Professional Documents
Culture Documents
IN P-photo
Between:
AND
H.No.2-251, Jaggaram,
Aswapuram Mandal,
Badradri Kothagudem District,
Telangana,
I. DESCRIPTION OF THE PETITIONER: The address and the description for the
petitioners is the same as mentioned in the cause title and for the purpose of service of
summons, notices etc., is that of their counsels M/s. M.Varalakshmi, B.Krushna &
II. DESCRIPTION OF THE RESPONDENT: The address and the description of the
Respondent for the purpose of service of summons, notices etc., is the same as is the
Hindu Rites and Customs. The marriage was arranged marriage. It is submitted that
after the marriage the petitioner and respondent were lived together happily for a
period of (13) years and in the meantime they have blessed with a 1 st male child
namely Mr.Sai Jathin on __________ after that they also blessed another male child
2. It is further submitted that the petitioner states that from the January, 2019 the
respondent behavior has been changed towards the petitioner and started harassing her
for each and every petty/small issues and respondent always uses bad and vulgar
language to the petitioner and the respondent started harassing the petitioner both
physically and mentally for arranging money he always used to torture the petitioner
and also beats children also for unknown reasons. As such the respondent used to
fight with the petitioner along with children for petty issues.
3. That the petitioner further submits that the respondent having illicit contact
with another woman namely _____________ and the respondent stated in front of
4. That the petitioner further submits states that a Panchayath was conducted
before the elders of Jaggaram village namely Sri. Sunnam Ram Babu and Sri. Avula
Venkanna, in that Panchayath the Respondent promised that he will change his
attitude and he will spend with petitioners and subsequently the respondent shifted his
4. It is further submits that the petitioner states that after shifting at Hyderabad
some days only they lived happily and again the respondent started harassment to the
petitioner for additional dowry. The respondent harassed the Petitioner mentally and
5. It is further submits that the petitioner states that due to unbearable tortures of
respondent she approached the S.H.O., P.S. Ashwapuram and lodged a written
complaint against the respondent, the Police registered a Criminal case against
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respondent vide Crime No.51/2021 on 26.3.2021 Under Section 498 (A), 324 of IPC
and 3 & 4 of D.P. Act the said case is pending vide C.C.No.239/2021, before Hon’ble
6. It is further submits that the petitioner states after filing of above criminal
case the respondent directly filed a false Divorce petition vide FCOP No.1465 of 2021
before Hon’ble Family Judge Court, Ranga Reddy District at L.B.Nagar and due to
reorganization of Districts the said case was disposed and transferred from L.B. Nagar
7. It is submits that the respondent always says that he don’t have money for
family and the respondent always never supports in anything financially for kids even
for kids school the petitioner asked several times but the respondent denied.
themselves with meager amounts and the Respondent herein is getting handful
amounts. The Respondent do not have any burden and on the other hand the
respondent had forgotten duty cast upon him to maintain to his own wife and sons as
such the Petitioners seeking the indulgence of this Hon’ble court may be pleased to
award the maintenance to the Petitioner No.1, 2 & 3 i.e. wife and minor sons of the
Rs.30,000/- P.M. and Rs.20,000/- for Petitioner No.2 & 3 School Fee etc. and
petitioners Medical and other needs. The same amount is not a burden to the
business including real estate with new car etc) and if the same is not considered, the
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petitioners will struggle for starvation and the little boys i.e. Petitioner No.2 & 3 will
have to ruin his bright future and remain as child labors for getting their livelihood,
9. It is further submitted that the Petitioner No.2 & 3 are growing children and
with great trouble the first petitioner bearing all their expenses and day-to-day needs
and requirements of the minor child’s. Hence, the Respondent being the husband and
natural father of petitioner no.2 & 3, he is liable and under obligation to pay the
maintenance to the Petitioners. That the respondent ill-treated the petitioners and
neglected them.
10. It is further submitted that the petitioner states that the respondent is well
JURISDICTION:
Telangana as such this Hon’ble Court has got jurisdiction both territorial as well as
COURT FEE:
PRAYER:
Therefore it is prayed, that the Hon’ble Court may be pleased to grant maintenance of
Rs.10,000/- per month to the Petitioner No.1 and Rs.10,000/- per month to the
Petitioner No.2 and Rs.10,000/- per month to the Petitioner No.3 and also Rs.20,000/-
for common needs for all petitioners respectively from the date of filing this petition
and to pass other order or orders at this Hon’ble Court deems fit and proper in the
circumstances of the case, otherwise the Petitioners will be put to irreparable loss and
injustice.
VERIFICATION
I, Smt. Jangili Swathi, W/o.Jangili Ravinder Yadav, Aged about 33 years, Occupation:
Housewife, presently R/o. H.No. 3-31, Swarnagiri Colony, Jodimetla, Chowdariguda,
Narapalli, Ghatkesar Mandal, Ranga Reddy District, Telangana-500088, do hereby
declare that the facts stated in above para are true and correct to the best of my
knowledge. Hence verified on this ___ day of September, 2022 at Malkajgiri.
