IN THE CHOPDA COURT AT ULHASNAGAR, MUMBAI

HARASSMENT OF SR. CITIZENS AND DEFAMATION PETITION NO. /

OF 2022.

MR. HRISHIKESH SHANTARAM PATIL )

Adult, Hindu, Indian Inhabitant, )

age about 32 years, Occupation : Service )

Residing at Flat No. 105, Shiv Saikiran Apt, )

Vadavali Section, MIDC Road, )

Ambernath East – 421501. )

Tel: 9359797273. )

Email: hrishipatil1706@gmail.com )

... PETITIONER

V/s.

MRS. DIVYA HRISHIKESH PATIL

Adult, Hindu, Indian inhabitant, )

age about 30 years, Occupation: Service, )

MR. DAYANAND NAIK

Adult, Hindu, Indian inhabitant, )

age about 61 years, Occupation: Pensioner , )

MRS. DIPTI NAIK

Adult, Hindu, Indian inhabitant, )

age about 58 years, Occupation: Pensioner, )

Adult, Hindu, Indian inhabitant, )

All Residing at B-17, Om Satyavinayak Chs. Ltd., )

Behind Suvarna Hospital, Kasturpark, )

Borivali West, Mumbai – 400092. )

... RESPONDENTS

PETITION FOR HARASSMENT AND DEFAMATION

UNDER SECTION ____OF:-

To,

THE HON’BLE PRINCIPAL JUDGE AND

OTHER HON’BLE JUDGES OF THE
CHOPDA COURT AT ULHASNAGAR, MUMBAI.

THE HUMBLE PETITION OF THE PETITIONER ABOVENAMED MOST

RESPECTFULLY SHEWEATH: -

THE PETITIONER ABOVE

NAMED BEGS TO SUBMIT AS UNDER: -

1. The Petitioner states that he and the Respondent are both Hindu by religion

and they are both domiciled in the State of Maharashtra. The Petitioner

states that he married the Respondent on 24/02/2019 at Aditya hall, Borivali

west, Mumbai- 400092, in a ceremony as per the Hindu Vedic rites and

rituals in the presence of friends and relatives of both sides.

2. The Petitioner states that at the time of the marriage he was a bachelor and

the Respondent was a spinster. The Petitioner states that the maiden name of

the Respondent was Miss. DIVYA DAYANAND NAIK and after the

marriage she is known as MRS. DIVYA HRISHIKESH PATIL. The

Petitioner states that the said marriage is not registered with the registrar of

Marriage. The Petitioner states there the marriage is duly consummated and

there is one issue out of the said wedlock i.e. Daughter named Kumari

Dhrisha Hrishikesh Patil born on 30/04/2020, age 2 years, presently in the

exclusive forcible custody of the respondent. The Petitioner states that the

said marriage is an arranged marriage. The Petitioner states that since neither

party belongs to a ST community, the section 2(2) of the Hindu Marriage

Act, 1955 does not apply to them. Hereto annexed and marked as Exhibit

“A” are marriage photographs of the said wedding. Hereto annexed and

marked as Exhibit “B” is the copy of the marriage invitation card of the said

marriage.
3. The Petitioner states that, during the talks of their said marriage, the

Respondent’s parent’s only condition was that they were looking for a

groom from western region of Mumbai, to which the Petitioner had agreed

that he can shift from Ambernath to Western region, but with the condition

that his own parents would also stay with them after their marriage, to which

the Respondent and her parents had totally agreed and the Respondent had

also promised to stay in a joint family with his said parents and it is a

common practice in society.

4. Petitioner states that when they disclosed about the marriage in the society

and their workplace, on 11th Dec, 2018 at 8:49:18 and 8:49:59, he had

received a call from Mr. Kushal Wasnik who was then working at Punjab

National Bank as a clerk currently posted at Pune and threatened the

respondent no.1 saying that “don’t come in between me and Divya…we are

having affair with each other”. The said Kushal Wasnik was also using

abusive words repeatedly and had also said that “she used me…She had

affair with me and now getting married to you”. Immediately after that he

had called the Respondent to get the clarification about this and the matter

was reported in the Borivali police station on the same day itself as per the

written complaint filed by the respondent and Mr. Wasnik who was on duty

was called to the police station by Mr. Shinde, Police Officer with whom
 Petitioner had also spoken over the phone. Petitioner states that Respondent

had requested that this incident should not come in applicant’s parent’s

knowledge. He was a clerk in Bank and Petitioner was manager at that time.

This means Respondent has the habit of bullying multiple boys for the

money and property and her own parents are guiding her for the same as

since beginning they are having an evil eye on the flat adjacent to their own

flat.

5. The Petitioner states that, after they returned from their honeymoon they

shifted to a rented house at Chikoowadi, Borivali west, Mumbai, where they

stayed for around 5-6 months. While residing in the said LL basis flat in

Borivali, one day around March, 2019 suddenly Respondents parents took

him to a Mall in Borivali and told him that they were searching for a good

shop for purchase to invest their money in the said Mall. The Petitioner

states that her parents did all the inquiry with representatives from the Mall

and then while leaving they said, they did not find it interesting and then

they told him that since they will be getting some retirement benefit funds

and they need to invest that money quickly as the real sister of her mother

Mrs. Mala (staying at Andheri) was having an evil eye on their huge money,

due to which they were looking to invest that money somewhere at the

earliest. Thereafter the Respondent’s father suddenly diverted the topic and
 told him that since he and the Respondent were staying in a rented house,

and since he was looking to purchase a new self-owned house in Western

Mumbai, that he and his wife will themselves use some amount from their

retirement benefits in the purchase of that new flat. The Petitioner states that

he informed the Respondent’s parents that this is not required and he will

purchase a new flat as and when possible for him, however her parents

began to insist that they wanted him to buy a new house for her sake and her

parents also told him that they will voluntarily help their own daughter

financially and put their money in the purchase of this new flat near to their

present residence. Hereto annexed and marked as Exhibit “C” is the

photograph of the Petitioner with the Respondent’s father in the said Mall.

6. The Petitioner states that, the Respondent and her parents had told to him

that the Respondent’s cousin i.e. Mr. Gaurav Yadav had gone to pursue the

course of Pilot at Australia which he could not complete and had made the

loss of fees paid by him which was amounting to Rs. 40-45 Lakhs and this

was the reason her aunty was having an evil eye on the retirement benefits of

the Respondent’s parents and they wanted a reason to tell her that the entire

money was given to her to purchase the house.

