A PETITION FOR RESTITUTION OF CONJUGAL RIGHTS U/S 9 OF THE

HINDU MARRIAGE ACT 1955

IN THE COURT OF THE JUDGE, FAMILY COURT, DELHI

AT DELHI
Marriage Petition No. __./ 200_

Mr. Anand Kapoor, age- 30 yrs, occupation- Service, r/o-

Delhi……………. Petitioner

Versus

Mrs. Neha Kapoor, age- 25 yrs, occupation- Service, r/o-

Bangalore………. Respondent

U/S 9 OF THE HINDU MARRIAGE ACT 1955

The petitioner respectfully submits as under:

1. That the petitioner is the husband of the respondent,
their marriage having been solemnized at Delhi on27-07-2016
according to the Hindu religion, vaidic rites and ceremonies. It
was a love marriage and both of their parents were agreed.
2. That Neha was working in Bangalore, while Mr. Anand was
working in Delhi till marriage.
3. After marriage they continued the long distance relationship for 1
year, howsoever they had sudden disputes that both of them were
working in different places. One asked another to move.
4. That finally after long dispute, Neha had to live the job and she
moved to Delhi, after that she couldn’t find the job of her focus area in
Delhi, which is public health, but she couldn’t find the job in Delhi
which sustain her.
5. That in Bangalore she was earning a salary of Rs 70,000 per
month, and, max she was offered in Delhi was 50000 and the job was
not specific to her area, so she had to suffer major pay cut. Because of
which her salary expectation has to be reduced because after which if
she move to another job she need to keep
6. That for those 6 month she was economically and financially
dependent on her husband, after that she got job of 50,000.She leaved
a lavish life in Bangalore, she want to dine a lot, while she alleges that,
when he married her, anand knows that she goes out a lot, so it was
not new to him,
now she is dependent on husband so she need money from husband to
dine a lot.
7. That during these 6 months Anand maintained her and after that
she got the job in which she had to suffer paycut and the office was
away from the house she use to live, because of which there was some
kind of verbal fight between them, which is very normal in every
married family.
8. That after the verbal fight the problem of the home could have
solved after talking to each other. But after that fight without trying to
resolve the conflict she mailed her
9. former employer and requested to get her old job back, and they
offered her employment on the same job, same, position, same salary
and she moved to Bangalore, but the parent of Anand was in Haryana
so he need to visit their parent, so he refuses to go to Bangalore and
she also refuses to come Delhi by wrongfully alleging that he was short
temper, and she had to suffer verbal harassment. But she didn’t file
any complaint.
10. That parents of Anand is in old age because of which it is not
possible for him to leave his parents and move to Bangalore with his
wife, as he need to take care of his parents who use to live in Haryana.
11. That the petitioner submits that he was right from
the beginning and has ever since been sincere, ready
 and willing to cohabit with the respondent, and the
respondent being his legally wedded wife has no right or
reason or ground to leave him alone.
12. That the marriage was solemnized at Delhi, and the
parties hereto also last resided together within the local limits
of the jurisdiction of this court, and hence this Hon'ble Court
has jurisdiction to try and decide this petition.
13. That the cause of action for this petition fi rst arose on 28 th
Dec, 2017, when the respondent voluntarily deserted this
petitioner and left his society with a view to breaking away the
matrimonial tries, and hence, this petition fi led today is well
within limitation.
14. That the petitione r also declares and confi rms that this
petition presented by him is not collusive.
15. That this petition being chargeable with a fi xed rate of
court fee, the same is paid herewith.
16. That the petitioner, therefore, prays that –
(a) A de cre e fo r the re s titu tion of conjuga l r ights be
pas s e d against the respondent, and she be directed to
resume cohabitation with this petitioner, and
(b)(b) Any other orders in the interest of justice be kindly
passed.

Delhi,
Sd/- Anand Kapoor
Dated : 27-08-2018………. PETITIONER
Sd/-
c
ADVOCATE FOR PETITIONER
VERIFICATION
I, Mr. Anand Kapoor, the present petitioner, do hereby state on
solemn affirmation that the contents of this petition in paras 1 to
15 are true and correct to the best of my knowledge and belief, and
so I have signed hereunder.
Sd/- Anand Kapoor…. PETITIONER