CIVIL PETITION

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 BEFORE THE COURT OF THE PRINCIPAL JUDGE FAMILY COURT,
JAMMU

MATRIMONIAL CASE NO. _____ OF 2023

Mr. Ravi Kumar PETITIONER

VERSUS

Mrs. Anumeha Kumari

RESPONDENT

IN THE MATTER OF:

S No. Particulars Page Nos.

1 List of dates and events
2 Petition alongwith affidavit
3 Annexure-I

(copy of the marriage certifcate)

4 Vakalatnama
5 Court fees

INDEX

Place: Jammu

Date:

Filed by:
Advocate
 BEFORE THE COURT OF THE PRINCIPAL JUDGE FAMILY COURT,
JAMMU

MATRIMONIAL CASE NO. _____ OF 2023

Mr. Ravi Kumar PETITIONER

VERSUS

Mrs. Anumeha Kumari RESPONDENT

IN THE MATTER OF: LIST OF DATES AND EVENTS

S. No. Dates Events

1. 03/05/2018 Marriage between the petitioner and the
respondent was solemnized.
2. 29/04/2020 A boy child was born as a result of
marriage of the petitioner and the
respondent.
3. 05/03/2023 Respondent left the society of the
petitioner and went to her parental
house, only to never come back to her
matrimonial house.
4. 25/04/2023 Petitioner went to the respondent’s
parental house to bring respondent back
to her matrimonial house.
5. 29/04/2023 Respondent filed a criminal complaint
of domestic violence u/s 12 of the
Domestic Violence Act against the
Petitioner.

PETITIONER

THROUGH
Advocate

Place: Jammu
Date:
 BEFORE THE COURT OF THE PRINCIPAL JUDGE FAMILY COURT,
JAMMU

MATRIMONIAL CASE NO. _____ OF 2023

IN THE MATTER OF:

Mr. Ravi Kumar PETITIONER

VERSUS

Mrs. Anumeha Kumari RESPONDENT

PETITION UNDER SECTION 9 OF HINDU MARRIAGE ACT 1955 FOR

RESTITUTION OF CONJUGAL RIGHTS

MOST RESPECTFULLY SHOWETH:

The Petitioner, above named states as under:

1. That marriage of the Petitioner and the Respondent was solemnized on 03/05/2018
at Jammu according to Hindu rites and ceremonies. The marriage was registered with
the Registrar of marriages at Jammu. Copy of the marriage certificate are herewith
annexed as Annexure-I.

2. That the status and place of residence of the Parties to the marriage before the
marriage and at the time of filing this petition is given as under:

Husband Wife
Status Age Place of Status Age Place of
Residence Residence
(i) Before Single 25 H. No. 11 Single 23 H. No. 22
marriage Talab Janipur,
Tillo, Jammu.
Jammu.
 (ii) At the Married 30 H. No. 11 Married 28 H. No. 11
time of Talab Talab
filing the Tillo, Tillo,
petition Jammu. Jammu.

3. That from this marriage, the couple has been blessed with a 3-year-old boy child
born on 29/04/2020.

4. That the Petitioner and his wife were living together happily at our house. That on
05/03/2023 the respondent went to her parental house at House no. 22 Janipur,
Jammu, 180007. She gave word to return within 15 days, but she did not abide by her
word and has not returned so far. The Respondent without any reasonable excuse has
withdrawn from the society of the Petitioner.

5. That the petitioner went to his father-in-law’s house at House no. 22 Janipur,
Jammu, 180007, to bring the respondent back to her matrimonial home a number of
times but on one pretext or the other, she declined to come along with the petitioner to
his house.

6. That lastly the petitioner went to the house of the respondent’s parents at House no.
22 Janipur, Jammu, 180007, on 25/04/2023 and asked the respondent to return with
him, but she refused to come. This incidence of petitioner going to the house of
respondent’s parents only to get the respondent back to her matrimonial house led the
respondent to file a domestic violence case against the petitioner before the Learned
Court of Special Mobile Magistrate, Jammu dated 29/04/2023.

7. That the respondent deserted the petitioner and has withdrawn from his company
without any reasonable or lawful excuse. The 3-year-old boy child is also facing
difficulties due to the same. Hence the necessity for the petition arose.

8. That the Petition is not being presented in collusion with the Respondent.

9. That the Petition is being presented without any unnecessary or improper delay on
the part of the Petitioner.

10. That there is no other legal ground as to why the decree of restitution of conjugal
rights be not granted in favour of the Petitioner.

11. That there is the following previous proceeding with regard to the marriage by or
on behalf of the parties:
 Serial Name of Number of Number and year Name and Result
Parties Proceedings of the case of location of
with court court
Section of
that Act
(i) Anumeha Criminal CNR No. Special Pending
Kumari Complaint 1128TU31Q/202 Mobile
of domestic 3 Magistrate,
Vs violence u/s Jammu
12
Ravi
Kumar

12. That this Hon'ble Court has jurisdiction to entertain and try this Petition as the
marriage was solemnized at Jammu, the parties last resided together at Talab Tillo,
Jammu and even presently the respondent is residing within the Jurisdiction of this
Hon'ble Court.

13. That the cause of action accrued to the petitioner against the respondent, within the
jurisdiction of this Court, on 05/03/2023 when the respondent left for her parental
house at House no. 22 Janipur, Jammu, 180007 and it continues to accrue from day to
day till the respondent comes back to the home of the petitioner and resumes his
company.

14. In the facts and circumstances of case mentioned herein above this Hon'ble Court
may graciously be pleased to:

PRAYER

That the Petitioner, therefore, prays:

a) for grant of decree for restitution of conjugal rights in favour of Petitioner and
against the Respondent; and

b) Any other relief or reliefs which the court may deem proper under the
circumstances be also awarded to the petitioner.

PETITIONER
 THROUGH
Advocate

Place: Jammu

Date:
 BEFORE THE COURT OF THE PRINCIPAL JUDGE FAMILY COURT,
JAMMU

Ravi Kumar

VS

Anumeha Kumari

IN THE MATTER OF: Affidavit in support of petition

I, Ravi Kumar, Age 30 years, s/o Rajesh Kumar R/o House no. 30 Talab
Tillo, Jammu, 180002, do hereby verify that the contents of this petition in Para No
_____ to Para No _____ are true to my personal knowledge and those of Para No
_____ to Para No _____ are true upon legal advice received by me which I believed to
be true.

I solemnly swear/affirm that this affidavit is true and no part of this is false and
nothing has been concealed.

DEPONENT

VERIFICATION:

Verified today on ____ day of May 2023 at Jammu that the contents of the
affidavit are true and correct to the best of my knowledge and nothing has been
concealed therein.

DEPONENT

PETITIONER

Place: Jammu

Date:
 CERTIFICATE OF MARRIAGE

Before the Marriage Registrar Jammu.

Date of marriage: 03/05/1980

PARTICULARS HUSBAND WIFE

Name Ravi Kumar Anumeha Kumar
Age 25 23
Birth Place Jammu Jammu
Occupation Teacher House-wife
Residence Talab Tillo, Jammu Janipur, Jammu
Name of father/guardian Rajesh Kumar Seeta Ram

WITNESSES
1) NAME: Shilpa Singh
ADDRESS: Janipur, Jammu.

2) NAME: Rahul Dev

ADDRESS: Janipur, Jammu.

REGISTERED AS NO.: 1198/2018

DATE: 03/05/2018

MARRIAGE REGISTRAR
JAMMU