PETITION UNDER SECTION 13 (B) (2) OF THE HINDU MARRIAGE

ACT, 1955 SEEKING DECREE OF DIVORCE BY MUTUAL

CONSENT AS PER THE MEMORANDUM OF UNDERSTANDING
FILED WITH THE PETITION WHEREBY THE WIFE IS GIVEN A
LUMP SUM AMOUNT AND A CAR ON ACCOUNT OF PERMANENT
ALIMONY, MAINTENANCE ETC. AND WIFE RELINQUISHES HER
50% SHARE IN THE JOINT PROPERTY IN THE NAME OF THE
HUSBAND

IN THE COURT OF DISTRICT JUDGE AT _________

H.M.A.NO.________ OF _______
IN THE MATTER OF:
Mr. __________ …Petitioner No.1
AND
Mrs. __________ …Petitioner No.2
INDEX
Sl. No. Particular Page No.
1. Memo of Petitioners A
2. Petition under section 13 (B) (2) of the Hindu 1-
Marriage Act 1955 along affidavits.
3. I-D And residence proof Petitioner no 1&2
4. Marriage proof
5 Vakaltnama

PETITIONER NO.1 PETITIONER NO.2

THROUGH: THROUGH:
( ) ( )
ADVOCATE ADVOCATE
ENROLLMENT NO……… ENROLLMENT NO………
ADDRESS:……………… ADDRESS:………………
EMAIL:………………… EMAIL:…………………
MOB. NO……………… MOB. NO………………

Place :_____
Signed on: ___________
Filed on :

IN THE COURT OF DISTRICT JUDGE AT _________

H.M.A.NO.________ OF _______
IN THE MATTER OF:
Mr. __________
S/o Mr. __________
R/o __________
__________. …Petitioner No.1
AND
Mrs. __________
D/o Shri__________
R/o _________
_________,
_________ …Petitioner No.2
MEMO OF PETITIONERS

IN THE MATTER OF:

Mr. __________
S/o Mr. __________
R/o __________
__________. …Petitioner No.1
AND
Mrs. __________
D/o Shri__________
R/o _________
_________,
_________ …Petitioner No.2

PETITIONER NO.1 PETITIONER NO.2

THROUGH: THROUGH:
( ) ( )
ADVOCATE ADVOCATE
ENROLLMENT NO……… ENROLLMENT NO………
ADDRESS:……………… ADDRESS:………………
EMAIL:………………… EMAIL:…………………
MOB. NO……………… MOB. NO………………

Place :_____
Signed on: ___________
Filed on :

IN THE COURT OF DISTRICT JUDGE AT _________

H.M.A CASE NO.________ OF ______

IN THE MATTER OF:

Mr. __________
S/o Mr. __________
R/o __________
__________. …Petitioner No.1
AND
Mrs. __________
D/o Shri__________
R/o _________
_________,
_________ …Petitioner No.2

PETITION FOR DISSOLUTION OF MARRIAGE BY A DECREE OF

DIVORCE BY MUTUAL CONSENT UNDER SECTION 13 (B) (2) OF

THE HINDU MARRIAGE ACT, 1955

The above named Petitioners most respectfully showeth:

Sir,

1. That the Parties to this Petition has previously filed petition

under section 13(B)(1) which was disposed off by this Hon’ble

Court vide its order dated _________.

2. That the Parties to this Petition are filing the present Petition for

Dissolution of Marriage by a Decree of Divorce by Mutual

Consent under section 13(B)(2) of the Hindu Marriage Act, 1955.

3. The marriage ceremony between Petitioner No.__ and the

Petitioner No.__ was conducted at _________ on _________.

4. That the status age and domicile of both the Petitioners before

their marriage and at the time of filing the present Petition is as

under:

Husband Wife
Status Age Place of Status Age Place of
residence residence
Before _________ __ _________, _________ __ _________,
marriage Years _________ _________
At the _________ __ __________ _________ __ _________,
time of Years __________ _________
filing of
petition

5. That after the marriage, the Petitioners lived together at

_________. The Petitioners have one daughter from this wedlock
namely Ms. _________, who was _________ on _________ & is
living happily with her husband in _________.

