In the Court of Family Judge (I), Bhubaneswar

C.P No-_______/2023
Pusparani Moharana @ Panda, age 36 years
W/o Himanshu Kumar Panda
of swastidham At/po- Jharpada,
P.S Laxmisagar B.B.S.R ,
Presently residing C/O- Rabindra nath Moharana
Of Rashmi Lawn house no.1
Brahmeswar patna(Tankapani road)
P.o BJB Nagar, PIN 750014
P.S- Badagada,Bhubaneswar, Dist- Khordha
Contact No- 7077589739 ……petitioner
V/S
Himanshu Kumar Panda, age 38 years
S/O Tanmay Kumar Panda
Of swastidham At/po- Jharpada,
P.S Laxmisagar ,Bhubaneswar
PIN- 751006, Dist- khordha
Contact No-9778074745 …….Respondent

Petition U/S 9 of Hindu Marriage Act-1956 Restitution of conjugal rights

The humble petition of
Above named petitioner
Most Respectfully Sheweth,

1. That this is an application for restitution of conjugal

rights of the parties inrespect of their marriage held on
dt 02/12/2022 in Gagansha Kalyan Mandap at
sisupalgarh, Bhubaneswar-2.
2. That the parties are Hindus and governed by Hindu law.
3. That the petitioner is an advocate by profession. The
respondant/ husband is a logistics manager presently
doing business.
4. That the marriage of the parties held on dt 02/12/2022
at Gagansha kalyan Mandap plot no 17/18 Gangotri
 Nagar, sisupalgarh,Bhubaneswar-2 as per Hindu rights
and custom in presence of the family members, relatives
and well-wishers of the parties.
5. That the marriage of the parties is purely an arrange
marriage. The respondant, his parents and sister after
seeing to petitioner and many times interactions with
her agreed to complete marriage with respondant.
During time of marriage, there was no demand of dowry
either by respondant or his parents.
6. That soon after marriage the petitioner went with
respondant to her in laws house at Jharpada. After
completion of other ritual ceremonies of marriage,
reception and chaturthi the parties consummated their
happy marital relations.
7. That the mother of the respondant is a very dominating
lady. Her daughter having same character supported to
her mother. The mother in law of the petitioner being
an adamant, egoistic and dominating character lady
always imposed her dictatorship actions on the
petitioners. The petitioner is a well-educated and a
sover nature lady she always respected to her in laws
and also ready to respect them in future but unable to
dance on their directions.
8. That it is not understood why the parents are not
tolerating the happiness of the petitioner in their house.
The father in law of the petitioner is a retired person.
The petitioner do not know why and for what
reason ,there is no good relation between father and
son and husband and wife(father in law and mother in
law)
9. That during marriage, the parents of the petitioner
presented her and to her husband more than eighty five
grams of gold ornaments, silver 35 grams apart from
other house hold articles and furnitures valued of
Rs.6 lakhs/- only apart from the marriage expenses of Rs
about 20 to 25 lakhs.
10. That the father in law of the petitioner demanded a
car for his son, scooty and the mother in law of the
petitioner demanded gold ornaments, money for
constructions of her house and for running her own
business.

