IN THE COURT OF LEARNED ADDITIONAL PRINCIPAL JUDGE FAMILY COURT

JAMMU

IN THE MATTER OF:-

SHOBHA DEVI V/S RAJESH SINGH

Petitioner Respondent

STATEMENT BY WAY OF AFFIDAVIT

I Shobha Devi age 37years W/O Rajesh Singh d/o Shamsher singh R/O
Nowgran , Tehsil Bishnah,Distric Jammu At present Ramnagar Jandror
Udampur do hereby solemnly affirm and declare as under :-
1. The Deponent is the petitioner in this case
2. The Deponent was legally married with Respondent Rajesh Singh s/o late
Pretam Sing R/O Nowgran , Tehsil Bishnah,Distric Jammu in accordance
with Hindu rights and customs on 17/04/2009 at the residence of
petitioner, a male child Surya Partap singh was borne on 21/03/2010 who
is now 13 Years old is residing and looked after by Deponent. The
Respondent was rude towards deponent due to his habit of consuming
liquor and in other immoral activities from the beginning of marriage and to
meet his debts he demanded dowry from the deponents father, and failure
to meet demands of respondent the deponent was beaten constantly and
threatening to kill the deponent and her son Surya Partap Singh by
throwing petrol on both of them. The respondent has never paid any
amount for household expenses to the petitioner and his son. Whenever
deponent demanded any money to meet the household expenses the
respondent beat miserably resulting in injuries to the petitioner and again
and again threatening to burn deponent and as well as his son Surya
Prartap Singh. In daily routine whenever respondent come to house as a
drunker the deponent along with her son Surya Partap Singh is compelled
to take shelter in her sister house which is adjacent to matrimonial house
due to the fear of trashing and threatening of killing deponent and her son
as previously the respondent had been given threshing to deponent
 number of times. Even relatives and Lumberdar of the village tried to
persuade the respondent to amend the way of his attitude towards
deponent and his son Surya Partap Singh before them he agreed to mend
his attitude but all efforts to change the respondent towards deponent and
son were in vain. To bring respondent in a right path the father of deponent
Shamsher Singh renovated matrimonial kacha house by way of changing
the house in a concrete one by barrowing the amount of 400000/- on loan
from relatives and friends even though the respondent did not mend his
attitude. The deponent and her minor son Surya Partap Singh is maintained
on the mercy of parents even though being old and in utter state of
poverty. Deponent complained the Women cell, on 09-12-2019 and SHO
police station Bishnah on 11-12-2019 but no action initiated by authorities.
The respondent is earning Rs.15000/ per month and is spoiling whole
earnings on liquor and other bad habits and not maintain deponent and her
son, the deponent is a job less lady her son Surya Partap Singh is school
going boy both are unable to maintain and despite requests made by
deponent to respondent to maintaining the respondent has willfully
neglected the request of deponent without any cause or excuse in contrary
respondent beat deponent.
3. That during the proceedings of this case in honable court the respondent
burnt the house and ran away thinking that deponent and her son will be
burnt, but by the grace of God deponent and her son Surya Partap Singh
were not in the house as they were in deponents’ sister house because
deponent along with her son used to go sisters house prior to the coming
of respondent due to fear of beating and threat of killing. After the house
was burnt the deponent along with her son went to the parent’s house and
are residing there till now even though the parents of deponent are living
hand to mouth. The deponent has prayed before the honable court for a
monthly allowance fee for maintaining of deponent and her minor son
Surya Partap Singh at the rate of Rs.10000 per month or any rate which
your may deem proper from the date of petition.

Verification Deponant
 IN THE COURT OF LEARNED ADDITIONAL PRINCIPAL JUDGE FAMILY COURT

JAMMU

IN THE MATTER OF:-

SHOBHA DEVI V/S RAJESH SINGH

Petitioner Respondent

STATEMENT BY WAY OF AFFIDAVIT

I Kanta Devi aged 57 years w/o Sansar Singh r/o Ramnagar Jandror district
Udampur do hereby solemnly affirm and declare as under:-

1. That deponent is the mother of Petitioner Shobha Devi and she was legally
Married with Rajash singh R/o village Nowgran Tehsil Bisnah District Jammu
on 17.04.2009 with all Hindu rites and out of their wedlock a son Surya
singh was born on 21/03/2010.That after the few months of marriage the
respondent started cruel behavior with the petitioner in respect of beating
trashing causing severe injuries to the petitioner regularly. Respondent
demanded dowry from time to time and on refusing respondent
threatened to kill petitioner by throwing petrol and burn them alive. One
day the respondent burned the house luckily petitioner as well her son
have a great escape and after that episode the petitioner came back to her
matrimonial house and now dependents on her parents.

