IN THE FAMILY COURT JUDGE, DELHI

MARRIAGE O.P No

Neha Kapoor ………Petitioner

Versus

Anand Kapoor ………Respondent

Respondent humbly submits as under –

1. That respondent married to petitioner on 1st September 2016 at Delhi, under

jurisdiction of Hon’ble court and does not have any child.
2. That marriage solemnised was a love marriage and was done with the consent
of parents of both the parties, both the parties were doing job before they got
married and they fell in love. After marriage the respondent continued to work
in Bangalore; while the petitioner continued to work in Delhi and they both
managed there long distance relationship until issue arose between both the
parties regarding the workplace.
3. That after consent respondent shifted to Delhi but afterwards could not find
desired job even after trying for six months in focused area which is public
health, after a struggle of six month respondent for a successful and married life
got ready to work for salary of 50,000/(Fifty thousand) which was 20,000/ less
from Bangalore.
4. That there was a serious lack of efforts from the side of petitioner; the workplace
of respondent in Delhi was too far from the residence and an increased working
hour i.e.9 hour a day, there was no step taken by the respondent to shift at the
place which is convenient for both the parties, in totality an exhaustive day of
working and huge expenses of traveling, this shows that petitioner is highly
irresponsible and has a careless attitude towards marriage. The husband has a
 duty to take care of his wife and this a marital obligation of husband, even
petitioner forced respondent to move Delhi from Bangalore without any attempt
to shift and find job in Bangalore despite of huge opportunities at Bangalore.
5. That respondent had to financially depend on petitioner as salary was reduced,
taxes and expenses of traveling were compatibly high that to of Bangalore and
maintain her lifestyle that of previous she was able to maintain herself. After all
reconciliation and effort of reasonable time period, petitioner moved back to her
previous post at Bangalore.
6. That the behaviour of petitioner was subject to verbal harassment and short
temper to solve issues of marriage and hence in light of above facts are
reasonable to leave apart.

Prayer

The petitioner therefore prays that the honourable court may be pleased to pass an order
and decree.

(a)The petition be dismissed.

(b) Direct the petitioner to pay cost of the petition and entitled to maintenance. And pass
such others and further orders as it deem fit and proper in the circumstances of the case.

Advocate for Respondent Respondent

Date -06-09-2018

Place - Delhi

VERIFICATION
 I, the respondent do here by declare that the facts state above are true and correct to the
best of my knowledge and belief and signed this verification on this the 06.09.2018 at
Delhi.

Petitioner

AFFIDAVIT TO BE FILED IN SUPPORT OF MATRIMONIAL

PETITION UNDER SECTION 9 HINDU MARRIAGE ACT

IN THE FAMILY COURT DELHI

Neha Kapoor ………Petitioner

Versus

Anand Kapoor ………Respondent

Affidavit of Ms. Neha Kapoor, affirm and say as follows:

1. That I am respondent in the accompanying written statement under section 9 of Hindu
Marriage Act and am well acquainted with the facts of the case.
2. That I have gone through the contents of the accompanying written statement. I reaffirm
the contents of the written statement, which are not being repeated here, for the sake of
brevity.
3. That the written statement is not being presented or prosecuted in collusion with the
petitioner.
4. That on1-09-2018 by all means attempts at reconciliation have been made, but in vain.
5. That there is no other legal ground as to why the decree prayed for should not be granted
in favour of the respondent.

Signed at Delhi Deponent

VERIFICATION
I, Neha Kapoor the named above deponent do hereby verify on oath that the contents
of the affidavit above are true to my personal knowledge and nothing material has been
concealed or falsely stated therein.
Verified at Delhi, Date- 6-09-2018 Deponent

SANDEEP KUMAR

R154216089

BA.LLB(Criminal law) B2