Mrs. Anuradha Modi (Divorce)
Mrs. Anuradha Modi (Divorce)
AT THANE
Age: 51 Years,
Occ.: Teacher,
VERSUS
Age: 51 Years,
Occ.: Service,
Filed on:
To,
1. The Petitioner and the Respondent belong to the same caste and
Community and as such the marriage was arranged between
them by the Relatives and Community elders.
7. That, they have two daughters out of the wed lock, named Ms.
Dhwani Modi, Aged: 21years, Physiotherapist by Profession and
Ms. Avni Modi, Aged: 16 years, studying in class 12 th.
8. That, post 2009, all the expenses of both the daughters were
taken care only by the Petitioner herself and that the
Respondent never fulfilled his responsibilities towards his own
daughters. The Petitioner started taking private tuitions to fulfil
the needs of the family as well as the Petitioner had to rely
financially on her parents till 2014, for her family’s survival. The
Petitioner also took help from her parents, financially to open a
Pre-Primary School named “Happy Feet” in Mira Road in the year
2014 which ultimately had to shut down in the year 2020 due
Covid-19 pandemic. The Petitioner states that, the family was
survived from year 2014 to 2020 on the above-mentioned
school’s income and online job.
12. That, during these years the Petitioner has been abused,
harassed and troubled by the creditors of the Respondent and is
left with no capacity to bear anymore harassment and troubles.
13. That, the marriage between the Petitioner and the Respondent
was only for namesake as the Respondent never obeyed his
duties towards the Petitioner, his own daughters and his own
mother but in return the Petitioner has been abused, troubled
and harassed by the creditors of the Respondent.
14. That, the above facts and circumstances clearly shows that the
Respondent has deserted the Petitioner on multiple occasion and
has completely failed to fulfil his duties as well as responsibilities
towards the Petitioner, his own daughters and his own mother.
Also, the Respondent at every stage of the marriage has
humiliated the Petitioner in private and in public. The Petitioner
for long tried her best to see to it that the marriage works out
but the Respondent never changed his behaviour or attitude.
The Petitioner has suffered irretrievably in this marriage and
cannot be made to suffer anymore.
18. That, there is no other legal ground as to why the decree prayed
for should be not granted in favour of the Petitioner.
19. That, This Hon’ble Court has jurisdiction to entertain and try
this petition as the marriage was solemnized on 3rd
November,1995 and the parties last resided together at: 2/504,
Prathmesh heritage, Near Galaxy Hospital, Kanakia Road, Mira
Road (East), Thane- 401107. Hereto Marked and annexed as
Exhibit “B” is the copy of Aadhar Card of the Petitioner.
PRAYER
b) Any other relief or reliefs which the court may deem proper
under the circumstances be also awarded to the Petitioner.
Thanking you!
Place: Petitioner:
Date:
VERIFICATION
PETITIONER,
Identified by me
AT THANE
VERSUS
PETITIONER,
AT THANE
VERSUS
MEMO OF ADDRESS
Age: 51 Years,
Occ.: Teacher,
VERSUS
Age: 51 Years,
Occ.: Service,
LIST OF DOCUMENTS
4. Memo of Address.
5. Vakalatnama
IN THE HON’BLE FAMILY COURT
OF THANE,
AT THANE
…Petitioner
And
…Respondent
DIVORCE PETITION
AT THANE
VERSUS
TO ENGAGE AN ADVOCATE
Date:
Place: Petitioner