Divorce petition under Section 13(1)(ia) Hindu Marriage Act with supporting affidavit
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IN THE COURT OF THE LEARNED PRINCIPAL JUDGE, FAMILY COURT, TIS HAZARI COURTS, DELHI.
H.M.A. CASE NO. HMA case number OF 2022.
IN THE MATTER OF :-
Petitioner's name: PETITIONER
VERSUS
Respondent's name: RESPONDENT
P.S. Police station
INDEX
S.NO.PARTICULARS PAGES
1.MEMO OF PARTIES + C.F.
2.PETITION FOR DISSOLUTION OF MARRIAGE BY A DECREE OF DIVORCE, AS AMENDED BY THE MARRIAGE LAWS (AMENDMENT) ACT, 1976, UNDER SECTION 13(1)(ia) OF THE HINDU MARRIAGE ACT, 1955, WITH SUPPORTING AFFIDAVIT.
3.LIST OF DOCUMENTS.
4.VAKALATNAMA.
DELHIPETITIONER
THROUGH
DATED
Advocate's name
Advocate
Advocate's office address,
New Delhi-110015
Mob. No. Advocate's mobile number
Email:
IN THE COURT OF THE LEARNED PRINCIPAL JUDGE, FAMILY COURT, TIS HAZARI COURTS, DELHI.
H.M.A. CASE NO. HMA case number OF 2022.
IN THE MATTER OF :-
Petitioner's name: PETITIONER
VERSUS
Respondent's name: RESPONDENT
P.S. Police station
MEMO OF PARTIES
Petitioner's name: PETITIONER
VERSUS
Respondent's name: RESPONDENT
DELHIPETITIONER
THROUGH
DATED
Advocate's name
Advocate
Advocate's office address,
New Delhi-110015
Mob. No. Advocate's mobile number
Email:
IN THE COURT OF THE LEARNED PRINCIPAL JUDGE, FAMILY COURT, TIS HAZARI COURTS, DELHI.
H.M.A. CASE NO. HMA case number OF 2022.
IN THE MATTER OF :-
Petitioner's name: PETITIONER
VERSUS
Respondent's name: RESPONDENT
P.S. Police station
A PETITION UNDER SECTION 13(1)(ia) OF THE HINDU MARRIAGE ACT, 1955, ON BEHALF OF THE PETITIONER, FOR DISSOLUTION OF MARRIAGE BY A DECREE OF DIVORCE, AS AMENDED BY THE MARRIAGE LAWS (AMENDMENT) ACT, 1976.
MOST RESPECTFULLY SHOWETH :-
1.That the marriage between the parties hereto was duly solemnized at Marriage venue, Dwarka, Delhi, on Date of marriage, in accordance with Hindu customs, rites and ceremonies, without any exchange of dowry.
2.That the petitioner is a law-abiding citizen of India and has always maintained peace and tranquility, and has discharged his social and moral obligations and liabilities in a fair manner; till date, no grievance against the petitioner is pending redressal before any forum.
3.That the status and place of residence of the parties to the marriage, before marriage and at the time of filing of the present petition, are as follows: -
H U S B A N D / P E T I T I O N E R
| Status | Age | Place of residence |
| Before Marriage | Bachelor, Hindu | Husband's age before marriage years | Husband's residence, Delhi-110059. |
| At the time of filing the present petition | Married, Hindu | Husband's age at filing years | -do- |
W I F E / R E S P O N D E N T
| Status | Age | Place of residence |
| Before Marriage | Spinster, Hindu | Wife's age before marriage years | Wife's residence before marriage |
| At the time of filing the present petition | Married, Hindu | Wife's age at filing years | -do- |
4.That the petitioner and the respondent were Hindus at the time of the solemnization of their marriage, and both continue to profess the same religion as on the date of filing of the present petition.
5.That after the marriage, the parties lived together as husband and wife and cohabited with each other. No child has been born out of the said wedlock. The respondent is presently residing at her parental home and has never shown any desire to discharge her matrimonial duties.
6.That the marriage between the petitioner and the respondent was solemnized in a low-profile manner and without any exchange of dowry.
7.That the petitioner and his wife last lived together in the matrimonial home on Date wife left matrimonial home, on which date she left the petitioner's house, taking with her all her belongings and valuables, including jewellery, from the matrimonial home.
