IN THE COURT OF THE HONORABLE JUDGE FAMILY

COURT; CITY CIVIL COURT

AT: HYDERABAD

F.C.O.P. NO. OF 2024

BETWEEN:

Nagireddy Anusha Rani alias Gandepudi Anusha Rani

w/o Nagireddy Bhaskara Raju,
Aged about 33 years, Occ: Software Employee,
R/o:
, Hyderabad-50. …PETITIONER NO.1

AND

Nagireddy Bhaskara Raju s/o Nagireddy Venkata Ramana,

Aged about 42 years, Occ: Software Employee,
R/o: H.No. 1-44, Rajanagaram Mandalam,
Nandarada Rajanagaram, East Godavari
Andhra Pradesh-533292 …PETITIONER NO.2

PETITION FILED UNDER SEC.13-B (2) OF THE HMA 1955, R/W SEC
7 OF FAMILY COURT ACT, FOR DISSOLUTION OF MARRIAGE BY
MUTUAL CONSENT.

DESCRIPTION OF THE PETITIONERS: -

That the address and description of the Petitioners is the same as

mentioned above in the cause title for the purpose of service of summons,
notices, processes, etc., is that of their counsel B. SRIKANTH, Plot No
#234 Adj Lane to ICICI Bank, Kalyan Nagar, Vengal Rao Nagar,
Hyderabad-38, Telangana State. Mobile No. 9059992948.
I. THE PETITIONERS SUBMITS AS FOLLOWS: -

1. The 1st petitioner is the wife of the 2 nd petitioner. The marriage of the
petitioners was solemnized on date: 13-02-2013 at Sri Shiridi Sai Baba
Devasthanam, Bose Bomma Center Vinukonda, Narasaraopet Andhra
Pradesh, as per Hindu rites and caste customs in the presence of elders,
well-wishers, and friends in both sides and it was an arranged
marriage. The 1st petitioner submits that immediately after the marriage
the she joined in the conjugal society of the 2 nd petitioner. The marriage
of the petitioners has consummated. Out of Wedlock two children were
born and named as 1) Nagireddy Vashist, Aged about: 10 years and 2)
Nagireddy Srivyas, Aged about: 8 years.

2. The petitioners submit that both of them enjoyed conjugal bliss only
for brief period after the marriage till 2021. Thereafter some disputes and
disagreements have been cropped up between the 1 st and 2nd petitioner.
Later on, the temperamental differences, different of opinions as against
each other and incompatibility between the petitioners, dispute and
differences have been arose from day to day, and as such they could not
continue their marital relationship happily which widened with time
without any chance of reconciliation. Thereafter both side’s elders and
well-wishers intervened and negotiations and conciliations were held over
a period and the same were proved futile. Finally, during the 1st week of
February, 2024, the 1st and the 2nd petitioners came to the matrimonial
home of the 1st petitioner. Even during this time also, both the petitioners
behaved like strangers and not like husband and wife. With no other
option, hence the 1st petitioner staying separately and she has been living
at Hyderabad, away from the 2nd petitioner conjugal society since 2021.
Hence the petitioners lastly resided at the 1 st petitioner’s residence in
Hyderabad. And there after the 2nd petitioner have been staying separately
and leading an independent life without interfering with the 1 st
petitioner’s life.

3. During this period also both the petitioners have realized that they have
no feelings of love and affection with each other and their personalities
are incompatible and they have decided to part with respect. Recently the
family members of the petitioners met and discussed over their
matrimonial issue and came a final understanding that their marriage has
been irretrievably and irreversibly broken down.

4. The petitioners submit that the family elders and well-wishers made
efforts from both sides for the reconciliation and reunion of the
petitioners but all those efforts have been in vein. It is submitted that the
marriage between the petitioners have been irretrievably and irrevocably
broken down. The petitioners submit that they have voluntarily come
forward to take divorce by way of mutual consent without any force,
fraud, coercion and undue influence, by anybody. In this backdrop, the
petitioners are inclined to take divorce from each other with mutual
consent rather than living a soul-less life together. As such, both of them
decided to part with respect and came to an opinion applying for
dissolution of their marriage would be the best course of action.

5. The 1st petitioner is not to make any claim what so ever under any head
towards permanent alimony, nor make any other claims in respect of the
movable & immovable properties of the 2nd petitioner or his parents now
and then.
6. The said children are in the care and custody of the Petitioner No. 1 it
has been agreed between the parties that the children above shall remain
in care and custody of the Petitioner No. 1 and only visitation rights
would be granted to Petitioner No.1 as per mutual consent.

7. That petitioner No. 2 shall never claim the custody of the said
children’s and the Petitioner No. 1 has undertaken not to claim any
maintenance from petitioner No. 2 for the said children.

8. Furthermore the 2nd petitioner also undertakes not to make any claim
what so ever in respect of the movable & immovable properties of the 1 st
petitioner or her parents now and then.

9. The petitioners submits that after the dissolution of the marriage, the
petitioners are free to re-marry at their whims and fancies and both the
petitioners further undertake that they shall not involve in other
petitioner’s personal life against each other.

10. Both the petitioners submit that there has been no collusion
whatsoever in making this application and also there is no legal
impediment. Both the petitioners have amicably and mutually settled all
matters and there are no outstanding claims of any nature whatsoever
against each other.

11. The petitioners submit that there is no similar petition before any
other court seeking divorce by mutual consent and this petition is not
filed in collusion with each other.

12. The Petitioners once again submits that the application is being filed
for dissolution of marriage on the ground of irretrievable, irreconcilable,
incompatibility and there is no similar application pending before any
other court.

13. Therefore, both the petitioners pray the Hon'ble Court may be pleased
to dissolve their marriage solemnized between them on 02-06-2013 by
way mutual consent under Section 13-B of the Hindu Marriage Act-1955.
Hence, this petition is filed by the petitioners for divorce by way of
mutual consent.

II. CAUSE OF ACTION:

The cause of action arose for filing the present petition seeking
dissolution of marriage between the parties hereto arose on 02-06-2013,
when the marriage was performed at (Place of Marriage) ,, as per Hindu
Customs and rituals and again on (Date of Living Separate), ever since
then the petitioners started living separately for more than one year and as
they were unable to live together and perform marital obligations
including consummation of marriage, they have therefore mutually
agreed that, the marriage should be dissolved on the terms and conditions
mentioned above.

III. JURISDICTION:

This court is having both territorial and pecuniary jurisdiction as the

Petitioner No.1 is residing (Address). which is within the jurisdiction of
this Hon’ble Court.

COURT FEES: -
A fixed court fees of Rs.__________ is paid herewith Under Article (1) 7
of Schedule of A.P.C.F.& S.V. Act which is sufficient.

IV. PRAYER: -

The petitioners therefore prays that this Hon’ble Court may be pleased to
dissolve the marriage solemnized on 02-06-2013 in between the
petitioners and pass a decree of divorce by Mutual Consent and pass such
other order or orders as it deems fit and proper in view of the
circumstances and in the interest of justice.

PETITIONER No.1 (WIFE)

PETITIONER No.2
(HUSBAND)

PLACE: HYDERABAD COUNSEL FOR PETITIONERS

DATE: -11-2024.