IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE, KARKARDOOMA COURTS, NORTH-EAST DISTRICT, DELHI

CT. CASE NO………. /20XX 

 IN THE MATTER OF:

XXXX                                                             …COMPLAINANT

                                 VERSUS

XXXX                                                        …. RESPONDENTS 

                                   INDEX

Date:                                                                                                              COMPLAINANT

New Delhi                         Through,

                                                COUNSEL                               

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE, KARKARDOOMA COURTS, NORTH-EAST DISTRICT, DELHI

CT. CASE NO………. /20XX

  IN THE MATTER OF:

XXX                                                                                                                     …COMPLAINANT

                                                                     VERSUS

XXX                                                                                                                                                  ... RESPONDENTS

MEMO OF PARTIES

SMT. XXX

W/o XXX

D/o XXXX

Ro- H-F-XXXX                                                                                                                                       … Complainant

Versus

1.  SH. XXX

S/o Sh. XXXX

R/o- H. No. XXXXX                                                                                                                         …. Respondent no.1

2.  SH. XXX

S/o Sh. XXX

R/o- H. No.  XXXXX                                                                                                                          …. Respondent no.2

3.  XXX

W/o XXX

R/o- H. No. XXXX                                                                                                                           …. Respondent no.3

Date:                                                                                                                                                                             COMPLAINANT

New Delhi                 Through,

                                                                                      COUNSEL

                                                                                              XXXX & ASSOCIATES

Office no._____________

 Mob .XXXXXXXXX

Email- XXXXX

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE, KARKARDOOMA COURTS, NORTH-EAST DISTRICT, DELHI

CT. CASE NO….../20XX

IN THE MATTER OF:

     XXXX                                                                                                           …COMPLAINANT

                                                                                                    VERSUS

XXXX                                                                                                                ….RESPONDENTS

COMPLAINT UNDER SECTIONS 12,17,18,19,20, AND 21 OF THE PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT 2005

MOST RESPECTFULLY SHOWETH: -

1.  That the complainant has been forced to approach this Hon’ble Court due to atrocities committed by the respondents.

2.  That the complainant has been subjected to domestic violence by the respondents and has been neglected further as respondent no.1 has refused to maintain the complainant, the respondents have caused physical and mental cruelties upon recreating circumstances leading to the complainant being forced to get out of the matrimonial home with minimal clothing, and respondents have not also provided shelter to her.

3.  That complainant is an aggrieved person, who has been in a domestic relationship with the respondents and has been subjected to acts of domestic violence committed by the respondents.

4.  That the respondents have committed acts of domestic violence by harming/injuring/endangering the health, safety, and life of the complainant and have caused physical abuses, sexual abuses, emotional abuses, and economic abuses and has deprived the complainant of economic and financial resources for which the complainant is entitled as per legitimate right and under section 22 of “The Protection of Women from Domestic Violence Act”, the complainant claims of Rs.__________ (_____________________________)  as compensation.

THAT THE BRIEF FACTS OF THE CASE ARE AS:

5.  That the marriage of the complainant and respondent no. 1 was solemnized according to the Hindu Rites and Customs dated 0X.X.20XX at _______. Out of the said wedlock, no child was born. The true copy of the marriage card and photograph is annexed herewith as ANNEXURE-A (Colly).

6.  That the respondent no.-2 is the father in law  (sasur) of the complainant, respondent no.-3 is the mother-in-law (saas) of the complainant, respondent no.-4 is the brother-in-law (devar) of the complainant, respondent no.-5 is the sister in law (nanad) of the complainant, and respondent no.-6 is the brother in law (jija) of the complainant.

7.  That it is pertinent to mention here at the time of the marriage a handsome amount was spent by the father of the complainant. Moreover, the demands of the parents of the respondent, various gifts and dowry articles including jewellery and other items were given to respondent no.1, his parents and sister and their other relatives.

8.  That the father of the complainant had spent more than that of his capacity on the marriage with great pomp and shows,but it is pertinent to mention here that in spite of it the respondent along with his family members didn’t get happy and were angry with the complainant and her parents because according to respondent, the complainant’s parents had not given enough dowry articles in the marriage as per their demands and this resultedin lots of mental as well as physical suffering to the complainant given by respondents and the same is mentioned below.

