IN THE COURT OF CHIEF METROPOLITAN

MAGISTRATE, ROHINI COURTS, DELHI

COMPLAINT NO. OF 2024

IN RE: -

DR. ANAMIKA GUPTA …COMPLAINANT

VERSUS

UJJAWAL KUMAR … RESPONDENT

P.S.: _____________

INDEX
S.NO. PARTICULARS PAGE COURT
FEES
------------------------------------------------------------------------
1. Memo of Parties
2. Complaint / application
U/s 12 PWDV Act along
With affidavit
3. Applicantion U/s 23(2)
PWDV ACT along with
Affidavit.
4. List of documents
Alongwith documents
5. Vakalatnama

DELHI COMPLAINANT
DATED:
THROUGH

COUNSEL
 IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE, ROHINI COURTS, DELHI

COMPLAINT NO. OF 2024

IN RE:

Dr. ANAMIKA GUPTA …COMPLAINANT

VERSUS

Sh. UJJAWAL KUMAR …RESPONDENT

MEMO OF PARTIES

Dr. ANAMIKA GUPTA(AGED ABOUT 29 YEARS)

W/O SH.UJJAWAL KUMAR
D/O SH. RAMNATH GUPTA R/O E-1/155, UNITY
APARTMENT,SECTOR-18,
ROHINI,
DELHI-110089 … COMPLAINANT

VERSUS

1. SH. UJJAWAL KUMAR (HUSBAND)

S/O NIRMAL KUMAR PRASAD

2. SH. NIRMAL KUMAR PARSAD (FATHER-IN-LAW)

3. SMT. SARITA PARSAD (MOTHER-IN-LAW)

W/O SH.NIRMAL KUMAR PRASAD

4. SH.PRAGATI KUMAR (BROTHER-IN-LAW)

 S/O SH.NIRMAL KUMAR PRASAD

ALL RESIDENT OF:-

R/O: ROAD NO. 10B, RAJENDRA NAGAR,P.S. KADAMKUAN,
DISTRICT PATNA(BIHAR)
DELHI-110052

… RESPONDENTS

DELHI COMPLAINANT
DATED
THROUGH

SHWETA GOEL & YOGESH

(ADVOCATES)
OFF. C-550, SARASWATI VIHAR,
PITAM PURA, DELHI
9871324432
 IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE, ROHINI COURTS, DELHI

COMPLAINT NO. OF 2024

IN THE MATTER OF: -

DR. ANAMIKA GUPTA … COMPLAINANT

VERSUS
1. SH. UJJAWAL KUMAR (HUSBAND)
S/O NIRMAL KUMAR PRASAD

2. SH. NIRMAL KUMAR PARSAD (FATHER-IN-LAW)

3. SMT. SARITA PARSAD (MOTHER-IN-LAW)

W/O SH.NIRMAL KUMAR PRASAD

4. SH.PRAGATI KUMAR (BROTHER-IN-LAW)

S/O SH.NIRMAL KUMAR PRASAD

APPLICATION / COMPLAINT UNDER SECTION 12 OF

THE PROTECTION OF WOMEN FROM DOMESTIC

VIOLENCE ACT, 2005 SEEKING GRANT OF RELIEF

(S) PROVIDED U/S 18, 19, 20 AND 22 OF THE SAID

ACT.

Most respectfully showeth:-

 That the application under section 12 of the Protection

of Women from the Domestic Violence Act, 2005 is

being filed by the complainant i.e. the aggrieved

person against the respondent no.1 who is the

husband and the respondent no.2 to 4 are in laws of

the complainant. Brief facts are stated hereunder: -

1. That the complainant is the law abiding citizen of the

country who is compelled to approach this Hon’ble

court by way of present complaint seeking reliefs

against the respondents, as she has been mentally,

physically and economically, abused, exploited,

tortured by them.

2. In June 2021, complainant family and above named

Respondents in persons met through matrimonial

platform as complainant family and Respondents

were looking for the marriage of their respective

child.
3. In may 2021, Respondent No. 2 offered a proposal to

complainant father and relatives for the relationship.

In this proposal Respondent No. 2 stated that his son

had completed M.B.B.S. degree in 2019 and

obtained a rank of 18,354 in relevant entrance exam

for admission to MD/MS medical course.

