IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT,

EAST, KARKARDOOMA COURTS, DELHI

PETITION NO. ………/2021

IN THE MATTER OF:

Smt. Shabana ……… Petitioner

VERSUS

Sh. Ahsan Ali. ……… Respondent

INDEX
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S.NO. PARTICULARS. PAGE NO. CFP
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1. Memo of Parties.

2. Application u/s 125 Cr.P.C.

for grant of maintenance
along withthe affidavit.

3. Application for grant of

interim maintenance u/s
125 Cr.P.C.

4. Documents as per list attached.

5. Affidavit of Income and Expenditure.

6. Vakalatnama.

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New Delhi Petitioner

Dated: __.03.2021 Through:

FOR ARVIND KUMAR & ASSOCIATES

Advocates
B-3, First Floor, Jangpura
Extn., New Delhi - 14
 IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT,

EAST, KARKARDOOMA COURTS, DELHI

PETITION NO. ………/2021

IN THE MATTER OF:

Smt. Shabana ……… Petitioner

VERSUS

Sh. Ahsan Ali. ……… Respondent

MEMO OF PARTIES

Smt. Shabana
W/o Sh. Ahsan Ali
D/o Sh. Mohsin Khan
R/o -
…… Petitioner

Versus

Sh. Ahsan Ali.

s/0-Ismail Ali

R/o ……. Respondent

---------------------------------------------------------------------------------------------

New Delhi

Dated: __.03.2021 Through:

FOR ARVIND KUMAR & ASSOCIATES

Advocates
B-3, First Floor, Jangpura
Extn., New Delhi - 14
 IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT,

EAST, KARKARDOOMA COURTS, DELHI

PETITION NO. ………/2021

IN THE MATTER OF:

Smt. Shabana ……… Petitioner

VERSUS

Sh. Ahsan Ali. ……… Respondent

P.S. - vasant kuna

APPLICATION U/S. 125 CR.P.C. FOR THE GRANT OF MAINTENANCE

The Petitioner most respectfully submits as under:

1. That the Petitioner was married to the Respondent on 14.02.2010 according

to Muslim Rites and Ceremonies , East Nada, and the Petitioner is the legally

wedded wife of the Respondent.

2. That the marriage of the Petitioner and the Respondent was an arranged

marriage. The family members of the Petitioner had spent a considerable

amount over the solemnization of her marriage with the Respondent.

3. That we have child from this wedlock who’s Eight year old. unfortunately my

son is suffering from kidney disease and my husband(respondent) was told

me that there is no proper treatment is available in bungle of this disease.

4. That after the respondent suggestion I was went to the Delhi for the

treatment of my child of kidney disease then I was residing in my maternal

home in Delhi

5. That the respondent (husband) does not give any financial support for the

treatment of his child and expense of my and my son riding in Delhi. And
 even do not in touch by phone call when I was call him he was avoid to

take call

6. That the Respondent had severe temperament issues and used to fight with

the Petitioner often and inflict grave mental and physical cruelties upon her.

The relationship between the Petitioner and Respondent was never smooth

as the Petitioner was suffering and tolerating unnecessary beatings, taunting,

and abuses to petitioner and her parents.

7. That the Petitioner was ultimately deserted by the Respondent on

17.11.2020 after he fought with her on 16.11.2020 for talking on the phone

with her Professor. During this fight, the Respondent cruelly beat the

Petitioner and abused her and her family members. He left for Mumbai and

refused to take the Petitioner with him. Even after multiple requests, she was

not allowed to move back into her matrimonial house. The Respondent even

took to social media and blocked the Petitioner on every single platform

thereby making it impossible for the Petitioner to get in touch with him. The

Respondent refused to answer any of the numerous calls made by the

Petitioner and her parents.

8. That the Petitioner and her parents visited the Respondent’s house in

Mumbai, in January 2021, in an attempt to reconcile. However, even then

they were not welcomed by the Respondent or his parents. No one uttered a

single word to them, and they were not allowed to stay at the house. They

were kicked out and forced to return to Noida on the same night. It was very

clear to the Petitioner and her family members by this time that the

Respondent and his family members had no intention of letting the Petitioner

live with her husband.

9. That the Petitioner only brought basic clothesfor herself from her matrimonial

home and all of her jewelry, testimonials, istridhan articles,etc. are all in the

custody of the Respondent and his family members. All of the Petitioner’s

istridhan is in the custody of the Respondent and his family members and

they are using it to date.There are chances that they might have sold some

of it for their personal gain. At the same time, the Petitioner is living at the

mercy of her parents who are taking care of the Petitioner and providing for

her.

