IN THE HON’BLE COURT OF PRINCIPAL JUDGE, FAMILY COURT,

TIS HAZARI, DELHI

Mt. PETITION NO.________________ of 20___

IN THE MATTER OF:-

BUNTY ….PETITIONER

VERSUS

RAMESH KAUSHIK ….RESPONDENT

INDEX
S. NO. PARTICULARS COURT PAGE
FEES NO.

1. Memo of Parties

2. Petition U/s 125 Cr.P.C. seeking

the maintenance along with
affidavit

3. Application for interim Rs.

maintenance along with affidavit

4. List of documents along with the

documents
5. Vakalatnama Rs.

Total: Rs.

PETITIONER

THROUGH
PLACE:
DATED:

COUNSEL
IN THE HON’BLE COURT OF PINCIPAL JUDGE, FAMILY COURT,
TIS HAZARI, DELHI

Mt. PETITION NO.________________ of 20___

IN THE MATTER OF:-

BUNTY ….PETITIONER

VERSUS

RAMESH KAUSHIK ….RESPONDENT

MEMO OF PARTIES

BUNTY
W/O. RAMESH KAUSHIK,
R/O. HOUSE NO. 9, GALI NO.7,
NANGLOI, NAJAFGARH,
DELHI
...PETITIONER
VERSUS

RAMESH KAUSHIK
S/O. SH. INDER KAUSHIK
R/O. H.NO. 143, SAFIABAD,
PANA PAPSOSHIAN(58)
NATHUPUR, SONIPAT, HARYANA-131029.

...RESPONDENT

PETITIONER

THROUGH
PLACE: DELHI
DATED: COUNSEL
IN THE HON’BLE COURT OF PRINCIPAL JUDGE, FAMILY COURT,
TIS HAZARI, DELHI
Mt. PETITION NO.________________ of 20____

IN THE MATTER OF:-

BUNTY ….PETITIONER

VERSUS

RAMESH KAUSHIK ….RESPONDENT

P.S.____________

PETITION UNDER SECTION 125 Cr.P.C. FOR

MAINTENANCE ON BEHALF OF THE PETITIONER.

MOST RESPECTFULLY SHOWETH:

That marriage of the petitioner and the respondent was solemnized on

6TH February, 2003, according to Hindu rites and ceremonies at
Nangloi, Delhi with great pomp and show as per the wishes and desire
of the respondent and his family members. The marriage between the
petitioner and the respondent was duly consummated and have two
kids, one boy namely Dev kaushik aged 16 years old and one female
child namely Gunjan Kaushik aged 10 years were born out of said
wedlock. The petitioner and the respondent lastly resided together as
husband and wife till 20.09.2020 at H.NO. 143, Safiabad, Pana
Papsoshian (58) Nathupur, Sonipat, Haryana.

1. That the petitioner’s marriage with the respondent was an

arranged marriage. It is pertinent to mention that during the
meetings regarding the marriage proposal, the respondent and
his family portrayed themselves as a decent family having
unorthodox views. In addition to this, the respondent and his
family, in an extremely calculated manner, told the petitioner’s
family before the marriage finalization that they did not have
any demands. Keeping in view the portrayal of the respondent
and his family, the petitioner’s family agreed for the marriage.
However, to the utter dismay of the petitioner’s family, the real
intentions of the respondent and his family came forth, weeks
before the marriage when demand over dowry item started.
2. That thereafter, various expensive jewelery, cash and other
items were given to the respondent and his family as per their
demands that were raised and the photos can reiterate the
same. Further, as per the demands of the respondent. The copy
of FIR is annexed herewith as ANNEXURE P-1.

