IN THE COURT OF ADDITIONAL CIVIL JUDGE (S

IN THE COURT OF ADDITIONAL CIVIL JUDGE (S.D.) MALOUT

(Exercising the Powers of Distt. Judge Under Hindu Marriage Act. 1955)

Major Singh S/o Suba Ram S/o Bali Ram R/o Village Raniwal Teh. Malout, Distt. Shri Muktsar Sahib.

( Petitioner)

Versus.

Daljeet Kaur w/o Major Singh ( D/o Late Roshan Lal) C/o Gurmeet Singh S/o Miraj Singh R/o Village Ranivala (at Village Kattiawali) Teh. Malout Distt. Shri Muktsar Sahib.

( Respondent)

Petition U/Sec. 9 of Hindu Marriage Act

for the Restitution of Conjugal Rights.

Sir

It is submitted as under:-

1.

That the petitioner was married with the respondent on before 12 years according to the customary Hindu rites of the parties i.e. by way of Anand Karaj at village Kattiawali Teh Malout Distt Sri Muktsar Sahib .An affidavit to this effect is attached with the petition.

2.

That the status and place of residents of the parties to the petition before marriage and at the time of filing the petition were as follows:-

Husband

Wife

Status Place of Status Place of

residence

residence

Before the marriage

Hindu Raniwala Hindu Kattiawali

At the time of filing the Hindu Raniwala Hindu Raniwala

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3.

That the marriage was simple. No dowry articles were given at the time of marriage. Rather the parents of the petitioner gave gold ornaments and costly clothes as gift to the respondent. After the marriage the petitioner and respondent lived and cohabited together as husband and wife at Raniwala and out of this wedlock four children were born out namely Kulwinder Kaur aged 9 year Harpreet Singh aged 7 year Kirandeep Kaur 5 year are reside with petitioner and new born male issue reside with respondent.

4.

That the respondent is an arrogant lady and used to quarrel with the petitioner and his parents on petty matter because respondent have no parents and marriage orgnised by grand father and respond misbehave and quarrel in on petty matter it is patient to mention here that repondent had illegal relations with Lakhwinder Singh s/o Gurmeet Singh R/O Village Raniwala and also reside with illegally leaving behind her husband and children..Petitioner also move an application to the higher authorities many times regarding the matter but not any action made against the respondent.

5.

That when the personal efforts of the respondent and panchayat failed then the petitioner convened 2-3 panchayat to rehabilitate the respondent but all in vain petitioner convened a panchayat consisting of Dharam singh (member) s/o Dilbagh singh ,Mejar singh (Sarpanch) s/o Angrej singh ,Bhajan singh s/o Bhan Singh all the residence of village Raniwala and other respectable member of locality went to the house of respondent at Village Raniwala (residence of Lakhwinder Singh )and where the respondent and parentents of Lakhwinder Singh and Lakhwinder Singh were present The panchayat requested them to send the respondent with them in the company of the petitioner , but they refused to send the respondent in the company of the petitioner and took a pressure on petitioner to give a devorce to the respondent against his wish .Thus the panchayat returned back without any positive result

6.

That the respondent has left the company of the petitioner without any sufficient cause and deserted petitioner intentionally,with cause to marry with lakhwinder singh without given any legal divorce to petitioner and hence the petitioner has been left no other alternative except to file the present petition.

7.

That the petition is not presented in collusion with the respondent.

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8.

That no other litigation is pending or decided by any court of law on the same subject matter of the present petition.

9.

That the present petition has been filed without any improper delay.

10.

That the cause of action arose to the petitioner to file the present petition when the marriage was took place and when the respondent left the house of the petitioner without any sufficient cause and reason 3 month before when the respondent refused to join the company of the petitioner in the presence of panchayat.

11.

That the petitioner and respondent lastly resided as husband and wife at village raniwala Teh. Malout dist sri muktsar sahib within the territorial jurisdiction of this court, hence this court is competent to try and decide the present petition.

12.

That a fixed court fee of Rs. 20/- has been affixed on the plaint.

It is, therefore, prayed that a decree U/sec. 9 of Hindu Marriage Act for the restitution of conjugal rights may kindly be passed infavour of the petitioner and against the respondent. .

Submitted by:-

Major Singh S/o Suba Ram S/o Bali Ram

R/o Village Raniwala Teh. Malout Distt.

Sri Muktsar Sahib

---- Petitioner Through counsel.

VERIFICATION

Verified that the contents of Parano.1 to 12 of the petition are true and correct to the best of my knowledge and belief and prayer is believed to be true. Verified at Malout on 30/01/2015

IN THE COURT OF ADDITIONAL CIVIL JUDGE (S.D.) MALOUT

(Exercising the Powers of Distt. Judge Under Hindu Marriage Act. 1955)

Major Singh

Versus.

Daljeet Kaur

Petition U/Sec. 9 of Hindu Marriage Act.

Affidavit. I, Major Singh s/o Suba Ram s/o Bali Ram r/o village Raniwala Teh. Malout, Distt. Shri Muktsar Sahib, do hereby solemnly affirm and declare as under:--

1.

That I was was married with the respondent on before 12 years according to the customary Hindu rites i.e. by way Anand karaj at Village Raniwala Teh.Malout Distt. Sri Muktsar Sahib.

2.

That out of this wedlock two female issue and tweo male issue were born out. Now 3 issue residing with the respondent new born male issue reside with respondent .

Deponent.

Verification:

Verified that the contents of my above said affidavit are true and correct to the best of my knowledge and belief and nothing has been concealed therein.

Deponent.