7. The Petitioner further states that, the Respondent’s parents had advised both

of them that, Petitioner should purchase the flat besides their house in Om
 Satyavinayak CHS LTD, Borivali, so that all of them can stay together with

the Respondent’s parents and that there can be support to each other.

However, the Petitioner states that, the Respondent and her parents never

wanted parents of the Petitioner to stay in their own son’s house and did

everything to throw them out of the house. The Petitioner states that, the

Respondent and her own parents view about their joint family changed

immediately after the Petitioner purchased the said flat and he felt that he

was used just for purchasing the house and the Respondent had no interest in

him or his parents since the beginning of their marriage which can be proved

from her own contradictory statements made in her handwritten police

complaint and her reply to his legal notice for divorce. Hereto annexed and

marked as Exhibit “D” is the copy of the handwritten complaint page no. 86

and 87 of DV case and page no. 4 of Divorce, legal notice reply dated

22/10/2020.

8. The Petitioner states that it appears that the said decision to make him

purchase a new flat near the Respondents parents existing house was pre-

meditated decision and Respondent & her parents were fully aware that their

next door neighbour and owner of Flat No. B-18, Om Satyavinayak Chs.

Ltd., Behind Suvarna Hospital, Kasturpark, Borivali West– 400092, i.e. Mr.

P.J. Jose was ready to sell the said house to them. The Petitioner states this
with certainty because this Flat No. B-18 was obtained on Leave License

basis by her parents from the said owner Mr. P. J. Jose, even prior to his

marriage with the Respondent and he was informed much later that

surprisingly the said flat no. B-18 was being used only for the purpose of

keeping their extra luggage and still they were paying a huge amount of

about Rs. 27,000/- only as the LL compensation fees / rent which seems

very strange and suspicious. The Petitioner states that naturally her parents

induced him to buy the said flat next to their own flat and during the

conversations informed him that this is the best deal and the said flat is

available for a very cheap rate and that he will have to obtain a loan amount

of only Rs. 60 Lakhs, whereas the rest of the amount for the purchase of the

said flat shall be arranged by them. The Petitioner states that the

Respondents mother also personally checked his salary slip, all the

deductions prior to them suggesting him to purchase said flat no. B-18 and

tricked him to pay the entire EMI after the purchase of the said flat, since

she had pre-ascertained that he had the financial capacity to pay the said

EMI. The Petitioner states that the Respondent had given false information

to the police that he was forcing her to buy the house, however, when the

loan was not sanctioned from his office, respondent had herself done all the

efforts to buy the house with the help of her father who himself had visited
 the BMC/advocate to arrange all the documents needed for the loan so that

the house can be bought by hook or crook. Petitioner also states that he has

also utilised his overdraft loan of Rs. 7.00 Lakhs for repair & renovation of

the said flat. Hereto annexed and marked as Exhibit “E” is the original &

amended sanction letter dated 11.09.2019 & 30.06.2020 of PNB bank for the

said loan amount.

9. The Petitioner states that, since he was under an impression that his relations

were good with Respondent, he agreed when Respondent told him that she

will be taking a loan of Rs. 40-45 Lakhs to purchase the said new flat and

her parents told him that they will be paying / investing Rs. 14-15 Lakhs to

purchase the said new flat. The Petitioner states that, when he suggested

buying some other flat, Respondent suddenly told him that she will be

allowing him to take any loan, only if he is ready to purchase the said flat

next to her parents flat and to otherwise, he must forget about buying any

house. The Petitioner states that, unfortunately, he took the said decision of

purchasing the said house next to her parent’s house.

10.The Petitioner states that, thereafter the Respondent’s parents insisted that

they want their names included in the flat purchase agreement as joint

purchasers, however since the concerned Bank refused to allow this under

staff scheme, the Respondent began to insist that her name must be placed as
 the first purchaser and the Petitioner could not see through her designs and

agreed for the same. The Petitioner states that, thereafter while obtaining the

loan for the said flat purchase, Respondent and her mother stated that though

the said loan would be a joint liability the EMI for the said housing loan

shall be paid only by the Petitioner and that Respondent will not be paying

any EMI for the reasons best known to her. The Petitioner states that, since

he is the male in this relationship once again, he had to compromise and he

agreed for the same with an understanding that in the event of him not being

able to pay, Respondent will bear the said liability being his wife and for the

entire period till date the Petitioner has been paying EMI for both the

accounts. Hereto annexed and marked as Exhibit “F” is the transaction

statement of repayment of both the loan accounts of PNB bank for the said

loan amount.

11.The Petitioner states that, after obtaining the said loan and purchase of the

said flat no. B-18, Om Satyavinayak Chs. Ltd., Behind Suvarna Hospital,

Kasturpark, Borivali West, Mumbai – 400092, he and his parents who were

staying at Ambernath and the respondent shifted from their earlier flat at

New Nikita CHS LTd, Chikuwadi, Borivali (W) and began to reside in the

said Flat No. B-18 since 23.07.2019. The Petitioner states that upon shifting

to the said new flat No. B-18, he marked a lot of change in the Respondent’s
 behaviour and he observed that Respondent began accumulating all her

income from her salary with her own parents, claiming that Respondent had

to repay her parents for the expenses incurred by them for her education in

the name of education loan taken prior to the Petitioner’s marriage with

Respondent and for which he was not given any idea before the marriage.

12.The Petitioner states that, despite being his legally wedded wife Respondent

did not support in any financial issues faced by him in the matrimonial

house at any stage which can be proved from her financial statements. The

Petitioner states that Respondent without any information suddenly

transferred around Rs. 35,000/- to 40,000/- in her mother’s account saying

that Respondent had taken some cash from her parents without his

knowledge. All in all there was no financial support whatsoever to the

Petitioner from Respondent.

13.The Petitioner states that his parents Mr. Shantaram Pundlik Patil and Mrs.

Pratibha Shantaram Patil has shifted from Ambernath to Borivali after

purchasing the 2 BHK flat at Borivali by the Petitioner and it was his

responsibility to take care of them being a single child. However, Mrs.

Divya forced him to throw them out of their own house with the help of her

own parents stating besides at Flat No. B-17. It is very clear from the

marriage counselling report of Dr. Brenda Fernandez that the parents of Mrs.
 Diva were over interfering in their daughter’s married lie just to make sure

that they shall get the chance to grab the entire jointly purchased property as

pre-planned. Within 6 months of their stay at Flat B-18, Mrs. Divya harassed

aged parents of Mr. Hrishikesh Patil and due to cruel treatment given by her

they had to shift immediately to Ambernath.