6. That the Petitioners have been living separately/ not cohabiting

as husband and wife since _________, and thereafter have not
been able to live together ever since on account of temperamental
differences. Despite best efforts of common friends and relatives
the Petitioners have been unable to reconcile their differences.
There is now no possibility of their living together as husband
and wife.

7. That the Petitioners have mutually agreed that their marriage may
be dissolved by decree of divorce by mutual consent as there are
irreconcilable differences between the Petitioners. That the
Petitioner No.__ and Petitioner No.__ mutually entered into a
“Memorandum of Understanding dated _________, whereby the
Petitioner No.__ and Petitioner No.__ have agreed to dissolve
their Marriage by mutual Decree of Divorce on the terms and
conditions contained in the said “Memorandum of Understanding
dated _________” and the said “Memorandum of
 Understanding” shall be read with and form part and parcel of
this Petition. A copy of the said “Memorandum of Understanding
dated _________” is filed herewith as Annexure “A”.

8. That as mutually agreed as per the said “Memorandum of

Understanding dated _________”, the Petitioners have agreed
that their marriage may be dissolved by a decree of divorce on
the following terms and conditions:
i. The Petitioners are jointly owing Apartment No. _________,
__________ (hereinafter referred to as the “said Apartment”) in
which the Petitioner No.__ & Petitioner No. ___ have ____%
Share each. The Petitioner No. ___ shall relinquish ____% Share
of her rights in the said Apartment and transfer her share in the
name of the Petitioner No.__ before going to the court for
recording of Statement for the Motion under Section 13 (b) of the
Hindu Marriage Act, 1955, subject to the following conditions:-
(a) That the Petitioner No.__ shall execute and get registered
an Irrevocable Will bequeathing his ____% Share in the
said Apartment in favour of his only _________ daughter
_________ and the Petitioner No.__ undertakes not to
ever change his will in his life time.
(b) In case the Petitioner No.__ ever decides to sell the “said
Apartment” and buy another Residential Property, the
Petitioner No.__ shall purchase the said Residential
Property jointly in his name and in the name of his
_________ Daughter _________. With both the Petitioner
No.__ and _________ having ____% share each and the
Petitioner No.__ undertakes not to ever change his will in
his life time.
ii. The Petitioner No.__ further undertakes that he shall execute
and get registered an Irrevocable Will bequeathing all his other
Movable and Immovable Properties (Present and Future) in
favour of his only _________ daughter _________ and the
Petitioner No.__ undertakes not to ever change his will in his life
time.
iii. The Petitioner No.__ shall pay an amount of Rs._________/-
(Rupees _________ Only), to the Petitioner No.__ towards full &
final settlement of payment for her maintenance & alumni to the
Petitioner No.__ in the following manner:-
(a) The Petitioner No.__ have already paid to the Petitioner
No.__ an amount of Rs._________/- (Rupees _________
only) vide Demand Draft No._________ dated
_________, drawn _________ Branch, and in favour of
the Petitioner No.__, at the time of signing the
“Memorandum of Understanding dated _________” and
the said payment of Rs._________/- (Rupees _________
only) already stands reflected in the said “Memorandum
of Understanding dated _________”. The Petitioner No.__
doth hereby acknowledges and confirms the receipt of the
said amount of Rs._________/- (Rupees _________ only)
from the Petitioner No.__. It is further agreed by the
Petitioner No.__ that in case the Petitioner No.__ does not
come to the Court and record her statement to give
consent to the passing of Decree of Divorce by mutual
consent for dissolution of their marriage by the Hon’ble
Court, then the Petitioner No.__ shall be liable to refund
the amount of Rs._________/- already paid by the
Petitioner No.__ to the Petitioner No.__ as per this para
then the Petitioner No.__ shall be liable to forthwith
refund to Petitioner No.__ the said amount of
Rs._________/- along with interest calculated @____%
per annum from the date of payment to the date of refund.
(b) The Petitioner No.__ shall further pay the balance amount
of Rs._________/- (Rupees _________ only) to the
Petitioner No.__, by way of a Bank Draft drawn in favour
of the Petitioner No.__ before going to the Court for
recording of the statement of the Petitioner No.__ before
the Court under Section 13 (b) of the Hindu Marriage Act
1955 for giving consent to the passing of decree of
Divorce by mutual consent for dissolution of their
marriage by the Hon’ble Court. It is further agreed by the
Petitioner No.__ that in case the Petitioner No.__ does not
come to the Court and record her statement to give
consent to the passing of Decree of Divorce by mutual
 consent for dissolution of their marriage by the Hon’ble
Court, then the Petitioner No.__ shall be liable to refund
the amount of Rs._________/- (Rupees _________
only)already paid by the Petitioner No.__ to the Petitioner
No.__ as per this para then the Petitioner No.__ shall be
liable to forthwith refund to Petitioner No.__ the said
amount of Rs._________/-(Rupees _________ only)
along with interest calculated @____% per annum from
the date of payment to the date of refund.
iv. The Petitioner No.__ has already taken all her Jewellery,
Cloths, & all other belongings of her. The Petitioner No.__ have
also given to the Petitioner No.__ Volkswagen Car No.
_________. The Volkswagen Car No._________ is hypothecated
to Finance Company and the Petitioner No.__ undertakes to pay
the EMI or repay the full loan. It is clearly understood that the
Petitioner No.__ shall get the Car free of any loan/encumbrances.
v. The Petitioner No.__ has received her entire stridhan. It is
further stated that both the Petitioners have settled their disputes
amicably and shall have no other claims regarding maintenance,
alimony etc. against each other in future.