8.That within a few days of the marriage, the respondent began picking quarrels with the petitioner, throwing unnecessary tantrums and subjecting the petitioner to mental cruelty by using harsh words in almost every conversation.
9.It is submitted that the petitioner always bestowed love and affection upon the respondent. Whenever the petitioner was away, the entire household remained in her custody, with no one to supervise her; taking advantage of this liberty, the respondent left the house with all the articles.
10.That the petitioner and the respondent first met each other in the year Year parties met, and the relationship, which began as a casual friendship, gradually developed into love, culminating in their decision to marry each other.
11.That Name of respondent's former boyfriend, a childhood friend of the respondent, shared a close relationship with her, and the two were having an affair with each other. The petitioner had met the respondent at the birthday party of their common friend, Name of common friend, in May Year of birthday party meeting, where there was only a formal introduction between them; thereafter, they met on a couple of occasions. When the family members of Name of respondent's former boyfriend learnt of the relationship, they opposed it, which resulted in the breakdown of the relationship between Name of respondent's former boyfriend and the respondent.
12.That Name of respondent's former boyfriend felt distressed at the breakdown of the relationship, but did not have the courage to go against the wishes of his family members, and therefore requested the petitioner to console the respondent and give her some company. It was only at the instance of Name of respondent's former boyfriend that the petitioner met the respondent on a couple of occasions. Over a period of time, and after a few meetings, the petitioner and the respondent became friends and began to enjoy each other's company.
13.That the petitioner fell in love with the respondent over a period of time, and the petitioner and the respondent travelled to First travel destination for a day, checking in on Check-in date of first trip and checking out on Check-out date of first trip. Thereafter, the petitioner and the respondent travelled together to Second travel destination and stayed there from Start date of second stay to End date of second stay. The respondent's cousin also came to the said premises along with his friends. The respondent met her cousin but did not introduce the petitioner to him, stating instead that she had come along with many other friends and that they were not alone.
14.That the petitioner was shocked that the respondent was unwilling to introduce him to her family members, and that she was keeping their relationship a secret from her family and friends.
15.That the petitioner and the respondent decided to spend the New Year together at Goa. The petitioner booked the air tickets and hotel accommodation, and they were together at Goa from Start date of Goa trip, where they stayed together. At Goa, in full public view, the petitioner proposed marriage to the respondent and presented her a ring as a token of his love, which the respondent accepted. A true copy of the flight tickets is annexed hereto as Annexure P1.
16.That the petitioner thereafter asked the respondent whether she would be able to inform her family members about their relationship, to which she replied that there was no urgency in informing her parents about the relationship and that she did not wish to marry any time soon. The petitioner, on the other hand, wished to marry the respondent, as the petitioner's mother was medically unfit and suffering from numerous medical conditions, and the petitioner's father was suffering from uncontrolled diabetes, pulmonary edema (a condition caused by excess fluid in the lungs, making breathing difficult), coronary artery disease (narrowing or blockage of the coronary arteries) and various other ailments, and was mostly confined to bed. The petitioner's father, desiring that the petitioner, being the elder son, should marry, given the uncertain future of the family on account of these medical complications.
17.That the petitioner desired the respondent to commit to the marriage so that their relationship could be taken to the next stage. The respondent, on the other hand, wanted complete freedom for herself, was unwilling to commit to any relationship, and was content to carry on the relationship without any baggage of commitment, family pressure or accountability to anyone.
18.That the respondent was residing at Respondent's PG address in a paying guest accommodation, stating that she was pursuing some post-graduation course; however, in fact she was not pursuing any post-graduation and was working in a night-shift job. On the pretext of pursuing post-graduation, the respondent was content to stay away from her family and away from the clutches of the relationship.
19.That the respondent regularly asked the petitioner for money, which was either transferred by the petitioner himself, or the petitioner requested his brother to transfer funds to the account of the respondent. This is evident from the receipt/email evidencing transfer of the amount into the bank account of the respondent by the brother of the petitioner, which is annexed as Annexure P2.
20.That the family members of the petitioner came to know of his relationship with the respondent, and the petitioner was questioned about it. The petitioner clearly told his parents that he would marry the respondent and no one else. The mother of the petitioner agreed and stated that if he was so deeply in love with her, there was no harm in their getting married. The parents of the petitioner consented to the marriage even though the petitioner and the respondent belonged to different castes, as the family of the petitioner is Petitioner's caste by caste and the respondent is Respondent's caste by caste.
