Draft for Legal Notice, Erwin Thomas Wilson@LexCliq

Dated – 04th May 2021


MRS. Sheeba Mathew

D/O John Thomas

209, Travancore Apartment,

MG Road,



Sub:-  Legal Notice for Restitution of Conjugal Rights


Under instruction from and on behalf of my client Mr. Mathew Tharakan son of Mr. Paul Tharakan, resident of Kunnathu house, C.P Road, Vadakara, Calicut, I do hereby serve you with the following notice, the contents of which are set forth herein below :-

  1. That you were married with my client on 11th May 2015, at St. Mary’s Church , according to Christian rites and ceremonies in the presence of friends, relatives and family members of both the parties.
  2. That after the marriage you and my client lived together as husband and wife and cohabited with each other and. Out of the said wedlock of my said client and you one son named Michael aged 2 years was born.
  3. That on 14th March 2021 last you went to your father’s house at MG Road Calicut. You gave word to return within 15 days, but you did not abide by your word and has not returned so far.
  4. That my client went to his father-in-law’s house at MG Road Calicut to bring you back, a number of times, but on one pretext or the other, you declined to come along with my client to his house.
  5. That lastly my client went to the house of your father at MG Road on 13th April 2021 and asked you to return with him, but you refused to come.
  6. That you have deserted my client or/and has withdrawn from his company without any reasonable or lawful excuse. Hence the necessity for the legal notice arose.
  7. Through this legal notice in a family matter, I hereby instruct you in your own interest to rejoin my client and perform your matrimonial obligations, for which he has the legal right and also rejoin my client in his house within 14 days otherwise my client has given me clear instructions to institute a suit for restitution of conjugal rights in the competent court of law, at your risk and costs.

A copy of this legal notice is retained in my office for record and further necessary action.


Erwin Thomas Wilson, Advocate

Dated – 04th of May 2021

Place – Calicut

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