The Petitioners agree that this is a full and final settlement. There
has been an understanding between both the Petitioners that no
further payment will be made to the Petitioner No.__.
9. That the Petitioners undertake to abide by the terms and
conditions stipulated herein above. The Petitioners further
undertake to appear before this Hon’ble Court for recording their
statement as and when required.
10. That the Petitioners are living separately, have not cohabited as
husband and wife, for the past two years, before the presentation,
of this Petition and there are irreconcilable differences between
the Petitioners, resulting in an irretrievable breakdown of
marriage.
11. That there is no collusion between the Petitioners in filing the
present Petition.
12. That the consent of the Petitioners have not been obtained by any
fraud, force or undue influence.
13. That the Petition has been filed without any improper or
unnecessary delay.
14. That there is no legal ground as to why the relief prayed for be
not granted.
15. That no other petition has been filed in the above matter by the
petitioners.
16. That both the Petitioners, Petitioner No.__ is a resident of
_________ and the Petitioner No.__ is the resident of
_________, hence this Hon’ble Court has the jurisdiction to
entertain and try this Petition.
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble Court
may be pleased to pass:
a) a decree of divorce dissolving the marriage between the
Petitioners in accordance with the terms and conditions contained
in the Memorandum of Understanding dated _________, filed as
Annexure “A” to this Petition.
b) Any such other or further order/ orders as this Hon’ble Court
may deem fit and proper in the facts and circumstances of the
present case.

PETITIONER NO.1 PETITIONER NO.2

THROUGH: THROUGH:
( ) ( )
ADVOCATE ADVOCATE
ENROLLMENT NO……… ENROLLMENT NO………
ADDRESS:……………… ADDRESS:………………
EMAIL:………………… EMAIL:…………………
MOB. NO……………… MOB. NO………………

Place :_____
Signed on: ___________
Filed on :
VERIFICATION:
Verified on solemn affirmation at _________ on this ____ day of
_________ that the contents of paragraph Nos.1 to __ of this Petition are true to
our knowledge and those of paragraph Nos.__ to ___ are based on information
received and believed to be true. The last paragraph is a prayer to this Hon’ble
Court.

PETITIONER NO.1

PETITIONER NO.2
 IN THE COURT OF DISTRICT JUDGE AT _________
H.M.A.NO. _______ OF ________

IN THE MATTER OF:

Mr. __________
S/o Mr. __________
R/o __________
__________. …Petitioner No.__

AND
Mrs. __________
D/o Shri__________
R/o _________
_________,
_________ …Petitioner No.__
AFFIDAVIT

I, __________, S/o. Mr. __________ R/o: _________, do hereby solemnly

affirm and declare as under:

1. That the above named Deponent is the Petitioner No.__ in the Petition
under Section 13 (B) (2) of Hindu Marriage Act, 1955, filed before this
Hon’ble Court for dissolution of Marriage by a decree of divorce by
mutual consent and is thus well conversant with the facts of the case.

