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IN THE COURT OF A.C.M.M, DISTRICT
ROHINI, DELHI.
MAINTENANCE
APPLICATION NO. OF 20..
IN THE
MATTER OF :-
……………………. …Petitioner
INDEX
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1. MEMO
OF PARTIES
2.
PETITION
FOR MAINTENANCE
UNDER SECTION 125 Cr.P.C
ALONGWITH AFFIDAVIT
3.
APPLICATION
FOR INTERIM
RELIEF ALONGWITH AFFIDAVIT
4.
LIST
OF DOCUMENTS.
5.
VAKALATNAMA.
--------------------------------------------------------------------------------
Petitioner
ENROLMENT
NO. AND ADDRESS
IN THE COURT OF A.C.M.M, DISTRICT
ROHINI,
MAINTENANCE
APPLICATION NO. OF 2007
IN THE
MATTER OF :-
………………….. …Petitioner
MEMO OF
PARTIES
………………….
W/O
SH………………….
D/O
SH……………………
R/O
………………………… ……PETITIONER
VERSUS
SH.
…………………,
S/O
…………………,
R/O………………………,
……RESPONDENT
Petitioner
ENROLMENT
No. AND ADDRESS
IN THE COURT OF A.C.M.M, DISTRICT
ROHINI,
MAINTENANCE
APPLICATION NO. OF 2007
……………..
W/O
SH. …………………
D/O
SH. ………………..
R/O…………
……PETITIONER
VERSUS
SH.
………………,
S/O
…………………,
R/O
……………….. ………RESPONDENT
APPLICATION FOR SEEKING MAINTENANCE UNDER SECTION 125 Cr.P.C FOR
AND ON BEHALF OF PETITIONER.
`````````````````````````````````````````````````````````````````````````````
AMOUNT CLAIMED –RS.50,000/- PER MONTH.
1. That
the petitioner is the legally wedded wife of the respondent The petitioner is
residing within the jurisdiction of this
2. That
petitioner was married to the respondent according to the Hindu rites and
ceremonies on 17.8.2004 at
3. That
petitioner and the respondent stayed together after their marriage till
26.11.2004 and thereafter the petitioner was residing with her parents.
4. That
the petitioner was subjected to the utmost cruelty by the respondent and his
family members on account of dowry demands. The petitioner has already filed a
criminal complaint to this effect before the CAW Cell against the respondent
and his family members and the same was converted into an FIR and the contents
of the same are not repeated herein for the sake of brevity and the same may be
read as part and parcel of this petition. Copy of the same is annexed herewith
as Annexure-A.
5. That it was an arranged marriage and father of
the petitioner solemnized a decent
marriage and gave Centro Car, golden
jewellery and other valuable articles in dowry and spend about Rs.8 lacs in the petitioner’s marriage.
6. That
it is regretted that respondent and his
family members are not satisfied with the dowry articles given by petitioner’s father at the time of solemnization of marriage and on very first night, the respondent said the petitioner that there were many parties who were ready
to given Rs.12-14 lacs in dowry. The
condition of the petitioner can be well imagined as she had
to listen these words on very first night of her matrimonial life. The petitioner became suspicious on very first night that the intention of the
respondent and his family members is malafide. The mother-in-law, father-in-law
and sister-in-law of the petitioner
taunted the petitioner for bringing dowry which was not upto their
satisfaction. All of them openly said
that such an ordinary marriage is
solemnized these days by common people
and they never expected that the petitioner
will b ring so less dowry with her.
7. That
thereafter, respondent and his family members used to taunt the petitioner for
bringing less dowry when the petitioner
said to the respondent that such
type of behaviour and taunts are very harassing for the her , the respondent said that the petitioner deserve these taunts as she has not brought
dowry upto their expectations. The
respondent only said that he wanted a Assent Car and not a Santro, which petitioner’s
father given in dowry.
8. That
whenever some one come from petitioner’s parental family to see the petitioner, respondent and his family members used to misbehave with them. Even father-in-law of the
petitioner said to the petitioner that
if her mother came to see her, they will kill the petitioner. The
respondent often used to beat the
petitioner mercilessly. Once
mother-in-law of the petitioner also
beated the petitioner with a frypan and once she pushed the petitioner from the
stairs, the petitioner was and there was
mild bleeding from her head. Inspite of
this, the petitioner did not respect the matter to police or to her parents as
she did not want to spoil her matrimonial life. The petitioner tolerated their
misbehaviour and taunts only to save her matrimonial life.
9. That
on the very next day of marriage, petitioner’s mother-in-law took all the jewellery given by petitioner’s parents to the petitioner and she also took all the jewellery which
was given to petitioner by her in-laws. She said that it is risky to wear jewellery and she will keep the jewellery at a safe place.
10. The
petitioner was not allowed even to watch T.V. whenever she tried so. The T.V. was switched
off by petitioner’s mother-in-law
as saying “BIJLI KA BILL KYA TERA BAAP BHAREGA.” The petitioner’s
sister-in-law is also in hand in gloves
with them and whenever she visited the matrimonial home of the petitioner, a meeting used to take
place and thereafter, the petitioner was
beaten by the respondent. All the provocation was from her Nand Poonam Talwar,
who also used to taunt the petitioner saying “KANGLE GHAR KI LADKI AAEE HAIN”.
