PETITION BY WIFE FOR JUDICIAL SEPARATION ON THE GROUND OF HER HUSBAND’S ADULTERY
In the (High) Court of ……
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.
1. That on the day of ……. one thousand nine hundred, your petitioner, then C.D., was lawfully married to A.B., at the Church of ……, in the ……
2. That after her said marriage, your petitioner cohabited with the said A.B. at, …. And at, … and that your petitioner and her said husband have issue living Of their said marriage, three children, to wit, etc., etc., (a).
3. That on diverse occasions in or about the months of August, September and October, one thousand nine hundred and ….., the said A.B., at aforesaid, committed adultery with E.F., who was then living in the service of the said A.B. and your petitioner at their said residence……………. aforesaid.
4. That on diverse occasions in the months of October, November and December, one thousand nine hundred and ……, the said A.B., at …. aforesaid, committed adultery with G.H. who was then living in the service of the said A.B. and your petitioner at their said residence …. aforesaid.
5. That no collusion or connivance exists between your petitioner and the said A.B. with respect to the subject of the present suit.
Your petitioner, therefore, prays that this (Hon’ble) Court will decree a judicial separation to your petitioner from her said husband by reason of his aforesaid adultery.
(Signed) C.B. (b)
(a) State the respective ages of the children.
(b) The petition must be signed by the petitioner.
Form of Verification: See No. I
STATEMENT IN ANSWER TO FOR JUDICIAL SEPARATION
In the (High) Court of …….. B. against B.
The ….. day of ……The respondent, A.B., by W.Y. his attorney or vakil sayeth,-
(1) That he denies that he committed adultery with E.F. as in the third paragraph of the petition alleged.
(2) That the petitioner condoned the said adultery with E.F., if any.
(3) That he denies that he committed adultery with G.H., as in the fourth paragraph of the petition alleged.
(4) That the petitioner condoned the said adultery with G.H., if any.
Wherefore this respondent prays that this (Hon’ble) Court will reject the prayer of the said petition.
STATEMENT IN REPLY TO FOR JUDICIAL SEPARATION
In the (High) Court of …….B against B.
The …….day of ….
The petitioner, C.B., by her attorney [or vakil], says-
(1) That she denies that she condoned that said adultery of the respondent with E.F. as in the second paragraph of the statement in answer alleged.
(2) That even if she had condoned the said adultery, the same has been revived by the subsequent adultery of the respondent with G.H., as set forth in the fourth paragraph of the petition.