IN THE COURT OF JUDICIAL MAGISTRATE 1st CLASS

FAMILY COURT, KKD COURTS, NEW DELHI

Maintenance Application No. ___ Of 2019

IN THE MATTER OF:-

SH.__________
S/O_______
R/O_________ APPLICANT

VERSUS

SMT. _______
D/O_________
R/O__________ RESPONDENT

APPLICATION FOR MAINTENANCE U/S 125, Cr.P.C.

The petitioner above named most respectfully state as under:

1. That the applicant was married to the respondent on _______ at___ within the
jurisdiction of this Hon’ble Court and the marriage was performed accordance with the
Hindu rites and ceremonies.
2. That from the very beginning of the married life, the respondent’s behavior towards the
applicant was not good. The rude behavior of the respondent caused unreasonable pain,
trouble and suffering to the applicant. The degree of the pain was gradually so increased
that it was very difficult for the applicant to live with the respondent. There was danger to
the life, health or limb of the applicant, and therefore, applicant left her matrimonial
house and now residing with her parents since last one year.
3. That the respondent is an alcoholic addict. He is a hard drinker and used daily to beat,
abuse and threaten to kill the applicant without any reason. The respondent’s
unnecessarily quarreling everyday made difficult for applicant to live with respondent,
life of the applicant became under apparent threat to life, bodily injury and living with
respondent miserable.
4. That on _____, the respondent crossed the limits, when he expelled the applicant from his
house and threatened the applicant by saying “if she returns back to his house, the
respondent will kill her certainly. Since then the respondent has willfully neglected to
maintain the applicant.
5. That the unavoidable circumstances, the applicant left the house of the respondent and
now living with her parents without any means of her own. The father of the applicant is
 a retired person from the government service and getting a minimal pension and her
younger brother in unemployed. Hence the parental family of the applicant is unable to
support her for long due to their own financial paucity.
6. That the respondent is a rich person having sufficient means to maintain the applicant.
His income from ___, ______ and other sources is more than Rs.____ per year. The
applicant’s request for maintenance has been refused by the respondent.
7. That the applicant is entitled to claim monthly maintenance allowance from the
respondent and the latter is liable to pay the same since him having sufficient mans to do.

PRAYER:

It is therefore, most respectfully prayed that, the respondent be ordered to pay at least Rs. ____
per month as her maintenance allowance from the date the applicant is forcefully expelled from
her matrimonial house and for the future until the respondent resumes his responsibility as
husband with decent behavior towards the applicant.

New Delhi Applicant

Dated: __/__/2019
Through Counsel
 IN THE COURT OF JUDICIAL MAGISTRATE 1st CLASS
FAMILY COURT, KKD COURTS, NEW DELHI
Maintenance Application No. ___ Of 2019

IN THE MATTER OF:-

SH.__________
S/O_______
R/O_________ APPLICANT

VERSUS

SMT. _______
D/O_________
R/O__________ RESPONDENT

AFFIDAVIT

I, Sh. ________, s/o Sh. _________, aged about __ Years, r/o ____, Employed in _____ as
_______, do hereby solemnly affirm and declare on oath as under-

1. I, ____, the applicant above-named, do hereby state on solemn affirmation that the
contents of this application in paras 1 to 7 are true and correct to the best of my personal
knowledge and I am competent to swear this affidavit.
2. That the accompanying application has been drafted under my instructions and its
contents are true and correct to the best of my knowledge.

DEPONENT

VERIFICATION:

This is verified at New Delhi on ____ day of July, 2019, that the contents of the above affidavit
are true and correct to best of my knowledge and nothing is false nor any material facts has been
concealed there from.

DEPONENT