In,

The Court of Principal Judge,

Family Court Purnea.

Ref :- Matrimonial Case No. /2023

Juli Sah ---------------------------------Petitioner
Versus
Laxman Sah-----------------------------Respondent

Statement of address filed on behalf of the petitioner

Juli Sah age about 38 Years W/O Laxman Sah D/O Anant Prasad Sah at
Naya Tola PS Nagar District- Katihar Presently Sharda Nagar P.S –
K.Hat (Sahayak) District Purnea Aadhar no- 883534537135 Mob no.
9835646125
Verification
I Juli Sah the petitioner do hereby declare that the address given above is
true to my knowledge and belief.
Verified and signed this the ____ day of _____
2023 within the civil court compound Purnea.
Identified by

Advocate Signature of the petitioner

In
The Court of Learned Principal Judge
Family Court Purnea
Ref: Matrimonial Case no- /2023
Juli Sah age about 38 Years W/O
Laxman Sah D/O Anant Prasad Sah at
Naya Tola PS Nagar District- Katihar
Presently Sharda Nagar P.S – K.Hat
(Sahayak) District Purnea Aadhar no-
883534537135 Mob no. 9835646125
-------------------------------– Petitioner
Versus
Laxman Sah age about 40 years S/O Late
Shital Sah at Naya Tola near Kali Mandir
P.S – Nagar District- Katihar Mobile no-
9431886828
----------------------------– Respondent
Humble Petition Filed u/sec 10 of Hindu
Marriage Act 1955 as amended in 1976
for Judicial Separation on behalf of the
Petitioner named above.
 Most Respectfully sheweth :-
1. That the petitioner is the legally wedded to the respondent on
06/02/2006 according to Hindu rites and customs in the presence of
several relatives, Pandit and Hajjam at the petitioner’s maiyka Purnea.
2. That on the eve of marriage “SAPTPADI” was performed.
3. That the petitioner and respondent marriage was arranged.
4. That after the marriage the petitioner went to Sasural on 07/02/2006
with domestic tools, silver and gold ornaments.
5. That both the parties started their marital conjugal life.
6. That the respondent is a short tempered person each and every moment
of life he beats the petitioner without rhyme and reason.
7. That the respondent and his family members have tortured the petitioner
for dowry. The Respondent’s mother used to say that bring Rs
5,00,000/- cash as dowry.
8. That the respondent always used to beat the petitioner with iron rod and
belt.
It is very important to mention here that the
respondent’s mother tried to push the throat of the petitioner. She always
told the petitioner your father has not fulfilled the demand of dowry. So,
you don’t have the right to live here. The petitioner used to work
morning till night she did not take any rest.
9. That the petitioner became pregnant, she conveyed the respondent that
she was pregnant, to listen her words, The respondent abused the
petitioner and he brutally assaulted the petitioner. Due to which the
petitioner felt down and became serious.
It is very important to mention here that the
petitioner’s family members reached there and took her to Purnea and
consulted Doctor Tripti Sinha. She advised for bed rest. The petitioner
lived in maiyka and gave birth to a female child.
10. That the petitioner went to sasural with her new born baby. The
respondent’s mother abused her with filthy language. She told the
petitioner if the petitioner again give birth to a female child then she will
ousted the petitioner from her house.
It is pertinent to mention here that the
petitioner again gives birth to two female babies. The respondent mother
and the respondent brutally assaulted the petitioner and they insulted the
petitioner in front of neighbours.
11. That the respondent’s mother did not pay attention, love, care to the
babies.
12. That the petitioner tried to make the respondent understand but the
respondent did not take proper attention towards the petitioner. The
inmates of both the parties tried to make the respondent understand and
both the parties decided to live separate from their house.
It is important to mention that both the
parties lived separately but the behaviour and attitude of the respondent
towards the petitioner did not change. The respondent always used to
say that she did not fulfil demand and she did not give him proper
attention. She also did not give birth to a male child. Due to which the
respondent did not want the petitioner to take him.
13. That the petitioner’s life became hell, after looking the situation of the
petitioner the family members throught that, to resolve the dispute we
should purchase the land in the name of the petitioner.
It is pertinent to mention here that the petitioners father
purchased the land in the name of petitioner vide Khata no- 583 Khesara
no- 163 mouja- katihar rakwa- 2 ¼ Kattha. The respondent told the
petitioner to transfer the said land in his name. The petitioner
vehemently opposed the respondent and she told the respondent she will
not transfer the said land in his name. She has three(3) daughters and no
source of income, and the respondent also have no fixed income. Due to
cruelty mental and physical the petitioner puzzled and she thought that
she should have committed suicide.
14. That the petitioner daughter namely Akshita Sah aged about 16 years
old, Ashmita Sah aged about 12 years old, Prerna Sah aged about 4
years old. Akshita Sah is studying in class 11th at Diksha institute in
Banglore. She is an intelligent student and she got Vedantu scholarship.
But Ashmita Sah is not studying properly due to lack of economic
condition and the respondent do not pay attention towards his daughters.
15. That the respondent brutally assaulted his daughters and in front of
babies he beats the petitioner. Due to which Prerna Sah shocked and she
awoke midnight and cried save me and my mother’s life from my father.
16. That the respondent does not fulfil demand of his daughters, he does not
supply proper food and basic amenities. When the petitioner become ill
the respondent does not bring medicine.
It is not out of place to mention here that the
respondent told the petitioner you are looking like dwarf and beggars, he
even used filthy language.
17. That the situation became bad to worse and every effort of the petitioner
become worthless the respondent abused every time and he ousted the
petitioner from his house many time and every time the petitioner tried
to resolve the matter. But the petitioner thinks that he will change his
feelings and one day he will become gentleman.
18. That the respondent brutally assaulted the petitioner 01/12/2019 and he
told the petitioner he will not give single farthing to maintain home. He
left the petitioner in a rental house Chhitabari Katihar and he did not
return in a rental house the petitioner has been paying rent. The
petitioner’s parents tried to make him understand. But the respondent
did not change. Once he visited rental house and told the petitioner go to
your maiyka Purnea.
19. That the petitioner parents are old ailing person and to see the situation
the petitioner’s father became seriously ill.
20. That the petitioner came Purnea on 16/06/2023 from Katihar. On that
day the respondent brutally assaulted the petitioner and he drove out the
petitioner from his home. He ousted his two daughters from his home
and told the petitioner to never come again otherwise the respondent
would kill their daughters. He told the petitioner to go to her maiyka
Purnea. She came Purnea on 16/06/2023 and told about the occurrence
to her parents. She also told that at the time of occurrence the
respondent’s mother, sister and brother in law were also present but they
provoked the respondent to beat the petitioner.
21. That the cause of action arose on 16th June 2023 when the respondent
ousted the petitioner and his daughter from his home after brutally
assaulting the petitioner from his home and she came Purnea.
22. That the petitioner presently lives with her old ailing parents at Purnea
and her marriage was solemnised at Purnea within your territorial
jurisdiction family court Purnea.
23. That the petitioner pays the appropriate court fee of rupees 250/- with
this plaint.
24. That the petitioner prays the following relief or reliefs: -