4. In June, 2021 After numerous calls and requests

from Respondents, complainant father agreed to a

meeting. Subsequently, Respondents proposed that

the meeting can take place in Hotel at Patna. They

leave no stone unturned to make sure to show their

lavish lifestyle. During the meeting Respondents

assured that they were open to settle their son,

alleged Dr. Ujjawal Kumar, either at Delhi or

Lucknow.

5. On July, 2021 Respondents visited complainant

residence Delhi to meet her family. After meeting

both families agreed to marriage. On 20 Aug, 2021

 Respondents once again visited complainant

residence and exchanged clothes and gifts.

6. That marriage was initially scheduled for 28, Apr.

2022 to accommodate the preferences of

Respondents. However, In January 2022 Respondent

no. 4 visited the complainant residence requested

for postpone the marriage due to NEET PG exam of

Respondent No. 1. Despite all the wedding

arrangement and booking having been finalized, we

agreed to postpone the marriage date at the request

of Respondents.

7. In October, 2022, Marriage was rescheduled for 20

Jan, 2023. In the first week of November 2022,

Respondents demanded a sum of Rs. 11,00,000/-

(Eleven Lakhs Only) in Cash alongwith high-quality

utensil sets, silver items, branded clothing, an I-

Phone 13 Pro and well designed gold. However my

 father could provide only Rs. 5,00,000/- to the

Respondents.

8. In 20 Jan, 2023 complainant was married to

respondent no. 1 according to Hindu Rites and

Ceremonies on 20.01.2023 at Royal Pepper

Banquet Hall, Rohini, Delhi. And reception on

22.01.2023 at Popular Residency, Rajendra

Nagar, Patna, Bihar.

9. On 22.01.2023 (Marriage Reception) complainant

received gifts and jewelry worth approximately Rs.

10,00,000/- ( Rupees Ten lakhs Only) from

complainant’s parents and relatives which was

forcefully seized by Respondent No. 3.

10. That after the marriage the complainant and the

respondent no.1 lived together as husband and wife

at their matrimonial home.

11. That from 21.01.2023 to 05.03.2023 complainant

stayed for approximately 44 days at her matrimonial

house and have a hell of time during those days

neither she was provided with sufficient food to

satisfy her hunger nor she was allowed to enter the

kitchen to prepare food and also she was forbid to

touch things from refrigerator and also not allowed

to socialize with other people.

12. On 23 Jan 2023, Respondents demanded Rs.

25,00,000/- (Rupees Twenty Five Lakhs Only) and a

Scorpio Car from complainant father. However the

demand was not fulfilled they resorted to abusive

language and subjected complainant to constant

torture.

13. That complainant was also not allowed to talk to any

of the relatives and also was not allowed to stand in

balcony or go outside.
14. On 25 Jan 2023 Respondent No. 1 went to Nepal

without informing her about the trip for 4-5 days

leaving complainant behind along with other

Respondents and respondent no.3 does not provide

adequate food to her making her life miserable with

her taunts as well as by not providing enough food

to satiate her hunger and also by repeatedly

taunting about not giving enough dowry by

complainant’s father.

15. On 18 Feb 2023 Respondent No. 1 came to Noida,

U.P. to his grandmother at his maternal uncle’s

residence and during this time complainant asked

her father to provide food for herself at the Railway

station on 18 Feb 2023 through Respondent No. 1.

16. On 23 Feb 2023 Respondents asked complainant to

give details regarding her bank balance, accounts,

Adhaar Card, and Pan Card Which complainant

refused to give as she can make out their mala-fide

 intention and sense something wrong as

Respondents kept on asking money from herself as

well as her family.

17. Respondents constantly asked her to practice in

Patna and subsequently transfer her salary to

Respondent No. 2 account which is refused by

complainant as she is new to the town and having

difficulty in understanding the dialect of Bihar so she

wants to seek some time for the same which

infuriates them and this makes respondent no1 and4

to brandish a gun and fire in the air instilling fear in

her to even raise her voice.

18. On 27 Feb 2023, Respondent No. 1 informed

complainant that he intended to pursue a medical

diploma course in Nepal. This revelation shocked

complainant that Respondent No. 1 did not possess

M.B.B.S certificate issued by relevant authorities

within India. Despite assurances from Respondents

 that he had completed his M.B.B.S. degree in 2019

and scored a rank 18354 in the entrance exam for

MD/MS medical courses. Complainant confronted

Respondent No. 1 for the first time about the

authenticity of his medical degree in response of

which Respondents scolded and warned her not to

disclose these facts to anyone including authorities

or courts. Respondents instill fear in her by

brandishing a gun and fired it into the air.