3. That on the very next day after the petitioner returned from her
parental home after her “pag fera” ceremony, for the occasion,
the respondent and his family started questioning the petitioner
by asking, “TUMHARE GHAR WALO NE SAGAN KE
ENVELOPE KE SATH SONE KE SIKKE BHI DENE
CHAIE THE, KYUN NAHI DIE?” The petitioner told them
that her parents had already given enough articles beyond their
capacity but the respondent’s father cut the petitioner in
between and stated that the women in their household were not
allowed to comment on what the men were saying and hence
the petitioner was asked to keep quiet.

4. That things got even worse after few years of marriage when
the respondent’s father and mother started questioning the
petitioner as to why her parents had not been sending them
gifts, jewelry for the respondent’s mother and the respondent’s
brother’s and his elder brother’s wife. As a response, the
petitioner asked them that there was no occasion or festival on
the account of which her parents would feel such a need to
send gifts. It is at this moment that the respondent’s mother
and 4 made the most demeaning and shocking statement
towards the petitioner regarding petitioner. The petitioner felt
extremely broken and discriminated against after so many
demeaning comment on her however they did not stop at that
and in the days that followed, the respondent’s sister in law on
the instruction of the respondent’s mother threatened to kill the
petitioner and started beating her mercilessly. This caused the
petitioner extreme mental and emotional turmoil and
constitutes extreme mental torture and cruelty.

5. That however, with time, the petitioner further realised that the
respondent and his family had misrepresented a lot of aspect to
the petitioner and her family. It is pertinent to mention that no
household maid was there and all the household work was
assigned to the petitioner and she was expected to do all of it
by herself. Such a contrasting behaviour to what the
respondent and his family had portrayed prior to the marriage
caused the petitioner extreme emotional turmoil and stress
however the petitioner did not want to tell her parents as
knowing the same would have caused them greater stress and
hence the petitioner chose to suffer everything in silence for
the next months to come, with the hope that on seeing her
 adjusting behaviour, things would get better at the matrimonial
home.

6. That the respondent and his family’s disliking towards the

petitioner became even more evident with the fact that the
respondent and his family had started treating the petitioner
like their house-maid as they would make her do each and
every household chore starting from mopping the floor to
washing clothes, cleaning the bathrooms as well as cooking. In
addition to such a degrading treatment, the respondent and his
family even forced the petitioner to lift heavy things knowing
full well that the petitioner was unable to do so and whenever
due to such physical exertion, the petitioner would fall sick, the
respondent’s mother and 4 would taunt the petitioner by
calling her a “KAAMCHOR.” The petitioner felt like she was
being used at her matrimonial house and no one including the
respondent cared about the petitioner or her well-being.

7. That the respondent and his family told the petitioner’s family
just a few days before the wedding that unless the respondent
was given a dowry articles along with Sagan envelopes for him
and his extended family members, the baraat would not be
entering the venue. It is pertinent to mention that the
petitioner’s father tried to explain to the respondent’s father
that since he had incurred a lot of expenditure in arranging the
venue which was also decided by the respondent and his
family in lieu of their demand that the venue should be up to
their and their guest’s standard. However, the respondent’s
father did not budge and stated, “DEKHIE JI, HUM TOH AAJ
BHI DUSRA GHARANA DHUNDNE KO TAYAAR HAI, YE
TOH HUM APKA SOCHKA BATA RAHE HAI KI KARLOGE
TOH APKA BHALA HOGA.” The petitioner’s father felt
extremely helpless due to such manipulations on part of the
respondent and his family but seeing no way out he agreed to
their demands.

8. That the petitioner felt caged at her matrimonial house as she

was not allowed to talk to her parents and take step out of the
house by herself. It is also pertinent to mention here that she
was even not allowed to go to her parental home without
taking permission from the respondent and his family.

9. That the petitioner was forced to keep quiet and suffer all the
cruelties in silence. As time passed and the true colors of the
respondent came forth, the petitioner realized that he was an
extremely aggressive man with temperamental issues. It is also
pertinent to mention here that on one such occasion, the
respondent had beaten the petitioner mercilessly over the
demand of scooter, which he demanded as a dowry article.
 Further the petitioner raised her concern to her mother-in-law
(Ramrati) but no solution for the same was done due to the
blind trust, support and fate she had on her son.

