IN THE COURT OF PRINCIPAL JUDGE FAMILY
COURT (DISTT.NORTH WEST),ROHINI COURTS,
DELHI
Petition No. of 2025
IN THE MATTER OF:
Pooja Vs Jitendra Kumar
INDEX
S.N O . PAGES COURT
PARTICULARS FEES
1. Memo of parties
PETITION UNDER
2. SECTION 144 OF THE
BHARTIYA NAGARIK
SURAKSHA SANHITA
BEHALFOF PETITIONER
APPLICATION U/S.
3. 144(2) OF THE
BHARATIYA NAGARIK
SURAKSHA SANHITA
FOR GRANT OF
INTERIM/EX-PARTE
ORDER.
4. Detailed affidavit
regarding income, assets
and liabilities.
5. List of documents along
with documents.
6. Vakalatnama.
DELHI. PETITIONER
DATED: Through
(YESHPAL. SINGH)
Advocate
.
IN THE COURT OF PRINCIPAL JUDGE FAMILY
COURT (DISTT.NORTH WEST),ROHINI COURTS,
DELHI
Petition No. of 2025
IN THE MATTER OF:
Pooja Vs Jitendra Kumar
MEMO OF PARTIES
Pooja
D/o Sh. Bhagirath
W/o Sh. Jitendra Kumar
R/o H.-12, Krishan Vihar,
North-West, Delhi-110086 ..Petitioner.
VERSUS
Jitendra Kumar
S/o Sh.Ashok Kumar
All R/o C-129, Welcome,
Seelampur Delhi-110053
Mob.No.9650261363
…Respondent
DELHI. PETITIONER
DATED: Through
(YESHPAL. SINGH)
Advocate.
Ch./St.256, Gajanand Block,
Tis Harari Court,Delhi-54
Mob. No. 9717375409
IN THE COURT OF PRINCIPAL JUDGE FAMILY
COURT (DISTT.NORTH WEST),ROHINI COURTS,
DELHI
Petition No. of 2025
IN THE MATTER OF:
Pooja Vs Jitendra Kumar
Pooja
D/o Sh. Bhagirath
W/o Sh. Jitendra Kumar
R/o H.-12, Krishan Vihar,
North-West, Delhi-110086 ..Petitioner.
VERSUS
Jitendra Kumar
S/o Sh.Ashok Kumar
All R/o C-129, Welcome,
Seelampur, Delhi-110053
Mob.No.9650261363
…Respondent
P.S.: Sultan Puri
Distt.North West.
PETITION UNDER SECTION 144 OF THE
BHARTIYA NAGARIK SURAKSHA SANHITA
BEHALF OF PETITIONER .
MOST RESPECTFULLY SHOWETH :-
1. That the Petitioner was married with the
respondent on 29.4.2013 according to Hindu
rites and ceremonies at C-129, Welcome,
Seelampur Delhi.
2. That the marriage between the Petitioner and
respondent was arranged marriage and was
solemnized with great pomp and show and
sufficient jewellery, dowry and household
articles, electronic appliances etc. was given by
the parents of the Petitioner to the respondent.
A sum of Rs.7,00,000/- were spent on the
marriage by the parents of the Petitioner.
3. That after the marriage the Petitioner was
brought by the respondent at her matrimonial
home and the marriage was duly consummated
and out of this wedlock a male child namely
Hemant Kumar was born on 10.7.2014, who is
in care and custody of the Petitioner. Now this
child is 11 years old who is studying in Vth
class and the plaintiff is bearing his school fees
of Rs.1550/- beside other expenses.
4. That since very beginning of the marriage the
behavior of the respondent was not good
towards the Petitioner as they were not
satisfied with the dowry articles brought by the
Petitioner in the marriage and they used to
taunt that the father of the Petitioner has not
given sufficient cash amount in the marriage as
per their status and they also taunted the
Petitioner that the articles given by the parents
of the Petitioner are of inferior quality.
5. That just after the marriage the respondent
father-in-law and mother-in-law of the
Petitioner took all the jewellery of the
Petitioner except gold ring and anklet/payal by
saying that they will keep the same in the safe
custody and will return as and when the
Petitioner will demand and the said jewellery
of the Petitioner is still lying with the them and
they refused to return the same.