11. That the marriage of the parties was purely an arranged marriage. While the marriage
performed at that time the petitioner was working as musical teacher in Kendriya Vidyalaya,
khordha in state of odisha. During that time the respondant working as an employee in
ministry of agriculture department under central govt. of India posted at B.B.S.R.
12. That the parties are belonging to Bengali community.
13. That soon after solemnization of marriage, the parties resided together as husband and wife
at first khordha in the rented house taken by petitioner at her service place and happily
consummated their marital relation
14. That thereafter, due to transfer of the petitioner from khordha to Kendriya Vidyalaya-1 at
satya nagar Bhubaneswar, she allotted her official type 2 quarter bearing no.2/2 where the
parties resided together as husband and wife. The petitioner gave birth a male child namely
sanit which now 33 year already married and their residing with the petitioner at her present
residence.
15. That in the year 2002, the respondant transfer to the west Bengal. From 2002 to 2007, the
repondant coming to Bhubaneswar and keeping his marital relation with petitioner but since
year 2007 they have separated from each other having no marital relation till today.
16. That the official residiental quarter bearing no.2/2 satya nagar Bhubaneswar was the last
residing place of the parties have separated from each other finally in the year of 2007.
17. That the respondant was not paying a single pai to the petitioner even from date of her
marriage, rather always extracting money from her demanding she being his wife should
give all of her money and income to him although respondant getting more salary than the
petitioner.
18. That apart from the salary of income, the respondant as lot of residential and commercial
properties at west Bengal whose income is more than three lakhs per month. The repondnat
spending all of his money for their brother and sister but was not spending any money for
petitioner and her son. The respondant always torturing mentally by showing his cruel
behavior that the petitioner is ugly looking and she is aged than him . while the respondant
transferred from Bhubaneswar to west Bengal, he was regularly keeping his extra marital
relation with other ladies by showing their photos to the petitioner. He also demanding
divorce from the petitioner for his remarriage. The well-wishers of the parties several times
attempted to settle the disputes between the parties and for their re inion but it was in vain.
19. That even after separation residing of parties since year 2007 having no conjugal relation
between parties, the respondant through several communication harassing to the petitioner
by giving her mentally torture with utmost cruel behavior
20. That the petitioner id a retired person and her son not got his job but maintaining herself
and family with all hardship from her little pension income whereas the respondant’s
present income is more than three lakhs per month from his all source income i.e from
income of house property, agriculture property and pension income. Considering the
income of the present respondant, his family should have maintain equal status but the
respondant always neglecting petitioner and her son.
21. That the petitioner after her retirement having no house to take shelter has purchased a 2
BHK residential flat in Rashmi Enclave of plot no-66/146 subudhipur apart from she
purchased a small plot at Rajarhatta, Koikhali. Due to old age of the petitioner she bequeath
an will in favor of her son apprehending danger from respondant
22. That the last residing marital place of the parties of official quarter of the petitioner bearing
no.2/2 satya nagar Bhubaneswar under territorial jurisdiction of Hon’ble court. The parties
have also separated from each other since from year 2007
23. That there is no necessity to continue the marital relation between the parties in future,
hence this divorce petition filed before Hon’ble court.
24. That there is no collusion between the parties to file this application
25. That on 20/09/2018, 13/11/2018 and 1/12/2018, the respondnat through her advocate
issued several pleader notice threatening to petitioner. She also gave his reply to the said
letters of the respondant through her advocate. The repondant filed O.A no1731/2022 in
central administration tribunal west Bengal against the petitioner
26. That the cause of action arose on 24/06/2007 when the parties separated from each other
from their resident quarter no.2/2 satya nagar Bhubaneswar, on 1/12/2018 respondant send
advocate notice to petitioner and lastly when the petitioner received the summon of case
filed by respondant against her of O.A no. 1731/2022.
27. That for purpose of jurisdiction of Hon’ble court, this being the petition for dissolution of
marriage of parties valued of Rs 1000 /-only and this being the family dispute no court fee
required to pay.
28. That therefore the petitioner pray the following reliefs :-
(a) Let an order and decree be passed dissolving the marriage of the parties held before
special marriage officer west bengal and marriage certificate issued beating no 165 on dt
12/06/1987 along with the customary marriage on dt 19/05/1987 at 20 central A road,
Anandapury, Barrackpur, west Bengal.
(b) Let the cost of the suit of the proceeding be passed in favor of the petitioner and against
respondant .
(c) Let permanent alimony of Rs 50 lakhs/- only be granted in favor of petitioner against
respondant.
(d) Let any other relief’s be passed in favor of the petitioner as deem fit by Hon’ble court as
petitioner is entitle.

B.B.S.R By the petitioner

Date :-

Documents Relied on
1. Marriage invitation card (original).
2. Joint photo of marriage.
 3. Marriage certificate bearing no.165 on dt. 12/06/1987.
4. Pleader notice issued by respondant as pleaded.
5. Reply notice of the petitioner.
6. Copy of the case filed by respondent against against petitioner in west Bengal
central administrative tribunal.
7. Electricity bill of the residential flat of the petitioner.
8. Any other document as per pleadings.
9. Oral evidence.

Verification
I, Mrs Mukti Biswas, aged 68 years, W/O-Drbabrata
Manadal,At/Po,Ramchak, P.S-Khairi,Dist- East Medinipur.
Last marital residing place-Qtr no- type 2/2,kendriya Vidyalaya Staff
quarter, Satya Nagar, B.B.S.R At present Rashmi Enclave ,Plot no. 66/146
Subudhi pur,P.S-Tamando, B.B.S.R,PIN-751028, Dist-Khordha,do hereby
solemnly affirm and state that the contents of the above said petition are
correct and I have verified the same and put my signature on
this_____day of _____2023 at court premises.

Bhubaneswar Verificant
Dt:-

Affidavit
I, I, Mrs Mukti Biswas, aged 68 years, W/O-Drbabrata
Manadal,At/Po,Ramchak, P.S-Khairi,Dist- East Medinipur.
Last marital residing place-Qtr no- type 2/2,kendriya Vidyalaya Staff
quarter, Satya Nagar, B.B.S.R At present Rashmi Enclave ,Plot no. 66/146
Subudhi pur,P.S-Tamando, B.B.S.R,PIN-751028, Dist-Khordha,, do hereby
solemnly affirm and state as follows:
1. That I am the petitioner in this case.
2. That the facts stated above are true to the best of my knowledge
and on record.

Identified by me Deponent
Advocate