1.
That the marriage between the Petitioner and the Respondent was
solemnized on 25.02.2015 at Sangam Vihar, Delhi in accordance with
Hindu rites and ceremonies. The said marriage was an arranged one and
was performed without any demand of dowry, gifts, or articles. The
parties cohabited as husband and wife at the matrimonial home situated at
C-411, Budh Nagar, Inderpuri, New Delhi – 110012.
2. That the Petitioner is aged about 34 years and is a graduate in Commerce
(B.Com) and a postgraduate in Finance (MBA), currently working as a
Consultant. The Respondent is aged about 35 years and is educated up to
M.A., having qualified the CTET Examination. At the time of marriage,
she was working as a Guest Teacher in Kendriya Vidyalaya, Pushp Vihar,
Saket, drawing a salary of ₹26,000/- per month.
3. That two daughters were born from the said wedlock, namely:
o Trisha Khanna, born on 01.02.2016, currently in Class IV; and
o Bhavishka, born on 08.04.2021, currently enrolled in Nursery;
Both daughters are studying at J.D. Tytler School, New Rajender
Nagar, New Delhi.
GROUNDS FOR DIVORCE:
4. From the very inception of the marriage, the Respondent has shown an
unwilling and hostile attitude towards cohabiting in the joint family
structure. She persistently demanded that the Petitioner sever all ties with
his family and live separately. This coercive demand caused significant
mental stress and strain to the Petitioner, who, being the only son living
with his aged parents and unmarried brother, was deeply burdened by
familial responsibilities, especially after the untimely demise of his
mother on 16.05.2018.
5. The Respondent repeatedly picked fights on trivial matters and used
abusive and derogatory language in the presence of family members and
neighbors, causing the Petitioner public embarrassment and humiliation.
Her demeanor remained aggressive and quarrelsome, making it
impossible for the Petitioner to live with peace and dignity in his own
home.
6. On multiple occasions, the Respondent left the house for hours without
informing anyone, even leaving the minor daughter unattended at home.
When questioned, she responded with aggression and, on at least one
occasion, physically assaulted the Petitioner, indicating complete
disregard for her duties as a wife and mother.
7. That in 2017, the Respondent, under pressure from her father and family,
underwent an illegal gender determination test and, upon learning the
fetus was female, consumed certain pills administered by her father,
resulting in miscarriage. This was repeated in 2018. Such acts not only
reveal a criminal mindset but also show cruelty towards the unborn
female child, and caused severe psychological trauma to the Petitioner,
who opposed such actions.
8. That on 21.06.2024, the Respondent, after causing self-inflicted injury by
hurling steel glasses in anger, falsely accused the Petitioner of physical
assault. She called the police and got the Petitioner detained at PS
Inderpuri under a concocted complaint. The next day, when he returned
home, he discovered that the Respondent’s brothers had taken away cash
and jewelry from the house, which was later confirmed via CCTV
footage. A complaint dated 24.06.2024 was filed by the Petitioner
regarding this theft and harassment.
9. That on 15.07.2024, the Petitioner received a call from the Women Cell,
PS Malviya Nagar, where the Respondent had lodged a false complaint,
influenced by her parents. However, during reconciliation, the
Respondent admitted before the authorities on 18.07.2024 that the
complaint was lodged on the insistence of her family members and
withdrew the same. Despite this, she never returned the stolen jewellery
fully and continues to behave abusively.
10.That after returning to the matrimonial home, the Respondent began
subjecting the Petitioner and his father to daily threats, shouting, and
insults. She flatly refused to return the gold chain and pendant gifted by
the Petitioner’s late mother and mocked the Petitioner’s emotional
sentiments attached to it. The verbal and emotional abuse continues
unabated.
11.The Petitioner, being repeatedly subjected to false complaints, police
harassment, and theft, lives under constant fear of being framed again in
fabricated cases by the Respondent and her family, which constitutes
grave mental cruelty.