The petitioner’s sister-in-law also said that she wanted a heavy golden chain for herself and a heavy golden kada for
her husband. Petitioner’s parents-in-laws said that they will marry their son with someone else and even in
second marriage, their son will get about Rs.15 lacs in dowry. In short, they all want to thrown
the petitioner out of her matrimonial
home.
11. That
the respondent never gave the
petitioner even a single paise for
petitioner patty expenses, which an ordinary women requires for her personal use articles. Whatever the
petitioner ‘s mother give her when she visited at the time of festivals,
petitioner’s mother-in-law snatched all
the money and articles from the petitioner, given to the petitioner by her mother.
12. That
petitioner’s mother-in-law used to taunt
the petitioner by calling her a
characterless lady and she used to take
the petitioner’s name with some persons whom even the petitioner do not know by their names. Their only ultimate aim is to harass and get rid
of the petitioner.
13. That
on 25.11.2004, late in the evening, the
petitioner heard some noises in the house and saw that the respondent and
father-in-law were discussing
something loudly and when they saw the petitioner, they said that they require Rs.2 lacs urgently and asked the petitioner to call her parents and informed them about
the demand of Rs.2 lakh by the abovesaid
persons. The petitioner said that recently her father has solemnized her
marriage and it will be very difficult for him to arrange such a big amount of
Rs.2 lacs. At this both, respondent and
his father got annoyed and said that now
they do not want to keep the petitioner
with them and even said that the
petitioner should leave their home immediately. The petitioner said that
she wants to stay at the matrimonial home. However, the developments were informed to her
parents by the petitioner. On listening all the things, the petitioner’s father got worried. Back
home the petitioner was not allowed to
sleep throughout night and in the morning, the respondent said that the petitioner is going to leave her at her parental
home. seeing no alternative, the
petitioner agreed. While the
petitioner and her husband were coming
out of the society by chance father of the petitioner also arrived and thereafter, all of us came
back for discussion and if was decided
that the petitioner will continue to stay at her matrimonial home. The police was also informed at telephone number 100. However, at that time, the matter was settled as parents-in-law
of the petitioner and respondent said that now they will keep the
petitioner properly and will not tease her or taunt her and will also
not demand dowry/cash from the
petitioner and her parents.
14. That
however, as soon as petitioner’s father
left on 26.11.2004, the respondent and
his family members started taunting and
harassing the petitioner and petitioner was forced to leave her matrimonial home in three plain wearing clothes only. It was change that petitioner’s father was still outside the Appartments. The petitioner informed all the developments to him and as
her life was also in danger at the hands of the respondent and his family members they though it better
to inform the police and the petitioner
reported the matter to incharge Dost Police post, ……………, Delhi.
15. That
since then i.e. DD.MM.YYYY, the petitioner
is living with her parents. The respondent and his family members ruined
her life and they have beaten the petitioner, taunted her for demand of dowry
and have made the life of the petitioner miserable. Now even a single day after
petitioner’s marriage, she was allowed to live peacefully.
16. That
the respondent has neglected and refused to maintain the petitioner and has
deliberately and malafidely never provided any maintenance allowance to her.
Since the time she is living separately the burden of looking after the
petitioner is on her parents and she has borne physical and mental cruelties at
the hands of the respondent and the respondent has been thoroughly insensitive
to the needs of the petitioner. The petitioner is entitled to the same standard
of living as maintained by the respondent. The respondent is legally, socially
and morally bound to maintain the petitioner. The respondent has no other
liability except to maintain the petitioner.
17. That
the break up of the expenses of the petitioner, incurred per month is being
given as under: -
Petitioner Bharti Arora
(a)
Expenses
on food including
Nutrition food-milk butter,
fruits etc. Rs 10, 000/-
(b)
House
maintenance including
Including electricity, water
and
Telephone charges
etc. Rs
10000/-
(c)
Medical expenses
Rs. 5,000/-
(d)
Expenses on clothes Rs.
10,000/-
(e)
Misc,
expenses, entertainment
Amusement
parks, etc.
Rs. 5,000/-
(f)
Transportation
Rs. 8,000/-
(g)
Other expenses Rs.
2,000/-
-------------------------------------------------------------------------
Total Rs. 50,000
---------------------------------------------------------------------------
18.
That the respondent is living in his own house and
enjoying all the luxuries available as he is earning approx. Rs.1,25,000/- p.m.
out of his aforesaid resources. The respondent has neglected the petitioner in
such a manner that he has totally forgotten her as that she has never existed
in his life.
19.
That the petitioner is claiming an amount of Rs.
50,000/- per month from the respondent for her food, clothing, house
maintenance, medical expenses. The amount claimed is quite reasonable. The
respondent who is having monthly income of Rs. 1,25,000/-per month can easily
afford to pay the amount of Rs.50,000/- per month towards the maintenance of
the petitioner and the respondent is legally and morally bound to maintain the
petitioners.
