IN THE COURT OF PRINCIPAL JUDGE FAMILY COURTS, SOUTH
DISTRICT, SAKET COURTS, DELHI
MAINTENANCE CASE NO ………. /2017
IN THE MATTER OF:
Mrs. PARUL BHARDWAJ … PETITIONER
VERSUS
Mr. ASHISH GUPTA … RESPONDENT
MEMO OF PARTIES
Mrs. PARUL BHARDWAJ,
W/o. Mr. ASHISH GUPTA,
D/o. Mr. NARESH CHANDRA BHARDWAJ,
R/o ……………………,
NEW DELHI …PETITIONER
VERSUS
Mr. ASHISH GUPTA (HUSBAND)
S/o. Mr.
R/o. 4196-17/20, BHAGWATI BHAWAN,
NEAR NEW DELHI RAILWAY STATION,
PAHARGANJ, NEW DELHI
ALSO AT:-
FLAT NUMBER G-2, GROUND FLOOR,
PLOT NUMBER- 3A/290,
VAISHALI, GHAZIABAD
DELHI …RESPONDENT
P.S.
DISTRICT:-SOUTH
PETITIONER
THROUGH
(RADHEY SHYAM)
ADVOCATE
DELHI CHAMBER NO: X-25, CIVIL WING
DATED: TIS HAZARI COURTS, DELHI
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURTS, SOUTH
DISTRICT, SAKET COURTS, DELHI
MAINTENANCE CASE NO ………. /2017
IN THE MATTER OF:
Mrs. PARUL BHARDWAJ,
W/o. Mr. ASHISH GUPTA,
D/o. Mr. NARESH CHANDRA BHARDWAJ,
R/o ……………………,
NEW DELHI …PETITIONER
VERSUS
Mr. ASHISH GUPTA (HUSBAND)
S/o. Mr.
R/o. 4196-17/20, BHAGWATI BHAWAN,
NEAR NEW DELHI RAILWAY STATION,
PAHARGANJ, NEW DELHI
ALSO AT:-
FLAT NUMBER G-2, GROUND FLOOR,
PLOT NUMBER- 3A/290,
VAISHALI, GHAZIABAD
DELHI …RESPONDENT
P.S.
DISTRICT:-SOUTH
APPLICATION UNDER SECTION 125 Cr.P.C. FOR GRANT OF
MAINTENANCE TO THE APPLICANT
MOST RESPECTFULLY SHOWETH:
1. That the petitioner is residing at the above mentioned address. Petitioner got
married to the respondent in Delhi on 6th May, 20141, as per Hindu rites, custom
and ceremonies.
2. That the petitioner is a helpless innocent lady and unless maintenance is
allowed she will be forced to destitution and vagrancy.
3. That after solemnization of their marriage, the petitioner was brought to her
matrimonial home by the respondent, where they resided and cohabited together as
husband and wife. That marriage was duly consummated and no child was born
out of the said wedlock.
4. That ever since the petitioner resides with the respondent, the conduct and
behavior of the respondent and her family members was never appropriate and
they always treat her with utmost, immense, intolerable, and unbearable cruelty,
harassment, hardships, humiliations, used to cause mental shock, agonies, pains
and sufferings without any cause or reason his part.
5. During her stay with respondent in her matrimonial home, he used to insult,
misbehave, pick up quarrel, use foul and filthy language and abuses to the
petitioner and his family members without any cause or reason on her part.
6. The petitioner is victim of circumstances. She never gave any chance of
complaint to the respondent and his parents, parental relations, about her conduct,
behavior, dealings, antecedents and way of living. She always provide him due
love and affection and always persuade him to lead a happy married life with the
petitioner, but all her sincere and consistent efforts to lead a happy and peaceful
life with the petitioner yielded no fruitful result.
7. That after filing the complaint in CAW Cell, when the petitioner was residing
with her sister, the respondent and his family members used to torture the
petitioner on phone by saying that they would defame & divorce the petitioner.
