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(Section 22)

In the (High) Court of ……..

To the Hon’ble 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 petitioner’s 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, endeavoured to knock your petitioner down, and was only prevented from so doing by the interference of F.D., your petitioner’s 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.

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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 …… of … thousand nine hundred and ……,your petitioner, by reason of the great and continued cruelty practised 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 (Hon’ble) 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.

(Signed) A.B.

Form of Verification: See No. 1


In the (High) Court of ……..

The …… day of …… Between A.B., petitioner, and C.B. respondent.

C.B., the respondent, in answer to the petition filed in this cause by W.J. his attorney [or vakil] sayeth that he denies that he has been guilty of cruelty towards the said A.B., as alleged in the said petition.

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(Signed) C.B.

(Section 24)

In the (High) Court of ………

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

The ….. day of …. 19 …..

The petition …… A.B.,of ……


1. That your petitioner was on the …… day of …… lawfully married to …..

2. That on the … of……, this (Hon’ble) Court at the petition of …., pronounced a decree affecting the petitioner to the effect following, to wit,- 

(Here set out the decree)

3. That such decree was obtained in the absence of your petitioner, who was then residing at ……

[State facts tending to show that the petitioner did not know of the proceedings; and, further, that had he known he might have offered a sufficient defence.]


That there was reasonable ground for your petitioner leaving his said wife, for that his said wife 

[Here state any legal grounds justifying the petitioner’s separation from his wife] 

Your petitioner, therefore, prays, that this (Hon’ble) Court will reverse the said decree.

(Signed) A.B.

Form of Verification: See No. 1


  1. While taking advantage of law, if someone (petitioner)put a fake case against defendent under Section 24,what should do?
    The attitude of petitioner is to get money and property. No inclination towards husband’s family and petitioner’s parents encouraging her to obstruct money.
    Defendent helped financially to the petitioner & their parents before & after marriage though they didn’t respect. They assumen that the defendent is innoscent and it is very easy to get money and failing which petitiener put a case for jurdicial separation. So that she can get atleast maintenance charge.
    Our indian law is fabours to wemen and such cases what men should do?

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