9.  That after the solemnization of marriage, the complainant was brought to the matrimonial home at House No. C-61, Ganesh Puri, Sahibabad, Ghaziabad, U.P by the abovenamed respondent where the complainant was welcomed very cold-heartedly by family members of the respondent, the reason of this was only that they didn’t get dowry as per their standard..

10.That when the complainant was brought to her matrimonial home after the marriage she realized through the behaviour of respondents that they were very aggressive, dominating and wanted to control the complainant in every respect, the complainant was not given any space and freedom to do anything in the house, the complainant found very difficult to deal with it but owing to the values given to the complainant by her parents, she always made every effort to deal with the miserable situation and kept quiet for the peace of minds of her parents.

11.That immediately after the marriage, when the complainant reached the matrimonial house instead of greeting the complainant, respondent no.1 and all the above-named persons started accusing the complainant that “TERE BAAP SE JAB HMNE FOUR WHEELER CAR MANGI THI DAHEJ ME TO USNE DAHEJ ME CAR KYU NHI DI. JAB TUM LOGO KI AUKAT HI NAHI THI DEMAND PURI KARNE KI TO SHAADI KARNE KI KYA JRURAT THI. HAME BHUT SARE UCHE RISHTE MIL RHE THE LEKIN HMARI KISMAT KHARAB THI JO TUM JAISAYE BHIKHARI HI LIKHE THE” But the fact is that the father of the complainant has given more than his capacity.

12.That it is pertinent to mention here on the next day of marriage, i.e. X.X.20XX, in morning the respondent no.3, who is the mother-in-law of the complainant, asked the complainant to hand over all stridhan belonging to her including the gifts, article and money.

13. That on the same day at the afternoon, all the above-mentioned respondents opened all dowry articles and looking to those articles, in spite of being of good quality, respondent no.3 (mother-in-law) remarked that the articles given by the parents of the complainant are very less and of worst quality and moreover commented that the father of the complainant has given very less dowry. The respondent no.2 (father-in-law) remarked that “HUMNE TO PHLE HI SAAF SAAF BOL RKHA THA KI DAHEJ ME LADKE KE LIYE EK CAR CHAHIYE LEKIN IN BHIKHARIO NE BINA KUCH DIYE HI PICHHA CHHUDA LIYA HAI” Respondent no.1, has also commented on this that “IN KANJOOSO NE NA HI CAR DI AUR NA HI CASH, KAM SE KAM EK JAGAH TO APNI BAAT RAKHTE YE HARAMI. CAR NHI DI TOH KAM SE KAM RS. ________/- DE DETE JISSE MAI EK KOI CHHOTI CAR KHARID LETA. IN BHIKHMANGO KI JAGAH MUJHE DUSRI JAGAH SHADI KR LENI CHAHIYE THI JO CAR DE RHE THE LEKIN SALA KISMAT HI KHRAB THI INN BHIKHARIO SE PALA PAD GYA HMARA”, afterlistening to all this the complainant felt quite humiliated but kept mum and felt that despite giving of so much things, the in laws were not satisfied. The complainant had no alternative expect to bear all such insult lest her marriage would be in danger that’s why she kept mum and started weeping going in her room.

14.That on the same day in evening mother-in-law called the respondent no.1 and started taunting and accusing the complainant in front of him, it is pertinent to mention here the respondent no.1 didn’t objected his mother at her taunts and willingly cooperated in all her bad acts against the complainant.

15. That one day in the morning parents-in-law and husband of the complainant called her and father-in-law (respondent no.2) and asked her to sit beside him. Then the respondent no.2 putting his hands on thighs of the complainant threatened that “AGAR YHA RHNA HAI TO MUJHE KHUSH RKHNA HOGA” that listening this the complainant objected, but the respondent no.1/ husband and respondent no.3 started abusing the complainant and thereafter the respondent no.1/ husband dragged the complainant into the room and started beating her, that it is pertinent to mention here that the respondent no.1 threatened the complainant that “MAIN ________ KE GUNDO KO JANTA HU, TERE PARIWAR AUR TERI BAHAN KO UTHWA LUNGA AUR USKI AUR TERI JINDAGI BARBAD KAR DUNGA AUR TUMHARI BAHAN KA BALATKAR KRWA DUNGA” That listening all this, the complainant felt quite humiliated but kept mum. The complainant had no alternative except to bear all such insult lest her marriage would be in danger that’s why she kept mum and started weeping in her room.

