Indian Divorce Act, 1869
NO. 8-PETITION FOR A JUDICIAL SEPARATION BY REASON OF CRUELTY
In the (High) Court of .
To the Honble Mr. Justice . or To the Judge of
The .. day of 19
The petition of A.B. (wife of C.B.) or ...............................................................
1. That on the .. day of ,one thousand nine hundred and ......................, your petitioner, then A.D., spinster, was lawfully married to C.B., at ..
2. That from her said marriage, your petitioner lived and cohabited with her said husband at .. until the .. day of .. one thousand nine hundred and .., when your petitioner separated from her said husband as hereinafter more particularly mentioned, and that your petitioner and her said husband have had no issue of their said marriage.
3. That from and shortly after your petitioners said marriage, the said C.B. habitually conducted himself towards your petitioner with great harshness and cruelty, frequently abusing her in the coarsest and most insulting language, and beating her with his fists, with a cane, or with some other weapon.
4. That on an evening in or about the months of . one thousand nine hundred and .., the said C.B. in the highway and opposite to the house in which your petitioner and the said C.B. were then residing at aforesaid, endeavored to knock your petitioner down, and was only prevented from so doing by the interference of F.D., your petitioners brother.
5. That subsequently on the same evening, the said C.B. in his said house at aforesaid, struck your petitioner with his clenched fists a violent blow on her face.
6. That on one Friday night in the month of .. one thousand nine hundred and , the said C.B., in .. without provocation, threw a knife at your petitioner, thereby inflicting a severe wound on her right hand.
7. That on the afternoon of the .day of ..one thousand nine hundred and ..,your petitioner, by reason of the great and continued cruelty practiced towards her by her said husband, with assistance withdrew from the house of her said husband to the house of her father at , that from and after the said day of ., one thousand nine hundred and ., your petitioner hath lived separate and apart from her said husband, and hath never returned to his house or to cohabitation with him.
8. That there is no collusion or connivance between your petitioner and her said husband with respect to the subject of the present suit.
Your petitioner, therefore, prays that this (Honble) Court will decree a judicial separation between your petitioner and the said C.B., and also order that the said C.B., do pay the costs of and incident to these proceedings.
Form of Verification: See No. 1