Kabelo and Annah have been married for five years. Initially, in particular the first 3 years of their marriage, the relationship between the spouses was very good. However, their marriage has been on the rocks for the past two years.

Annah has taken to hitting the bottle rather excessively. When she has imbibed the alcohol she uses foul language in the matrimonial home to both the husband and their two sons. At times she becomes abusive to the children. Thato is the oldest son, who is 12 years old while his younger brother Warona is 8 years old.

Furthermore, she misuses the joint estate funds and also denies Kabelo conjugal rights. Kabelo now wants to divorce Annah and has engaged you to file action against his wife.

Prepare summons in terms of Order 6 Rule 5 of the High Court Act, and decide on the relief sought. Also prepare the Plaintiffs Particulars of Claim. (50 Marks)