14.After they shifted to Ambernath, it was the duty of Mr. Hrishikesh Patil, to

visit his parental house at least when they were in need. Mrs. Divya had

problem with the same. Mrs. Divya has given statement in writing that

whenever Petitioner was visiting his parental house his parents were

provoking him to fight with her. Which also shows that she never wanted the

joint family.

15.The Petitioner states that, he has suffered unparalleled mental and physical

harassment under pressure at the Respondent’s hands, only to save this

marriage at any costs. The Petitioner states that, since the Respondent’s

parents were now her next door neighbours, she used to stay at their house

more than with him in the said Flat No. B-18 which is their matrimonial

home. The Petitioner states that, even during this lockdown he was the one

who used to do all the work at home like, “Sweeping, Cleaning with Pocha,

washing utensils, bringing groceries, Sanitizing the house, sometimes drying

wet clothes, cleaning Toilet and Bathroom, arranging utensils in the kitchen,
 cleaning kitchen platform after use, giving massage to his minor daughter,

bathing her, giving medicines to her, feeding her with milk at least waking

up 3-4 times every night and so on”. The Petitioner says that, despite all his

said efforts in the house Respondent was not satisfied and used to simply say

“I am not happy with you, I am not enjoying with you, you are not doing

anything for me”. he Petitioner states that, this non appreciative behaviour

totally frustrated him as he had to deal with his own office work, house

work, and the Respondent’s daily fights with him.

16.The Petitioner states that, this attitude that Respondent developed due to the

proximity of her parents, went beyond his tolerance level, and one day he

called his paw parents and requested them to talk to her father or else there

may be damage to his health. The Petitioner states that, thereafter his father

communicated with her father and it was decided to take the help of some

marriage counsellor to save this marriage.

17.The Petitioner states that, after Respondent rejected all the marriage

counsellors suggested by him, Respondent searched on the internet and

selected Ms. Brenda Fernandez from IC Colony and took her appointment

for marriage counselling. The Petitioner states that, the said Miss. Brenda

had originally suggested to Respondent that both of them should come

together for counselling, for which also Respondent refused for reasons best
 known to her and after hearing him at her house, she accompanied him to

their matrimonial home to talk to Respondent and she suggested that at the

end for conclusion she will have to talk to both the Respondent as well as

the Petitioner and to the Respondent’s parents also if necessary. The

Petitioner states that, after hearing both of them at length, the said Miss.

Brenda suggested that Respondent should stay away from her parent’s house

to improve her relation and grow her daughter with love and care like others.

The Petitioner states that, the said marriage counsellor realized that the core

issue was that her parents were too interfering in her married life and

therefore she suggested that they could stay at Malad which is near to the

Respondent’s office so that Respondent can manage her office work and also

can take care of the minor baby daughter with help of full time maid for

which Respondent and her parents refused to agree and insisted that their

daughter will stay besides them only even after making efforts to convince

them till 10:30 pm at night. Hereto annexed and marked as Exhibit “G” is

the copy of the said marriage counsellor’s report, along with details of

appointment taken by respondent, transaction details of fees paid by him and

respondent for the said marriage counselling.

18.The Petitioner states that, thereafter for no good reason at all the

Respondent’s father suddenly came to the Petitioner and began to issue

 various threats to him and told him that “I have the capacity to throw your

money on your face on and I will throw it on Monday, you just get lost from

here”. The Petitioner states that, such kind of rude and meaning less

behaviour was earlier too tolerated by him in his house but when these

threats was repeated in the presence of the said counsellor he was deeply

hurt. The Petitioner states that, thereafter since it was getting late, he decided

to drop said Ms. Brenda at her house and they left.

19.The Petitioner states that, when he returned to his home at 11:00 pm, he was

highly disturbed due to the Respondent’s father’s behaviour and he

requested Respondent to tell her father not to interfere in his married life

with her and that he had not married Respondent for their money. The

Petitioner states that, suddenly Respondent began to provoke him with her

taunts and also started recording this and began leaving the said house. The

Petitioner states that, thereafter Respondent suddenly without any grave

provocation or reason picked up their daughter and went outside the main

door where his CCTV could not capture Respondent and suddenly started

shouting “Bachao bachao, ye mujhe mar raha hai….pappa…papa…

mummi…mummi…”(Exact words).

20.The Petitioner states that, upon hearing the Respondent’s loud shouts,

her father suddenly rushed to the B-18 flat main door, where the
Petitioner also came to see why Respondent was suddenly shouting and

without any reason or provocation, her father kicked hard directly on

the private part of the Petitioner as if the said act was well planned and

rehearsed by him in advance with Respondent. The Petitioner states

that, after the said kick he had to bend to grasp his groin and taking

advantage of this, the Respondent’s father started throwing fist blows

on the Petitioner’s head rapidly and kept hitting him until the spectacles

worn by the Petitioner flew and went down on 4 th staircase. The

Petitioner states that, even while he had bent down to collect it, again

her father hit him on his head with force and due to which he was not

able to do anything, as this attack was surprise for him and could not

understand what had happened for the moment. The Petitioner states

that, for about 5 minutes he was gasping for air as he fell down on the

ground having no strength in his body and could barely breathe due to

the huge painful impact of her father kicking him mercilessly on his

private parts. The Petitioner states that, his head started spinning and

he almost became unconscious with excruciating pain and there was no

body to pick him up. The Petitioner states that, thereafter one elderly

neighbour living on the ground floor came up hearing his screams and

another neighbour from third floor came down to pacify her father
 saying “Daya, jane de mar mat”. The Petitioner states that, he somehow

managed to survive this attack and even when he was in immense pain

her father began to tell Respondent to immediately call police and give

false complaint against the Petitioner alleging that he had beaten the

Respondent.

21.The Petitioner states that, thereafter the Respondent’s father once again

came rushing inside his house at B-18 to beat him, however, this time the

residents of the said building stopped him. The Petitioner states that, even

when he was suffering in pain the Respondent called the local police who

began to make inquiry on the issue and Respondent began to compel them to

lodge a criminal complaint and FIR against the Petitioner, on which the said

police saw that in fact the Petitioner was severely injured and needed

medical help and did not listen to Respondent. The Petitioner states that,

Respondent and her parents lied to the said local police, when he complained

to them that he was mercilessly beaten by her father and the other residents

of the said building also refused to tell the truth and thus, he had to himself

approach the said police station and had to lodge a formal NC against

Respondent and her father Mr. Dayanand Naik and returned to his house B-

18 at late night around 1:00 Pm.