2. That the marriage between the Petitioners was solemnized on

_________ at _________.

3. That the present petition is being filed on the basis of consent given by
the deponent of his own free will and without any force, fraud, coercion,
duress and undue influence.

4. That there is no collusion between the Petitioners in filing and

prosecuting the present petition.

5. That the Petitioners are living separately since _________ i.e. for about
one and half years, preceding the date of filing the present Petition and
there has been no co-habitation between the Petitioners since ______.
6. The Petitioner No.__ states that this dissolution, shall resolve all
liabilities, between Petitioners.

DEPONENT
VERIFICATION :
Verified at _________ on _________day of _________ that the
contents of my above affidavit are true and correct to my knowledge and
nothing has been concealed therefrom.

DEPONENT
 IN THE COURT OF DISTRICT JUDGE AT _________
H.M.A.NO.________ OF ______

IN THE MATTER OF:

Mr. __________
S/o Mr. __________
R/o __________
__________. …Petitioner No.__
AND
Mrs. __________
D/o Shri__________
R/o _________
_________,
_________ …Petitioner No.__
AFFIDAVIT

I, Mrs. __________ D/o Shri__________, R/o, _________, _________ do

hereby solemnly affirm and declare as under:

1. That the above named Deponent is the Petitioner No.__ in the Petition
under Section 13 (B) (2) of Hindu Marriage Act, 1955, filed before this
Hon’ble Court for dissolution of Marriage by a decree of divorce by
mutual consent and is thus well conversant with the facts of the case.

7. That the marriage between the Petitioners was solemnized on

_________ at _________.

8. That the present petition is being filed on the basis of consent given by
the deponent of his own free will and without any force, fraud, coercion,
duress and undue influence.

9. That there is no collusion between the Petitioners in filing and

prosecuting the present petition.

10. That the Petitioners are living separately since _________ i.e. for about
one and half years, preceding the date of filing the present Petition and
there has been no co-habitation between the Petitioners since ____.
11. The Petitioner No.__ states that this dissolution, shall resolve all
liabilities, between Petitioners.

DEPONENT

VERIFICATION :
Verified at _________ on _________day of _________ that the
contents of my above affidavit are true and correct to my knowledge and
nothing has been concealed therefrom.

DEPONENT
 MEMORANDUM OF UNDERSTANDING

This Memorandum of Understanding is made at ______ on this __ day of ______.

BETWEEN

Mr. ________, S/o ________, R/o _________, The Laburnum, Gurgaon-122002

(hereinafter referred to as the “First Party”), which expression shall unless, opposed
or repugnant to the context or expressly excluded by the context or by law, mean and
include his heirs, legal representatives, administrators, executors, nominees and
assigns of the First Part.
And
Mrs. ________, D/o __________, R/o _________, Safdarjung Enclave, New Delhi,
(hereinafter referred to as the “Second Party”) which expression shall unless, opposed
or repugnant to the context or expressly excluded by the context or by law, mean and
include her heirs, legal representatives, administrators, executors, nominees and
assigns of the First Part.

WHEREAS the marriage ceremony between First Party and the Second Party was
conducted at New Delhi on ________.

WHEREAS after the marriage, the Parties lived together at Gurgaon. The Parties
have one daughter from this wedlock namely Ms. ______-, who was married on
_______ & is living happily with her husband in USA.

WHEREAS the Parties have been living separately/ not cohabiting as husband and
wife since __________, and thereafter have not been able to live together ever since
on account of temperamental differences. Despite best efforts of common friends and
relatives the Parties have been unable to reconcile their differences. There is now no
possibility of their living together as husband and wife.

WHEREAS the Parties have mutually agreed that their marriage may be dissolved by
decree of divorce by mutual consent as there are irreconcilable differences between
the Parties.