16.That on the very next day the complainant went upstairs to put wet clothes under sunlight, but when she returned downstairs , the respondent no.5 (nanad) asked the complainant that “CHAT PR ITNI DER SE KYA KAR RI THI TU, ROJ  ROJ CHAT PR JAKR ITNI DER KISSE NAIN MATAKKA KARTI H, TERA CHAT PR JANA BANDKARNA PDEGA MUJHE AB” but when complainant told that she had only gone upstairs to make the clothes dry, the respondent no.5 said that“MUJHSE JBAAN LDATI H RUK TUJE ABHI BATATI HU” and then the respondent no.5 pulled the hair of complainant and kicked at her stomach badly, the respondent no.5 never used to miss any opportunity to harass the complainant

17.That on the birthday of the respondent no.2 i.e. on 0X.0X.20XX everyone was present in the house. That day since the morning respondent no.5 & 6 kept provoking respondent no.1 making false allegationson the complainant, resulting which the respondent no.1 scolded the complainant in the evening and slapped on her face and kicked badly on her stomach in front of everyonepresent there, the complainant felt very humiliated and went into her room,that from behind the respondent no.6 (jija) came into the room to show his sympathy and to make understand the complainant, But to the utter surprise of the complainant the respondent no.6 (jija)put his hand on the waist of the complainant and grabbing her waist pulled toward him, that the complainant felt scared and pushed the respondent no.6 back and rushed out from the room, after this molestation the complainant started feeling unsafe in that house, the complainant couldn’t tell about this molestation by respondent no.6 (jija) to anyone due to hesitation and close family relation, the complainant reserves her right now to file a separate criminal case against respondent no.6 under relevant sections before the competent court of jurisdiction.

18.That on XX.0X.20XX when the complainant was washing clothes, the respondent no.2 (sasur) came to the complainant and took off his pant and underwear and thereafter throwinghis underwear on the face of the complainant, he asked her to wash it, the complainant started weeping and went to respondent no.3 (Saas) to tell about this conduct of the respondent no.2, but to the utter shock of the complainant respondent no.3 instead of doing something started scolding and shouting at the complainant that “TU KUTIYA BHUT BESHARAM HAI TUJHE APNE SASUR PR ESA BEHUDA AROP LGATE HUE SHARM NHI AATI HAI AGER UNDERWEAR UTAR BHI DI TOH KYA HUA DHONE KO HI TOH DI HAI AUR AGER SASUR KO KHUSH NAHI RAKHYEGI TOH TERA YANHA KYA KAAM TERA KAAM HAI YEH KI GHER SABHI ADMIYO KO KHUSH RAKHNA HOGA” Hearing the noise respondent no.2 (sasur) and respondent no.4 (devar) came there and respondent no.2 started slapping the complainant and respondent no.3 pulled her hair from behind,the conduct of respondent no.2 was such bad as he grabbed the breast of the complainant, the complainant was helpless and tried tooppose it, but the respondent no.2 held the hands of complainant from behind and told the respondent no.4 that “AAJ ISKA KAAM TAMAAM KAR DETE HAIN”, That the complainant tried hard to escape from there but respondent no.4 grabbed her tightly put his hand inside her salwar and rubbed her private part and the  complainant was helpless and started shouting to save herself at the mean timeall of them left her and warned if she open her mouth to anyone she would be raped and murdered, that when the respondent no.1 came home in evening the complainant told about all incidents happened to her but this is utter surprise the respondent no.1 didn’t care of this, the complainant had expected that her husband would understand what she was bearing with but instead the respondent no.1 didn’t bother to listen the problems of the complainant and said“KUTIYA TU TO BILKUL HI BESHARAM HAI BAHAR DUSRO SE CHAKKAR HAI TERA AUR GHR ME LOGO KO BADNAM KRNE ME LAGI HUI HAI”, this response of respondent no.1 to the complainant harassed her mentally as well as emotionally. Her own house had become hell to the complainant as she was living like a dead body with this mental trauma in that house, not a single person in the house was ready to talk to her gently and all members of the family were willingly torturing the complainant with the motive that the complainant would leave the house one day being tired of all kind of torture. The Copy of the duly signed written complaint of the complainant is annexed herewith as ANNEXURE-B.