22.The Petitioner states that, the Respondent’s father is a habitual and a heavy

drunker and due to which he loses his temperament as being an alcoholic he

has no control over his brain on daily basis, which can be proved from the

WhatsApp communication between the Petitioner and the Respondent. This

proves that under the influence of alcohol Respondent’s father has beaten up

my client brutally on 26/09/2020, after which the Petitioner went to Borivali

police station to complaint about the said incident at mid night i.e. on

27/09/2020 at 00:30 am and the said complaint was taken by sub-inspector

Mr. Shahadev Dole and the complaint is true in all respect which can be

verified with the sub-inspector as well as CCTV footage at police station of

that date. Hereto annexed and marked as Exhibit “H” is the copy of the said

NC made in Borvali S.V. Road Police Station. Hereto annexed and marked

as Exhibit “I” is the copy of the medical and sonography report of

petitioner.

23.The Petitioner states that, Respondent slept with her own parents and on the

following day he had to call his own father to help him as he was trapped all

alone. The Petitioner states that, after his father came to his aid, he again

visited the said local police station and submitted to them a hand written

letter in which he apprehended danger to his life and informed them that he

had to move out of his own house to protect his life from Respondent and
 her father and therefore, he transferred his personal belongings and goods

from his said house and shifted to stay with his own parents at Ambernath.

The Petitioner states that, he also submitted the copy of the said NC and the

said letter to society secretary of the said building, which the Respondent

accepted but refused to give acknowledgement, stating that it was a personal

matter. The Petitioner states that, he had to therefore record a video in which

he narrated on how and why he had to shift from his own house and the said

shifting was also recorded in the CCTV installed in the said house. The

Petitioner states that, while leaving the said house, he also pasted a note on

the main door of the said house, wherein he had mentioned that he was

shifting only his own articles for his own safety and that the society may not

allow any sale of the said flat. The Petitioner states that, even while leaving

the said house, the Respondent’s mother was interested more in the gold

mangalsutra already given to the Respondent rather than saving her marriage

relationship and did not even bother to ask why Petitioner left the said

house.

24.The Petitioner states that, after that incident he had lost all hope in the future

of this marriage with Respondent and he had huge apprehension for the

safety of his life in her company. The Petitioner had no other option but to

stay separately from Respondent, however he is terribly missing his minor

 daughter Kum. Dhrisha and wants the Respondent to give him periodic

peaceful access to his said daughter until the entire issue of divorce with

Respondent is settled through the Hon’ble Court.

25.The Petitioner states that, the Respondent duly received the said legal notice

dated 12/10/2020 at her present residential address of her parents i.e. B-

17, Om SAtyavinayak CHS Ltd., and after which the Respondent

instructed her own advocate to send a somewhat vague reply dated

22/10/2020 to his said legal notice dated 12/10/2020. The Petitioner states

that, the Respondent in her said reply made a series of mindless allegations

as an afterthought and wanted to draw him in a bad image. Hereto annexed

and marked as Exhibit “J” is the legal notice dated 12/10/2020 sent to the

Respondent. Hereto annexed and marked as Exhibit “K” is the reply of the

respondent’s advocate dated 22/10/2022 to the said legal notice. The

Petitioner states that he promptly instructed his own advocate to send a

detailed Rejoinder dated 21/11/2020 to the said reply of the respondent dated

22/10/2020 and in which the Petitioner refused to accept all the false,

baseless and vague denials of Respondent of all the true allegations made by

him against Respondent in his said legal notice. Hereto annexed and marked

as Exhibit “L’’ is a copy of the said rejoinder dated 21/11/2020. The

Petitioner states that, the Respondent again received it at her present

 residential address of her parents i.e. B-17 Om SAtyavinayak CHS Ltd.,

and then through her advocate had sent a sur-rejoinder dated 27/11/2020 to

the Petitioner’s rejoinder dated 21/11/2020. Hereto annexed and marked as

Exhibit “M” is a copy of the said sur-rejoinder dated 27/11/2020.

26.The Petitioner also instructed his advocate to address a letter of objection

dated 15/10/2020 to request the said Om Satyavinayak CHS Ltd. to not issue

any NOC for the sale/ lease/ rent or otherwise for the said Flat No. B/18 in

their society to which the said society replied vide reply dated 25/01/2021

and assured that their society will follow the due process of law. Hereto

annexed and marked as Exhibit “N” is the copy of the said Petitioner’s

advocate letter dated 15/10/2020 to the Om Satyavinayak CHS.

27.The Petitioner states that, in his rejoinder he had mentioned that he was

ready to settle the matter by going for a mutual divorce, to which the

Respondent gave a sur-rejoinder in which she had expressed that she does

not want to end their marriage, rather wanted to continue their marriage by

resolving the matter amicably. The Petitioner states that, while their meeting

to resolve the matter amicably was still going on; suddenly the Respondent

filed a false and fabricated Domestic Violence case against the Petitioner

and his family, which showed that she was not interested in resolving her

marriage with the Petitioner. Hereto annexed and marked as Exhibit “O” is
 a copy of the said false and fabricated Domestic Violence case dated

24/11/2020.

28.The Petitioner states that he instructed his advocate to write and send a

rejoinder to the said reply vide rejoinder dated 21/11/2020, and the

respondent sent her sur-rejoinder dated 27/11/2020 in which she has

instructed her advocate in para-12 that she is ready and willing to settle the

issue amicably out of Court only for reuniting and not for divorce and that if

the Petitioner is intending to reside with her in that case the baby will get

love and affection of father. The Petitioner states that after sending the said

sur-rejoinder till today the original respondent or her said advocate have not

given any clue to her readiness to live together and instead of waiting for

amicable discussion they simply filed the false and fabricated DV Act Case

No. 222/ DV/ 2020 in the 26th MM Court Borivali Mumbai on 24/11/2020

i.e. even before sending the said Sur-rejoinder on 27/11/2020. The

Petitioner states that the said Sur-rejoinder is therefore just a facade to

mislead this Hon’ble Court to believe the real intentions of the respondent.

In view of the apparent self-rejection of her, own contention by filing the

said DV Act case the said rejoinder of the applicant no.1 remains

undisturbed and deemed to have been admitted by the original respondent.

Hereto annexed and marked as Exhibit “P” is a copy of the said rejoinder
 dated 21/11/2020 from applicants advocate. Hereto annexed and marked as

Exhibit “Q” is a copy of the said Sur-rejoinder dated 27/11/2020 from the

complainants advocate.

