IN THE COURT OF PRINCIPAL FAMILY JUDGE,
ALIGARH
Case No. ……. /2023
Fasha Imran V/s. Mohammad Salman Faiz
U/s.125 Cr.P.C.
PS Civil Lines, Aligarh
Interim Maintenance Application on behalf of the Complainant
wife Fasha Imran W/o Shri Mohammad Salman Faiz U/s.125 Cr PC
for maintenance:
Sir,
Applicant wife most respectfully submits as follows:
1. That the Complainant is aging around 26 years and is law abiding
citizen of India living on mercy of her old age parents.
2. That Marriage of the complainant was solemnized with OP husband
on dated 23/03/2021 at lavish wedding ceremony at Shubham
Samagam Lodge, Aligarh according to Muslim rites and ceremonies,
and father of the complainant incurred more than Fifteen lakh rupees
3. That at the time of marriage father of the complainant has also given a
car S Presso Maruti car which was rejected by the OP husband and
other in laws by saying they want bigger car and same should have
been given to them.
4. That sometime after the marriage the Opposite Party Husband, and his
family members shown unhappiness with respect to the articles and
gift(s) given by the father of the complainant in marriage and started to
demand “Two lakh Rupees and big car ”. That for the demand of the
dowry Father in law and mother in law family members of the
Opposite Party Husband used to constantly taunt and insult
complainant and her parents and for generating pressure for
fulfillment of such demand the complaint was mentally and physically
harassed by including but not limited to abuse, beating by OP husband
on inducement other in laws, keeping hungry, keeping in closed room,
by not talking to her etc.
5. That on unfortunate night on dated 03/12/2022 at mid night when the
complainant categorically refused to fulfill OP husband demand the
OP husband beaten the complainant badly by foot and fist taken knife
by saying to kill on immediately as you are not obeying me and
attempted to kill the applicant wife but applicant saved her life by
locking herself in room. That the OP husband has abused badly to
father and uncle of the complainant and also threaten to kill them.
6. That as complainant father received information about the such
unfortunate incident then he reached at Knapur on very day i.e.
04/12/2022 and tried to reconcile with the OP husband and his family
members but they were not agree to reconcile without satisfaction of
their dowry demand including two lakh rupees and big car and
forcefully evicted the complainant in night then complainant father
took shelter in one relatives home on 04/12/2022 in night and came
back at Aligarh in single pair clothes as worn by the complainant and
since then complainant is living at maternal home at the mercy of the
old age parents.
7. That the Complainant husband is having sufficient means to maintain
his applicant wife as the Complainant husband is working as
Assistant Accountant/Assistant Auditor in office of Additional
director, Treasury & pension, Kanpur Region, Kanpur earning around
more than Rs. 80000/- per month and father of the OP husband is
retired from the post of Senior Executive officer from Electricity
Department, brother working on private job and earning handsomely
earning around Rs. 100000/- thereby and not burdened from any
responsibility of the family but in spite of having sufficient income the
unscrupulous husband of the applicant wife manifestly
neglected/ignored to maintain his applicant wife .
8. That in view of the aforesaid facts and circumstances it is apparent that
applicant wife does not have sufficient source of income to maintain
herself. That thereby the applicant wife is unable to meet out the
expenses for fulfilling the basic requirement (food, clothing, daily life
expenses , medical expenses etc. ) and, further the Complainant
husband not only have sufficient means to maintain her but also not
burdened with any responsibility to maintain his family members .
Thus it is most expedient in the best interest of the justice that the
Complainant husband to be directed for the payment Rs. 50000/- per
month as interim maintenance of the complainant.
Prayer:
It is hereby most respectfully prayed that Hon’ble Court may
pleased to issue an order directing the husband of the Applicant Wife for
payment of the Rs. 50000/- per month for Interim maintenance to the
complainant in the best interest of justice.
Dated: …./…../2023 Applicant/Respondent
Place: Aligarh
Through Counsel
Deepak Chaudhary
Rawat Advocates & Legal Consultants