2. That relatives and village officials tried to advice respondent to keep away
with habit of liquor and maintain cordial relation with petitioner and her son
Surya Partap Singh but respondent’s behavior did not changed his behavior and
again beat the petitioner miserably causing injuries to the petitioner.

3. That the respondent is a habitual drunker of liquor and wasting all his earnings
on liquor and other immoral activities and has not maintained petitioner as well
as her son. The petitioner was always helped by the father Sansar Singh and by
deponent, though deponent and her husband are meeting daily expenses of
petitioner and her son, but petitioner’s father and I are from hand to mouth these
days. Now petitioner is wholly solely dependent on parents, the respondent has
not paid any penny towards the maintenance to the petitioner and her son
though the respondent is earning more than Rs 15000 per month.

4. That several times petitioner approached to women cell and police but
respondent did not change his attitude.

5. That the father of petitioner also tried to change the rude behavior by way of
renewing the kacha house to a concrete house taking loan of Rs 400000 from
friends and relatives even though respondent did not change his attitude of
beating.

6.That the petitioner always threatened the petitioner to kill her and her son, one
day respondent burnt the house with the intention that petitioner and his son
have been burnt the respondent burnt the house and ran away thinking that
deponent and her son will be burnt, but by the grace of God deponent and her
son Surya Partap Singh were not in the house as they were in deponents’ sister
house because deponent along with her son used to go sisters house prior to the
coming of respondent due to fear of beating and threat of killing. After the house
was burnt the deponents along with her son went to the parent’s house and are
residing there till date.

Verification Deponent

IN THE COURT OF LEARNED ADDITIONAL PRINCIPAL JUDGE FAMILY COURT

 JAMMU

SHOBHA DEVI V/S RAJESH SINGH

Petitioner Respondent

IN THE MATTER OF:-

STATEMENT IN FORM OF AFFIDAVIT

I Sansar Singh aged 62 years s/o Jammeet Singh r/o Chowki Jandror district
Udampur Tehsil Ramnagar do hereby solemnly affirm and declare as under:-

1. That Petitioner is the daughter of the deponent and was lawfully married
with respondent Rajash Singh r/o Nowgram Thesil Bishnah District Jammu
on 17-04-2009accordingly to tradition Hindu Vedic rites and a male child
was born on21-03-2010 out of this wed lock.
2. That the Respondent start demanding dowry since the beginning of
marriage and for not accepting his demand respondent start ill behaving
by way of beating resulting in injuries to the petitioner.
3. That Respondent earns 15000 per month but is a habitual of consuming
liquor all the time and waste his all earning on liquor and other immoral
activities and used to give daily beating miserably to petitioner whenever
he comes to home.
4. That Respondent never pays a single penny to look after petitioner and his
son all needy expenses were bearded by the deponent who is already living
hand to mouth and have to bear the expenses of daughter and her son.
5. That relatives,friends and even village officials advice Respondent to change
his behavior so many times but he did not care for them and did not change
his attitude. Petitioner approached before Women cell and police, even
then Respondent continued threatening and to burn the respondent and
his son by way of throwing petrol on them.
6. The Deponent tried to pacify the Respondent by way of renewing his kacha
house to a concrete house by taking loan of Rs 400000/ from relatives and
friends.
7. One day he actually burnt the house and ran away thinking that Petitioner
and his son will have been burnt. But by the grace of God both were not in
the house as they were in petitioner’s sister’s house because petitioner
along with her son used to go sisters house prior to the coming of
Respondent in the house. After the house was burnt the deponent along
with her son came to deponents’ house and is residing with the deponent
till date. That it has become very hard to bear the expenses of Petitioner
and his son by the deponent because the source of income is less than
expenditure.
Verification Deponent