A PETITION FOR RESTITUTION OF CONJUGAL RIGHTS U/S 9 OF THE HINDU MARRIAGE ACT 1955
IN THE COURT OF THE JUDGE,   FAMILY COURT, PUNE
AT PUNE
Marriage Petition No. __./ 200_
Shri	YES	 	)
age 30 years, occupation - service,	)        Petitioner
resident of  999 Kasba Peth,	)
PUNE 411 O11.	)
Versus
Smt.	NOT		)
age 25 years, occupation - education,	)        Respondent
resident of C/o Shri RAT,	)
House No. 760 Nashik, District Nashik.                 
A PETITION FOR RESTITUTION OF CONJUGAL RIGHTS U/S 9 OF THE HINDU MARRIAGE ACT 1955
The petitioner abovenamed submits this petition, praying to state as follows:
1. That the petitioner is the husband of the respondent, their marriage having been solemnised at Pune on____according to the Hindu religion, vaidic rites and ceremonies.
2. That the respondent,  prior to the marriage, was known by her
maiden name as (Nee) Shobha, while there is no change resulted in
the name of the petitioner.
3. That after their marriage, the parties hereto cohabited and resided
together only for about two months, and hence, the question of any
child by the respondent out of the said wedlock does not arise.
4. That even though the residence of the joint family of the petitioner
has presently been at the within mentioned address, the petitioner
has also a separate residential flat in the Deccan Gymkhana area where the parties have liberty, privilege and privacy to go and stay there.
5. That immediately after the marriage,  on	March 200	,  the
petitioner and the respondent along with the brother and sister-in-law of the former went to Nashik for attending a religious ceremony on account of the solemnization of the marriage of the parties hereto and after the ceremony was held on	March 200_, the petitioner's brother and sister-in-law returned to Pune, and the petitioner alone stayed on further there for a fortnight.
6. That during this stay, when the petitioner inquired with the respondent about their return to Pune, she straightaway refused to accompany him back to Pune,  saying that she had her final-year B.  Com Examination in April 200_, for which she wanted to prepare by staying at her parents' only,  and the respondent promised  the petitioner that she would in the meantime visit the petitioner are Pune, on 31st March 200_, but despite such a promise on her part the respondent neither came to Pune, nor informed her inability, i] any, on that account.
7. That since the respondent did not come to Pune or inform anything in that respect, the petitioner himself went to Nashik and brought the respondent back.
8. That the petitioner respectfully submits that during his stay with the respondent and. her parents at Nashik, he was surprised about the indifferent behaviour on the part of his in-laws, and by his personal experience with them for about twelve days, he also came to a tacit conclusion that they are the persons having two sides : one, which is ostensibly open in public and the other ulterior and intrinsic, which was rather recondite and not revealed,  at least,  to this petitioner, he being an innocent and poor creature.
9. That even though the petitioner realised that the respondent being under the heavy influence  of her parents  has  not been much interested in a happy domesticity and may flout the sacrosanct ties of the marriage, the petitioner always hoped that perhaps there may be a new day bringing some light in the life of this petitioner and the respondent, for the petitioner is such a man who devoutly and fervently believes that every day is a new life to a wise man as well as a woman.
10. That then by the end of May 200, the respondent came to Pune and cohabited with the petitioner only for a while.
11. That on 1st June 200	, the respondent told this petitioner and his parents that her mother was sick, and she wanted to see her at Nashik, and accordingly, as per the wish of the respondent, this petitioner accompanied her to Nashik.
12. That, however, on reaching Nashik and finding there that there was nothing wrong with her mother, who was quite well, it was a great shock to this petitioner, and he was broken into pieces for the total indifferent and misbehaviour on the part of his in-laws and the respondent.
13. That while this petitioner was in such a hypercritical and delicate condition at Nashik, his in-laws managed by threat and coercion to write down the contents of an undertaking and sign the same to the effect that the petitioner would give up drinking, non-vegetarian food, beating the respondent up, etc. 
14. That the parents of the respondent and other in-laws of the petitioner created excruciating mental cruelty, tortures and severe tensions for this petitioner subsequently by filing a false criminal complaint under section 498-A of the Indian Penal Code with the police as well as the court of law.
15. That, thus, the respondent only at the instigation of her parents and other relations left the society of this petitioner without any sufficient, justifiable or reasonable cause or ground deprived this petitioner of his conjugal rights against her, and for no reason deserted him and subjected to suffer unhappiness and misery in life for no fault of his.
16. 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.
17. That the marriage was solemnised at Pune, 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.
18. That the cause of action for this petition first arose on 1st June 200 _, when the respondent voluntarily deserted this petitioner and left his society with a view to breaking away the matrimonial tries, and hence, this petition filed today is well within limitation.
19. That the petitioner also declares and confirms that this petition presented by him is not collusive.
20. That this petition being chargeable with a fixed rate of court fee, the same is paid herewith.
21. That the petitioner, therefore, prays that -
(a) A decree for the restitution of conjugal rights be passed against  the  respondent,   and  she  be  directed  to  resume cohabitation with this petitioner, and
(b) Any other orders in the interest of justice be kindly passed.
Pune,
Sd/- YES
Dated : __..	PETITIONER
 Sd/-   xXx
c
ADVOCATE FOR PETITIONER
VERIFICATION
I, Shri YES, the present petitioner, do hereby state on solemn affirmation that the contents of this petition in paras 1 to 21 are true and correct to the best of my knowledge and belief, and so I have signed hereunder.
Sd/- YES PETITIONER
Subject to the permission of the Court, as the parties shall not be allowed to be represented by legal practitioners, vide the Family Court Act 1984.
Note : One more draft is provided for the convenience of the readers.