29.The Petitioner state that they appeared in the said DV case matter in the said

26th MM Court accordingly and the matter was sent to joint marriage

counseling / mediation on 09th February, 2021 by the said Hon’ble Court as

per the choice of the parties of both sides and the said matter was pending

counseling and the next date for mediation was 09 th March, 2021 and the

regular Court date was 30/03/2021.

30.The Petitioner state that in the mean-time on 18/02/2021 they received a

letter dated 17/02/20201 vide which they were shocked to receive a call

letter under section 41 (A) of CrPC calling upon them to appear within a

week before the concerned lady officer PI Gayatri Bedse since the original

respondent has filed a criminal case and FIR no. 1158 / 2020 under sections

498-A, 323, 506, 504, 34 of the IPC against them with the Borivali Police

station. Hereto annexed and marked as Exhibit “R” is a copy of the said

call letter notice U/s 41 A of the CrPC dated 17/02/2021 to the applicant

from the Borivali Police station.

31.The Petitioner state that the said notice was not accompanied with a copy of

the said FIR and they were not aware of the exact nature of the said criminal
 complaint and it is clear that the original respondent has been misguided to

file the said false and fabricated case against them by her ill-wishers. The

Petitioner state that the father of the original respondent is politically strong

and has strong contacts with anti-social elements and he often uses his

political influence to put pressure on the local police to agree to his

commands and they apprehend that in this case too, the said father of the

respondent has put undue pressure on the police machinery to act as per his

whims.

32.The Petitioner state that they are totally innocent and have not committed

any illegal act as alleged in the said FIR No. 1158/2020 by the said

respondent and clearly the filing of this criminal complaint is out of personal

vendetta since the respondent wife had nothing to respond to the said

rejoinder dated 21/11/2020 sent by the advocate of the applicant No.1 and

even before she could send her Sur-rejoinder on 27/11/2020, the original

respondent had already filed her fake and fabricated DV Act, matter stated

above, on 24/11/2020.

33.The Petitioner state that they have a very good name and reputation in the

society and clearly the respondent has hidden the fact that she and her own

parents are sadists and are mentally unfit to live in a peaceful society and are

always in search for trouble to create a rift in the lives of the Petitioner and
 the respondent. This fact is proved with the certificate issued by a doctor and

a live witness to the mental illness of the respondent and her parents and the

said Psychiatrist Dr. Mrs. Brenda Fernandes who was approached by the

original respondent herself has issued a detailed letter dated 02/10/2020

which is a certificate of the innocence of the applicant no.1 and his parents

and the said certificate and its contents be read carefully before any decision

is taken by this Hon’ble Court. Hereto annexed and marked as Exhibit “S’’

is a copy of the said certificate / letter dated 02/10/2020 by the said Doctor

Mrs. Brenda Fernandes.

34.The Petitioner state that interestingly the original complaint nor the

Petitioner have filed any petition in the Hon’ble Family Court to demand

divorce or restitution of conjugal rights and the original respondent has

herself filed her said fake DV Act case as stated above on 24/11/2020 and in

which she has herself agreed to marriage counseling / mediation on

09/02/2021 and before waiting for an opportunity to settle the matter and to

possibly stay together with the Petitioner, the original respondent directed

the concerned police station to send the said Notice U/s 41A of the CrPC

without thinking about the repercussions on the mind of her own husband or

in-laws.
35.The Petitioner therefore say that until further investigation into the

complaint filed by the Respondent against them U/s. 498 (A), 323, 506, 504,

34 of the IPC and in view of the threats of illegal arrest issued by the

original respondent to misuse women power with the Borivali Police Station

they apprehend that they may be arrested by the officer attached to the

aforesaid Police Station, and he filed his ABA No. 298/2021 on 24.02.2021

in the Hon’ble Dindoshi Sessions Court, Mumbai to pray that the Hon’ble

Court be pleased to grant Anticipatory Bail to the petitioner and his parents,

in the event of their arrest by the concerned police station.

36.The Petitioner states that at present the respondent and his said minor

daughter Kumari Dhrisha Hrishikesh Patil, age about 2 years are currently

residing in the flat no. B-17, Om Satyavinayak Chs. Ltd., Behind Suvarna

Hospital, Kasturpark, Borivali West, Mumbai – 400092., which is a flat

owned by the parents of the respondent. The Petitioner states that throughout

his marital life together with the respondent and his said daughter, he had

constantly endeavoured to give the best that he can afford to them and

despite his efforts over the years, the respondent has sun a very sorry and

insensitive fake story to create a strong anti-character narrative to demean

and to show him in bad light in the eyes of the Court just to grab the flat

which shall go under redevelopment very soon.

37.The Petitioner states that he has filed a detailed Written Statement to deny

and refute and counter all false and baseless allegations made against him by

the respondent in her said fake DV case which is still pending today. The

Petitioner craves leave to refer and rely upon the various averments made in

the said written statement as if the same are set out herein and specifically

traversed.

38.The Petitioner states that despite obtaining his said ABA Order on

07/05/2021, he was suddenly arrested on 01/04/2022 from his office

premises at Dadar by the IO attached to the Borivali Police station in the

said C.R. No. 1158 of 2020 in a criminal complaint made by his wife Mrs.

Divya Patil vide her criminal complaint under section 498-A, 323, 504 and

34 of IPC and was confined in the Taloja Prison for 28 days.

39.The Petitioner states that after his ABA No. 298/2021 was allowed by H.H.J.

Shri. L.S. Chavan (C.R. No. 10) of the Dindoshi Sessions Court, Goregaon,

Mumbai on 07/05/2021 due to the then situation of Covid-19 Pandemic he

and his father and mother could not immediately attend the concerned

Borivali Police Station as per the said directions in the said Order dated

07/05/2021 since Mr. Shantaram Patil, i.e. the father of the present Petitioner

was required to be treated for Corona and the other Petitioner were required

to be quarantined and were advised not to move around, they had to remain
in their home. It is pertinent to note that the distance of travel from the

residence of the Petitioner at Ambernath East, Thane to Borivali West,

Mumbai is huge and it was impossible for the Petitioner and other accused

persons to travel the said distance without any risk to their health and hence

they began to regularly attend the said Police station from August, 2021 to

December, 2021. In the mean-time it appears that the respondent i.e. the

wife of the Petitioner filed her M.A. No. 212 of 2021 on 29/09/2021 and the

said M.A. was on board of this Hon’ble Court on 1/10/2021 when this

Hon’ble Court passed directions to the said applicant wife to issue notice to

the Respondent and the matter was adjourned for hearing to 16/10/2021.

