Christian Divorce Petition

IN THE COURT OF THE LEARNED court_type, district

Divorce Petition No. _____ of year

petitioner_name ... Petitioner / Husband/Wife

VERSUS

respondent_name ... Respondent / Wife/Husband

PETITION FOR DISSOLUTION OF MARRIAGE UNDER SECTION 10 OF THE DIVORCE ACT, 1869

Respectfully sheweth:

1. That the Petitioner and the Respondent are both of Christian faith and were validly married according to the rites and customs of the Christian Church on marriage_date at marriage_place, as evidenced by the marriage certificate dated marriage_certificate_date (Annex A).

2. That the Petitioner is petitioner_gender and the Respondent is respondent_gender, and both are domiciled in Pakistan. The Petitioner has been ordinarily resident in Pakistan for residence_period.

3. That the Petitioner and the Respondent cohabited as husband and wife from marriage_date to cohabitation_end_date at cohabitation_address.

4. That the marriage has broken down irretrievably, and the Petitioner seeks dissolution of the marriage under Section 10 of the Divorce Act, 1869, on the following grounds: dissolution_grounds.

5. specific_ground_1_details.

6. specific_ground_2_details.

7. That the Petitioner petitioner_innocence_claim. The marriage has irretrievably broken down due to cause_of_breakdown.

8. That there are number_of_children children born of this marriage, namely: children_details. The Petitioner intends to arrange for child_care_arrangement.

9. That the Petitioner dower_and_maintenance_terms. The settlement agreed is financial_settlement.

10. That no reconciliation between the parties is possible, and the efforts made by reconciliation_efforts_by to bring about reconciliation have failed.

11. That this Honourable Court has jurisdiction to entertain this petition under the Divorce Act, 1869, read with the Family Courts Act, 1964. The Petitioner is jurisdictional_qualifying_factor.

12. That the petition is duly valued at Rs. petition_value for purposes of court fees and jurisdiction, and is within the cognizance of this Honourable Court under the applicable provisions of family law statutes.

PRAYER

It is, therefore, most respectfully prayed that this Honourable Court may be pleased to:

(a) Grant a decree of dissolution of marriage between the Petitioner and the Respondent with effect from dissolution_effective_date;

(b) Pass such orders as deemed appropriate regarding the custody and maintenance of minor children;

(c) Pass such orders as deemed fit regarding the payment of dower and other financial obligations of either party; and

(d) Pass such further or other order as deemed just and proper in the circumstances of the case.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of the above petition are true and correct to the best of my knowledge and belief, and nothing material has been concealed.

_____________________________ petitioner_name Petitioner / Husband/Wife Through: _____________________________ counsel_name Advocate