Quick Contact
- Office No.101, Himland House, Commercial Complex,Karampura, Delhi-110015, India
- 8171974067
- info@lawvs.com
Copyright ©2025 Lawvs.com | All Rights Reserved
MC
NO. XXX OF 2022.
IN
THE MATTER OF :-
XXXXX : COMPLAINANT
VERSUS
XXXXX : RESPONDENTS
EVIDENCE BY WAY OF AFFIDAVIT
OF THE COMPLAINANT (CW1)
1.
That I am the complainant
in the above-said case and well
conversant with the facts of the case and competent to swear the present
affidavit.
2.
I stated that the
marriage between the Deponent and the respondent was solemnized according to
Hindu customs and ceremonies on 21.02.2019 at New Delhi with pomp and shows.
3.
I further stated that
after the marriage the Deponent and respondent no.1 lived together as husband
and wife and the marriage was duly consummated at matrimonial home.
4.
I further stated that the
Deponent’s parents spent decent money on her marriage from personal sources and
from relatives to meet the expenses and demands of her in-laws. Deponent’s
parents also spent on dowry articles, gifts at reception of marriage and
incurred a total expense of Rs.9.50 Lacs/-.
5.
I further stated that after
few days of her marriage Deponent’s sufferings started when respondent no.1 and
respondent no.2 ill-treated her and harassed her for not bringing dowry as per
there expectation. That the Deponent suffered atrocities committed by my
husband and his family members namely Mrs. XXXXX mother-in-law, XXXXX father in
law and XXXXX sister in law.
6.
I further stated that all
respondents had neglected, abuses, taunted and committed cruelty upon the Deponent
due to dowry greed and have caused physical and mental cruelties to the Deponent
and her parents.
7.
I further stated that there
the Deponent was subjected to multiple incidents of atrocities/violence,
physical and mental cruelties/ harassment committed by my husband and his
family members.
8.
I further stated that for
few weeks of marriage everything was going normal but with the interference of
Bhabhi of my husband XXXXX (respondent No.4) Respondnent No.1 started to
torture Deponent for getting less dowry. That respondent No.1 , 2 & 3(i.e.
husband, mother in law XXXXX and bhabhi XXXXX all jointly harassed Deponent and
ill treated her in daily basis and their behavior was always taunting and
abusing for not getting BIKE and A.C on
regular basis in collusion with each other.
9.
I further stated that respondent
No.1 husband, mother-in-law Mrs. XXXXX
,my father in laws XXXXX and
sister-in-law(Bhabhi) XXXXX in collusion and with common intention have caused
physical and mental cruelties in order to harass Deponent and forced Deponent
the demand of dowry, initially they have been able to take out Rs. XXXX/- in
first 3 months of marriage from my parents on my visits to my parental home
.But soon Deponent refused to adhere to their illegal demands, then Deponent
was beaten badly by husband for the first time on first week of April 2019 in
support of all of the above named respondents and she was left in agony, pain
and tears.
10.
I further stated that on
17.05.2019 Deponent came to her parental home with her parents in Delhi for few
days. At that time Deponent pregnant of three months. The parents of Deponent
also invited respondent No.1 to Delhi on 18.05.2019 and when respondent No.1
was informed about pregnancy at Delhi and on 19.05.2019 very next day at Delhi
respondent No.1 give Deponent one medicine and insisted and requested her to
consume it and cheated her by giving her medicine to abort pregnancy of 3
months punishable under law. Respondent No.1 under the pretext of mu good
health said the said medicine is good for health of Deponent and her child in
womb. That soon after consuming the said medicine, Deponent’s health started to
deteriorate and her mother took her to private doctor’s clinic at XXXXX, Delhi
on 20.05.2019.
11.
I further stated that Doctor
diagnosed Deponent and informed that Deponent has suffered miscarriage and Deponent
informed doctor that her husband has given her one tablet and thereafter she
felt uncomfortable and came to doctor’s clinic. Deponent suffered miscarriage
only due to medicine given by respondent No.1 and when Deponent tried to talk
to respondent No.1 he ignored questions of Deponent and went back to Himachal
on 21.05.2019 at my matrimonial home leaving Deponent alone in pain and agony
at her parental home.
12.
