In the Hon’ble court of Smt. Priyanka Sharma, JMIC Amritsar.

Harkrishman Kaur age 22 years W/o Jaspreet Singh Sodhi R/O Bebe Nnanki

Hostel, Khalsa College, Amritsar.(Addar Number:

.. ..Applicant/Complainant

Versus

1. Jaspreet Singh S/o Jaswinder Singh (Husband)

2. ????? D/o Singh (Sister in law) all R/O ..

..Respondents/Accused.

Application/Complaint under section 12 read with section 17, 18, 19, 20 & 22

of the Protection of Woman from Domestic Violence Act, 2005.

P.S. – City Tarn Taran

Sir,

Most respectfully showeth:

The applicant/complainant submits as under:-

19, 20 & 22 of the Protection of Woman from Domestic Violence Act, 2005 is

being filed by the applicant/complainant i.e. wife of respondent/accused No.1, who

is aggrieved person.

2. That it is prayed that this Hon’ble court kindly take cognizance of the present

complaint and may pass following necessary orders :-

A] Pass protection order as provided under section 18 of this Act.

B] Court may also pass an order directing the officer incharge of the nearest

police station to give protection to the aggrieved person under section 19(5)

C] Direct the respondents/accused to pay monetary relief as provided under

section 20[1](d).

D] Direct the respondents/accused to grant compensation or damages as

provided under section 22 of this Act.

E] Pass such interim order as this Hon’ble court may deem fit and proper. A

separate application to claim interim relief's is also filed herewith.

3. That the applicant/complainant is married with the respondent/accused No.1 on 13-

12-2020, according to the Sikh religious, rites and ceremonies i.e. by way of

Anand Karaj in the presence of relatives and friends of both the parties at Sheesh

Mahal, Siswan, with great pump and show in which the parents of the complainant

spent a huge amount on the welcome of Barat brought by the accused persons.
 Respondent No.2 is sister in law of complainant. All of them committed domestic

violence towards the applicant/ complainant.

4. That Harkrishman kaur aged 22 got marriage with the Jaspreet Singh Sodhi, aged

42, who is so-called BABA on 13/12/2020 as case of arranged marriage. She was

brought up in Italy with her guardian parents (Mamma-Mammi). Harpreet Singh

Sodhi usually visited outside countries of his Katha Kirtan and there her guardian

parents under his influence engagement was done with him when she was minor,

when she crossed 18, within week her guardian parents done her marriage with

respondent.

5. That soon after marriage she was used to be tortured by mentally, physically and

emotionally by respondent with bruises on her body and usually she was beaten

brutally black and blue for nothing by him.

6. That she was not allowed to talk with her parents or anybody else as her mobile

phone ever remained under her husband control which her mobile smashed and

broken by him.

7. That her husband often claimed to be bloodline of Sikh Gurus thus ever wanted to

remain bowed in front of him even when he tortures her.

8. That such atrocities and cruelty and his inhuman behavior faced by her almost two

years since marriage, causing severe injuries such as cutting of major vines of right
 hand, sprinting several muscles of body many times, injuries on head, punching

and kicking in belly even while was pregnant resulting in miscarriage.

9. That she had to face such cruelty not within the walls of house but several times

she was beaten at entry gate of colony and on road also.

10. That was the height of cruelty when she was sexually harassed to such a level that

she was left without the clothes on the top floor.

11. That various times she was got kicked out of the house even at night and allowed

to enter back only when she used to fell on his feet.

12. That after their marriage, the complainant/applicant cohabited with her husband

Jaspreet Singh Sodhi as his legal wedded wife and after wedlock she was pregnant

and she faced miscarriage due to beaten by her husband. Reports and medical also

attach with this complaint.

13. That she had to face such cruelty not within the walls of the house even several

times she was beaten on roads of the colony. The height of cruelty was increased

and she was sexually harassed such level that she was left without cloths on the top

floor of the house. Various times she was got kicked out of the house even at night

and allowed to enter back only when she used to fell on his feet. Complainant also

have videos where he beaten her and saying that he will do same act.

14. That usually Respondent threat her to with death showing with his revolver and ask

her not to disclose anything to anybody.

female friend who meet with her at Golden Temple sewa times. She started to

living with her friend who supported emotionally and financially. She also take her

admission in Khalsa College in Psychology Department, her admission fees and

other expenses also faced by her friend.

