IN THE HON’BLE COURT OF THE SUBORDINATE JUDGE /BEFORE THE HON’BLE

FAMILY COURT AT
.......................................................

H.M.O.P. / 2020

Amutha --- Petitioner.

Vs

Ravi --- Respondent

PETITION HUMBLY FILED UNDER SECTION 9 OF THE HINDU MARRIAGE ACT 1955

I. PETITIONER :-
Amutha, aged about ............. years, W/o.Ravi, residing
at ....................................................................................

The address for service of the petitioner is the same as above and care of
................................................................

II. RESFONDENT :-
Ravi, aged about ........... years, S/o. ........................................ Residing
at...........................................................................................................................

The address for service of the respondent is the same as above.

III.
1. It is submitted that the marriage of the petitioner, with the respondent was
solemnized
on ........................................................................................ ............................
... as per Hindu Religious Caste, Custom, Rites and practice with the
consent, willing and wishes of both, the petitioner as well as the
respondent and their family members.

2. It is submitted that the couples have resided in their matrimonial home

at ........................................................... for ................. years together.

3. It is submitted that from out of their matrimonial togetherness with the

respondent gave births to ............................... namely
1) .........................and, 2) ................... years
 and ............................................. years respectively. The initial starts of life
of matrimonial togetherness in – fact rendered salubrious hue to the
couples which often have been prized by the local publics of the
surroundings. It is shock-able to bear the followings that whoever happens
to hear the pathetical events which took place in the matrimonial life of the
litigants. The petitioner could not able to predict in advance about the
pervert-ness of the respondent as he was of the opinion that she would be
the good one who could able to discharge the matrimonial obligations and
duties with whole hear tingly for the celestial pleasure-ness, martial
happiness and for the betterment of whole family, but in contra the
respondent had acted upon his own whim and turned upside down the
expectation of the petitioner as what has to be followed, adopted and
maintained by a husband in the life of togetherness as being a husband and
wife.

4. It is submitted that years have passed on but the tears of the petitioner and
her parents never allowed to be dried off. The mental agony which caused
by the respondent against the petitioner and her parents cannot be
expressed in any terms of words. No woman is born so far to find out the
art and structure of the mind of a man; as such the petitioner is no
exception to the same.
5. It is submitted that the respondent never had sustained any injury both
mentally or physically at the hands of the petitioner but the respondent on
his antic and inborn asperities used to spell out vulgar and obscene abuse,
rudeness of language opprobrious and offensive remarks, petulance
manners, austerity of temper and never realized to become normal from
his penance and malign against the petitioner and his parents has ramified
every were in the village and he did not change his mentality and thereby
caused severe mental injuries to the petitioner and his parents.
6. However that the petitioner wants to make her family to be with peace and
healthy one and she wants to make the children to become top position in
the society and she wants to lead the matrimonial life together with the
respondent with a hope that one day he will become normal and will
realize the marital tie.
7. It is submitted that the respondent had deserted the petitioner continuingly
for the last six months without had any sufficient reasons and the petitioner
is put to get shelter in the home of her poor parents. She is struggling for
her livelihood but in the mean time she wants to look after her in lass who
are aged and proper attention had to be given to them.
8. Despite the efforts taken by the petitioner to dwell with the respondent
have ended in to failure as the respondent had adamantly refused to take
back the petitioner to their matrimonial home.
9. It is submitted that the petitioner is ready to forget all the events and the
agony which sustained by her because of his commissions and omissions
and ready to reside with him in their matrimonial home to lead their happy
martial life and to care the children for better future and to maintain the
social status. The petitioner had caused his notice to the respondent
on ....................... and called him to take her back to their matrimonial
home to lead their marital life. But so far the respondent did not care about
it. He is neither called the petitioner nor worried about the absence of his
wife and children in the home of him.
10. There were no sufficient or real causes for the respondent to desert the
petitioner.
11. The petitioner is put to the necessity of filing this petition against the
respondent for restitution of conjugal rights because of the circumstances,
which were maintained, by the respondent in the matrimonial life of the
petitioner.

12. It is submitted that there is no collusion between the petitioner and the
respondent in filling the petition. The petitioner further submits that no
other similar petition was filed in any other court.
13. The petitioner submits that there is no unnecessary or improper delay in
filing this petition.
14. The cause of action for the petition arose when on the marriage has been
solemnized between the litigants on ................................................... and
thereafter when the litigants residing at ................................................
for .............................. and thereafter desertion of the respondent and
when he deserted the petitioner and living separately in his home without
 caring and maintaining the petitioner and when the petitioner had caused
her notice to the respondent on......................... and the failure of the
respondent to take back the petitioner to their matrimonial home and on
subsequent dates at ............ village ..........................Taluk .................District
and within the jurisdiction of this Hon’ble court.
15. The petitioner pays a Court fee of Rs. 50/- under Art. 1 of Schedule II of the
T.N.Court Fees and Suit Valuation Act 1955.
16. Therefore, the petitioner prays, that this Hon’ble Court may be pleased to
pass a decree and judgment for restitution of conjugal rights against the
respondent and to direct the respondent to live with the petitioner and to
discharge the matrimonial obligations, and duties and may be pleased to
grant such other and further relief’s as are deemed fit and proper in the
circumstances of the case.

Advocate for petitioner Petitioner.

I the petitioner do hereby declare that the facts stated in the above
paras 1 to 16 are true and correct to the best of my knowledge and belief
and I signed in this on ............................. at ...................

Petitioner
LIST OF DOCUMENTS FILED BY THE PETITIONER

1 ,.................... Marriage Invitation Original

2 ...................... Lawyer’s notice of the petitioner Office Copy
3 ...................... Ration Card Xerox.
4 ...................... Courier receipt for the notice of the Original
petitioner

Advocate for petitioner

Photo of the litigants

Identified by me
Advocate for petitioner