21.That the petitioner discussed the issue with the respondent, who was initially unwilling to marry him, but at the insistence of the petitioner she agreed to discuss the matter with her parents. Thereafter, the respondent and her mother visited the office of the father of the petitioner, where her mother clearly stated that they did not have much money and hence could not spend much on the marriage. The mother of the respondent further stated that they had no relatives at Marriage city who could make arrangements there, and therefore the entire arrangements would have to be made by the parents of the petitioner.
22.That the engagement between the petitioner and the respondent took place on Date of engagement at Engagement venue, and the entire arrangement for the engagement ceremony was made by the parents and family members of the petitioner. There was never any contribution from the respondent or her family members.
23.That the petitioner and his family members were happy and showed their love and care towards the respondent and her family members; on the other hand, the respondent and her family members showed no enthusiasm or emotion and sat together in a huddle without much cheer or expression on their faces.
24.That after the engagement, the behaviour of the respondent towards the petitioner changed completely, and she did not allow the petitioner to spend much time with her. However, the petitioner was not alerted by this change of attitude, and only subsequently realised that there had been a change in her attitude immediately after the engagement.
25.That the petitioner and his parents, being excited about the first marriage in their family, took the respondent for shopping, purchased her lehenga and bridal makeup, booked the marriage venue, booked accommodation for the respondent and her family members to stay, and made arrangements for their guests.
26.That the petitioner and his family members bore the entire expenditure towards the marriage, and the respondent and her family members made very little contribution towards the marriage expenses. As the family of the respondent had informed the petitioner that they would not be in a position to manage anything at Marriage city, it fell upon the petitioner and his family members to arrange everything.
27.That the family of the respondent transferred some amount towards sharing of the expenditure; however, when they came to Marriage city, they took cash from the petitioner and his family members for purchasing their own clothes and articles. Thus, there was no, or very little, contribution from the respondent or her family members towards the marriage. The respondent had taken a personal loan for the marriage, and the petitioner paid the principal and interest towards its repayment. A true copy of the receipts received in electronic form towards repayment of the loan taken by the respondent is annexed as Annexure P3.
28.That the marriage of the petitioner with the respondent was solemnised as per Hindu rites and ceremonies on Date of marriage at Marriage venue without any exchange of dowry. The expenses of the marriage were borne by the petitioner. A true copy of the bank statement and cheque towards the said expenses of Rs.Marriage expenses amount (₹)/- is annexed as Annexure P4 (colly.).
29.That it is submitted that the father of the petitioner also paid some amount in cash towards the balance payment of the marriage expenses; the receipts thereof are being searched for by the father of the petitioner, who undertakes to file the same as soon as they are found.
30.That after the marriage, the respondent was completely reluctant to create any physical relationship with the petitioner, even though earlier they had enjoyed each other's company. After the marriage, the respondent did not allow the petitioner to come close to her, and the petitioner was not permitted even once to have any physical relationship with the respondent.
31.That the respondent further disrespected the parents of the petitioner on several occasions and was never willing to talk to them. The respondent would sit in her room for long hours without making any effort to speak to them. The parents of the petitioner treated her like their own daughter and purchased things to please her, be it clothes, jewellery, food, etc.; however, the respondent remained least responsive.
32.That the petitioner also showered all his love and affection upon the respondent, but the same was not reciprocated.
33.That within a few days of the marriage, the respondent began regularly picking up fights with the petitioner on each and every issue. The respondent appeared to be looking for an opportunity to fight with the petitioner, would raise disputes over the smallest of issues, and never made any effort to adjust to family life. She would always be engrossed in her mobile phone and would remain awake at night chatting on the phone.
34.That in the middle of the night, the respondent started fighting with the petitioner over trivial issues and disturbed the peace of the entire family. The mother of the petitioner was always on medication, and any such disturbance would wake her up, leaving her unable to sleep any further. The petitioner made every effort to persuade the respondent, but she, on the other hand, told the petitioner that she did not wish to reside with the parents of the petitioner and demanded a separate house for herself.
35.That the petitioner told the respondent that he could not leave his parents, as both were suffering from various ailments — particularly the mother of the petitioner, who was suffering from uncontrolled sugar, pulmonary edema, coronary artery disease, etc., and required constant care. However, the respondent remained adamant on her demand.