16. That respondent did not disclose that he was also divorced earlier he became veil

before marriage, and still he have extra matrimonial affair.

17. That it is further submitted here that from the very inception of the marriage, the

present respondents/accused started misbehaving with the applicant/complainant

on very petty matters. Her husband barred her from doing path from Gutka Sahib.

Respondents/accused are persons of cruel in nature and have no any emotions. The

accused no. 1 maltreating, harassing, beating and mentally torturing the

applicant/complainant in a cruel manner. Accused started taunting the

applicant/complainant that she have no status due to which their reputation has

been lowered in the society.

18. That besides this all the respondents/accused often gave severe beating to the

applicant/complainant thereby created a hell for her in the house. On her big day

when she was achieved citizenship certificate in Italy but he did not allow her to go

for that ceremony. She missed her citizen certificate of Italy only for his

disallowed.
19. Complainant also wrote the complaint to the Chief Secretary Punjab and DGP on

09/5/2023 and complaint NO. 1353/GC-6/DGP/23 issued on 18/05/2023 when

complaint marked to women cell the matter was compromised and respondent

said this will be never happened. But again after some weeks he repeats same act

and did not change their cruel behavior towards the applicant/complainant. She

faced too much cruelty and cannot tolerate more she shift and live with her female

friend from_________

20. That respondent even agreed before the police that he beaten her and gave

statements that her important documents were under his control. But same day

before police he compromised with her but he resiled from promise.

21. That the respondents/accused even threatened the complainant and her friends who

helped her respectables to bear dire consequences if they again approach the

accused persons for the rehabilitation of complainant.

22. That the applicant/complainant is student and she started her Graduation at the

time of online exams respondent cut her answer sheets forcefully and beaten her

badly.

23. That the respondent is the man of sources, he is Katha Wachak (baba) he usually

goes outside the country for doing Katha and earn much more money some

societies also funding him, he is also running the business of Property Dealer, has

agriculture land, has 3 owned house and from all the sources he earns Rs. 3.5 Lakh
 per month and he has no other legal liability except to maintain her aged mother.

The respondent is also an able bodied person. Hence is duty bound to maintain his

wife.

24. That from the above said facts, it reveals that protection order as provided under

section 18 of The Protection of Woman from Domestic Violence Act, 2005, is

urgently required for the applicant/complainant.

25. That similarly as per the provisions of section 19[8] of the above said Act, this

Hon’ble court may kindly direct all the respondents/accused to return to the

applicant/ complainant all her important documents.

26. That as per the section 20 of the Act, the monetary relief should be granted

immediately from the respondents/ accused.

27. That prescribed court fee as per law has been affixed on the present

application/complaint.

28. That the domestic Violence to the complainant was also had to face at Amritsar her

matrimonial house, which falls within the ordinary territorial and jurisdiction and

local limits of the P.S _______, as such this Hon’ble court has got jurisdiction to

try and decide the present application/Complaint.

It is therefore, prayed that this Hon’ble court may take cognizance of

the present application/complaint and pass the following orders against the

respondents/accused.
A) That the respondents/accused may kindly be directed to pay maintenance at

the rate of Rs. 70,000/- per month to the applicant/complainant immediately

and that to from the date of filing the present application/complaint, for the

maintenance of complainant Restraining the accused/respondents from

committing any action of domestic violence against the applicant/

complainant.

B) Restraining the respondents/accused from aiding or abetting in the

commission of act of domestic violence.

C) The respondents/accused may kindly be directed to hand over all the

important articles and important documents which are Italy Residence

certificate and others belonging to the applicant/complainant.

D) Litigation expenses of Rs.30,000/- be also granted to the

applicant/complainant.

E) Compensation to the tune of Rs. 15,00,000/- for the damages for the injuries

including mental torture, emotion distress and physically and sexual

harassment by the respondents/accused by the act of domestic violence to

the applicant/complainant.

F) The applicant/complainant may also be awarded with any relief, which they

shall be found legally entitled to under law, equity and justice.

Date - Applicant/Complainant
 Harkrisham Kaur

Through counsel

Sh. Simran Singh, Advocate