19.That on XX-0X-XX when the complainant didn’t leave the matrimonial house in spite of lots of cruelties on her, the respondent played a trick and asked the complainant that to complete her file of B.A final year she should go to her paternal home because the situation in her matrimonial home was not good and promised to bring her back when everything would be normal.

20.That it is pertinent to mention here when the complainant was sent to her paternal home, the respondent started avoiding her phone calls and if ever he picked up her phone call, he would blame the complainant that it is because of the complainant the situation of his house gone wrong and then after abusing her over the phone the respondent used to cut the call.

21.That the same state of affairs was pursued till XX.0X.20XX and when the complainant made a phone call to the respondent on XX.0X.20XX. During the phone call conversation, the respondent started giving false excuse and said that he has been abandoned from his house and now he is living separately in rented accommodation and it is further submitted that the complainant continuously made an efforts for a successful and bright married life but respondent never showed any interest or put any efforts during the phone call the complainant continuously approached and voluntarily wanted to reside with respondent. That the respondent further said that “MUJHE TUJHE APNE SATH NAHI RAKHNA OR AB TOH MERI POLICE MEI NAUKARI LAG GAYI HAI AB TU MERE LAYAK NAHI RAHI OR MUJHE PHONE KARNE KI JARURAT NAHI HAI” Thereafter the respondent started avoiding phone calls of the complainant.

22.That on XX.0X.20XX the complainant herself reached at her matrimonial home but the respondent’s parents did not open the gate of the house and started shouting from inside the house that “MERA BETA UTTAR PRADESH POLICE ME BHARTI HO GYA HAI AB AGAR TUM 5 LAKH NAGAD AUR GAADI FOUR WHEELER LA SAKATI HO TO IS GHAR KE DARWAJE TUMHARE LIYE KHUL JAYENGE NAHI TO YE DARWAJA HAMESHA KE LIYE BAND HAI AUR AGAR TUM POLICE SE JABARDASTI GHAR ME AOGI TO HUM TUMHE NAUKRANI BNAKAR RAKHENGE”  the complainant left with no other option despite of making a phone call to the police station, after reaching of police official at Complainant’s matrimonial home officials requested the respondent’s parents for opening the main gate of the house but they did not come out, as an alternative the police official marked XX-0X-20XX with mutual consent of complainant and respondent and his family for settlement of disputes between the complainant, respondent and his family.

23.That on XX.0X.20XX PANCHAYAT was held and the respondent himself voluntary admitted in PANCHAYAT that respondent and Complainant would stay together in rented accommodation i.e. address at ____________. That it is further submitted the respondent made the life of the complainant like a nightmare from XX.0X.20XX till 0X.XX.20XX, the respondent used to abuse and assault her and the respondent clicked nude pictures of the Complainant and forced her for unnatural sex, It is pertinent to mention that the respondent threatened the Complainant with acid & blade attack on her face if Complainant did not fullfill all his erotic/sexual desires or did not go back to her parental home.

24.That the respondent was selected for UP Police and according to the parameters training is mandatory before getting posted as police official therefore the Complainant requested her lived at rented accommodation  near her parental house during his training period, all her clothes, ornaments and other necessary items were at her matrimonial home and she felt unsafe while staying alone in rented accommodation but the respondent clearly refused to do so, but on 0X.XX.20XX the respondent took other rented room near complainant’s parental home for Complainant to stay there during his training period and promised her that he would take her back when he returned back from his training, that it is pertinent to mention here that in PANCHAYAT the respondent was asked to open a joint bank account therefore he opened a joint bank account in Central Bank of India with the Complainant and deposited Rs. ________ and the respondent further signed written commitment that he would deposit monthly expenses of complainant of Rs__________ in the joint bank account for the expenses of Complainant. That the respondent failed to deposit money for the monthly expenses of the complainant as promised by him in the written commitment.  The Copy of the duly signed written commitment of the respondent is annexed herewith as ANNEXURE-C.