19. Meanwhile Respondent No. 1 continued to practicing

medicine in various hospital across Patna and other

district of Bihar with the assistance of Respondent

No. 2 , friends and associate ( Dr. Sheshank

Shubham and Md. Naseem Ansari). Respondent No.

1 provides medical services at trust called Jeewan

Sparsh and also at Nirog hospital with the help of

Respondent No. 2 and friends and associate.

20. On 28 Feb 2023, Respondent to make up with

petitioner planned a trip to Chennai (Tirupati) and

Pondichery and thereafter Respondent came along

with petitioner to petitioner’s parental house on

06.03.2023.

21. On 06 March 2023, complainant alongwith

Respondent No. 1 returned to her parental house.

There Respondent No. 1 again raised a demand of

Rs. 20,00,000 /- (Rupees Twenty Lakhs Only) cash

and a New Safari Car as instructed by Respondents

which is not fulfilled by complainant father

consequently Respondent No. 1 returned to Patna

without taking complainant along with him in order

to pressure to her family for meeting their demands.

22. On 28 April 2023, Respondent no.2 along with

Respondent no. 4 came to complainant house for

lunch and having conversation with complainant

father regarding her younger sister marriage with

 Respondent no.4 but by that time complainant and

her family knows their greediness and their

misbehavior towards complainant therefore they

refused.

23. On 04 Aug 2023, Respondents again demanded Rs.

25,00,000 /- (Rupees Twenty Lakhs Only) cash and a

New Safari Car over the Phone which is not fulfilled

by Complainant father knowing their mala-fide

intention and greedy nature.

24. Being a women who maintain the dignity and society

and understanding the circumstances, particularly

considering the substantial expenses my parents

incurred, approximately Rs. 35,00,000/- (Rupees

Thirty Five Lakhs Only) during marriage. Initially

chose to overlook the various problems and issues

caused by my husband’s family, qualifications and

Respondent No. 1 medical and health issues

pertaining to sexual dysfunctionality. However,

 complainant father could not meet their earlier

demands. Consequently, On 08, Aug 2023

Respondents berated me over the phone. On that

day complainant demanded to see Respondent No. 1

valid M.B.B.S degree. Subsequently, Respondents

continuously threatened complainant family and

complainant warned to not reveal the truth to

anyone including authorities and courts under the

threat of severe consequences. Due to constant

threats and fear for complainant and her family,

complainant refrained from filing any complaints

until Feburary 2024.

25. That during this period complainant also comes to

know that her husband has medical and health

issues pertaining to sexual dysfunctionality.

26. That complainant has lived in constant fear and

threat right after marriage which is a mental cruelty

leading to constant demands from grooms family,

 shocking revelations of Respondent No.1 that make

her cry all day having a mental trauma of this

marriage.

27. That during the time complainant spent in her

matrimonial home the kind of trauma she

experienced there she has changed from being

lively and cheerful person to a quiet person.

28. That Respondents used cruelty in various manners

to the complainant as the respondents were not

happy with dowry brought by the complainant in

her marriage with the respondent no. 1 and she was

always subjected to unbearable, immense and in

tolerable cruelty, , harassments, humiliations,

mental shock and agonies and suffering by the

respondents on account of bringing less dowry and

for bringing more and more dowry, though sufficient

dowry even beyond capability resources of family of

the complainant were given in the marriage.

29. That the complainant is suffering with depression

and mental shock because of the cruelty caused by

the respondent no.1 and his family members.

30. That the complainant to save her married life quietly

faced all the cruelties of the respondents inflicted

upon her.

31. That on 06.03.2023, the respondent no. 1 with the

complainant made a visit to complainant parents

house and demanded Rs. 20,00,000 /- (Rupees

Twenty Lakhs Only) cash and a New Safari Car as

instructed by Respondents which is not fulfilled by

complainant father consequently Respondent No. 1

returned to Patna without taking complainant along

with him and all the jewellery articles are lying in the

custody of the respondent no. 3 and since, then she

is residing at her parental house and is dependent

upon her old parents for her survival.

32. That the complainant has been living in her parental

house since 06 Mar 2023 and during this period

neither respondent no.1 nor any of his family

member ever provided maintenance and never tried

to know the well-being of the Complainant.