WHEREAS the First Party and Second Party have mutually agreed to entered into
this “Memorandum of Understanding, whereby the First Party and Second Party have
agreed to dissolve their Marriage by mutual Decree of Divorce on the terms and
conditions contained herein. Whereas the First Party and the Second Party have
agreed to deduce the terms and condition of this Memorandum of Understanding in
writing.
NOW THIS MEMORANDUM OF UNDERSTATING WITNESSETH AS
UNDER:-

1. That as mutually agreed the Parties have agreed that their marriage
may be dissolved by a decree of divorce on the following terms and
conditions:

vi. The Parties are jointly owing Apartment No. ______, The Laburnum,
Gurgaon-122002 (hereinafter referred to as the “said Apartment”) in
which the First Party & Second Party have 50% Share each. The
Second Party shall relinquish 50% Share of her rights in the said
Apartment and transfer her share in the name of the First Party before
going to the court for recording of Statement for the Motion under
Section 13 (b) of the Hindu Marriage Act, 1955, subject to the
following conditions:-
(c) That the First Party shall execute and get registered an
Irrevocable Will bequeathing his 100% Share in the said
Apartment in favour of his only married daughter Vidyun and
the First Party undertakes not to ever change his will in his life
time.
(d) In case the First Party ever decides to sell the “said Apartment”
and buy another Residential Property, the First Party shall
purchase the said Residential Property jointly in his name and
in the name of his Married Daughter _____, with both the First
Party and _____ having 50% share each and the First Party
undertakes not to ever change his will in his life time.

ii The First Party further undertakes that he shall execute and get
registered an Irrevocable Will bequeathing all his other Movable and
Immovable Properties (Present and Future) in favour of his only
married daughter ____ and the First Party undertakes not to ever
change his will in his life time.

iii The First Party shall pay an amount of Rs._________/- (Rupees

_______ Only) to the Second Party towards full & final settlement of
payment for her maintenance & alumni to the Second Party in the
following manner:-

(c) The First Party have already paid to the Second Party an
amount of Rs.______/- (Rupees ______ only) vide Demand
Draft No._______ dated ______, drawn on ______ Bank,
 Gurgaon Branch, and in favour of the Second Party, at the time
of signing the “Memorandum of Understanding, and the said
payment of Rs._____/- (Rupees _______ Lacs only) already
stands reflected in the said “Memorandum of Understanding.
The Second Party doth hereby acknowledges and confirms the
receipt of the said amount of Rs._____/- (Rupees ________
Lacs only) from the First Party. It is further agreed by the
Second Party that in case the Second Party does not come to
the Court and record her statement to give consent to the
passing of Decree of Divorce by mutual consent for dissolution
of their marriage by the Hon’ble Court, then the Second Party
shall be liable to refund the amount of Rs._____/- already paid
by the First Party to the Second Party as per this para then the
Second Party shall be liable to forthwith refund to First Party
the said amount of Rs._______/- along with interest calculated
@9% per annum from the date of payment to the date of
refund.

(d) The First Party shall further pay the balance amount of
Rs.______/- (Rupees _______ only) to the Second Party, by
way of a Bank Draft drawn in favour of the Second Party
before going to the Court for recording of the statement of the
Second Party before the Court under Section 13 (b) of the
Hindu Marriage Act 1955 for giving consent to the passing of
decree of Divorce by mutual consent for dissolution of their
marriage by the Hon’ble Court. It is further agreed by the
Second Party that in case the Second Party does not come to
the Court and record her statement to give consent to the
passing of Decree of Divorce by mutual consent for dissolution
of their marriage by the Hon’ble Court, then the Second Party
shall be liable to refund the amount of Rs.______/- (Rupees
Seventy Five Lacs only) already paid by the First Party to the
Second Party as per this para then the Second Party shall be
liable to forthwith refund to First Party the said amount of
Rs._______/-(Rupees Seventy Five Lacs only) along with
interest calculated @9% per annum from the date of payment
to the date of refund.

vii. The Second Party has already taken all her Jewellery, Cloths, & all
other belongings of her. The First Party have also given to the Second
 Party Volkswagen Car No.________ The Volkswagen Car
No.________ is hypothecated to Finance Company and the First Party
undertakes to pay the EMI or repay the full loan. It is clearly
understood that the Second Party shall get the Car free of any
loan/encumbrances.
viii. The Second Party has received her entire stridhan. It is further stated
that both the Parties have settled their disputes amicably and shall have
no other claims regarding maintenance, alimony etc. against each other
in future.