Hereto annexed and marked as Exhibit “T” is the screen print of the said

directions from the archives of ecourtservices website for the date 1/10/2021

in M.A. No. 212 of 2021. It is also pertinent to note that in the said

application the present Petitioner and his both parents are inducted as

Respondents alongwith the State of Maharashtra and it was incumbent upon

the applicant wife to serve a copy of her said application upon the Petitioner

and his parents as per the said specific directions of this Hon’ble Court.

However, from 16/10/2021 to 20/12/2021 to the date of passing of the final

order dated 14/03/2022, partly allowing the said application, if the Roznama

of the said M.A. no. 212 of 2021 is seen and perused carefully, it is clear that
 the present Petitioner persons i.e. respondent nos. 1, 2 and 3 were never

served with the notice about this application for cancellation of their ABA

dated 07/05/2021 by the applicant wife and only the State of Maharashtra,

i.e. the Respondent no.4 were served and issued notice to appear. It is

therefore submitted that at the outset the applicant wife did not follow the

directions of this Hon’ble Court to issue notice to all respondents and thus

she has misled the said Hon’ble Sessions Court to believe her that the said

M.A. no. 212 of 2021 was duly served upon all respondents. Hereto annexed

and marked as Exhibit “U” is the Order dated 14/03/2022, in M.A. No. 212

of 2021 vide which the ABA granted to the Petitioner no.1 i.e. Mr.

Hrishikesh Shantaram Patil was cancelled by the said Hon’ble Sessions

Court on the grounds of non -attendance of the said Petitioner at the

concerned police station.

40.It is respectfully submitted that the Petitioner and his both parents as accused

persons in the said CR no. 1158 of 2020 had earlier approached this Hon’ble

Court in the month of December, 2021 with their application for Exemption

from periodic attendance to the said Police Station, however the said

application was sought to be moved across the Bar and was requested to be

filed as a regular Misc. Application and accordingly, he and the other

Petitioner on 24/02/2022, had filed Misc. Criminal Application no. 65/ 2022
 before this Hon’ble Dindoshi Sessions Court to alter / modify the said Order

dated 07/05/2021 and to exempt and stop the periodic personal attendance of

the Petitioner and despite the said application being pending before the same

Court, his said ABA was cancelled at the behest of the false claims of the

respondent. The Petitioner states that he and his parents had infact attended

the said Police station and have the attendance book marking their

attendance till December, 2021. Hereto annexed and marked as Exhibit “U”

(Colly) are the copies of the respective periodic attendance record books of

all three Petitioner persons, which show regular attendance.

41.It is respectfully submitted that as stated above on 01/04/2022 the concerned

IO and other officers attached to the Borivali Police station suddenly barged

into his work place i.e. his office at Dadar and informed him that they want

to arrest him since his aforesaid ABA was cancelled on 14/03/2022. The

Petitioner informed the officers that he was totally unaware about the said

Order dated 14/03/2022 and that infact he was never issued notice about the

said M.A. no. 212 of 2021 filed by his wife for cancellation of his said ABA

and that if he had known, he would have brought forth the aforesaid periodic

attendance record book of all Petitioner persons to show that he had

followed the directions of this Hon’ble Court to the best of his ability. The

Petitioner also informed the said officers that he had just returned to his
office after appearing in his own M.A. No. 65 of 2022 which was pending in

Dindoshi Sessions Court no.10 and that the said application was for seeking

modification of original Order of ABA for Exemption of Petitioner persons

from regular periodic attendance and that all the investigations were already

done. The Petitioner states that despite this the concerned officers compelled

him to accompany them to Borivali Police station on the telephonic

instructions of Ms. Gayatri Bedse, I/O attached to Borivali Police Station

and he was taken into their custody at around 3:00 pm on 01/04/2022 from

his said PNB bank office at Dadar like a common criminal and was brought

to Borivali Police station and was wrongly shown as arrested at 20:15 hours,

when he was arrested in the afternoon. Respondent and her father Mr.

Dayanad Naik were already present at the Borivali Police station when he

was arrested and brought to the police station which can be verified from the

CCTV footage of the Borivali police station for the date 01.04.2022. ABA

cancellation order was given by Hon’ Dindoshi Court on 14.03.2022,

petitioner was arrested deliberately on 01.04.2022 considering the Holidays

on 02.04.2022 and 03.04.2022 He was requesting I/O Ms. Gayatri Bedse to

produce him before the Judge of Borivali Court on 01.04.2022, the same was

denied by Ms. Gayatri Bedse stating the reason that the Respondent and her

father are not allowing us to perform our duty and they are arguing with our
 seniors. Hereto annexed and marked as Exhibit “V” is an extract from the

Register of his office, showing the time of Petitioner leaving his said office

at Dadar on 01/04/2022.

42.The Petitioner states that after his said illegal arrest, he was first produced

before the Holiday Court at 43rd MM Court of Shri. Kamat Borivali, and

instead of inquiring if his said arrest was legally valid or necessary or done

after following all the parameters in such arrest as stipulated in the directions

of the Hon’ble Supreme Court in Arnesh Kumar V/s State of Bihar matter,

he was simply not heard and the concerned MM Court allowed the remand

application of the Borivali Police and IO Mrs. Gayatri Bedse and sent him to

Police Custody for two days. The Petitioner states that thereafter when he

was produced before the regular 26th MM Court of Mrs. Vrushali Kore and

once again without bothering to adhere to the directions of the aforesaid

parameters in such arrest as stipulated in the directions of the Hon’ble

Supreme Court in Arnesh Kumar V/s State of Bihar matter the said 26 th MM

Court once again allowed the remand application of the said IO and his PC

was further extended till 05/04/2022. Upon hearing the said chain of events

for his arrest on 05/04/2022 the said Mrs. Vrushali Kore, Ld. 26 th MM Court

granted him JC (Judicial Custody) till 19/04/2022. Hereto annexed and

marked as Exhibit “W” is the copy of the said Order dated 05/04/2022 vide
 which he was granted JC till 19/04/2022. The Petitioner states that upon

pronouncement of the said Order, his advocate presented his Bail application

on the same day i.e. on 05/04/2022 with relevant information and prayer to

grant bail immediately, upon which the Ld. MM Court directed the

concerned IO to give say on the said Bail application. Hereto annexed and

marked as Exhibit “X” is a copy of the said Bail Application of Petitioner

dated 05/04/2022 numbered as 764/BA/ 2022.