RELIEFS
a. A decree of judicial separation may be passed in favour of the petition
against the respondent.
b. Any other relief or reliefs which is fit and proper may be passed.
And for this the petitioner shall ever pray.
 Verification

I, Juli Sah age about 38 Years W/O Laxman Sah D/O Anant Prasad
Sah at Naya Tola PS Nagar District- Katihar Presently Sharda Nagar
P.S – K.Hat (Sahayak) District Purnea Aadhar no- 883534537135
Mob no. 9835646125 the petitioner do hereby solemnly affirm and
declare that the statement made in paras 1 to 24 of the plaint are true
to my knowledge and belief. Nothing is false and concealed.
Verified and signed this_____ day of
_____ 2023 in the court compound Purnea.

Identified by

Advocate Signature of the petitioner

 Affidavit
I, Juli Sah age about 38 Years W/O Laxman Sah D/O Anant Prasad Sah
at Naya Tola PS Nagar District- Katihar Presently Sharda Nagar P.S –
K.Hat (Sahayak) District Purnea Aadhar no- 883534537135 Mob no.
9835646125 the petitioner do hereby solemnly affirm and declare that
the statement made in paras 1 to 24 of the plaint are true to my
knowledge and belief.
No part of it is false and nothing has been concealed.
Verified and signed this the______ day
of ______ 2023 in the court compound Purnea

Identified by

Advocate Purnea Deponent

Aadhar no- 883534537135