DIVORCE NOTICE
Date
To,
Sir,
Under instruction from and on behalf of my
client Smt. _________ daughter of Shri __________, resident of
_________________, I do hereby serve you with the following notice, the
contents of which are set forth herein below :-
1. That you were
married with my client about ______ years ago at _____________, according to
Hindu rites and ceremonies in the presence of friends, relatives and family
members of both the parties.
2. That after the marriage you and my client
lived together as husband and wife and cohabited with each other at ___________
and . Out of the said wedlock of my said client and you one son named _____
aged __ years, _____ daughter aged __ years were born.
3. That at the time
of solemnization of this marriage the parents of my client had given sufficient
dowry articles to you. At the time of marriage you were involved in unsocial
activities. You used to consume wine daily and were also involved in gambling.
You started adopting cruelties mentally as well as physical upon my client and
whenever my client tried to mend your ways then you and your mother mercilessly
beat my client.
4. That your attitude towards my client was very
rude and indifferent from the very beginning and my client always fulfilled
your illegal demands time to time. Your mother always taunted my client and
said if she was interested to live in the matrimonial house then she would have
to bear all the atrocities and cruelties.
5. That my client was of the opinion that after
the birth of children you will improve your acts and behaviour and would leave
your bad habits but you did not do so and you and your mother always abused,
insulted, maltreated and misbehaved my client. Your mother refused turned out
my client time to time from her matrimonial house.
6. That on
_____________ you turned out my said client from her matrimonial house in three
wearing clothes. You kept the children of my said client in our custody. Since
the month of ____________ you and your above said mother are black mailing my
client and her family members. You and your family members threatened to my
client and her family members threatening my client for dire consequences
according and as per directions of mother. You have refused to return the
entire dowry articles and jewelaries of my said client. You have deserted my
said client and hence my said client is not interested to live in your client.
My client is also not interest to take the custody of the minor children from
you. It my client would join your company then you would cause her death hence
my client wants to dissolve her marriage immediately.
I, therefore, call
upon you through this legal notice to execute the Divorce Deed and papers etc.
dissolving this marriage immediately within a period of 15 days from the date
of receipt of this legal notice, failing which my client shall constrained to file
appropriate proceedings against you in the court of law and in that event you
shall be responsible for all costs, risks and responsibilities which you please
note well.
A copy of this legal notice is retained in my
office for record and further necessary action.
Advocate