10.That soon after the marriage, with an addition to the prior

demands for gifts and dowry items, the respondent and his
parents started their new demand over a scooter from the
petitioner and her parents.

11.That on 3.02.2006 on the birth of first child of petitioner and

the respondent was born and huge numbers of gifts, jewellery
articles were given to respondent and his family but due to the
greedy and demanding nature of the respondent he was not
satisfied and again scooter.

12.That the petitioner being a dedicated Hindu wife and who have
been inculcated with moral and social values, used to do entire
household chores such as preparing all the meals, preparing
children to go to school, taking care of the two children and
practically with no help from the respondent or his family
members. During the course of time the respondent used to
pick fights over one or other trivial pretext. However, the
petitioner tolerated all the atrocities with the hope that good
senses would prevail over the respondent and his family
members. The petitioner made all the best efforts to create
conducive atmosphere in the matrimonial house both with the
respondent and his parents and she succeeded in doing the
same and the marriage survived for over seventeen years till
the time of separation(20.09.2020) only because of the efforts
an compromise made by the petitioner from time to time.

13.That during petitioner’s second pregnancy in month of august

2012, the younger brother-in-law namely sonu slapped the
petitioner for no reason. Thereafter the petitioner informed her
parents about this humiliating and degrading conduct of her
brother in law, which shocked the petitioner form inside. It is
further submitted that thereafter the petitioner’s parents
confronted the respondent about the conduct of their younger
brother (sonu) in order to pacify the matter, but no solution
was provided for the same.

14.That being aggrieved by all the prior actions of the respondent

and his family, the petitioner could not suffer anymore and out
of frustration and the cruel acts of the respondent and his
family, the petitioner went to her parental home. The
petitioner’s family called up and arranged a meeting in order to
discuss the conduct of the respondent and his family.
Thereafter, a family meeting was conducted between the
petitioner’s family and the respondent and his family, wherein
 the respondent and his family gave the petitioner’s family the
assurance that no such incidents of beatings and cruelty would
be repeated and since the reputations of both family’s w
ere at stake, the petitioner’s family should give them another
chance. Hence, based on their assurance, the petitioner
returned to the matrimonial home.

15.That the rest of the few months went by without much

turbulence however the respondent and his mother often used
to taunt in regard of dowry, jewelry, food and stuff but the
petitioner used to ignore the same for the sake of her marital
life and peaceful environment. It is pertinent to mention that
later there was an increase in the taunts aimed at her. It is also
submitted that not only this, the respondent’s parents also kept
a close eye on the petitioner and did not let her use her mobile
phone as much or let her visit her maternal home. It is
pertinent to mention that they would constantly monitor all
conversations of the petitioner with her family that she used to
have by sitting next to the petitioner the entire time.

16.That the petitioner chose to ignore the same as she did not
want any further issues to arise and the petitioner wanted to
make her marriage with the respondent work. However the
respondent never showed any sense of love or affection
towards the petitioner. It is pertinent to mention that the
respondent never bothered to spend any quality time with the
petitioner.

17.That the respondent and his family chose to take advantage of

the fact that the petitioner had decided to remain quiet and they
further started to inflict more cruelties on the petitioner daily.

18.That however, the parents of the petitioner gave valuable gifts

and cash throughout the course of the petitioner’s marriage
with the respondent and further, the petitioner’s parents gave
money to the respondent and his family as per his demand.

19.That the petitioner was under the impression that with the
passage of time and with her hard work and good nature, she
would change the behavior and attitude of the respondent and
his family members but all the endeavors made by the
petitioner failed as the respondent never improved his
behavior.
 20.That the respondent has neglected the petitioner throughout
her stay in her matrimonial home and the petitioner was
entirely dependent upon her parents for looking after her daily
expenses and necessities. On the other hand, the respondent is
a well-established person has a family business.