8. That family of the respondent has supported the respondent for paining,
torturing and insulting the petitioner. All member of the family of the respondent
are guilty for committing the crimes mentioned above.
9. Respondent is working as Manager- Business Development in a German
Logistic Multinational Named Deugro Projects India Pvt. Ltd. He is earning more
than Rs. 12 lakhs per month.
10. That the petitioner has apprehension from the respondent and his family
members that they may kill her and her family members. All the Istridhan of the
petitioner including her gold jewellery, clothes and other costly items are in
possession of the respondent and his family members and even after repeated
demands , they refused to return the same to the petitioner.
11. That after being fed up with day to day cruelties meted out to her by the
respondent and his family members, the petitioner filed a complaint at CAW Cell,
----------------------, Delhi in the month of August, 2017.
12. That even now the respondent and his family members are threatening the
petitioner and her family members that they can do anything they want and nobody
can touch the respondent and his family members as they are having good contacts
in higher authorities.
13. That the respondent, being the husband of the petitioner, is under legal and
social obligations to maintain the Petitioner. The respondent has no other liability
except to maintain the petitioner.
14. That the petitioner is totally helpless and has no source of income.
15. That the petitioner lodged complaint in CAW cell, -----------------, Delhi,
against the respondent and his family members but no strict action is taken against
them till date .
16. That, in fact respondent never respected the petitioner, his parents, relations,
respectable and elders and always dominated the entire family of petitioner and
tried to dance them on his tune.
17. The conduct, behavior, attitude and dealings of respondent was harsh, non-
cooperatives indifferent, short tempered, aggressive and violent.
18. That the petitioner is totally helpless and having no source of income. The
respondent has been neglecting her since ________________. So finding no way,
the petitioner has filed this complaint to get maintenance from her husband
through this Hon`ble Court.
19. That the petitioner needs immediate maintenance for her survival and to end
vagrancy and destitution.
20. That the cause of action for this complaint arose on various dates on which the
respondent beaten, threatened and taunting the petitioner. It further arose when the
petitioner was left at her parental home by the respondent ________________. The
cause action is still exist as no provision of maintenance is made by the respondent
for petitioner.
PRAYER
The petitioner, therefore, prays that –
(a) This application may please be kindly allowed, and the respondent/opponent
be ordered to pay to the petitioner maintenance allowance of Rs.35,000/-(thirty
five thousand) per month from the date of this application;
(b) cost of litigation of Rs. 25,000/-(twenty five thousand)
(c) Any other orders in the interest of justice be kindly passed.
Delhi/Dated Petitioner
Through
Counsel
Verification
Verified on this day of August, 2017 at Delhi that the contents of this petition are
true and correct to the best of my knowledge and belief and nothing material has been
concealed there-from.
Petitioner
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURTS, SOUTH
DISTRICT,SAKET COURTS, DELHI
MAINTENANCE CASE NO ………. /2017
IN THE MATTER OF:
Mrs. PARUL BHARDWAJ … PETITIONER
VERSUS
Mr. ASHISH GUPTA … RESPONDENT
AFFIDAVIT
I, PARUL BHARDWAJ, W/o. SH. ASHISH GUPTA, D/o. SH. NARESH
CHANDRA BHARDWAJ, R/O--------------------, NEW DELHI, DO HEREBY
SOLEMNLY AFFIRM AND DECLARE AS UNDER:-
1. That I am the petitioner in the above noted case and I am well conversant to the
facts and circumstances of the case, and as such am fully competent to swear the
present affidavit.
2. That the contents of the present petition under section 125 Cr.P.C. has been drafted
by the counsel as per my instructions and the contents of the same have been
duly read and understood by me and after fully understanding the contents of
the same I hereby state that the facts stated therein are true and correct to my
knowledge and the same may kindly be read as part and parcel of this affidavit and
the same has not been repeated here for the sake of brevity.
