To the Hon’ble Mr. Justice …..or To the Judge of ……..

The ……. day of ….. 19 ……..

The petition of C.B. , of …… the wife of A.B.

Sheweth,

That on the ……. day of …….. She was lawfully married to A.B., at ……….

That she lived and cohabited with the said A.B. for years at ……, and also at ……, and hath had ……. children, issue of her said marriage, of whom ….. are now living with the applicant, and wholly dependent upon her earnings. That on or about ……, the said A.B., without any reasonable cause, deserted the applicant, and hath ever since remained separate and apart from her.

That since the desertion of her said husband, the applicant hath maintained herself by her own industry or on her own property, as the case may be, and hath thereby and otherwise acquired certain property consisting of [here state generally the nature of the property] ……………………. 

WHEREFORE she prays an order for the protection of her earnings and property acquired since the said, …… day of ….. from the said A.B., and from all creditors and persons claiming under him.