36.That the petitioner, having been left with no other option and for the sake of his matrimonial life, agreed to the demand of the respondent, and thereafter he, along with the respondent, arranged rented accommodation at Rented accommodation locality. The rent agreement was prepared in the names of both the petitioner and the respondent, at a monthly rent of Rs.Monthly rent (₹)/- per month. A true copy of the rent agreement is annexed herewith as Annexure P5.
37.That the petitioner and the respondent shifted to the rented accommodation and started living separately from the father and mother of the petitioner, as per the demand of the respondent.
38.That even after the parties shifted to separate accommodation, the attitude of the respondent did not change and she continued to fight with the petitioner. She was not even once loving, caring or affectionate towards the petitioner.
39.That the constant quarrels and fighting over petty issues began to take a toll on the petitioner, and he started suffering from depression.
40.That the aforesaid mental condition of the petitioner was easily discernible to the respondent, but she did not care for the petitioner at all.
41.That the petitioner suffered from lack of sleep and would remain awake throughout the night, disturbed by the entire situation. His love for the respondent was abundant; however, he did not receive the same response from her, which hurt him deeply.
42.That one day, the father of the petitioner received a telephone call from the landlord of the petitioner, who informed him about the mental condition of the petitioner.
43.That the father of the petitioner rushed to the house of the petitioner and found him in an acute state of depression. The petitioner was in a very bad condition, and his father took him to Name of hospital where petitioner was treated for treatment. The respondent, on the other hand, showed no emotion or respect towards the petitioner, and in the month of Month respondent left matrimonial home she left the house.
44.That while leaving the house, the respondent took all her belongings and valuables with her. The respondent, being the wife of the petitioner, ought to have taken care of him, but she never showed him any love or respect, and when he needed her by his side, she was nowhere to be found.
45.That the petitioner sent numerous messages to the respondent seeking some response from her, but she showed no reciprocation and remained unmoved. The petitioner shared photographs of the good times they had spent together and sent voice messages while crying and imploring her to be at his side, to return and to be with him, but the respondent failed to do so.
46.That the petitioner also sent an e-mail to the respondent, pouring his heart out and requesting her to come back, but the respondent again failed to respond. On Date of email to respondent, the petitioner sent an e-mail to the respondent, which is reproduced hereinbelow and which clearly shows the love of the petitioner for the respondent and his mental condition consequent upon her leaving his company without any reason:-
•“Text of email describing petitioner's condition”
47.That the petitioner is still deeply in love with the respondent and wants her to be by his side. The respondent left the petitioner in Month/year respondent left petitioner without any rhyme or reason, and at a time when he was unwell and suffering from depression.
48.That all the sincere efforts of the petitioner, his family and his friends to bring the respondent back to the matrimonial home, so as to enable her to resume her matrimonial obligations, have borne no fruit, and the petitioner continues to be made to suffer.
49.That the respondent has thus left the matrimonial home, withdrawn from the society of the petitioner and deserted him, and the aforesaid acts of the respondent are without any just or reasonable cause, without the consent of the petitioner and against his wishes.
50.That the petitioner, thereafter, having been left with no other option, was constrained to file a petition under Section 9 of the Hindu Marriage Act, 1956 before the court of the Ld. Principal Judge, Family Courts, Court and district where Section 9 petition was filed. A true copy of the petition under Section 9 of the Hindu Marriage Act, 1956 is annexed as Annexure P6.
51.That when the respondent came to know of the filing of the aforesaid petition, she, in order to safeguard herself, lodged a false and frivolous F.I.R. bearing Crime No.FIR number under Sections 498A/323/504 of the Indian Penal Code read with Sections 3 & 4 of the Dowry Prohibition Act, with Police Station Police station and district where FIR was lodged, against the petitioner and his family members. The entire F.I.R. is based on assumptions and does not state even a single word about the commission of any offence whatsoever.
52.That the respondent is the legally wedded wife of the petitioner and is thus legally and morally bound to perform her marital obligations. It is incumbent upon her to fulfil her matrimonial obligations, including cohabiting with the petitioner, which obligations she has miserably failed to discharge without any just or reasonable cause.
53.That the respondent has further committed various acts of mental and physical cruelty against the petitioner and his family members, and has also severely damaged his reputation and goodwill.
54.That the respondent, with an intent of travelling to new destinations outside India, forced the petitioner to indulge in numerous misadventures, which left the petitioner financially and mentally exhausted, and he has also suffered immensely in respect of his job prospects and options.
