1237
No. 20.
PETITION BY WIFE FOR JUDICAL SEPARATION ON THE GROUND OF
HUSBAND'S ADULTERY.
(General Heading.)
the wife of A. B..
The petition of C. B., of
residing at
SHEWETH:
1. That your petitioner and the sand A. B. are in Colony of Hong Kong.
2. That on the
day of
your petitioner, then
C. D. (spinster, or widow as the case may be) was lawfully married to A. B. at
in
The said marriage was a Christian marriage for the civil equivalent of a Christian marriage).
3. That after her said marriage your petitioner cohabited with the said A. B. at
and at
and that your petitioner and her said husband have issue living of their said marriage
children (give names and ages).
4. That on divers occasions in or about the months of
the said A. B. at
committed adultery with
E. F., who was then living in the service of the said A. B. and your petitioner at their said residence
5. That on divers occasions in the months of the said A. B. at
aforesaid.
aforesaid committed adultery with
a female whose name the petitioner believes to be R S. (or cohabited and habitually committed adultery with G. H.).
6. That no collusion or connivance exists between your petitioner and the said A. B. with respect to the subject of the present suit.
Your petitioner therefore humbly prays that this Honourable Court will decree a judicial separation to your petitioner from her said husband by reason of his aforesaid adultery, and that, she may have the custody of her said children, together with such other and further relief in the premises as to this Honourable Court may seem fit.
(Signed) C. B.
(Affidavit as in Form No. 2).
No. 21.
ANSWER TO WIFE'S PETITION FOR JUDICIAL SEPARATION ON GROUND OF HUSBAND'S ADULTERY.
(General Heading.)
The respondent A. B. in person (or by his solicitor), in answer to the petition filed in this cause, saith:-
1. Denial hal either party, or both parties, were in the Colony at the time of the Commencement of the proceedings and denial that the marriage was a Christian marriage for the civil equivalent of a Christian marriage).
2. That he denies that he committed adultery with E. F., as in the fourth paragraph of the petition alleged.
3. That the petitioner condoned the said adultery with E. F., (it any).
4. That he denies that he committed adultery with R. S. (or with G. H.) as in the fifth paragraph of the petition alleged.
5. That the petitioner condoned the said adultery with R. S., if any (or as the case may be).
Wherefore the respondent prays that this Honour able Court will reject the prayer of the said petition
(Affidavit as in Form No. 12).
(Signed) A. B
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