43.The Petitioner states that upon hearing the both sides and the Ld. App the

said Ld. 26th MM Court did not pass any Order on 05/04/2022 and kept the

said Bail application for passing Orders on 08/04/2022. The Petitioner states

that thereafter on 08/04/2022 Order rejecting the said Bail application dated

05/04/2022 was passed by the said Ld. 26 th MM Court and in the said Order

the said Ld. MM Court did not consider the fact that the Petitioner had

relevant proof of his periodic attendance at the said Borivali Police station

till December, 2021 and that thereafter without issuing any notice to him, the

said ABA granted to him was cancelled by the applicant wife, by

misinforming this Hon’ble Court and that there was no urgent need to

investigate a matter under section 498-A of IPC in which FIR was filed in

the year 2020 and that after lapse of two years, the Petitioner had attended

the said police station for aiding all investigation and that just because his
 ABA was cancelled as stated above, there was no need for his such brutal

custodial interrogation or arrest by the said IO of Borivali Police station, and

that his Nationalized Bank job as a senior manager was at stake and that if

he is not released on bail, he may loose his job permanently. The Petitioner

states that his advocate had also presented case laws and Judgement in case

of Arnesh Kumar v/s State of Bihar, which is a leading example against

unwanted arrests in such cases under section 498-A IPC. Hereto annexed

and marked as Exhibit “Y” is a copy of the said Order dated 08/04/2022

passed by the Ld. 26th MM Court rejecting his Bail application and the said

Order contains the copy of the fake and fabricated FIR dated 02/12/2020

vide C.R. No. 1158 of 2020.

44.The Petitioner states that though in the Order dated 14 th March, 2022, this

Hon’ble Court had placed no relevance on the alleged report of the marriage

counselor which is alleged to be forged or manipulated by the Petitioner by

the respondent, in the Order dated 08/04/2022, heavy relevance is placed by

the said allegation of the respondent and infact there was no substance in the

said allegation since this Hon’ble Court had not cancelled the said ABA of

the Petitioner based on these allegations at all.

45.The Petitioner states that entire dispute is with regards to a joint flat which

was purchased by the Petitioner herein and his wife and which matrimonial
the Petitioner had himself left being beaten up by his father-in-law who

resides in the very next adjoining flat and for which Petitioner had filed his

own criminal complaint on 29.08.2020 against his father for life threatening

hard kick on his private parts by his father-in-law causing him excruciating

pain that may have caused his death and there are several witnesses to this

attach on him, since he was kept lying in the building corridor staircase for a

long time by his said wife and her father. Till today no FIR had been filed

against his said father-in-law by the I/O attached to the said Borivali Police

station, for the reasons best known to her. Petitioner had filed RTI on

11.10.2021 under RTI act, 2005 to know the status of complaint filed by him

on 29.08.2021 to which I/O Ms. Gayatri Bedse had replied vide letter dated

03.11.2021 informing that petitioner shall attend Borivali police station

within 7 days to give the statement with all the evidences. He had attended

the Borivali police station immediately on 14.11.2021 after receipt of this

letter on 13.11.2021. However, his presence was not acknowledged by the

said police station on 14.11.2021. On 15.11.2021, he had written letter to I/O

Ms. Gayatri Bedse duly received by her to inform her to call him for

recording his statement as per her convenience. However, the said complaint

was closed by Ms. Gayatri Bedse without doing any investigation. Hereto

annexed and marked as Exhibit “Z’’ is a copy of the detailed written

 complaint filed by the petitioner against his father-in-law and the respondent

with the said Borivali Police station.

46.It is also submitted that it is this flat No. B-18 which the Petitioner herein

himself vacated and the respondent wife claimed that she is residing in the

said flat with his minor daughter and since the Petitioner on the grounds of

parity of co-borrowers of housing loan, requested his employees to deduct

equal EMI from the salary account of the respondent wife, she decided to

take revenge upon him and caused him to be arrested by the concerned

Borivali Police station to teach him a lesson out of grudge carried by her.

47.Hence the Petitioner states that his sudden arrest in the FIR of the year 2020

despite his regular attendance by mis-informing this Hon’ble Court is a

concerted attempt by the respondent wife to put him behind bars at all costs.

The Petitioner has all relevant proof of the aforesaid facts and can be

produced as and when needed. The Petitioner states that he at the time of his

said Bail application in the Hon’ble Session Court he was lodged in the

Taloja Prison and he suffered immense hardships for about 28 days of

wrongful imprisonment, suffering untold miseries and hardships even when

he was totally innocent and his Judicial custody was not at all necessary or

legal for any purpose as he had good credentials.

48.The Petitioner states that after a long delay and wait finally vide Order dated

25th April, 2022 his Bail application No. 407 of 2022 was allowed and he

was released from the prison on 27.04.2022 i.e. after 28 days of

imprisonment due to the said nonsense of the respondent and due to which

he almost lost his job with the PNB Bank which is a Government of India

undertaking. However, he was suspended from his job at Punjab National

Bank for 28 days when he was behind the bars. As such, he remained short

of a service by 28 days and was debarred from the promotion from Scale 3

to Scale 4 i.e. Senior Manager to Chief Manager. Also, due to fake and

fabricated criminal case filed under dowry act just to grab the property

purchased after marriage his next all the promotions shall be referred under

the sealed cover by the said Punjab National Bank which is a big loss to the

Petitioner in his professional carrier. Hereto annexed and marked as Exhibit

“A1’’ is the said Bail order dated 25/04/2022, letter of suspension and the

letter of reinstatement of his job issued by his employers.

49. The petitioner states that his sister’s name i.e. Mrs. Ashwini Aher was also

been involved just to harass her even when she was not staying in India

since 2015. Her name was deliberately involved in the Fake and Fabricated

DV case as well as FIR dated ______. Even during the investigation of

Borivali Police station nothing has been found against her and her name has
 been removed from the case by the Investigation officer. Due to deliberate

involvement of her name in the Fake and Fabricated cases Mrs. Ashwini

Aher had to face lot of issues in her personal as well as professional life.

Hereto annexed and marked as Exhibit “B1’’ is the said copy of the report

from the IO attached to Borivali Police Station.

50. We would like to draw attention of Hon’ble Court towards the legal notice

dated 19/07/2021 sent by Mr. Dayanand Naik, father of Mrs. Divya through

his advocate Mr. H. M. Shetty wherein the applicant’s father has clearly

threatened and pressurised Dr. Brenda Fernandez to withdraw her original

marriage counselling report. Also, she was threatened and pressurised by

Ms. Gayatri Bedse, the IO attached to the Borivali Police station multiple

times to give statements against accused Mr. Hrishikesh Patil. We say that

after being so threatened, said Dr. Brenda, suddenly changed her stand and

her statement was given immediately after receipt of the said notice by Dr.