55.That the petitioner tried to fulfil all the demands of the respondent with the sole hope of restoring the happiness and togetherness of the family; however, the respondent never bothered about any such matters and has deserted the petitioner without any rhyme or reason.
56.That the respondent was never in love with the petitioner. She used to pretend that she was in love with him in order to extract money from him. The respondent married the petitioner solely because she was after his money and for nothing else.
57.That it is also pertinent to mention here that the petitioner and his family are financially quite well placed, possessing their own house and a car, and as such there was no need for them to demand a sum of ₹ Alleged dowry demand amount (₹)/- and a car from the respondent or her family members.
58.That the petitioner was suffering from depression on account of the torture and harassment caused by the respondent and remained under treatment in the hospital for a long period of time. A true copy of the documents with regard to the medical treatment of the petitioner is annexed as Annexure P7.
59.That the petitioner and his family fully accommodated the financial condition of the respondent, and even then false allegations were made against them, which shows that the respondent wanted to exert pressure upon the petitioner and his family and to harass them in order to meet her illegal demands.
60.That the marriage between the parties was never consummated, as the respondent refused to have a marital relationship or to start a family. The respondent did not allow the petitioner to touch her, and she has refused to have any relationship with him.
61.That it is submitted that no one from the family of the respondent — her parents, her brother or her sister — has ever visited the home of the petitioner to spend time with them as part of the family. Her family was never keen to build a family-to-family bond, and there was no regular communication except for occasional greetings on birthdays, anniversaries and the like.
62.That the petitioner tolerated her rudeness, reckless attitude, ill-treatment and harassment at all times, firstly because the family of the petitioner believes that marriages are made in heaven, and secondly because the petitioner did not wish to trouble or disturb his parents any further, as they were already spending their lives in very painful circumstances for the reasons stated above. The petitioner raised the issues relating to her behaviour and attitude with her family, whereupon he was threatened that the petitioner and his parents would be implicated in false cases of dowry and harassment and would be put behind bars. The petitioner stopped visiting his in-laws' place thereafter.
63.That during the marriage, neither the petitioner nor anyone from his family ever asked for anything from the respondent or her family by way of gifts or dowry. The petitioner was drawing a good salary and therefore neither expected nor ever thought of demanding anything from the respondent or her family, as such conduct is against the culture of the family of the petitioner.
64.That with the passage of time, the respondent made such fights a routine affair and subjected the petitioner to considerable mental agony and stress by creating a ruckus at their house, which resulted in the petitioner falling sick frequently and damaged his health in every way possible.
65.That the petitioner, being affectionate, did everything possible to make the respondent feel comfortable and loved; however, in return, the respondent quarrelled with the petitioner constantly, which affected his health. That the respondent refused to assist in any household work, complained persistently, and also harassed the petitioner for not having sufficient means to satisfy her whims and fancies. That the respondent did not respond to the love showered upon her by her husband in an ordinary manner; rather, she complained about the weak economic condition of the hardworking petitioner.
66.That the respondent developed an inhuman habit of fighting with and mentally torturing the petitioner, and derived pleasure from the distressed condition of the petitioner, as no person of stable mind would.
67.That the petitioner somehow managed to come out of the trauma caused to him by the respondent and did not disclose the said habit of the respondent to anyone, not even to his own family members, and instead requested the respondent to desist from such behaviour so that the sanctity of the marriage could be maintained.
68.That any sane spouse, upon learning of such dark and disturbing facts regarding the intentions of his partner, would be mentally shattered. That the petitioner underwent the same ordeal and suffered great difficulty in thinking clearly for a couple of months. That during these two months, the petitioner tried to convince the respondent not to bring the marriage to an end, but the respondent turned a deaf ear to his requests and continued to quarrel over petty issues.
69.That the petitioner, having tried everything possible to make the marriage work, attempted to ascertain the whereabouts of the respondent. That the failure of the respondent to revert to the petitioner made him lose all hope of leading a normal married life.
70.That for more than a year, the petitioner tried to contact the respondent but eventually gave up hope of reunion with her.
71.That the respondent had left the matrimonial home of her own volition, as her nefarious demands, including the transfer of property in her name, had not been met.
72.That thereafter, as there remained no chance of reconciliation between the parties, the respondent having categorically expressed her intention to separate from the petitioner.