10. That the Respondent is a Senior Advisor at Ernst & Young, Bangalore,

earning about Rs. 20,00,000/- p.a. Apart from that he has income from

various investments and FDs. He owns two properties at M.G. Road,

Goregaon West worth more than Rs. 2.5 crores each. The Respondent is

leading a luxurious and peaceful life, whereas the Petitioner is currently

studying – pursuing higher studies from Symbiosis International, Pune

University. The Petitioner is currently unemployed, living at the mercy of her

parents.It is her parents who have been forced to pay for her studies, rent

and other necessities. It is pertinent to mention that to date,the Respondent

has not made any arrangements for the financial security and maintenance

of the Petitioner even though he has deserted her.

11. That the Respondent does not have any other liabilities except to maintain

the Petitioner. The Respondent is living a luxurious life while on the other

hand, the Petitioner is struggling day by day to live.

12. That the Respondent intentionally, willfully, and deliberately has neglected to

maintain the Petitionerand has caused economic domestic violence against

 her. The Petitioner has been forced to live without her belongings and she

has been traumatized again and again.

13. That the Respondent is a man of means and status.

14. That the istridhan and other articles of the Petitioner are in the possession of

the Respondents, which they have not returned to the Petitioner despite her

repeated requests and demands. The Petitioner even tried to collect the

same when she visited the Respondent’s house in January 2021, however,

the Respondent’s family members prevented her from doing so and did not

let her take it with her.

15. That the Petitioner is not able to maintain herself as she does not possess

any movable or immovable properties in her name. The Petitioneris living on

rent in Delhi while it is her parents who are providing for her.

16. That the Respondent has not made any provisions of any payment to the

Petitioner towards her maintenance since the day she was neglected by the

Respondent. The Respondent has been enjoying a luxurious comfortable

life, while on the other hand, the Petitioner is made to lead a helpless,

miserable, and isolated life.

17. That the Respondent is living a life of absolute luxury. The Petitioner has the

legal right to live and be maintained in the same standard of living as that of

the Respondent and therefore, she requires sufficient money for maintaining

herself according to the status of the Respondent. Thus, the Petitioner

requires a sum of at least Rs. 1,00,000/- per month for herself towards her
 basic living expenses including educational and school expenses, food, rent,

basic healthcare, personal maintenance and other day to day needs. This

maintenance amount is very reasonable according to the status and standard

of the Respondent. The Petitioner is also unable to pay the counsel fee and

bear other litigations expenses. The Respondent is liable to pay the same

because the Respondenthas compelled the Petitioner to file the present

Petition as he has neglected the Petitioner without any cause and reason.

The Petitioner requiresRs.25000/- as litigation cost.

It is, therefore, prayed that the Respondent be ordered to pay maintenance

of Rs.1,00,000/- per month for the maintenance of the Petitioner from the date of

filing of the present Petition till its realization along with the cost of litigation

(drafting, conferences, and counsel's fee and litigation expenses) amounting to

Rs.25000/- to the Petitioner, which will be in the interest of justice.

It is prayed accordingly.

New Delhi Petitioner

Dated: __.03.2021 Through:

FOR ARVIND KUMAR & ASSOCIATES

Advocates
B-3, First Floor, Jangpura
Extn., New Delhi - 14

VERIFICATION:-
 Verified at New Delhi on this the __ day of March 2021 that the contents of

Para Nos. 1 to __ of the petition are true and correct to my knowledge and no part

of it is false.Nothing material has been concealed therefrom. The lastpara is a

prayer to this Hon’ble Court.

Petitioner
 IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT,

EAST, KARKARDOOMA COURTS, DELHI

PETITION NO. ………/2021

IN THE MATTER OF:

Smt. Sangeeta Devraj ……… Petitioner

VERSUS

Sh. Venkitasubramanian @ Varun Neelakantan ……… Respondent

AFFIDAVIT

I, Sangeeta Devraj W/o Sh. Varun Neelakantan D/o Sh. T. Devraj R/o D-314,
D-Block, Ganesh Nagar, Pandav Nagar Complex, East Delhi, Delhi -110092 do
hereby solemnly affirm and declare as under:-

1. That the deponent is the Petitioner in the above-noted case and is well
conversant with the facts and circumstances of the case and as such is
competent to swear this affidavit.

2. That the Petitioner was married tothe Respondent on 06.02.2019 according

to Hindu Rites and Ceremonies at Guruvayur Temple, East Nada,
Guruvayur, Kerala, and the Petitioner is the legally wedded wife of the
Respondent.