33. That the complainant has already lodged the

complaint before the SHO, CAW Cell etc. on dated

10 Apr. 2024, but no action has been taken against

them till date.

34. That the Respondent no.1 has liability to maintain

the complainant. That the Respondent no. 1 is

enjoying all comforts of life with liberty and privilege

of life. The complainant being legally wedded wife of

the Respondent no. 1 has right to enjoy similar

status, enjoyment of life but she is living miserably

and is living a tough and hard life. And his family

members are the persons of means and the

Respondent no. 2 is having his own income,

 movable and immovable properties and other assets

and bank balance in his name in which the

complainant is also having equal share and right as

the legally wedded wife of the Respondent no. 1.

35. That the Respondent no. 1 is capable and competent

and is having resources to maintain and support the

complainant and are legally, socially morally liable

to maintain and support the complainant but he has

intentionally and deliberately made no provisions or

arrangements for maintenance and support,

accommodation to live for the complainant.

36. That respondents have committed an offence of

domestic violence by fraudulently leaving the

complainant to leave the matrimonial house and not

making any provisions of maintenance of the

complainant and by harassing mentally & physically

torturing and filthy and abusive language, hence the

complainant filed present application before Hon’ble

 court for protection her rights and life. It is prayed

that the Hon’ble court may take cognizance of the

complainant / Domestic Incident Report and pass

all / any of the orders as deemed necessary in the

circumstances of the case.

ORDERS / RELIEF REQUIRED

 Pass Protection Order U/s 18 of the Protection of

Women from Domestic Violence Act, prohibiting

acts of domestic violence by granting injunction

against the Respondent no.1 from repeating any

of the acts of violence mentioned in the

complaint of the complaint and prohibiting any

form of the communication by the respondents

and other relatives, friends and associates with

the complainant / complainant family and pass

necessary directions to the concerned S.H.O. for

the protection of the complainant.

 Pass residence order under section 19 and An

order directing Respondent no.1 (s) to secure it

level of accommodation directing the Respondent

no.1 to pay a sum of Rs. 20,000/- for rented

accommodation and further be pleased for Re-

announcing her rights in the shared house.

 Direct the Respondent no.1 to pay monetary

relief under section 20 for Monthly expenses for

food, clothes, medication and other basic

amenities Rs.20,000/- per month for the

complainant.

 Direct the Respondent no.1 to grant

compensation or damages under section 22 for
ruining the life of the complainant, damage for
mental injuries, emotional distress, caused by the
acts of the respondents under the Domestic
Violence committed by the respondent no.1 for
Rs.1,00,00,000/-.
 Pass such interim orders as the court deem just
and proper.
 PRAYER

It is therefore, respectfully prayed that this

Hon'ble Court be pleased to grant the relief(s)
claimed hereinabove and pass such other or further
orders as this Hon'ble Court may deem fit and
proper under the given facts and circumstances of
the case for protecting the complainant from
domestic violence, in the interest of justice.

COMPLAINANT
DATED
DELHI
THROUGH

SHWETA GOEL & YOGESH

(ADVOCATES)
LEGIT LAW ASSOCIATES
OFF. C-550, SARASWATI VIHAR,
PITAM PURA, DELHI
9871324432
Verification:
Verified at Delhi on this day of 2024, that the
contents of the above complaint from para no. 1 to ___
and para no.___ to ___ are true and correct to the best of
my knowledge and nothing material has been concealed
therefrom.
Last Para is the prayer to this Hon’ble Court.

COMPLAINANT
 IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE, ROHINI COURTS, DELHI

COMPLAINT NO. OF 2024

IN RE: -

DR. ANAMIKA GUPTA …COMPLAINANT

VERSUS

DR. UJJAWAL KUMAR … RESPONDENTS

AFFIDAVIT

I, Dr. Anamika Gupta W/O Sh. Ujjawal Kumar D/O Sh.

Ram Nath Gupta R/o- E-155, Unity Apartment, Sector-18,

Rohini, Delhi-110089, do hereby solemnly affirm and

declare as under:

1. That the deponent is the complainant in the above

noted matter and I am fully conversant with the

facts of the case and as such competent to swear

this affidavit.

2. That the accompanying application U/s 12 of DV Act

has been drafted by my counsel on my direction

and as per my instructions and read over the

 content of complaint before me in vernacular

language and I understood the same and which is

correct as per my knowledge and the same may be

read as part and parcel of this affidavit and the

same are not repeated here for the sake of brevity.