6. That respondent to tell his wife/Petitioner to
bring Rs.2,00,000/- from her house. The
Petitioner told her husband that her father has
already spent a lot of money on my wedding.
He cannot arrange Rs.2,00,000/- right now. On
this the respondent got very angry at this and
slapped the Petitioner several times and kicked
her and made her fall. The mother-in-law
taunted upon the Petitioner by saying that,
“Kanglon Ki Ladki Aa Gayi Hai”.
7. That this incident is of 15/04/2014 when the
Petitioner was pregnant at that time the
Petitioner requested respondent not to come
home drunk. On this respondent got angry with
the Petitioner and he beat the Petitioner a lot
under influence. The Petitioner called her
father and her parents came to in-laws house
and they explained to the respondent.The father
of the Petitioner brought the Petitioner to with
him and got her treated.
8. That the Petitioner gave birth to a son on
10/07/2014. Her delivery took place at Dr.
Baba Saheb Ambedkar, Sector-6, Rohini. Her
parents took complete care and bore all the
expenses of delivery as well as medicines of
the Petitioner as well of newly born child and
hospital. The respondent and other in-laws did
not even come to the hospital to see the newly
born child.
9. That when the newly born childn turned 2
months old. On 05/09/2014 the respondent and
other in-laws came to parental home of the
Petitioner and accepted their mistake and said
to parents of the Petitioner that from now
respondent will not beat the Petitioner and will
treat the Petitioner well. After coming to
parental home, the Petitioner was was fine for
4 months, then again respondent started beating
the Petitioner after drinking alcohol and left
the Petitioner at her parental home.
10. That on 15/07/2016 the respondent came to
parental home of the Petitioner and started
apologizing for his acts and said that now he
will not drink alcohol nor will he fight nor will
he gamble and he also told the Petitioner that
he will give the Petitioner and her son a good
care/atmosphere
11. This incident is of 11/07/2021, the respondent
started quarreling with the Petitioner. the
Petitioner told him not to play Satta, as the
child is growing up and he asked the Petitioner,
do I play Satta with your father's money and
respondent beat the Petitioner badly.
12. This incident is of 19/02/2024 when the
respondent asked the Petitioner for 5,000/-
rupees to play betting. When the Petitioner
refused, he beat the Petitioner and snatched the
money from the Petitioner. The Petitioner
called her parents, they came and explained to
respondent but the all the respondent abused
the parents of the Petitioner and behaved
rudely with them. They pushed the Petitioner
and her parents along with minor son out of the
house and since then the Petitioner is living at
her parents' house.
13. That thereafter the Petitioner so many times
tried to make the respondent understand but
they flatly refused to allow the Petitioner to
enter in their house.
14. That finding no other way the Petitioner has
also made a complaint dated 30.4.205 to the
A.C.P. CAW Cell, as well as Commissioner of
Police Distt.North-West, Pitampura, Delhi
against the respondent but till date no action
has been taken.
15. That the Petitioner is a house wife and she has
no source of income from any corner and she
is unable to maintain herself and her minor
child. At present she is living at her parental
home at the mercy of her parental family, who
are unable to maintain the Petitioner and her
minor child for a long period.
16. That on the other hand the respondent is a man
of means and is leading a luxurious life. The
respondent is running his own purse factory
and earning handsome amount of about
Rs.50,000/- per month. He is residing in his
own house and he has no other liability except
to maintain the Petitioner and her minor
children but he is avoiding neglecting and even
refused to maintain the Petitioner and her
minor child.
17. That during the period the Petitioner remained
at her matrimonial home, she was subjected
with utmost cruelty and domestic violence by
the respondent.
18. That all the jewellery and stridhan of the
Petitioner is still lying with the respondent and
they refused to return the same.
19. That this Hon’ble Court has got the jurisdiction
to try and decide the present petition.
PRAYER :-
It is, therefore, most respectfully prayed that this
Hon'ble Court be pleased to grant the relief (s) claimed
therein and pass such order or orders other order as this
Hon'ble Court deems fit and proper.
a) Grant monthly maintenance of Rs.25,000 per
month in favor of petitioner.
b) Any other relief which this Hon’ble Court
deems fit and proper may also be passed in
favour of the Petitioner and against the
respondent.