73.That the petitioner and the respondent were Hindus by religion at the time of the solemnization of their marriage and continue to profess the same religion till the date of filing the present petition. That after the marriage, the parties did not cohabit with each other as husband and wife. There is no issue born out of the said wedlock. That the respondent has been staying at her parental home and has never desired to discharge her matrimonial duties. That the aforesaid series of incidents has resulted in the deterioration of the mental health of the petitioner and has seriously impaired his self-confidence and self-esteem.
74.That it is trite to mention that the conduct and behaviour of the respondent, and the circumstances intentionally created by her against the petitioner, are such that the respondent has caused immense mental cruelty, torture and agony to the petitioner without any fault on his part. That since the respondent, after the marriage, treated the petitioner with utmost cruelty and has wilfully deserted him, as detailed in the foregoing paragraphs, the petitioner is entitled to the dissolution of the marriage by a decree of divorce under Section 13(1)(ia) of the Hindu Marriage Act, 1955, as amended by the marriage laws up to date.
75.That the petitioner is left with no other remedy but to approach this Hon'ble Court. Hence this petition.
76.That there has been no unnecessary or improper delay in filing this petition.
77.That there is no legal ground as to why the relief sought should not be granted.
78.That the marriage was solemnized and the parties last resided together within the limits of the ordinary original civil jurisdiction of this Hon'ble Court. That the parties last resided together as husband and wife at Place of last cohabitation. Hence, this Hon'ble Court has the jurisdiction to entertain the present petition.
79.That the prescribed court fee has been paid and affixed on the petition.
PRAYER
It is, therefore, most respectfully prayed that this Hon'ble Court may graciously be pleased to pass a decree of divorce dissolving the marriage between the parties under Section 13(1)(ia) of the Hindu Marriage Act, 1955, as amended by the marriage laws up to date.
AND
Any other relief which this Hon'ble Court deems fit and proper in the facts and circumstances of the case may also be granted in favour of the petitioner and against the respondent.
PETITIONER
THROUGH
ADVOCATE
Dated: Date of signing petition
Advocate's name
Advocate's address
Mobile No.: Advocate's mobile number
Email: Advocate's email address
VERIFICATION
The above-named petitioner states on solemn affirmation that paragraphs 1 to Number of last paragraph on petitioner's knowledge of the petition are true to the petitioner's own knowledge, and paragraphs Number of first paragraph on information and belief to Number of last paragraph on information and belief of the petition are true to information received and believed to be true. The last paragraph is the prayer made to this Hon'ble Court. Verified at Delhi on this Day of verification day of Month of verification.
PETITIONER
IN THE COURT OF THE LD. PRINCIPAL JUDGE, FAMILY COURT, TIS HAZARI COURTS, DELHI
H.M.A. CASE NO. HMA case number OF Year of the HMA case
IN THE MATTER OF:
Petitioner's name: PETITIONER
VERSUS
Respondent's name: RESPONDENT
AFFIDAVIT
Affidavit of Deponent's name, aged about Deponent's age years, S/o Sh. Deponent's father's name, R/o Deponent's address, do hereby solemnly affirm and declare as under:
1.That the marriage between the petitioner and the respondent was solemnized according to Hindu rites and ceremonies on Date of marriage at Marriage venue.
2.That the accompanying petition under Section 13(1)(ia) of the Hindu Marriage Act, 1955 has been drafted by my counsel under my instructions; the contents thereof are true and correct to my knowledge, and the same may kindly be read as part and parcel of this affidavit, the contents not being repeated herein for the sake of brevity and to avoid repetition.
3.That the contents of the accompanying petition with regard to the acts of cruelty may also be read as part hereof and are not being repeated herein for the sake of brevity.
4.That the marriage between the parties has completely broken down and there is no possibility of the parties living together.
5.That the accompanying petition has not been filed in collusion with the respondent.
6.That there is no impediment in granting the relief sought by the petitioner.
7.That there has been no improper delay in filing the petition.
8.That the petitioner has not in any manner been accessory to or connived at, or condoned, the acts complained of.
DEPONENT
VERIFICATION
I, the above-named deponent, do hereby verify that the contents of the above affidavit are true and correct to my knowledge, that no part of it is false, and that nothing material has been concealed therefrom.
Verified at Delhi on this Day of verification day of Month of verification.
DEPONENT