3. That the Petitioner is unable to maintain herself and she does not possess
any movable or immovable properties in her name.

4. That the Respondentis a man of means and status. The Respondentis

earning Rs. 20,00,000/- p.a. approx. There is no liability upon the shoulders
of the Respondent except to maintain the Petitioner.

5. That the contents of the accompanying application u/s 125 Cr.P.C. have
been drafted by my counsel under my instructions, and the same has been
read over to me in the vernacular language. The contents of the same may
be read as part and parcel of this affidavit, which are not reproduced herein
for the sake of brevity.Nothing material has been concealed therefrom and
no part of the same is false.
 DEPONENT

VERIFICATION:

Verified at New Delhi, on this the …… day of March 2021 that the contents of

the above affidavit are true and correct to my knowledge.Nothing material has been

concealed therefrom and no part of the same is false.

DEPONENT
 IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT,

EAST, KARKARDOOMA COURTS, DELHI

PETITION NO. ………/2021

IN THE MATTER OF:

Smt. Sangeeta Devraj ……… Petitioner

VERSUS

Sh. Venkitasubramanian @ Varun Neelakantan ……… Respondent

APPLICATION ON BEHALF OF THE PETITIONER FORINTERIM

MAINTENANCE U/S. 125 CR.P.C.

MOST RESPECTFULLY SHOWETH:

1. That the Petitioner has filed an accompanying petition for maintenance u/s

125 Cr.P.C., the contents of which may be read as part and parcel of this

application also as the same are not repeated herein for the sake of brevity.

2. That the Respondent has sources of income and owns movable and

immovable properties. The Respondentis earning a handsome income as

described and mentioned in the main petition and the same may also be read

as a part and parcel of this application.

3. That the Respondentdoes not have any liabilities except to maintain the

Petitioner. The Respondent is living a luxurious life while on the other hand,

the Petitioner is living at the mercy of her parents.

4. That the Petitioner has no source of income and is not in a position to

maintain herself.
 5. That the Respondentintentionally, willfully and deliberately has neglected to

maintain the Petitionerand he is legally bound to maintain the

Petitionerbecause the Petitioner is the legally wedded wife of the

Respondent.

6. It is apprehended that the Respondent and his family members through their

concocted and malicious means would tend to delay the matter of

maintenance and otherwise too, the final disposal of the above-noted case

may take some time.Meanwhile, the Petitioner is not able to maintain herself

as the parents and relatives of the Petitioner too have been engulfed in a

financial crunch. Hence this application before this Hon'ble Court.

P R A Y E R:-

It is, therefore, most respectfully prayed that the Respondent may kindly be

directed to pay an amount of Rs.60000/- per month to the Petitioner underthe law

for her interim maintenance from the date of filing of the present petition in the facts

and circumstances of the case and the interest of justice, till the final disposal of the

present petition.

Such other or further order(s) as this Hon'ble Court may deem fit and proper in

the facts and circumstances of the case be also passed in favor of the Petitioner

and against the Respondents.

It is prayed accordingly.

New Delhi Petitioner

Dated: __.03.2021 Through:

FOR ARVIND KUMAR & ASSOCIATES

 Advocates
B-3, First Floor, Jangpura
Extn., New Delhi - 14
 IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT,

EAST, KARKARDOOMA COURTS, DELHI

PETITION NO. ………/2021

IN THE MATTER OF:

Smt. Sangeeta Devraj ……… Petitioner

VERSUS

Sh. Venkitasubramanian @ Varun Neelakantan ……… Respondent

AFFIDAVIT

I, Sangeeta Devraj W/o Sh. Varun Neelakantan D/o Sh. T. Devraj R/o D-314,
D-Block, Ganesh Nagar, Pandav Nagar Complex, East Delhi, Delhi -110092 do
hereby solemnly affirm and declare as under:-

1. That the deponent is the Petitioner in the above-noted case and is well
conversant with the facts and circumstances of the case and as such is
competent to swear this affidavit.

2. That the contents of the accompanying application for interim maintenance

have been drafted by my counsel under my instructions and the same has
been read over to me in the vernacular language.The contents of the same
may be read as part and parcel of this affidavit, which are not reproduced
herein for the sake of brevity.Nothing material has been concealed therefrom
and no part of the same is false.

DEPONENT

VERIFICATION:

Verified at New Delhi, on this the …… day of March 2021 that the contents

of the above affidavit are true and correct to my knowledge.Nothing material has

been concealed therefrom and no part of the same is false.

DEPONENT