20.
That the cause of action for filing the present
petition arose in the DD.MM.YYYY the day the petitioner got married and again
on DD.MM.YYYY when the respondent turned out the petitioner from the
matrimonial home. It again arose when the respondent failed to provide
maintenance to the petitioner and the cause of action is still continuing as
the respondent has neglected to maintain the petitioner.
21.
That the marriage of the petitioner with the
Respondent was solemnized in
It is, therefore, most
respectfully prayed that this Hon'ble Court may very kindly be pleased to: -
a). direct the respondent
to pay a sum of Rs.25,000/- per month for the maintenance of the petitioner and
a decree to that effect be passed and /or
b). award the Cost of
litigation to the tune of Rs.11,000/-.
c). This
Hon’ble court may pass any other or further order as may be deemed fit and
proper in the facts and circumstances of the cases.
Petitioner
VERIFICATION: -
Verified at
Delhi on this of Jan., 2021 that the
contents of Para 1 to ___ of the petition are true and correct to the best of
knowledge while those of paras __ and __ are true and believed to be correct.
Last para is a payer to this
PETITIONER
IN THE COURT OF A.C.M.M, DISTRICT
ROHINI,
MAINTENANCE
APPLICATION NO. OF 2007
IN THE
MATTER OF :-
…………………… …Petitioner
I,…………………….
W/O SH……………. D/O SH……………….. R/O ……………………………………….., do hereby solemnly affirm and declare as
under:-
1. That
I am the petitioner and am well conversant with the facts and circumstances of
the case and also competent to file the present affidavit.
2. That
the contents of the annexed petition u/s
125 Cr.P.C. has been drafted by my counsel as per my instruction and the
contents of the same have been duly read over and understood by me and after
fully understanding the contents of the same, I hereby state that the facts
stated therein are all true and correct to the best of my knowledge.
The
contents of said application may kindly be read as part and parcel of this
affidavit also as the contents of the same have not been repeated herein for
the sake of brevity.
DEPONENT
VERIFICATION
Verified at Delhi on this __ day of Jan.,
2021, that the contents of my above affidavit are true and correct to
knowledge, no part of it is false and nothing material has been concealed
therefrom.
DEPONENT
IN THE COURT OF A.C.M.M, DISTRICT
ROHINI,
MAINTENANCE
APPLICATION NO. OF 2007
IN THE
MATTER OF :-
……………………..
…Petitioner
Application for the grant of interim maintenance.
Most
respectfully showeth:-
1.
That the petitioner has filed the accompanying
petition for maintenance of Rs. 25,000/- per month from the respondent who is
the husband of petitioner. The petitioner has filed the present petition.
2.
That the respondent is the husband of the petitioner
and has neglected to maintain the petitioner. The petitioner is, thus, claiming
an amount of Rs.25,000/- per month from the respondent who is a man of means
and well to do and earning an handsome amount of Rs. 52,000/- per month. The
amount claimed is more than reasonable and the respondent can easily afford to
pay such a sum towards the maintenance of petitioner.
3.
That the respondent has deliberately and malafidely
never provided any maintenance allowance to the petitioner. All these years,
the burden of looking after her was totally upon her old aged parents, who has
borne physical and mental cruelties at the hands of the respondent and the
respondent has been thoroughly insensitive to the needs of the petitioner. The
petitioner is entitled to the same standard of living as maintained by the
respondent as she is his legally wedded wife.
4.
That the balance of convenience lies in favour of
the petitioner and in case the respondent continues to neglect to provide
maintenance to the petitioner, the petitioner will be deprived of various
opportunities which other women and children of the same status and standard
would be enjoying.
PRAYER:
It is, therefore, most respectfully prayed
that
a.
The respondent be directed to pay a sum of Rs.
25,000/- per month as maintenance to the petitioners by way of interim
maintenance.
b.
This Hon’ble court may pass any other or further
order as may be deemed fit and proper in the facts and circumstances of the
case.
PETITIONER
THROUGH
ENROLMENT
No. AND ADDRESS.
IN THE COURT OF A.C.M.M, TIS HAZARI,
MAINTENANCE APPLICATION NO.
OF 2011
IN THE MATTER OF :-
…………………., …PETITIONER
I, ………………. W/o Sh. ………………….. D/o …………………..
R/o …………………, do hereby solemnly affirm and declare as under:-
1. That I am the petitioner and am well
conversant with the facts and circumstances of the case and also competent to
file the present affidavit.
2. That the
contents of the annexed petition u/s 125 Cr.P.C. has been drafted by my counsel
as per my instruction and the contents of the same have been duly read over and
understood by me and after fully understanding the contents of the same, I
hereby state that the facts stated therein are all true and correct to the best
of my knowledge. The contents of said application may kindly be read as part
and parcel of this affidavit also as the contents of the same have not been
repeated herein for the sake of brevity.
DEPONENT
VERIFICATION
Verified at Delhi on this __ day of ………….,
2023, that the contents of my above affidavit are true and correct to
knowledge, no part of it is false and nothing material has been concealed
therefrom.
DEPONENT
