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MC
NO. ___ OF ___.
IN THE MATTER OF :-
______________ : COMPLAINANT
VERSUS
___________________-__ : 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 __________
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._____ 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 ________ mother-in-law, ________ ________ father in
law and _________ 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 ____________ (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 __________ and bhabhi _________) 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. __________
,my father in laws __________ and
sister-in-law(Bhabhi) ________ 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.______/- 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 ________ in support
of all of the above named respondents and she was left in agony, pain and
tears.
10.
I further stated that on ________ 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 _________ and when respondent No.1 was informed about pregnancy at
at Delhi and on ________ 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 _________, Delhi on ___________.
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 _______
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 ________ 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 __________
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 _________ on
instruction of respondent No.4 and No.1 Deponent was asked that where is AC and
Bike and further said that, ______________, 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________/- 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 ill treat Deponent and also caused mental torture her.
15.
I further stated that on ___________ 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 (_________)
of Deponent used to say “____________” 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 _________) snatched all her jewelry and valuables worth Rs._________
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
________ 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 ________ and informed all the incident to
parents of Deponent in Delhi over the phone that “____________” 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 againt 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 “_________”, 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 “____________” 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. ________ and other articles i.e. Istridhan to the Deponent
which are in the custody of all the accused persons and in total amount spent is
Rs______. 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 a 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 ___________ 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, ____ 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.
