___________ RESIDENCE CUM OFFICE
Seat No.___, _________
Ref No.________ Dated ____________
_______ S/o Shri __________
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, _________.