I further stated that then
Deponent came to know that her husband came to her parents home in Delhi with
sole intention to abort 3 months pregnancy of Deponent on the instruction of his
bhabhi respondent No.4. After 21/05/2019, my in laws and my husband never
bothered to contact Deponent and ask her health condition this was very
shocking for Deponent and her parents. Thereafter the real intentions and true behavior
of all the respondents was revealed and with the intervention of common
relatives in March, 2020 Deponent went back to my matrimonial home along with her
mother at Himachal there she was not welcomed and soon the same ill treatment
continued towards Deponent on regular basis. Deponent was not provided proper
food and basic necessities of day to day by Respondent No.4 and No.1.
13.
I further stated that on
15/03/2020 on instruction of respondent No.4 and No.1 Deponent was asked that
where is AC and Bike and further said that, tu khal haath aa gai tere ko AC
bola wo nahi layi or na hi Bike lai hai, tera yaha jiwan nark bana de ge agar
AC & bike nahi lai to, and thereafter Deponent was slapped by her husband
and my mother in law and bhabhi stood there and kept on supporting respondent
No.1.
14.
I further stated that before
marriage respondent No.1 told parents of Deponent that he was earning Rs.XXXX/-
but after marriage he never give Deponent a single penny for day to day
expenses and never bought her a single item of daily basis necessity. All the
members of matrimonial home use to illitreat Deponent and also caused mental
torture her.
15.
I further stated that on
March 20** Deponent was forced to confine herself in a room and thereafter she
was locked in a room at basement of the matrimonial home. Deponent was starved
for long hours, and was only given food and water one in 24-30 hours, even
washroom was not accessible to her .Life of Deponent was full of suffering at
my matrimonial home complainant regularly requested all respondents (her mother
in law /Bhabhi/father in law and my husband) for mercy and asked for food water
and freedom of movement in matrimonial home but no one listened to her requests
and her life continued to be like prisoner in hell.
16.
I further stated that all
the above named persons did not allowed Deponent to go outside from that room
and treat her like animal and serve the food on like animal and they cut the
electricity of the room and window the room completely in dark and hot when Deponent
shouted and bagging for food my husband and his bhabhi and her mother in law
given me beating several times mercilessly, she continued to suffer cruelty and
torture due to the acts of her husband and his family members.
17.
I further stated that mother
is law (XXXXX) of Deponent used to say “jo kuch bhi chahiye apne maa baap se
mang, aur hume paisa chahiye tabhi tujhe khana mile ga” and on her instance,
husband and his bhabhi use to beat Deponent. Respondent No.1,2 & 4 (husband,
mother-in law and sister-in law XXXX) snatched all her jewelry and valuables
worth Rs. XX Lakhs which given by parents and relatives. As and when Deponent tried
to inform all this cruelty to her parents over phone her phone was snatched by her
husband. On 18/04/2020 and respondent No.1 (husband) also snatched and torn
diary of Deponent where she wrote all the crudities, harassments and dowry
demands and painful incident.
18.
I further stated that Respondent
No.1 (husband) consumed/ tried all type of drugs and always intoxication and in
state of intoxication used to beat Deponent mercilessly on petty issues and
mobile phone of Deponent was also damaged by him, parents of Deponent were
unable to contact her and they requested Massi and Mama of Deponent, who live
near to matrimonial home of her. That relatives of Deponent came to matrimonial
home to get her well being and why her in laws are not picking up their calls. Deponent’s
Massi and Mama came to matrimonial house on 19/03/2022 and informed all the
incident to parents of Deponent in Delhi over the phone that “isee ek kamre mai
band rakha gaya hai na hi waha light hai aur na hi pankha hai” my Massi and
Mama also click my photo and send it to her parents thereafter Deponent’s
parents regularly called to all respondents but they didn’t not respond to any
calls.
19.
I further stated that during
the period of lockdown brother in law (Jeth) of Deponent died in the night and
at that time whole family of respondent No.1 shifted to another place at night
8-9 pm, living behind Deponent alone in that locked room and in the morning at
4-5 AM and thereafter Deponent was dropped to her Massi’s home and upon
inquiring by Deponent that what happened respondent No.1 didn’t responded.