2. That the Parties are living separately, have not cohabited as husband
and wife, for the past two years, before the presentation of this Petition and
there are irreconcilable differences between the Parties, resulting in an
irretrievable breakdown of marriage.
3. That the consent of the Parties have not been obtained by any fraud,
force or undue influence.

4. That the Parties agrees to file petition under section 13 (b) of the
Hindu Marriage Act 1955 for a Decree of Divorce by before the appropriate
court within 15 days of signing of this Memorandum of Understanding so as
to proceed to get the decree of divorce by mutual consent passed by the
appropriate Court

5. That the Parties undertake to abide by the terms and conditions of this
Memorandum of Understanding and it has been further mutually agreed
between the First Party and Second Party, that this Memorandum of
Understanding is irrevocable and shall not be revoked/cancelled rescinded
under any circumstances. This is a full and final settlement. There has been an
understanding between both parties that no further payment will be made to
the second party till the full and final divorce does not come through.

IN WITNESS WHEREOF the First Party, the Second Party, the Third Party and the
Fourth Party have put their hands on this Memorandum of Understanding on the
date, month and year first above written in the presence of the following witnesses

1. (_____________)
First Party

2. (_________)
Second Party
 COMPROMISE DEED

This Compromise Deed is made at ____ on this ___ day of ______.

BETWEEN

Mr. ____, S/o Mr. ____, R/o _______ (hereinafter referred to as the
“First Party”), which expression shall unless, opposed or repugnant
to the context or expressly excluded by the context or by law,
mean and include his heirs, legal representatives, administrators,
executors, nominees and assigns of the First Part.
And
Mrs. _______, D/o _______, R/o _______, (hereinafter referred to as
the “Second Party”) which expression shall unless, opposed or
repugnant to the context or expressly excluded by the context or
by law, mean and include her heirs, legal representatives,
administrators, executors, nominees and assigns of the First Part.

WHEREAS the marriage ceremony between First Party and the

Second Party was conducted at _______ on _______.

WHEREAS after the marriage, the Parties lived together at ____.

The Parties have one daughter from this wedlock namely Ms.
_______, who was married on _______ & is living happily with her
husband in _______.

WHEREAS the Parties have been living separately/ not cohabiting

as husband and wife since _______, and thereafter have not been
able to live together ever since on account of temperamental
differences. Despite best efforts of common friends and relatives
the Parties have been unable to reconcile their differences. There
is now no possibility of their living together as husband and wife.

WHEREAS the Parties have mutually agreed that their marriage

may be dissolved by decree of divorce by mutual consent as there
are irreconcilable differences between the Parties.

WHEREAS the First Party and Second Party have mutually agreed
to entered into this “Compromise Deed, whereby the First Party
and Second Party have agreed to dissolve their Marriage by
mutual Decree of Divorce on the terms and conditions contained
herein. Whereas the First Party and the Second Party have agreed
to deduce the terms and condition of this Compromise Deed in
writing.

NOW THIS COMPROMISE DEED WITNESSETH AS UNDER:-

6. That as mutually agreed the Parties have agreed that their

marriage may be dissolved by a decree of divorce on the following
terms and conditions:
(i) The Parties are jointly owing Apartment No. __________
(hereinafter referred to as the “said Apartment”) in
which the First Party & Second Party have __% Share
each. The Second Party shall relinquish __% Share of
her rights in the said Apartment and transfer her share
in the name of the First Party before going to the court
for recording of Statement for the Motion under
Section 13 (b) of the Hindu Marriage Act, 1955, subject
to the following conditions:-

(a) That the First Party shall execute and get

registered an Irrevocable Will bequeathing his __
% Share in the said Apartment in favour of his
only married daughter _______ and the First Party
undertakes not to ever change his will in his life
time.

(b) In case the First Party ever decides to sell the

“said Apartment” and buy another Residential
Property, the First Party shall purchase the said
Residential Property jointly in his name and in
the name of his Married Daughter _______, with
both the First Party and _______ having __%
share each and the First Party undertakes not to
ever change his will in his life time.