DELHI. PETITIONER
DATED: Through
(YESHPAL. SINGH)
Advocate.
Ch./St.256, Gajanand Block,
Tis Harari Court,Delhi-54
Mob. No. 9717375409
VERIFICATION:-
Verified at Delhi on this day of May, 2025,
that the contents of para No. 1 to 19 of the above
application are true and correct to the best of my
knowledge and also on the basis of information
received and believed to be true. Last para is prayer to
this Hon'ble Court.
PETITIONER
IN THE COURT OF PRINCIPAL JUDGE FAMILY
COURT (DISTT.NORTH WEST),ROHINI COURTS,
DELHI
Petition No. of 2025
IN THE MATTER OF:
Pooja Vs Jitendra Kumar
AFFIDAVIT
I, Pooja D/o Sh. Bhagirath W/o Sh. Jitendra Kumar R/o H.-12,
Krishan Vihar, North-West, Delhi-110086, do hereby
solemnly affirm and declare as under:-
1. That I am the Petitioner in the above noted case
and well conversant with the facts of the case and
hence competent to swear this affidavit.
2. That the contents of accompanying complaint
under section 144 Bhartiya Nagarik Suraksha
Sanhita may kindly be read as part and parcel of
this affidavit, as the same have not been repeated
here for the sake of brevity.
VERIFICATION :- DEPONENT.
Verified at Delhi on this day of May,
2025, that the contents of my above affidavit are true
and correct to the best of my knowledge and nothing
material has been concealed therefrom.
DEPONENT
IN THE COURT OF PRINCIPAL JUDGE FAMILY
COURT (DISTT.NORTH WEST),ROHINI COURTS,
DELHI
Petition No. of 2025
IN THE MATTER OF:
Pooja Vs Jitendra Kumar
APPLICATION U/S. 144(2) OF THE BHARATIYA
NAGARIK SURAKSHA SANHITA FOR GRANT OF
INTERIM/EX-PARTE ORDER.
MOST RESPECTFULLY SHOWETH: -
1. That the applicant has filed a petition U/s. 144 of
the Bhartiya Nagarik Suraksha Sanhita which is
pending disposal before this Hon’ble Court.
2. That the details of the facts have already been
mentioned in the main application and the same
are not being repeated here to avoid repetition.
The same may be read as part and parcel of the
present application.
3. That even after this incident the respondent are
not sparing any chance to harass, humiliate and
gave merciless beatings to the applicant.
4. That the applicant has every apprehension that the
respondent would go to any extent to get rid of
her.
5. That the applicant has a very good prima facie
case to establish in her favour and against the
respondent.
It is, therefore, most humbly prayed that this Hon’ble
Court may graciously be pleased pay monetary
relief/maintenance to the Petitioner of Rs.25,000/-
per month till the final disposal of the main petition.
Any other relief which this Hon’ble Court deems fit
and proper may also be passed in favour of the
Petitioner and against the respondent.
DELHI. PETITIONER
DATED: Through
(YESHPAL. SINGH)
Advocate.
Ch./St.256, Gajanand Block,
Tis Harari Court,Delhi-54
Mob. No. 9717375409
IN THE COURT OF PRINCIPAL JUDGE FAMILY
COURT (DISTT.NORTH WEST),ROHINI COURTS,
DELHI
Petition No. of 2025
IN THE MATTER OF:
Pooja Vs Jitendra Kumar
AFFIDAVIT
I, Pooja D/o Sh. Bhagirath W/o Sh. Jitendra Kumar R/o H.-
12, Krishan Vihar, North-West, Delhi-110086, do hereby
solemnly affirm and declare as under:-
1. That I am the Petitioner in the above noted case
and well conversant with the facts of the case and
hence competent to swear this affidavit.
2. That the contents of accompanying application
U/s.144(2) of BNSS may kindly be read as part
and parcel of this affidavit, as the same have not
been repeated here for the sake of brevity.
VERIFICATION :- DEPONENT.
Verified at Delhi on this day of May,
2025, that the contents of my above affidavit are true
and correct to the best of my knowledge and nothing
material has been concealed therefrom.
DEPONENT
