On 23 January 2022 you had a consultation with Mrs Pearl Peters (Mdange). During the consultation, Mrs Peters told you the following:

"On 05 May 1996 and at johannesburg, South Africa Mr John Peters and Mrs Pearl Peters got married to each other out of community of property excluding the accrual system. There are two children born out of this marriage namely Peter, a boy age 14 years and Susan, a girl aged 9 years. Prior to their marriage, the Mr Peters was employed as a Plumber at Plumblink in Pretoria, South Africa. Immediately, after they got married they acquired a house at 17 Market Street, Berea, Johannesburg and lived there together. This is the place where Mrs Peters currently reside with her two children."

With regard to the state of her marriage Mrs Peters said the following:

"I wish to sue John for divorce because in 2019 I discovered that the John is involved in an adulterous relationship with another woman. Subsequent to this discovery he became physically and verbally abusive towards me. It became axiomatic for John not to sleep at home over weekends. On or about June 2019 John did not come home and I have not seen him ever since. It became clear that my marriage with John was inevitably heading for a rocky ending. We were estranged and despite attending marriage counselling we were unable to rescue our relationship. I believe that our relationship has broken down irretrievably and that there is no prospect that the marriage may be saved. Accordingly, I wish to divorce John."

Instruction:

Draft Particulars of Claim relating to the divorce proceedings Mrs Peters intend to institute