Before the Hon’ble Principle Judge Family Court

No…….at Nagpur.

Petitioner No. E :-……../2018

Petitioner :- 1) Sau. Anuma W/o Kishore Shende,

Age about : 25 Years,

Occupation : Housewife,

2) Ku. Anagha D/o Kishore Shende,

Aged about : 11 Months,

Occupation : Nil

Both R/o – C/o Shri Sidharth Bhauqe,

Plot No. 27, Hanuman Nagari, Behind Rajiv

Nagar, Hingna Road, Nagpur.

-Versus-

Respondent :- Shri Kishore S/o Tanbaji Shende,

Aged about : 33 Years,

Occupation : Service,

R/o Dahegaon (Rangari)

Ward No. 3,

Tah. Saoner, Distt. Nagpur.

 Petition Under Section 125 of Cr. P.C. for Grant of
Maintenance
The Petitioner most respectfully submit as under :-

1) That, the petitioner no. 1 came into matrimonial alliance

with the respondent on 15.01.2016 at Kusumtai Wankhede Hall,

North Ambazari Road, Nagpur. As per rites and costumes

prevailing in the society with the consent of both the families. That

after the marriage the petitioner came to the marital house and

stayed with the company of the respondent at the father’s house of

residing at Dahegaon.

2) That, the respondent is serving at Western Coal Fields

ltd, Tawa mines no. 1 Patharkheda Area, Tah. Ghoradongri, Distt.

Betul (M.P.). The respondent four Bach to his father’s house,

where he kept the petitioner once in a mouth. The Petitioner was to

stay with the parents of the respondent and not with the respondent.

The respondent stayed at his father’s house with the company of the

Petitioner no. 1 and 2 only for a day or two.

3) That after 15 days from the date of marriage the

petitioner felt ill. This night have happened due to mental stress on

the petitioner during marriage arrangements. The respondent

accompanied with the petitioner only for 10 to 12 days.

Thereafter, the respondent joined for his duties at Tawa Mine no. 1

Patharkheda Area.

4) That, when the respondent left the company of the

petitioner to attend for duties. Naturally, it is the duty of the parents

to look after the petitioner. But, the seen at the house of the

respondent was unnatural and beyond the expectation from parents

of the respondent. The mother in-law of the petitioner directly

uttered the words as the petitioner is washing draw. She is not

having any ailment. Immediately the mother in law called parents

of the petitioner and ask them to take your daughter at their house

and send after treated fully. Don’t send their daughter with ailments

of disease.

5) That, the behavior of the mother in-law was showing

for the newly married lady at the house which was truly new for

her. The new lady was not knowing the uatara and the behavior of

the parents of the respondent. The mother in-law started to tahe out

loopholes occurred during the marriage. The mother in law told

that your father should have done this and that he has not given

honour to this person or that person. Mean the mother respondent

searched for the reason to depress & dishonor the petitioner. The

mother of the respondent always fried to search silly reason to

blame the parents of the petitioner. This the mother of the

respondent started to fortune mentally the petitioner for no

sufficient cause. It was charged alleged over the petitioner and

parents of the petitioner which were baseless and beyond logic.

6) That after taking the petitioner to the Hospital Dr.

Wankhede, Khaparkheda, the mother of the respondent immediately

called father of the petitioner and given the Doctors report in the

hands of father of petitioner and ask them to pay the bill for the

various test and medicines thereafter. Father of the petitioner paid

all the charges of the hospital.

7) That the argument the petitioner was discharged from

the hospital, the mother of respondent declared that the petitioner

was not having normal health. The petitioner was having this or

that diseases. The mother further added that such girl was fore ad

on the head of the respondent for marriage.

8) That there were many many restrictions over the

petitioner at the house of parents of the respondent. The petitioner

was not allowed to talk ever with the cousin sister of the

respondent. That the mother of respondent did not allow the

petitioner to talk to parents on telephone. It at all it was allowed to

speech with parents, at that time if was the condition that the

petitioner should talk in from of mother of the petitioner and as per

the directions of the mother of respondent. The mother dictated the

petitioner to say this or that.

9) That the mother of the respondent foread the petitioner

to bring ‘Gold Mangalsutra’ from her parents. The mother further

added to sold out the farmland which was in the name of father of

the petitioner.

10) That the mother of the respondent played a foul game

with the petitioner. During dictating the petitioner the mother of the

respondent dictated the petitioner to say to her parents that “the

marriage was forcefully done. The petitioner was not interested in

the marriage. If was father of the petitioner due to which the

petitioner had to worry with the respondent. Due to fear of mother

of respondent the petitioner repeated above words while talking

with her parents. Further, the mother acted as when the petitioner

uttered above words as dictated by mother of respondent and passed

on rumors as the petitioner was saying likewise with her parents.

Means, the mother of the respondent was creating methods and way
to fortune the petitioner. During whole this episode the respondent

being obedient son did not speech in favour of the petitioner.

11) That after the above serve parents of petitioner take to

their house and the petitioner was there for almost 3 months.

12) That after 3 months in the month of June 2016 the

respondent had been to the house of father of the petitioner. Here,

the mother of respondent forced the petitioner to come back to her

matrimonial house. On deeply suffering on the further of life the

petitioner decided to return back to the matrimonial house.

13) That during the live in the month of August 2016 the

petitioner became pregnant. Here, it was the duty of the respondent

to take care of his wife. Whenever, the respondent come back to

house it was the natural expectation of the wife that her husband

will spend much of time with her. But here, the respondent did not

& bothered for the thieving and the wishes of the petitioner. The

petitioner waited for dinner with husband but the respondent

returned back in late night hours and the petitioner slept down

without the dinner, because the mother of the respondent did not

allow taking the dinner without her husband.

