In the Hon’ble Court of Civil Judge ( or where such Court has been established)…………… (Nadiad)
Suit No. ________/2024
Smt. ‘Name of wife’ wife of ‘Name of Husband’
Age: ……………….
Caste ……………
Residence of ………. Plaintiff
Versus
Shri ‘Name of Husband’ son of ‘XYZ’
Age: ……………….
Caste ……………
Residence of ………. Defendant
Plaint under section 2, Dissolution of the Marriage Act, 1939
The petitioner prays as under
(1) That the marriage between the parties was solemnized on _________ (date) at Nadiad (Home city of the father of the petitioner) according to Muslim Law.
(2) That after their marriage, both the parties lived as husband and wife together for more than four years. Both husband and wife peacefully performed their marital obligation and during the aforesaid wedlock period, the plaintiff gave birth to a daughter, namely ________ who is presently six years old.
(3) That after the birth of the daughter, the defendant began to treat the plaintiff with cruel behavior and often used to beat and abuse her.
(4) That on _______ the defendant solemnized second marriage with _______ and brought her to his house.
(5) After his second marriage, the defendant and his second wife have been compelling the plaintiff to lead an immoral life. Since, the plaintiff did not agree to it, the defendant has developed his habit of often beating and abusing the plaintiff; and begun to neglect her together with her female child and on _________, confined the petitioner in the store-room. Since the life of the plaintiff has become miserable, she has no other option except to seek divorce.
(6) That there is no collusion between the parties.
(7) That the cause of the action accrued to the plaintiff on _____ when after his second marriage, the defendant
(8) That this Hon’ble court has jurisdiction to entertain this petition.
(9) That the petition has been filed with the requisite court fees of Rs________ It is, therefore, prayed that:
(a) Suit of the plaintiff for dissolution of marriage be decreed with costs in the favour of the plaintiff and against the defendant.
(b) The amount of Mehr amounting Rs______ be paid to the plaintiff from the defendant.
(c) Any other relief, which the court deems fit, be given to the plaintiff,
Sd/-_____________ Sd/- _________
Counsel for the plaintiff Plaintiff
Verification
I, Smt. ‘Name of wife’ wife of ‘Name of Husband’, aged ______ years resident of Nadiad, hereby verify that paras No 1 to 6 of the petition are correct and true on the basis of my personal knowledge and belief, and paras No 7 to 9, based on legal advice, are also correct.
Place: Nadiad SD/- _________
Date:_________ Plaintiff