25. That on 0X.X0.20XX the respondent left for training and since then the respondent never picked up the phone call of the complainant. It is pertinent to mention here that 20 days later the respondent came to the complainant’s rented accommodation and forcefully made an unnatural physical relationship with her against her wish and returned back in morning, Again it is pertinent to mention here that the respondent now stop answering the phone and if he ever picks, then abuses over the phone and threatens to commit suicide to falsely implicate the complainant. It is also pertinent to mention here that now the respondent has stopped depositing any monthly expense to the complainant in the account. The copy of the bank statement of the complainant is annexed herewith as ANNEXURE-D.

26.That it is pertinent to mention here on XX.0X.20XX to her utter surprise & shock the complainant received the Divorce paper sent by the respondent, the complainant felt humiliated as her life has become meaningless and now is forced to live in solidarity being dependent on her old parents in this present pandemic situation. Being aggrieved the complainant approached the police officials to register her complainant but till now no course of action was taken against the respondent on the complaint.

27.That the complainant had really gone to a drastic trauma and her life has become hell since the first day of her marriage. Whatever the worst thing she could have faced from the respondent she faced it but she has got mentally sick day to day due to the inhuman behaviour by the respondent and his family, as the respondent had very careless and irresponsible attitude towards his personal relationship with the Complainant and the respondent never perform his husbandly duties, he only abused and tortured the Complainant without any reason which was a complete mental and physical trauma for her, the complainant bear all the expenses even the doctor expenses of her and on every alternate day on one pretext or the other the respondent pressurised the Complainant to leave him by giving her mental torture and showing his disrespectful behaviour but when he didn’t succeeded in this, he played a well calculated trick to throw out the Complainant from his life, but the Complainant was in the hope that one day the situation would get normalise and the respondent would take her back at her matrimonial home but the attitude and behaviour of the respondent did not improve at all and his behaviour became inadequate day by day, the Complainant was ill-treated and put through extremely grave and inhabitable circumstances by her husband, she was abused, put into torturous state of affairs, got harassed, continuously rebuked and physically as well as mentally tortured and ultimately to her utter surprise she received divorce paper from the respondent.

28.That the complainant was in the hope that one day the situation would get normalise and the respondent would take her back in her matrimonial home but the attitude and behaviour of the respondent didn’t improved at all and his behaviour became bad to worst the complainant was ill-treated and put through extremely grave and inhabitable circumstances by her husband, she was abused, put into torturous state of affairs, got harassed, continuously rebuked, and physically as well as mentally tortured and ultimately to her utter surprise she received divorce paper from the respondent.

29.That for the purposes of fetching more and more dowry and other related items because the respondent has been selected in UP Police, the complainant was left abandoned by the respondent and his family. It is pertinent to mention here that due to the extreme unpleasant treatment and not being given any monthly allowances to the complainant, the complainant had to leave her rented accommodation and became dependent on her old aged parents, It is pertinent to mention here that the in laws of the complainant didn’t not returned the complete dowry and stridhan articles, which were entrusted to them and they were having domain and control on the same, despite demands for the return of the same by the complainant. Thus, all of them have committed the offence under various provision of law.

30.That the complainant became the victim of the mental and physical tortures made upon her by respondent on account of non-fulfilment of his illicit demands and moreover a fraud and breach of trust is committed upon her by respondent.

31.That the respondent has been working as constable in UP Police and taking a handsome salary but the complainant is totally helpless having left with no option but to become dependent on her old parents, the respondent owns many agricultural lands in his village and receiving good income from there, it is imperative to mention that the respondent also possesses many rental properties and getting handsome amount from the rent. That the father of the respondent is working and getting sufficient income for his survival. That, in spite of having no social liability except to maintain the complainant, the respondent is not discharging his responsibility, the complainant is unable to maintain herself and the respondent has wilfully neglected the complainant and has failed to maintain her, It is submitted here that the respondent left the complainant abandoned and said that he would soon remarry.