After a week respondent No.1 came and took Deponent back to his home and against
Deponent was confined/locked in same room, Respondent No.1 used to give Deponent sleeping pills and as a
result she use to be lying in a like animals and when parents of Deponent asked
respondent No.1 why you have locked me in room, he flatly refused and said I
never locked her in a room and in reaction he filed a complaint against Deponent
for implicating me in a suicide case, when police come at matrimonial home then
immediately respondent No.4 my sister in law unlock Deponent from room and told
her “don’t open your mouth otherwise you know the consequences and do what we
say” thereafter they stand me in front of those policeman and they signed some
papers from me and warned me “asi dhamkiya dubara nahi deni hai”, and
thereafter they again locked Deponent in that room. That Deponent secretly told
the entire incident to her parents when her parents called in laws and asking
about this incident but all the respondents flatly refused that any such incident took place and further
abused parents of Deponent, but they (parents of Deponent) never stopped and contacted
to village Pradhan and then all the respondents told the truth and said “Anu ke
khilaf dhamki pradhna ke bhi sign karwaye hai aur usmai yah likha gaya hai ki
Anu mansik tor per preshan hai” this fact was never in the knowledge of Deponent.
Thereafter immediately father and brother of Deponent came to matrimonial home
and try to resolve the issues but respondent No.1 husband refused to talk
anything and abuses father and brother of Deponent and used filthy language against
the Deponent in front of her father and brother after this Deponent’s father
took her back to Delhi to save her life from the atrocities of all the
respondents and constant dowry demands.
20.
I further stated that Deponent
during her entire stay at the matrimonial home had not been given a single
penny to meet her day to day expenses her life became miserable in her
matrimonial house due to the acts of all the respondents. All the above named
persons threaten Deponent, that husband and in laws of Deponent will attack father
and brother and other family members of Deponent. All the respondents used to
beat, taunted and humiliated Deponent and by deceiving respondent No.1 gave
aborting pill to the Deponent and her 3 months pregnancy was aborted and
matrimonial life was ruined by Respondent No.1 and all other respondents and
they all committed all acts deliberately and intentionally, to force Deponent
throw away from my matrimonial home.
21.
I further stated that Deponent
cannot write all details of the atrocities committed by my husband and his
parents and sisters in laws, as such Deponent reserves her right to file
additional details before your lady police officer/protection officer during
investigation.
22.
I further stated that parents
of Deponent gave gold jewelry worth Rs.4.50 Lakhs and other articles i.e. stridhan
to the Deponent which are in the custody of all the accused persons and in
total amount spent is Rs. XX lacs. Due to these acts of the cruelties committed
by all the respondents Deponent is perforce to file this complaint so that appropriate
action against the all the respondents. That the entire jewellery, cloths, valuables and necessary things lying in my matrimonial
home as the Deponent was thrown out in two cloths since then she is not allowed to enter in
the matrimonial home.
23.
I further stated that entire Jewellery and Stridhan which are illegally
retained with my husband and mother in law despite my repeated requests, both
have refused to handover Deponent by saying that they will not return Jewellery,
Stridhan and clothes at any cost.
24.
I further stated that an
complaint has already been registered at CAW cell and FIR under provisions of
498-A/406 IPC is already registered.
25.
I further stated that the
Deponent and respondent no.1 forced the Deponent to go from matrimonial home on
04.09.2020 and the act of cruelties committed by the respondents is affecting
the Deponent mental health.
26.
I further stated that while
the Deponent was living in matrimonial with her husband; the Respondent No.2
& 3 and respondent no.4 all were sharing same kitchen and shared meals and
basic amenities at the matrimonial home of the Deponent. During her stay at
matrimonial home the Deponent, all the
respondents always used to complain a lot for not being given enough dowry and
subsequently let to opportunity of harass and pressurize Deponent for Bike and
AC and cash.
27.
I further stated that till
date, the Respondents are commenting about the Deponent and her parents to
common relatives on regular basis and hurls abuses and alleges on complaint’s
character and casts aspersion upon the character of Deponent.
28.
I hereby state that
whatever is stated hereinabove is true and correct to the best of my knowledge.
DEPONENT
VERIFICATION:-
Verified at New Delhi on ___ day of June,
2024 that the contents of paras 1 to 28 of my above evidence affidavit are true
and correct to the best of my knowledge and belief and nothing has been
concealed there from.
