PETITION FILED UNDER SECTION 9 OF HINDU MARRIAGE ACT R/W

7(C) OF FAMILY COURTS ACT

1. The petitioner got married with the respondent on 29/5/2005 at Visakhapatnam as per the
Hindu Law and cast custom. The marriage was consummated immediately thereafter and
the petitioner and the respondent lived as man and wife at Visakhapatnam.
2. The petitioner was transferred to Hyderabad and the respondent joined him at Hyderabad,
where they lived independently for some time.
3. The petitioner was working in a private organization. The petitioner with a view to
improve his position shifted to another organization at Pune and the respondent also
joined.
4. The respondent is an educated lady and did master of business administration as such she
joined in a job initially at Hyderabad and later shifted to Visakhapatnam.
5. The respondent joined the petitioner in the month of January 2012, at
where
they lived happily till 2014.
6. The petitioner used to look after the respondent and his son very affectionately. The
petitioner being in a supervisor position has to travel frequently and must against his will
had to stay away from the family.
7. There after there was a difference of opinion between the petitioner and respondent in
respect of the frequent travelling of the petitioner in respect of a purchase of a flat in
Visakhapatnam. The respondent quarreled with the petitioner and left his house in Feb
2014.
8. Thereafter in spite of the requests made by the petitioner and the respondent have not
joined the company of petitioner at Pune. The petitioner having made vein attempts
informed his parents about the respondent not joining him. The parents of the petitioner
also made attempts to convince the respondent to join the company of the petitioner the
also mediated to parents of the respondent but to no avail. The relatives of petitioner as
well as the respondent also tried to convince the respondent to join the company of the
petitioner.

While the mediation through third parties in progress the respondent filed a petition
before
the family court visakhapatnam for refund of the alleged dowry amount and other
amount for an amount of rs 10,30,000/-

The petitioner was never willing for separation or for severing the marital ties.

The respondent has also never expressed any desire for severing the marital ties.

the petitioner is very much fond of his wife and son and was always willing to take
them along
with him but the respondent with out having any reasonable ground staying away
from the petitioner . In the house of appearance

The petitioner even suggested that he would take a house on lease where the
respondant could stay with there son and the petitioner can join them as and when
convenient the petitioner in fact suggested that he would purchase a flat where the
respondent can stay independent ly
The petitioner in a bit to convince the respondent in fact entered into an agreement
with a developer to purchase in spite of the same the respondant was not willing
they join.

As such the petitioner has no other alternative except to approach the court seeking
the relief of restiution of conjugal rights to join the petitioner.
Hence the petition the cause of action for the petition arouse on 29/ 5 /2005 when
the petitioner
got married with the respondent and when the marriage was consunated at
visakhapatnam and when the petitioner and respondant lived as man and wife at
hyd , visakhapatnam, pune . And the respondent gave birth to a boy on 9/8/2011
and in the month of Feb 2014 thr respondant left the petitioner for last time and all
the days when the petitioner requested the respondent to join his company
personally, through his parents and mediator within the jurisdiction of the court.
This being an application for restitution of conjugal right a fixed court fee of so and
so is paid under ap cf and svact
Therefor the hon be court is pleased to pass a decree and order in favour of
petitioner as against the respondent.

A) for restitution of conjugal rights of the petitioner with that of the respondent
B)for such other relief for relief as the court deemed fit as per the said
circumstances of the case.