32.That the complainant is residing at her parent’s home and facing hardship to maintain herself as she is having no source of income to fulfil all her necessities of life, the complainant is not working and her husband owes duty to maintain her but failed to do so instead the complainant is totally dependent on her old and poor  parents who are not working. The copy of the adhaar card of the complainant is annexed herewith as ANNEXURE-E.

33.That the complainant was ill-treated and put through extremely grave and inhabitable circumstances by her husband, she was abused, put into torturous state of affairs. She was harassed, continuously rebuked, and physically as well as mentally tortured,she was repeatedly abused in all ways and forced to be dependent on her parents.

34.That immediately after marriage, the respondents tortured the complainant with all types of cruelty, bodily and physically beatings, thrashing and further bodily, physical and mental cruelty and harassment more particularly for the purposes of fetching more and more dowry and other related items because the respondent has been selected in UP Police, It is pertinent to mention here that due to the extreme unpleasant treatment and being given any monthly allowances to the complainant, she was forced to leave rented accommodation and go to her parents it is pertinent to mention here that the in laws of the complainant had not returned the complete dowry and stridhan articles, which were entrusted to them and they were having domain and control on the same, despite demands for the return of the same. Thus, all of them have committed the offence under various provision of law. She could never live a happy married life with respondent.

35.That the complainant’s entire stridhan dowry articles are in the custody of respondent and his family which haven’t been returned by them to the complainant despite repeated request made by the complainant and is misappropriating the same and repeatedly threatening the complainant and her family members.

36.That the complainant became the victim of the mental and physical tortures made upon her by her husband and in laws on account of non-fulfilment of their illicit demands and moreover a fraud and breach of trust committed upon her by her husband and her in-laws. That the acts committed by the respondent come within the definition of domestic violence as enshrined in the act.

37.That the respondent no.1 has been openly threatening the complainant and her family members of elimination from the world and thereafter he would soon remarry. The complainant reserves her right to lodge criminal complaint against the respondent and his family members about the same.

38.That the complainant is residing in Delhi from the date when she was left abandoned by the Respondent and the complainant is also residing within the territorial jurisdiction of this Hon’ble Court. Hence this Hon’ble Court has power to entertain and try the present petition. 

PRAYER

It is therefore most respectfully prayed before this Hon’ble Court to take cognizance of the complaint/Domestic Incident Report and this Hon’ble Court may be pleased to pass:-

A.  Pass protection orders under section 18 and/or

-      Prohibiting acts of domestic violence by granting an injunction against the Respondents from repeating any of the acts mentioned in terms of the application.

-      Directing the respondents to stay away from complainant and her parents.

B.       Monetary reliefs under Section 20

-      Direct the respondent to pay monetary relief of Rs.________/ - ( ­______Only) per month

-      Direct the respondent to pay Rs._________/- towards litigation charges.

C.  Compensation order under section 22

-      Direct the respondent to pay an amount of Rs.________ (__________ Lakhs Only) towards compensation for damages under the Protection of Women from domestic violence act 2005.

D. Directing the respondents to hand over the goods/clothes, articles, and belongings of the complainant which are still in the custody of the respondents.

E.  Pass such interim orders as the Hon’ble Court deem just and proper.

F.  Pass any other orders as deems fit and proper under the given facts and circumstances of the case for protecting the aggrieved person from domestic violence and in the interest of the justice.

Complainant / Aggrieved Person

VERIFICATION

Verified at New Delhi on this __ day of __, 2021 that the content of the above affidavit is true and correct to my knowledge. No part of it is false and nothing material has been concealed therefrom.