DEPONENT
VERIFICATION:-
I, the above named deponent do hereby state on solemn affirmation that the contents of the
above affidavit are true and correct to the best of my knowledge. Nothing material has been
concealed therefrom.
Verified at Delhi on this day of August, 2017.
DEPONENT
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURTS, SOUTH WEST
DISTRICT, DWARKA COURTS, DELHI
MAINTENANCE CASE NO ………. /2017
IN THE MATTER OF:
Mrs. PARUL BHARDWAJ … PETITIONER
VERSUS
Mr. ASHISH GUPTA … RESPONDENT
APPLICATION ON BEHALF OF PETITIONERS FOR GRANT OF INTERIM
MAINTENANCE
MOST RESPECTFULLY SHOWETH:
1. That the contents of the main application under section 125 Cr.P.C. are made
part of this interim application and the same are not repeated herein for the sake
of brevity.
2. That the petitioner is helpless and innocent person and unless interim
maintenance is allowed she will be forced to destitution and vagrancy.
3. That the respondent is not at all looking after the petitioner.
4. That the respondent is a man of means and working in
________________________ _______
5. That the petitioner is totally helpless and she has no source of any income. The
respondent has been neglecting her since _____________. So finding no way
out the petitioner has filed this complaint to get maintenance from her husband
through Court.
6. That the petitioner, therefore, prays that –
(a) This application may please be kindly allowed, and the opponent be
ordered to pay to this petitioner maintenance allowance @ Rs.25,000/- per
month from the date of this application till disposal of this case;
(b) cost of litigation of Rs. 25,000/-;
(c) Any other orders in the interest of justice be kindly passed.
Delhi
Dated Petitioner
Through
Counsel
Verification
Verified on this day of August, 2017 at Delhi that the contents of this petition are
true and correct to the best of my knowledge and belief and nothing material has been
concealed there-from.
Petitioner
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURTS, SOUTH WEST
DISTRICT, DWARKA COURTS, DELHI
MAINTENANCE CASE NO ………. /2017
IN THE MATTER OF:
Mrs. PARUL BHARDWAJ … PETITIONER
VERSUS
Mr. ASHISH GUPTA … RESPONDENT
AFFIDAVIT
I, PARUL BHARDWAJ, W/o. SH. ASHISH GUPTA, D/o. SH. NARESH
CHANDRA BHARDWAJ, R/O-_____________, NEW DELHI, DO HEREBY
SOLEMNLY AFFIRM AND DECLARE AS UNDER:-
1. That I am the petitioner in the above noted case and I am well conversant to the
facts and circumstances of the case, and as such am fully competent to swear the
present affidavit.
2. That the contents of the present application for grant of interim maintenance has
been drafted by the counsel as per my instructions and the contents of the same
have been duly read and understood by me and after fully understanding the
contents of the same I hereby state that the facts stated therein are true and
correct to my knowledge and the same may kindly be read as part and parcel of
this affidavit and the same has not been repeated here for the sake of brevity.
DEPONENT
VERIFICATION:-
I, the above named deponent do hereby state on solemn affirmation that the contents of the
above affidavit are true and correct to the best of my knowledge. Nothing material has been
concealed there-from.
Verified at Delhi on this day of August, 2017.
DEPONENT
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURTS, SOUTH
DISTRICT, SAKET COURTS, DELHI
MAINTENANCE CASE NO ………. /2017
IN THE MATTER OF:
Mrs. PARUL BHARDWAJ … PETITIONER
VERSUS
Mr. ASHISH GUPTA … RESPONDENT
INDEX
Sl.No. Particulars Court fees Page No.
1 Memo of Parties
2 Complaint U/s 125 CrPC
with affidavit
3 Interim Application with
Affidavit
4 Detailed income affidavit of
petitioner
5 List of documents with
documents
6 Vakalatnama
Delhi
Date: Petitioner
Through
Counsel