12.That the Respondent, without any reasonable cause or provocation, has
been subjecting the Petitioner to continuous mental agony, emotional
blackmail, and psychological pressure. She has made the matrimonial
home a living hell for the Petitioner by engaging in habitual nagging,
belittling his professional stature, questioning his ability to provide, and
ridiculing him in front of relatives and even the minor children, thereby
severely denting the Petitioner’s self-esteem and mental well-being.
13.That the Respondent has persistently denied the Petitioner his rightful
companionship and has failed to fulfill her matrimonial obligations. Her
attitude has been devoid of warmth, understanding, and mutual respect.
She has displayed complete disinterest in maintaining the sanctity of the
matrimonial relationship and has deliberately ignored her duties as a wife
and as a daughter-in-law, creating an emotionally toxic and unstable
domestic environment.
14.That the Respondent, during almost every domestic disagreement, has
resorted to threats of implicating the Petitioner and his family members in
false criminal cases, including dowry harassment and domestic violence
cases. The constant threats of litigation have left the Petitioner mentally
distressed and emotionally vulnerable. The Respondent has misused her
position as a wife to coerce the Petitioner into submission through such
intimidatory tactics, which amount to grave cruelty.
15.That the Respondent has often interfered in the Petitioner’s professional
commitments by making repeated calls during office hours, creating
scenes on trivial issues, and falsely accusing him of character flaws and
financial mismanagement before his colleagues and friends. Her actions
have tarnished the Petitioner’s image in society and have led to
significant emotional distress and social embarrassment.
16.That the Respondent has, on various occasions, made false and
scandalous allegations regarding the Petitioner’s character and fidelity,
without any basis or evidence. Such baseless accusations, made not only
in private but also in front of extended family and friends, have caused
irreparable damage to the Petitioner’s dignity, peace of mind, and social
reputation.
17.That despite repeated attempts by the Petitioner and his family members
to mend the relationship, the Respondent has shown a non-cooperative
attitude and has never displayed a genuine intent to preserve the marriage.
Even during counselling at the Women Cell, her return was conditional
and mechanical, and she continued her cruel conduct post reconciliation.
The Petitioner submits that all efforts of revival have failed due to the
Respondent’s rigid and disrespectful conduct.
18.That due to the frequent quarrels, verbal abuse, and threats in the
presence of their minor daughters, the children are being forced to grow
in a deeply disturbing and violent household atmosphere. The Petitioner
apprehends that continued exposure of the children to such traumatic
environment would have long-lasting negative effects on their mental
health and emotional development.
19.That the cause of action for the present petition arose initially on
16.05.2018 with the death of Petitioner’s mother and gradually intensified
with the Respondent’s hostile behavior, false complaints, forced abortion,
and culminated in the police episode dated 21.06.2024, theft, and
withdrawal of false complaint on 18.07.2024. The cruelty is ongoing, and
the Petitioner finds it impossible to continue marital relations with the
Respondent.
LIST OF ANNEXURES:
Annexure A: Copy of Marriage Certificate dated 25.02.2015
Annexure B: Birth Certificates of daughters Trisha Khanna and Bhavishka
Annexure C: Copies of school fee receipts/admission documents from J.D.
Tytler School
Annexure D: Copy of Police Complaint dated 24.06.2024 filed by the Petitioner
Annexure E: Photographs of injuries/self-inflicted wound used by the
Respondent
Annexure F: Extracts of CCTV Footage showing Respondent’s family removing
items
Annexure G: Copy of Complaint filed at Women Cell, PS Malviya Nagar
Annexure H: Letter/Record of mediation proceedings at Women Cell dated
18.07.2024
Annexure I: List of missing/stolen jewellery and cash as per locker inventory
Annexure J: Copy of employment proof and income details of the Petitioner
Annexure K: Respondent’s written statement/admission during reconciliation
proceedings
(Additional annexures may be filed at the time of evidence or as directed by this
Hon'ble Court.)
