Format For Divorce Notice

Date:- XXXXX To, Mr/Mrs._______ XXXXXXXX XXXXXXXXX Dear Sir, Under the
instructions & information received from my client Mrs. ________________ presently residing at
________________ I hereby address you this legal notice as under:-
1. That, you were lawfully married with my client according to Vedic Rites on
22/05/2011 at Andheri, Further, before marriage you were a bachelor & my client
was a spinster. The maiden name of my client is  _______________
 
2. That, my client is dutiful Hindu woman having a great regard in the institution of
marriage, she always help you for smooth running of family life. Since you also were
also cohabitated & lived together with my client( as husband & wife) at
_____________________________for past seven yrs. Out of the wedlock of the said
marriage, client & you have one son namely  _________________ aged about 4yrs, 
who is suffering from heart diseases Kawasi

3. That, after birth of your said Child, you started neglecting and refusing my client. My
client observed mental acute change in your attitude; you used to beat your wife (my
client) indiscriminately for no fault of her even for the trivial things. You started ill
treating my client and did not mind to render the basic necessities and amenities of
life without any reasonable or justifiable cause to do so. On several occasion, you &
your mother Smt. __________________, Sister: ______________ ______________
alias __________________  Bhagat all together  beat my client black & blue for no
fault of her and caused brushes all over body & when she questioned that, why you
all change your behavior & started ill treating her for without any reasonable cause &
reason, then you replied that, you have no interest in your marriage life, you want to
get second marriage with more beautiful teen age earning woman to enjoy more
sexual & luxury life & your mother, sister, brother are agree to arrange second
marriage with your lover/ Girlfriend   ______________________ who is your ex –
boss maid servant . Further, my client also says that, on several occasions she caught
you red handed when you were enjoying physical relationship with your lover/
girlfriend ________________.  My client also says that, she will produce photo
graph & Mobil clip to prove illegal relationship with your said Girlfriend/ Lover at
the relevant time if any necessities arise.  Further, my client also says that, you &
your mother, sister & brother says to my client that if she will raise any voice against
the second marriage then your sister’s husband, brother: Mr. _________________ &
you all together will manage each & everything with the police department &
judiciary because your relative who work in the court having tremendous contact
with the several Judges in the court.
 
4. My client further says that, whenever, she tried to mend your ways then you & your
above said family members behaved badly & given several mental cruelties as well
as physical upon my client. Further my client says that, on 02/05/2017, your brother
Mr. ______________________ tried physical upon my client & my client was
constrained to approach police department to lodge complaint against your said
brother, who always instigate you for second marriage with your girlfriend.
Thereafter, you & your family did not allow my client to stay in her matrimonial
house, you & your mother & brother fist & kicked my client & thrown out from the
house & closed the door.  Furthermore my client also says that, you kept the said
child in your physical custody, who is suffering from the said heart disease having
very critical condition & cannot survive without the mother. My client says that if
anything happened to the said child then you & your all family members will be held
responsible, please note carefully
 
5. Furthermore , my client also say that, after birth of said child you stopped providing 
basic  necessities for survival, my client is unable to generate sufficient source of
income to meet even the basic   necessities for survival for herself &  for said child 
due lack of technical qualification and unemployment.  The said son is under medical
treatment & suffering from heart diseases.  Further, the aforesaid inevitable pitiable
and agonizing facts and atmosphere has also further resulted in destructive
deterioration of education, welfare, upbringing, talents and personalities of the said
child. As such, my client is unable to maintain herself and her child & they are even
deprived of basic necessities of life for survival and evidently foreseen that, the
education, welfare and upbringing of said child are totally in dark side of the human
life. The above said atmosphere and situation is not all conducive for happy and
healthy growth of the said child.
 6. That, it was your abandon duty to maintain my client( your wife) &the said
child( your son), however you failed to do so only to enjoy your adultery life &
unsocial activities, whenever, my client’s parent tried to approach you to mend your
ways you started threatening my client with dire consequences. Since 2015 you have
deserted my client without any lawful reason only enjoys your unsocial activities &
illegal relationship with your said girlfriend.  Hence, in the above circumstances my
said client is not interested to live with you & my client wants to dissolve her
marriage immediately.
 
7. I, therefore, call upon you through this legal notice to give  Physical custody of said
child to my client & to  execute the Divorce Deed and papers etc.& to give 
maintenance to my client  & the  said child and to dissolve 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  criminal & civil 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.  
Thanking you   Advocate for ______________________

__________ RESIDENCE CUM OFFICE

Ref No.________ Dated ____________

LEGAL NOTICE
To,

_______ S/o Shri __________

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, _________.