21.That the respondent has many income from various sources

which are not known to the petitioner and his income tax
returns would disclose such sources and quantum of income
accruing from them. The respondent has no other liability
except to maintain the petitioner. The petitioner requires
Rs.__________ for the maintenance of herself keeping in view
the status enjoyed by the respondent. The Respondent is liable
to pay maintenance to the Petitioner u/s-125 Cr.P.C.

22.That the respondent has not made any provisions for the
maintenance of the petitioner. The respondent is morally,
socially and legally bound to maintain them as the petitioner is
the legally wedded wife of the respondent. The petitioner is
also entitled for litigation expenses.

23.That since 20.09. 2020, the petitioner and the respondent are
residing separately. That the petitioner is presently residing at
H.NO. 9, GALI NO. 7, NANGLOI, NAJAFGARH, DELHI-
110041, therefore this Hon’ble Court has jurisdiction to try and
adjudicate the present petition.

PRAYER

It is, therefore, most humbly prayed that this Hon'ble

Court may kindly be pleased to:-

1. Direct the respondent to pay a sum of Rs.25,000/- per

month to the petitioner;

2. Direct the respondent to pay a sum of Rs.25,000/-

towards the litigation charges to the Petitioner, in the
interest of justice.

Any other or further order which this Hon’ble

Court deems fit and proper under the facts and
 circumstances of the present petition may also be passed
in favor of the Petitioner and against the respondent.

PETITIONER
THROUGH

DELHI
DATED:

COUNSEL

VERIFICATION:-

I, Bunty the above named Petitioner, do hereby verify on

solemn affirmation that the contents of para no. ___ to ___ of the
petition are true and correct to my knowledge and para no. ___ is true
and correct upon the information received and believed to be true.
Last para is prayer to this Hon’ble Court.

Verified at DELHI on this __ day of _________, 2022.

PETITIONER
IN THE HON’BLE COURT OF PRINCIPAL JUDGE, FAMILY COURT,
TIS HAZARI, DELHI
Mt. PETITION NO.________________ of 2020

IN THE MATTER OF:-

BUNTY ….PETITIONER

VERSUS

RAMESH KAUSHIK ….RESPONDENT

AFFIDAVIT

I, BUNTY, AGED 35 YEARS W/O. RAMESH KAUSHIK,

R/O. HOUSE NO. 9, GALI NO.7, NANGLOI, NAJAFGARH,
DELHI, DO HEREBY SOLEMNLY AFFIRM AND DECLARE ON
OATH AS UNDER:-

1. That I am the petitioner in the above noted matter and am

well conversed with the facts and circumstances of the case,
as such am fully competent to swear the present affidavit.
2. That the accompanying petition under section 125 Cr. P.C.
has been drafted by my counsel under my instructions and
the facts stated therein are true and correct to my knowledge
and the same has not been reproduced here for the sake of
brevity and the same be read as part and parcel of the
present affidavit.

DEPONENT
VERIFICATION:-
Verified at Delhi on this _____ day of __________,
2020, that the contents of my above affidavit are true and correct to
the best of my knowledge and belief, no part of it is false and
nothing material has been concealed there from.

DEPONENT
IN THE HON’BLE COURT OF PRINCIPAL JUDGE, FAMILY COURT,
TIS HAZARI, DELHI
Mt. PETITION NO.________________ of 20___

IN THE MATTER OF:-

BUNTY ….PETITIONER

VERSUS

RAMESH KAUSHIK ….RESPONDENTS

APPLICATION FOR INTERIM MAINTENANCE

Most respectfully showeth:-

1. That the petitioner is the wife of the respondent. The petitioner

is claiming maintenance for herself and has filed accompanying
petition under section 125 Cr.P.C. for grant of maintenance and
the contents of the same are not being reproduced herein for the
sake of brevity, the same may be read as part and parcel of this
application.