DEPONENT

VERIFICATION: -

Verified at Delhi on this day of 2024, that

the contents of this affidavit are true and correct to the

best of my knowledge and belief and nothing has been

concealed therefrom.

DEPONENT
 IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE, ROHINI COURTS, DELHI

COMPLAINT NO. OF 2024

IN RE:-

DR. ANAMIKA GUPTA …COMPLAINANT

VERSUS

DR. UJJAWAL KUMAR … RESPONDENTS

APPLICATION UNDER SECTION 23 (2) OF THE

PROTECTION OF WOMEN FROM DOMESTIC
VIOLENCE ACT, 2005 (43 OF 2005) FOR GRANT OF
INTERIM AND EX-PARTE ORDERS:

Most respectfully showeth:

1. That the applicant has filed the accompanying

complaint under Section 12 of the Protection of

Women from Domestic Violence Act, 2005 facts

leading to filing of the said complaint have been

mentioned in detail in the accompanying

complaint. The complainant craves leave of this

Hon'ble Court to refer and rely upon the same as

 forming part and parcel of this paragraph, same

are not repeated herein for the sake of brevity

and to avoid repetition.

2. That the complainant is having strong prima facie

case in her favour, balance of the convenience is

entitle in favour of the complainant and the

complainant is likely to succeed in her complaint.

The complainant is filing affidavit in the

prescribed form along with this applicant.

3. In the facts and circumstances of the case, it is

necessary that an Ex-Parte order as prayed for be

passed for in favour of the complainant and

against the Respondent no.1. The complainant

would suffer irreparable loss and legal injury

incase ex-parte order are not passed forthwith.

Complaint is totally depend for good and shelter

on her parents.
 It is, therefore, most respectfully prayed that

ex-parte order in terms of relief sought the

complaint may kindly be passed in the interest of

justice.

Any other order (s) which this Hon’ble Court

may deem fit and proper may be passed in favour

of the complainant and against the respondent

no.1.

DELHI COMPLAINANT
DATED
THROUGH

SHWETA GOEL & YOGESH

(ADVOCATES)
LEGIT LAW ASSOCIATES
OFF. C-550, SARASWATI VIHAR,
PITAM PURA, DELHI
9871324432
 IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE,
ROHINI COURTS, DELHI
COMPLAINT NO. OF 2024
IN RE: -

DR. ANAMIKA GUPTA …COMPLAINANT

VERSUS

DR. UJJAWAL KUMAR … RESPONDENTS

AFFIDAVIT UNDER SECTION 23 (2) OF THE PROTECTION

OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005 (43
OF 2005) FOR GRANT OF INTERIM AND EX-PARTE
ORDERS:

I , Dr. Anamika Gupta W/O Sh. Ujjawal Kumar D/O Sh.

Ram Nath Gupta R/o- E-155, Unity Apartment, Sector-18,

Rohini, Delhi-110089, do hereby solemnly affirm and

declare as under:

1. That being conversant with facts and

circumstances of the case I am competent to

swear this affidavit.

2. That the details provided in the accompanying

petition for grant of relief(s) U/s 18, 19, 20 and 22

 of the said act have been set out at my

instructions.

3. That the contents of the said petition have been

read over explained to and understood by me in

my vernacular language in Hindi.

4. That the contents of the said petition may be

read as part and parcel of this affidavit and same

are not being repeated herein for the sake of

brevity.

5. That the complaint apprehends repetition of the

acts of domestic violence by the accused persons

against which relief is sought in the

accompanying petition.

6. That the respondents have threatened the

complainant with forcible dispossession from the

entire property and such malafide objective he

 has been resorting to unprovoked violence

against the complainant.

7. That the relief(s) claimed in the accompanying

application are urgent in as much as the
complainant would face grave financial hardship
and forced to live under threat of repetition
/escalation of acts of domestic Violence
complained of in the accompanying petition by
the respondents if the said relief(s) are not
granted on ex-parte and interim basis.

8. That the facts mentioned herein are true and the

best of my knowledge and nothing material has
been concealed therefrom.

Deponent
Verification: -
Verified at Delhi on this day of 2024, that the
contents of above affidavit are true and correct to my
best of knowledge and nothing material has been
concealed therefrom.

Deponent