Divorce.
FORM 15.
PETITION BY WIFE FOR JUDICIAL SEPARATION ON GROUND OF
HUSBAND'S CRUELTY.
(General Heading)
The petition of C. B. (wife of A. B.) residing at
SHEWETH:
1. (As in paragraph 1 of Form 12.)
2.
That on the
day of
your petitioner, then C. D. spinster (or widow), was lawfully married to A. B. at
The said marriage was a Christian marriage (or the civil equivalent of a Christian marriage).
3. That from her said marriage your petitioner lived and cohabited with her said husband at
until the day of
when your petitioner separated from her said husband as hereinafter more particularly mentioned, and that your petitioner and her said husband have had no issue of their said marriage.
4. That from and shortly after your petitioner's said marriage the said A. B. habitually conducted himself towards your petitioner with great harshness and cruelty, frequently abusing her in the coarsest and most insulting language, and beating her with his fists, with a cane, or with some other weapon.
5. That on an evening in or about the month of the said A. B. in the highway and opposite to the house in which your petitioner and the said A. B. were then residing at
aforesaid, endeavoured to knock your petitioner down, and was prevented from so doing only by the interference of F. D., your petitioner's brother.
6. That subsequently on the same evening the said A. B. in his said house at
aforesaid, struck your petitioner with his clenched fist a violent blow on her face.
7. That on one Saturday night in the month of the said A. B. in
without provocation, threw a knife at your petitioner, thereby inflicting a severe wound on her right hand.
day of
8. That on the afternoon of the your petitioner, by reason of the great and continued cruelty practised towards her by her said husband, with assistance withdrew from the house of her said husband to the house of her father at
; that from and after the said your petitioner hath lived separate and apart from her said husband, and hath never returned to his house or to cohabitation with him.
day of
9. That there is no collusion or connivance between your petitioner and her said husband with respect to the subject to the present suit.
393
[CAP. 179