Brenda Fernandez. In this way, she has also tried to manipulate the

important evidence in the matter so that the cruelty done by her to the entire

family of the Petitioner should not come in front of the Hon’ble Court.

Hereto annexed and marked as Exhibit “ ” is the copy of the legal notice

dated 19/07/2021 given by Mr. Dayanand Naik to Dr. Branda Fernandez.

Hereto annexed and marked as Exhibit “ ” is the copy of the statement

 given by Dr. Brenda Fernandez dated 22/12/2021 to the Borivali Police

Station.

51. On ____, accused Mrs. Divya Patil has again filed an application in the

Hon’ble Mumbai Metropolitan Magistrate Court, Borivali that parents of

Petitioner i.e. Mr. Shantaram Patil aged 62 and Mrs. Pratibha Patil aged 55

are not attending the Court in her fake and fabricated DV case file against

them just to harass them repeatedly even when the application filed by

Petitioner for permanent exemption of attendance of his parents is pending

before the Hon’ble Court is pending for disposal. These are just the tactics

being utilized to harass the senior citizens by her to extort maximum money

and grab the entire flat B-18 purchased after the marriage which has gone

under redevelopment and to make lot of money with the help of her own

parents who were having an evil eye on the said flat since beginning.

Exhibit “C1’’ is the said copy of the said application made by Mrs. Divya

Patil on ______ in the hon’ble Metropolitan Magistrate Court.

52.Mrs. Divya has also maligned the image of Mr. Hrishikesh in the Society.

Mr. Hrishikesh is making correspondence with the Chairman and secretary

of Om Satyavinayak CHS Ltd. legally through his advocate for obtaining the

information regarding redevelopment of the Flat jointly purchased after the

marriage. However, the society has never given any proper reply to his
correspondence. Rather the society has always commented upon the

personal life of Mr. Hrishikesh Patil humiliating him for no reasons without

giving the proper desired information to the joint owner of the said flat. The

petitioner states that he has sent legal notice to the society on ____ just to

seek information regarding redevelopment of the Flat mortgaged to Punjab

National Bank, BO: Pnb House, for which he is continuously paying huge

EMI since he beginning to which society again had given vague reply

through their advocate Mr. _______ dated wherein society again used

humiliating language for reasons best known to them rather than providing

the desired information. Then, Petitioner had filed complaint with the Dy.

Registrar office on _____. Dy. Registrar office has given the directions to

the society to provide the desired information to Mr. Hrishikesh Patil. Even

then the society has not provided vital information regarding redevelopment

of the said flat even after Two reminders. Even after the clear directions

from the office of Dy. Registrar office to share the information regarding the

redevelopment of the said flat again society vide their reply dated ____ has

avoided to give the proper information to the joint owner of the flat. We

have attached the multiple communications made with the said society

wherein society has always commented upon the personal life of the

petitioner. It is clearly evident from the communications that the said society
 is being managed by Mrs. Divya just to grab the entire flat B-18 jointly

purchased by taking huge amount of loan by the petitioner from the bank for

which petitioner is paying havey EMI’s from the salary for no reasons.

Hereto marked as ___

53. Petitioner states that Mrs. Divya Patil and he is working in the same

organization i.e. Punjab National Bank. Mrs. Divya Patil has defamed him in

the said organization multiple times resulting which he has to face lot of

issues while working in the said organization. When the Petitioner was in

the custody of the Borivali Police Station, on 06/04/2022, Mrs. Divya file

application blatantly lying that both of them are working in same

organization and being senior to him he is harassing her at workplace.

However, there is no connection of Mr. Hrishikesh with Mrs, Divya what so

ever as the institute is same but the premises was different. As he was

relieved from the Taloja prison after 28 days, Mr. Hrishikesh resumed his

office as his suspension was revoked by the authorities as per Bank

guidelines. He had the submitted the application to Human Resource

Department under CC to Investigation Officer Ms. Gayatri Bedse at Borivali

Police Station and other agencies that the statements made by her are

irrelevant and defaming him openly outside the bank. The authorities had

duly acknowledged the letter on _____ and he was informed that the
appropriate action shall be taken on the said application. Till date nothing

has been done by the bank in connection with the representation given by

Mr. Hrishikesh Patil. He had already informed the authorities that if the

necessary action is not taken by the authorities the same shall be repeated by

her in future as the matter is still going on in multiple Courts. In the

meantime, on _____ Mr, Hrishikesh was transferred from CO: Mumbai

Western region to CO: Thane and then to Ulhasnagar 4 for further place of

posting. Since then he is working at the said branch as a Senior Manager and

Mrs. Divya is working as Clerk at BO: Borivali. Both of them are working at

different offices under different Circle altogether. There is no connection as

such between then officially as well as unofficially. Still, Mrs. Divya has

filed an income affidavit on ______, in the metropolitan magistrate Court

wherein on Page No. ______ has mentioned that Mr. Hrishikesh is still

harassing her at her workplace and due to which she is searching for another

government job and giving exams for the same and has demanded money

against the same. Mrs. Divya is just using these tactics to extort maximum

money from Mr. Hrishikesh and harassing him publicly for the money

misusing the Law and taking the advantage being the lady. Hereto annexed

is the copy of ______

54.Mrs. Divya had also made false complaints in written to Head Office of

Punjab National Bank at Delhi making false allegations on him just to

malign his image at his office. Even the authorities have given her caution

notice for her behavior and creating nuisance in Punjab National Bank. Still,

she is not refraining from her behavior as there is no fear of Law remained

taking the advantage being woman. Hereto annexed is the Copy of the

_________

55. Based on the above matter, the petitioner had filed complaint with a

complaint with police authorities that Mrs. Divya Patil is continuously

harassing Mr. Hrishikesh Patil by making repeated false allegations on him

at his workplace and also harassing his old age parents who are senior

citizens maligning their image publicly just to extort money from the

husband and old age in laws. Police authorities at Vitthalwadi Police stations

have sent multiple communications to Mrs. Divya as per procedure to be

present in the Police Station to file her say in the said matter. When

Petitioner inquired about the status of the said matter with the Investigating

Officer at Vitthalwadi Police Station, the officer has given in writing that

Mrs. Divya is not co-operating in the investigation and there is no fear in her

mind for the Law. Exh “ ’’ is the copy of the said complaint and other

documents related to the said case.

56.In view of the above, Petitioner is filing the petition with this Hon’ble Court

in the interest of the Justice against Mrs. Divya Patil, Mr. Dayanand Naik,

Mrs. Dipti Naik under section _______.

57.

58.

59.