2. That marriage of the petitioner and the respondent was

solemnized on 6TH February, 2003, according to Hindu rites and
ceremonies at Nangloi, Delhi.

3. That since the respondent has neglected the Petitioner and has
refused to maintain her. The Petitioner is the legally wedded
wife of the respondent and being the husband of the petitioner,
the respondent is entitled to maintain the petitioner.

4. That on the other hand, the respondent is a well-established

person and he is a builder and his own family business The
respondent no.1 has also invested amount in various policies.
Respondent no.1 has other sources of income too which are
currently not known to the applicant. The respondent should be
directed to furnish the details of all his moveable and
immoveable properties.
5. That the respondent has not made any provisions for the
maintenance of the petitioner. The respondent is morally,
socially and legally bound to maintain the petitioner as the
petitioner is the legally wedded wife of the respondent.
6. That the petitioner will suffer irreparable loss and injury if an
interim order is not passed thereby directing the respondent to
pay the monthly allowance/maintenance to the petitioner as the
petitioner is in dire need of money and also the respondent is
morally, legally as well as socially bound to maintain the
petitioner up to the standard of the respondent to which the
petitioner is entitled as per the law.

7. That the disposal of the main petition is likely to take a long

time but the petitioner is in dire need of money for maintain
herself and hence this application for grant of interim
maintenance.

PRAYER

It is, therefore, most humbly prayed that this Hon'ble Court may
kindly be pleased to:-

(i) Direct the respondent to pay a sum of Rs.25,000/- (Rupees

Twenty five Thousand Only) per month to the Petitioner;

(ii) Direct the respondent to pay a sum of Rs.___________towards

the litigation charges to the Petitioner, in the interest of justice.

Any other or further relief which this Hon’ble Court

deems fit and proper under the facts and circumstances of the
present petition in favor of the Petitioner.

PETITIONER
THROUGH
PLACE: DELHI
DATED:
COUNSEL
IN THE HON’BLE COURT OF PRINCIPAL JUDGE, FAMILY COURT,
TIS HAZARI, DELHI
Mt. PETITION NO.________________ of 2020

IN THE MATTER OF:-

BUNTY ….PETITIONER

VERSUS

RAMESH KAUSHIK ….RESPONDENTS

AFFIDAVIT

I,
I, BUNTY, AGED 35 YEARS W/O. RAMESH KAUSHIK,
R/O. HOUSE NO. 9, GALI NO.7, NANGLOI, NAJAFGARH,
DELHI, DO HEREBY SOLEMNLY AFFIRM AND DECLARE ON
OATH AS UNDER:-

1. That I am the petitioner in the above noted matter and am

well conversed with the facts and circumstances of the case,
as such am fully competent to swear the present affidavit.

2. That the accompanying application for interim maintenance

has been drafted by my counsel under my instructions and
the facts stated therein are true and correct to my knowledge
and the same has not been reproduced here for the sake of
brevity and the same be read as part and parcel of the
present affidavit.

DEPONEN
T
VERIFICATION:-
Verified at DELHI on this _____ day of _______, 2020, that the
contents of my above affidavit are true and correct to the best of my
knowledge and belief, no part of it is false and nothing material has
been concealed there from.
DEPONEN
T
IN THE HON’BLE COURT OF PRINCIPAL JUDGE, FAMILY COURT,
TIS HAZARI, DELHI
Mt. PETITION NO.________________ of 2020

IN THE MATTER OF:-

BUNTY ….PETITIONER

VERSUS

RAMESH KAUSHIK ….RESPONDENTS

LIST OF DOCUMENTS
S.NO. PARTICULARS PAGE
1. Original Photograph of marriage.
2. Original wedding card
3. Photocopy of Aadhaar card as Identity Proof.
4. Address proof
5. Any other document with the kind permission of
the court.

PETITIONER

THROUGH

PLACE: DELHI
DATE COUNSEL