Sonali Goyal Plaint Assignment

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IN THE COURT OF FAMILY BHILWARA DISTRICT

Civil Suit No. 2154/2023

Sandhya, residing at Ramdev Marg, Nehru Colony, Bhilwara, Rajasthan

Plaintiff

Versus

Ashutosh kumar S/o Ramesh kumar, residing at Gandhi chock, Bhilwara, Rajasthan

Defendant

PLAINT

The Plaintiff, Sandhya, respectfully submits the following plaint against the Defendant,
Ashutosh:

1. The Plaintiff and Defendant were married on [insert date] at [insert place of marriage] in
Bhilwara district, Rajasthan, according to Hindu customs and traditions.
2. The marriage between the Plaintiff and Defendant was duly solemnized and registered
under the Hindu Marriage Act, 1955.
3. After the marriage, the Plaintiff went to live with the Defendant at his home in Bhilwara.
However, from the beginning of their marriage, the Defendant and his family members
began subjecting the Plaintiff to various forms of cruelty, harassment, and torture, both
physical and mental.
4. The Defendant and his family members frequently abused the Plaintiff, called her names,
insulted her, and threatened her with physical harm. The Plaintiff was often forced to do
menial and degrading tasks, and was not provided with adequate food, clothing, or
medical care.
5. Despite numerous attempts to reconcile with the Defendant and his family members, the
Plaintiff's situation continued to deteriorate. Finally, on [insert date], the Plaintiff was
forced to leave the Defendant's home and return to her parents' home due to the
unbearable physical and mental trauma she was being subjected to.
6. The Plaintiff has made repeated attempts to reach out to the Defendant and his family
members in order to resolve their differences and save their marriage. However, the
Defendant and his family members have consistently refused to engage with the Plaintiff
or attempt to resolve the issues between them.
7. The Plaintiff has no other alternative but to approach this Hon'ble Court seeking relief.
8. The Plaintiff claims the following relief from this Hon'ble Court:
a. A decree of dissolution of the marriage between the Plaintiff and Defendant under
Section 13 of the Hindu Marriage Act, 1955.
b. An order directing the Defendant to pay a sum of [insert amount] as permanent
alimony to the Plaintiff.
c. Any other relief that this Hon'ble Court deems fit and proper in the circumstances.
9. The cause of action for the present suit arose on [insert date] when the Plaintiff was
forced to leave the Defendant's home due to the physical and mental trauma she was
being subjected to.
10. The present suit is being filed within the jurisdiction of this Hon'ble Court as the marriage
between the Plaintiff and Defendant was solemnized and registered in Bhilwara district,
and the Plaintiff and Defendant both reside within the jurisdiction of this Hon'ble Court.
11. The value of the suit for the purpose of jurisdiction and court fees is estimated at [insert
amount].
12. The Plaintiff has engaged [insert name and address of advocate] as her Advocate to
represent her in this matter.

PRAYER

In the light of the facts stated above, it is respectfully prayed that this Hon'ble Court may be
pleased to:

a. Admit this plaint and grant a decree of dissolution of the marriage between the Plaintiff and
Defendant under Section 13 of the Hindu Marriage Act, 1955.

b. Direct the Defendant to pay a sum of [insert amount] as permanent alimony to the Plaintiff.

c. Grant any other relief that this Honble Court may deem fit.

Plaintiff
Verification

I, Sandhya, the Plaintiff in the above suit, do hereby verify that the contents of the above plaint
are true and correct to the best of my knowledge and belief and nothing material has been
concealed therein.

Plaintiff

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