          Date:                         Complainant / Aggrieved Person

              New Delhi                          Through,

COUNSEL

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE, KARKARDOOMA COURTS, NORTH-EAST DISTRICT, DELHI

CT. CASE NO……/20XX

IN THE MATTER OF:

      XXXX                                                                                                                                                             …COMPLAINANT

                                                                                           VERSUS

  XXXX                                                                                                                                                               ….RESPONDENT

AFFIDAVIT

I, Ms. XXX, W/o Sh._____, R/o-H. No.- XXXXXXXXXXXXXX the deponent, do hereby solemnly affirm and declare as under:

1.  That the deponent is the complainant in the abovementioned case, filing the present complaint, and well conversant with the facts and circumstances of the present case hence, competent to sign this affidavit.

2.  That the content of the accompanying complaint is drafted by my counsel and all the legal averments are true and correct to my belief which is based on legal advice rendered and believed to be correct

3.  That I have gone through and understood the contents of the same, I say that the facts stated therein are true and correct to my knowledge.

DEPONENT

VERIFICATION

Verified at New Delhi on this __ day of __, XXXX that the content of the above affidavit are true and correct to my knowledge. No part of it is false and nothing material has been concealed therefrom.

                                                                                                                                             DEPONENT

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE, KARKARDOOMA COURTS, NORTH-EAST DISTRICT, DELHI

CT. CASE NO…../20XX

IN THE MATTER OF:

XXXX                                                                                                                                                                      …COMPLAINANT

VERSUS 

    XXXX                                                                                                                                                                ...RESPONDENT

AFFIDAVIT U/S 23(2) OF THE PROTECTION OF WOMEN FROM DOMESTIC VOILENCE ACT,2005

I, Ms. XXXXXX, W/o Sh. XXXXXX ,R/o- H. No.-X-X, Street No.-X, XXXX, Delhi, XXXXXX, the deponent, do hereby solemnly affirm and declare as under:

1.  That the deponent is the Complainant/Applicant in the accompanying application filed by the complainant under the relevant sections of the Prevention of Women from Domestic Violence Act 2005. That the contents of the complaint may be read as part and parcel of the present application and the same is not being repeated here for the sake of brevity and applicant craves to leave to refer the same at the time of arguments.

2.   That being conversant with the facts and circumstances of the case I am competent to swear this affidavit & accompanying application has been drafted by my counsel under my instruction, the contents of the same have been explained to me in vernacular and the said contents are true and correct.

3.  That the stridhan articles are under the care and custody of the respondents.

4.  That the details provided in the present application for the grant of relief under section 18, 19, 20 and 23 have been entered into by applicant/at my instruction by counsel.

5.  That the contents of the application have been read over, explained to Applicant in English/Hindi.

6.  That the contents of the said application may be read as part and parcel of this affidavit are not repeated herein for the sake of brevity.

7.  That the applicant apprehends repetition of the acts of the domestic violence by the respondents against which relief is sought in the accompanying application.

8.  That the applicant apprehends repetition of the acts of the domestic violence by the respondents against which relief is sought in the accompanying application. Because the respondents have threatened the applicant that the applicant will be eliminated at any point of time.

9.  That the reliefs claimed in the accompanying application are urgent in as much as the applicant would face great financial hardship and would be forced to live under threat of repetition/escalation of acts of domestic violence complained of in the accompanying application by the respondents if the said relief are not granted on an ex-parte ad-interim basis.

10.That the facts mentioned herein are true and correct to the best of my knowledge and belief and nothing material has been concealed there from.

DEPONENT

VERIFICATION

Verified at New Delhi on this __ day of __, XXXX that the content of the above affidavit are true and correct to my knowledge. No part of it is false and nothing material has been concealed therefrom.

DEPONENT

IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT, KARKARDOOMA COURTS, NORTH-EAST DISTRICT, DELHI

CT. CASE NO………../2021

 IN THE MATTER OF:

      XXXXXX                                                                                                                                      …COMPLAINANT

VERSUS

   XXXXXXXXXXXXX                                                                                                                             ...….RESPONDENT

LIST OF DOCUMENTS

Date:                                                                COMPLAINANT

New Delhi                                 THROUGH,

COUNSEL

XXXXXXXXXXXXXX & ASSOCIATES

                                             Office no. X, XXXXXXXXXX,

        Delhi-XXXXXX, Mob. XXXXXXXXXX

Email- xxxxxxxx@yahoo.in