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IN THE COURT OF CIVIL JUDGE SENIOR

DIVISION PANVEL, AT PANVEL

MARRIAGE PETITION NO. OF 2021

Mrs. Shubhada Shriram Dhawde

Age 37 years, Occ.-housewife,

Residing at ,603 Citi Park CHS,

Plot No. 6a, Khanda Colony, New Panvel

raigad , 410206. .......PETITIONER 1

AND

Mr. Shriram Ramesh Dhawde

Age 38 years, Occ.-service,


Residing B-103, Om Darshan CHS,
Plot No-A-5-2, Sector 07, Near Pillai School,
Khanda Colony, Panvel, Raigad-410206 …PETITIONER
2

INDEX

Sr. Particular Page Numbers


No.

1 Petition
2 Petitioner No. 1 Affidavit

3 Petitioner No. 2 Affidavit

4 List of Document

5 Exhibit A

Copy of the marriage


certificate.

6 Exhibit B

Copy of the petitioner child


Aadhar card & birth certificate

7 Exhibit C

Adhar Card & Pan Card of both


the petitioners

8 Vakalatnama

Place: Panvel
Date: / /2021.
Advocate for the Petitioner.No.1 & 2
IN THE COURT OF CIVIL JUDGE SENIOR

DIVISION PANVEL, AT PANVEL

MARRIAGE PETITION NO. OF 2021

Mrs. Shubhada Shriram Dhawde

Age 37 years, Occ.-housewife,

Residing at ,603 Citi Park CHS,

Plot No. 6a, Khanda Colony, New Panvel

raigad , 410206. .......PETITIONER 1

AND

Mr. Shriram Ramesh Dhawde

Age 38 years, Occ.-service,


Residing B-103, Om Darshan CHS,
Plot No-A-5-2, Sector 07, Near Pillai School,
Khanda Colony, Panvel, Raigad-410206 …PETITIONER
2

PETITION FOR A DECREE FOR DISSOLUTION OF


MARRIAGE BY MUTUAL CONSENT UNDER SECTION
13B OF THE HINDU MARRIAGE ACT.
To,

THE HONOURABLE PRINCIPAL JUDGE AND OTHER


HONOURABLE JUDGE OF THIS HONOURABLE COURT:

HUMBLE PETITION OF THE PETITIONER’S


ABOVENAMED:

MOST RESPECTFULLY SHEWETH:

The petitioners’ above-named states as under: -

1. The Petitioners states that they got married to the each

other on 15/06/2010 at Thane as per Hindu Vedic

rites and rituals. The copy of marriage certificate of

the petitioners is hereby marked and annexed as

Exhibit “A”.

2. The Petitioners states that, the said marriage was love

marriage, they cohabited together at – P-27,Such

Vaibhavrabivashi Sangh, Saneguruji, Sector

4,Airoli,Navi Mumbai-400708.

3. The Petitioners state that till date i.e. after lapse and

issues of almost 11 years both the Petitioner’s given up


the hopes of their married life and there are no hopes of

whatsoever nature in future and therefore they have

decided to break-up the relationship as husband and

wife by way of decree of divorce by Mutual consent.

4. The petitioner’s state that, therefore, both the

petitioner’s and their family members have decided out

of their own will and wish that the marriage between the

petitioner’s to be dissolved by mutual consent under

section 13-B of the Hindu Marriage Act, 1955.

5. The petitioners state that, out of the said wedlock they

have a minor son Master. Swaroop Shriram Dhawade ,

born on dated 04/03/2011 and is presently 9 years

old. The petitioner further states that, the permanent

custody of the son (Master. Swaroop Shriram

Dhawade) will remain with petitioner no.1. Petitioner

no.2 will have access to meet their son in every month

at residence of petitioner no.1 or any other place

suggested by the petitioner no. 1. The copy of the

aadhar card & birth certificate of the child Master.


Swaroop Shriram Dhawade is hereby marked and

annexed as Exhibit “B”.

6. The Petitioners states that, petitioners submitted

Adhar Card and Pan Card Copies. The copy of Adhar

Card & Pan Card of both the petitioners is hereby

annexed and marked as “Exhibit C”

7. The petitioners’ states that they both are residing

separately from each other for the period of more than

1 years. Therefore, they are entitled for a Decree of

Divorce under section 13 –B of the Hindu Marriage

Act, 1956.

8. The petitioners have agreed to get divorce under

certain terms and conditions which are as follows: -

I. Both the petitioners mutually decided that all the stridhan

received by petitioner no.1 in the marriage is in the custody

of petitioner no.1 and will be remain with petitioners no 1.

II. It is agreed that both the Petitioner’s, that Petitioner no.2

have agreed to give custody of son ( Master. Swaroop

Shriram Dhawade to Petitioner No.1.


III. The petitioner states that, it is decided between the petitioners

that in order to secure the future of their son Master.

Swaroop Shriram Dhawade and his safety, after the

demised/death of petitioner no.2 all should be immediate

transferred to his son as he being their immediate legal heir

for his presently and future assets/property/land as well as

bank FD etc.

IV. The Petitioner no.2 will be responsible for paying the expenses

towards the educational fees as well monthly expenses of their

son. The petitioner no.2 decided that petitioner no.2 will

monthly contribute some amount towards the upbringing of

their son depending upon his earning and wish. The petitioner

no.2 will take a residing expenses of their son (Master.

Swaroop Shriram Dhawade).

V. The petitioners’ states that both the petitioners have agreed

that in a case if any of the petitioners got remarried its agreed

that their future spouses will not have absolutely no rights

towards any of share in the property of petitioner no.2


VI. The petitioners hereby undertake not to claim anything from

each now or any time in future as they will take all their

belongings as mutually agreed upon.

VII. The petitioners shall not claim any right, title or interest in

any of the movable or immovable property of the each other

any time in future.

VIII. The Petitioners hereby undertake that both of them shall not

keep any kind of relations of whatsoever nature and they shall

not interfere with each other’s social & family life.

9. The petitioner’s state that each of them have given their

consent for divorce out of their own free will and wish as

prayed herein.

10. The petitioner’s state that, both the petitioners have

settled their respective claims and counter claims

against each other as agreed upon.

11. The petitioner’s state that, there is no collusion or

connivance between the parties for dissolution of their

marriage.
12. The petitioners shall not claim any right, title or interest

in any of the movable or immovable property of the each

other any time in future.

13. The petitioner’s state that the said marriage between the

petitioner’s was solemnized on 15 June 2010 and

thereafter the Petitioners no. 1 and 2 resided in khanda

colony within the jurisdiction of this Hon’ble court and

hence this Hon’ble court has got jurisdiction to try and

entertain this present petition.

14. The Petitioner’s State that the petitioners have paid the

requisite court fees for filing this present petition.

15. THE PETITIONER’S THEREFORE PRAY THAT:-

a) The marriage between the petitioner’s’ solemnized on 15


June 2010 be dissolved and decree for divorce be
passed in their favor under section 13 – B of the Hindu
Marriage Act 1956.

b) Such further and other relief is as the circumstances of


the case may require for.

Date: / /2021
Place: Panvel.

Advocate for the Petitioners No. 1 and 2

PETITIONER NO.1
Mrs. Shubhada Shriram Dhawde

PETITIONER NO.2
Mr. Shriram Ramesh Dhawde

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