IN THE HONOURABLE COURT OF THE JUDGE FAMILY COURT
Location (City/Village)
O.P. No: OF 2010
BETWEEN:
Mr. ?????? S/o: ????????
Occ:?????, AGE:??,
R/o: ?????
….Petitioner
….Petitioner
AND:
Mrs. husband surname 498a wife name (aka: inlaws surname 498a wife name)
W/o: ??????
Occ: ?????, AGE:?? ,
R/o:?????
....Respondent
....Respondent
PETITION FILED U/S 9 OF HINDU MARRIAGE ACT 1955
I. DESCRIPTION OF THE PETITIONER
The description and the address of the petitioner for the purpose of issuing notices, summons etc., for the above Petitioner is same as mentioned in the above cause title.
II. DESCRIPTION OF THE RESPONDENT
The Respondent is Mrs. W/o: ??? OCC: ?????, AGE:??, HINDU
Mrs. husband surname 498a wife name (aka: inlaws surname 498a wife name)
R/o: ???
III. CLAIM: RESTITUTION OF CONJUGAL RIGHTS
May it please your Honour:
I, ??????, the Petitioner herein respectfully submit that I am working for a private company in Hyderabad. I am the legally wedded husband of the Respondent and that both of us are Hindu by birth. My marriage to the Respondent took place at ?????? on ????, as per Hindu rites and customs, with the consent and blessings of elders on both sides.
THAT, we both parties had led a happy married life for ?????? months/years. We both have been an absolutely normal couple and either of them have not given any reason to complain against each other. However the parents, family members, relatives and some neighbours of the respondent, constantly interfered and attempted to poison our marital relations by carrying tales, to the respondent against me. Since ??????????(your story) more mis-communications, misunderstandings were at play due to constant back-biting by these evil elements against us. In such a vitiated atmosphere, respondent fell prey to their machinations and became a tool in their manipulative hands. As a result the respondent who went to her parental home on ??????as a and did not return to her matrimonial home even though my communicating with her many times but she did not respond to my attempts.
THAT, to my surprise and dismay suddenly on ??????, I was confronted with a totally unexpected legal proceedings slapped against me by the respondent at the instigation of her parents, family members, relatives and some neighbours. Whereas I had to contend with these false criminal proceedings, the respondent continued to stay in her matrimonial home. These proceedings consist of a criminal case u/s 498(a), a divorce suit and a suit for maintenance, separately.
I further submit that I am living all alone at ??????as I am working here in ?????without the support of any family members from either side. My continued communication with the family members of the Respondent have not yielded any information as to the whereabouts of the Respondent. Subsequently, I came to know that Respondent was living with her parents, through the police personnel who came to arrest me and my family members on ??????.
I respectfully submit that the Respondent is staying away from me without informing as well as for no valid reasons whatsoever. Thus far, the Respondent has not let me know of her intentions as well as her future plans. She neither responded to my communications nor acknowledged.
Since the acts of the Respondent have arrested my married life. I pray this Hon’ble Court to seek restitution of my conjugal rights. I am left with no other option but to approach this Hon’ble Court for redressal of my grievances.
Hence this petition for restitution of conjugal rights.
IV. CAUSE OF ACTION
The cause of action for this Petition arose on ??????, when the respondent left petitioner’s residence to her parental home but never returned thereafter.
V. JURISDICTION
The Petitioner as well as the Respondent were residing at ??????, when the cause of action arose and thus this Hon’ble Court has jurisdiction to try and adjudicate this Petition.
VI. VALUATION
The Petitioner is paying a court fee of Rs. 10/- which is sufficient as per the Act.
VII. PRAYER
It is therefore prayed that this Hon’ble Court may be pleased to pass a decree and/or order in favor of the Petitioner, as hereunder:
(a) To direct/order the respondent to join the Petitioner at his residence in ?????? so as to enable him to lead the happy married life.
(b) Pass any other orders as this Hon’ble Court may deem appropriate in the interest of Justice.
Place: ??????
Date:?????? PETITONER
LIST OF DOCUMENTS
S. No. | DATE | DESCRIPTION |
1 | Wedding invitation held @ ????? | |
2 | FIR Copy filed by the respondent | |
3 | Address proof of last resided place |
IN THE COURT OF HON’BLE JUDGE FAMILY COURT
Location (City/Village)
O.P. No: OF 2010
BETWEEN:
Mr. ?????? S/o: ????????
Occ:?????, AGE:??,
R/o: ?????
….Petitioner
….Petitioner
AND:
Mrs. husband surname 498a wife name (aka: inlaws surname 498a wife name)
W/o: ??????
Occ: ?????, AGE:?? ,
R/o:?????
....Respondent
....Respondent
AFFIDAVIT VERIFICATION BY PETITIONER
I, , do hereby state and affirm under oath as follows:
Mr. ?????? S/o: ????????
Occ:?????, AGE:??,
R/o: ?????
1. I am the Deponent herein and as such I am well aware of the facts and circumstance of the case.
2. I submit that I filed the above petition against the Respondent for restitution of conjugal rights under section 9 of Hindu Marriage Act.
3. I further submit that the contents of the petition are true and correct to the best of my knowledge and belief and hence I verify the same to be correct.
Place: ????????
Date:??????? DEPONENT
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