex, Premises being No. 971,
Majumdar Para, Phase – 2, Block 2, 3F, Garia, Police Station Narendrapur, Kolkata
– 700084, District – South 24 Parganas, do hereby solemnly affirm and says as
follows;
1.
That I am the petitioner in the
present application. I am acquainted and conversant with the material facts
stated in the foregoing paragraph of this application. I am competent to swear
this affidavit.
2.
That the statement made in paragraph
number _____to _____ are true to my knowledge and belief and the rests are my
humble submissions before the Learned Court.
That
the statements made above are true to my knowledge and belief.
DEPONENT
Identified by me,
Advocate
Prepared
in my Chamber;
Advocate
Date
: ___________________2024,
Place
:Baruipur Court, South 24 Parganas,
N O T A R Y
Very useful
ReplyDelete