14) That on quashing about the late coming of the

respondent, by the petitioner the respondent got angry and ever in

late night house caller his mother and both consolidately quarreled

with the petitioner.

15) That the respondent was heavy drunker. He drank daily

without fail and thereafter beaten without any sufficient reason

mercilessly to the petitioner.

16) That as per the custom after during the pregnancy there

is the program me of 7th months. Generally this is done in the house

of parents of the petitioner. But here mother of the respondent

arranged the above program me at her house itself. The parents and

relatives of petitioner were not called for the programme. Even

they were not informed about the programme by mother of

respondent.

17) That on the next day of this programme there started the

bleeding in the body of the petitioner. Now, the respondent admitted

the petitioner ad hospital Renuka maternity home of Dr. dadhana

Deshmukh shradhanand Peth, Nagpur. But the respondent did not

informed the fact to parents of the petitioner. The mobile phone

was also taken out by the mother of respondent from the petitioner,

so as the petitioner should not inform to her parents as she is

admitted in the hospital.

18) That on 31.03.2017 the petitioner has given birth of

female child.

19) That after knowing the delivery of daughter through

other sources, the parents came to the hospital to see the petitioner.

But here the respondent quarreled with the father of the petitioner

and ordered to leave the hospital or otherwise thereafter the father

in the hospital itself.

20) That arrival of parents in the hospital because reason to

quarrel with the petitioner. Respondent and her mother while

quarrelling with the petitioner repeated the same take again and

again. Here due to mental further the petitioner because

unconscious on 03.04.2014.

21) That on 04.04.2017 the respondent admitted the

petitioner along with her child in the Lata Mangeshakar Hospital,

Digdoh, Hingna Road, Nagpur. Since the new kid was also required
medical assistance the petitioner was also kept in I.C.U. in the

hospital. Here, the respondent and his mother left the hospital

without inferring to the petitioner. When the petitioner came to

know that the respondent and her mother left her in the hospital,

immediately the petitioner called her parents at the hospital. Due to

mental fortune from the respondent and her mother the petitioner

became serious and admitted to ICU in the hospital. Here, the

petitioner was kept in ICU for 5 days.

22) That doctor had given bills of hospital to the respondent

but the respondent given the bills in the hands of brother of

petitioner with the comment to as he his father to pay the hospital

bill. That all the medical bills includly hospitalization expenses,

medicine etc. was borne by father of petitioner.

23) That, thereafter the respondent never farmed to hospital

to take the petitioner back to his home. On the contrary on mobile

phone by mother of petitioner the respondent uttered the words as

take your daughter at your home.

24) That after this incidence the respondent through his

mobile always threaten the petitioner that he will bring gunda

people at the residence of taken of petitioner and further threaten

the father and petitioner in very filthy language. The petitioner

finally made a police complaint on 03.07.2017. This was registered

as NCR No. 0756/2017 dated 03.07.2017.

25) That, from 14.04.2017 the petitioner is away from the

company of the respondent and is at her parents’ house.

26) That, the petitioner is helpless and is unable to maintain

herself and her daughter and needs Rs. 25,000/- per month as

maintenance for her and 15,000/- to her daughter.

27) That, the respondent is a pursuant government

employee working is the western coal fields ltd. & is having salary

Rs. 80,000/- per month. The respondent is not having any financial

responsibility other than to maintain the petitioner and her child.

Since the father of the respondent is also working as ..

28) That since a year us one from the respondent side

includly the respondent did not came to the house of parents of

petitioner her contacted on mobile. On the contrary the petitioner

tried to call on phone but she had not given any response from the

respondent side.

29) That the marriage between the petitioner and the

respondent took place under the jurisdiction of this Hon’ble Court.

The petitioner is residing in the area under the territorial jurisdiction

of this Hon’ble Court. That the present case is tribal before this

Hon’ble Court.

30) That, the petitioner is lady and as such is exploted from

paying the court fees.

31) That, the cause of action arose on 14.04.2017 when the

petitioner was forced to go to her maternal house from the hospital

since the respondent was not ready to take her at his house.

32) That the petitioner has filed documents as per list and

craves leave to file were documents during the proceeding of the

present petition.
Prayer :- It is therefore most respectfully prayed that this

hon’ble court be pleased to :-

1) Grant the maintenance allowed Rs. 25,000/- to the

petitioner and Rs. 15,000/- to her daughter from

the date the respondent denied to take the

petitioner back to his house i.e. 14.04.2017.

2) Award the cost of application to be paid by the

respondent to the of Rs. 10,000/- only to the

petitioner.

3) Further relied as this Hon’ble Court deems fit and

proper to the facts and circumstances of the case

in the interest of justice.

Nagpur.

Date :- 02.04.2018

Petitioner

Counsel for the petitioner

 SOLEMN AFFIRMATION

I, Sau. Anuma w/o Kishore Shende, aged about

25 years, occupation Housewife, resident of C/o Shri Sidharth

Bhauqe, Plot No. 27, Hanuman Nagar, Behind Rajiv Nagar, Hingna

Road, Nagpur, do hereby go on oath and on solemn affirmation

states that the contents of plaint from paras 1 to 32 are true and

correct to my personal knowledge and belief.

Nagpur.
Date :- 02.04.2018
Petitioner

VERIFICATION

Signed and verified at Nagpur on this____th day of

February, 2013.

I know and identify the

Deponent DEPONENT