(ii) The First Party further undertakes that he shall execute

and get registered an Irrevocable Will bequeathing all
his other Movable and Immovable Properties (Present
and Future) in favour of his only married daughter
_______ and the First Party undertakes not to ever
change his will in his life time.

(iii) The First Party shall pay an amount of Rs.______/-

(Rupees ______ Only) to the Second Party towards full &
final settlement of payment for her maintenance &
alumni to the Second Party in the following manner:-

(a) The First Party have already paid to the Second

Party an amount of Rs.______/- (Rupees ______
only) vide Demand Draft No.______ dated ______,
drawn on ______ Branch, and in favour of the
Second Party, at the time of signing the
“Compromise Deed, and the said payment of
Rs.______/- (Rupees ______ only) already stands
reflected in the said “Compromise Deed”. The
Second Party doth hereby acknowledges and
confirms the receipt of the said amount of
Rs.______/- (Rupees ______ only) from the First
Party. It is further agreed by the Second Party
that in case the Second Party does not come to
the Court and record her statement to give
consent to the passing of Decree of Divorce by
mutual consent for dissolution of their marriage
by the Hon’ble Court, then the Second Party
shall be liable to refund the amount of
 Rs.______/- already paid by the First Party to the
Second Party as per this para then the Second
Party shall be liable to forthwith refund to First
Party the said amount of Rs.______/- along with
interest calculated @__% per annum from the
date of payment to the date of refund.

(b) The First Party shall further pay the balance

amount of Rs.______/- (Rupees ______ only) to the
Second Party, by way of a Bank Draft drawn in
favour of the Second Party before going to the
Court for recording of the statement of the
Second Party before the Court under Section 13
(b) of the Hindu Marriage Act 1955 for giving
consent to the passing of decree of Divorce by
mutual consent for dissolution of their marriage
by the Hon’ble Court. It is further agreed by the
Second Party that in case the Second Party does
not come to the Court and record her statement
to give consent to the passing of Decree of
Divorce by mutual consent for dissolution of
their marriage by the Hon’ble Court, then the
Second Party shall be liable to refund the
amount of Rs.______/- (Rupees ______ only)
already paid by the First Party to the Second
Party as per this para then the Second Party
shall be liable to forthwith refund to First Party
the said amount of Rs.______/-(Rupees ______
only) along with interest calculated @__% per
annum from the date of payment to the date of
refund.

(iv) The Second Party has already taken all her Jewellery,
Cloths, & all other belongings of her. The First Party
have also given to the Second Party ______ Car
No.______. The ______ Car No.______ is hypothecated to
Finance Company and the First Party undertakes to
pay the EMI or repay the full loan. It is clearly
understood that the Second Party shall get the Car
free of any loan/encumbrances.

(v) The Second Party has received her entire stridhan. It

is further stated that both the Parties have settled
their disputes amicably and shall have no other
claims regarding maintenance, alimony etc. against
each other in future.

2. That the Parties are living separately, have not cohabited as

husband and wife, for the past two years, before the presentation
of this Petition and there are irreconcilable differences between
the Parties, resulting in an irretrievable breakdown of marriage.

3. That the consent of the Parties have not been obtained by

any fraud, force or undue influence.
4. That the Parties agrees to file petition under section 13 (b) of
the Hindu Marriage Act 1955 for a Decree of Divorce by before the
appropriate court within 15 days of signing of this Compromise
Deed so as to proceed to get the decree of divorce by mutual
consent passed by the appropriate Court

5. That the Parties undertake to abide by the terms and

conditions of this Compromise Deed and it has been further
mutually agreed between the First Party and Second Party, that
this Compromise Deed is irrevocable and shall not be
revoked/cancelled rescinded under any circumstances. This is a
full and final settlement. There has been an understanding
between both parties that no further payment will be made to the
second party till the full and final divorce does not come through.

IN WITNESS WHEREOF the First Party, the Second Party, the

Third Party and the Fourth Party have put their hands on this
Compromise Deed on the date, month and year first above written
in the presence of the following witnesses

1. (__________)
First Party

2. (__________)
Second Party