LIST OF DOCUMENTS
Place: Malkajgiri
Date: .11.2022 Petitioner
(On behalf of petitioner no.2 & 3 also)
IN
Between:
AND
….Respondent
MAINTENANCE PETITION
FILED UNDER SECTION 125 OF
Cr.P.C
IN
Between:
LIST OF DOCUMENTS
IN
Between:
AND
….Respondent
LIST OF DOCUMENTS
Between:
AFFIDAVIT
I, Smt. Jangili Swathi, W/o.Jangili Ravinder Yadav, Aged about 33 years, Occupation:
Housewife R/o. H.No. 3-31, Swarnagiri Colony, Jodimetla, Chowdariguda,
Narapalli, Ghatkesar Mandal, Ranga Reddy District, Telangana-500088, do hereby
solemnly affirm and state as follows:-
1. I submit that I am the deponent herein and the petitioner no.1 in the M.C. as
such I am aware of the facts of the case.
2. I filed the present case seeking maintenance against the Respondent and since I
am unable to understand the court proceedings I pray this Hon’ble court be
pleased to permit me to appoint M/s. M.Varalakshmi and B.Krushna Advocates
as my legal counsels in assisting me in the proceedings.
IN
M.C.No. of 2022
Between:
AND
Sri. Jangili Ravinder Yadav
S/o. J.Nageshwara Rao,
Aged about 36 years,
Occ: Milk Business,
R/o. Plot No.180,
Flat No.101, Chilukuri Castle,
P & T Colony, Medipally,
Ghatkesar Mandal, Medipalle,
R.R. District, Telangana – 500039
Cell: 9182735678 & 9533665569 ….Respondent
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For the reasons stated in the accompanying affidavit, it is prayed that this
Hon’ble court be pleased to permit the petitioners to appoint M/s. M.Varalakshmi and
B.Krushna advocates as their legal counsels in assisting them in the proceedings and
to pass such other order or orders as this Hon’ble court may deem fit and proper in the
interest of justice.
Date: .11.2022
Place: Malkajgiri
PETITIONER NO.1
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IN
Between:
AND
….Respondent
Between:
Smt. Jangili Swathi
& (2) others ….Petitioners
AND
I, Smt. Jangili Swathi, W/o.Jangili Ravinder Yadav, Aged about 33 years, Occupation:
Housewife, R/o. H.No.3-31, Swarnagiri Colony, Jodimetla, Chowdariguda,
Narapalli, Ghatkesar Mandal, Ranga Reddy District, Telangana-500088, is the
petitioner do hereby appoint and retain
to appear for me/us in the above suit/case and to conduct and prosecute (or to
defend) the same and all proceedings that may be taken in respect of any application
for execution of any decree or order passed therein. I/We empower my/our
Advocate(s) to appear in all miscellaneous proceedings in the above suit or matter till
all decrees or orders are fully satisfied or adjusted to compromise and to obtain the
return of documents and draw any money that might be payable to me/us in the said
suit or of matter (and I/We do further empower my/our Advocate(s) to accept on
my/our behalf, service of notice of all of any appeals or petitions filed in any Court of
Appeal. Reference or Revision with regard to the said suit or matter before the
disposal of the same in the Hon'ble Court. To file compromise and admit the same.
Certified that the executant who is well acquainted with English/Urdu/Telugu and this
Vakalatnama and the contents of the Vakalatnama have been read our and explained
in Telugu/Urdu to executant as he she they being unacquainted with English who
appeared perfectly to understand the same and signed or put his/her/their name or
mark in my presence.
IN
Between:
AND
….Respondent
VAKALAT
Accepted
Between:
1. I am the Deponent herein and the Petitioner in the main suit I am deposing on
behalf myself and my minor sons i.e., Petitioners No.2 and 3 and as such I am well
2. It is submits that myself and the respondent were married on 28th May, 2005 at
Customs. The marriage was arranged marriage. It is submitted that after the marriage
we are lived together happily for a period of (13) years and in the meantime I have
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blessed with a 1st male child namely Mr.Sai Jathin on __________ after that I also
3. It is further submitted that from the January, 2019 my husband behavior has
been changed towards me and started harassing her for each and every petty/small
issues and he always uses bad and vulgar language to me and my husband started
harassing me both physically and mentally for arranging money he always used to
torture me and also beats children also for unknown reasons. As such my husband
4. That I further submits that my husband having illicit contact with another
woman namely _____________ and he stated in front of villagers that he will marry
her.
4. That I further submits that a Panchayath was conducted before the elders of
Jaggaram village namely Sri. Sunnam Ram Babu and Sri. Avula Venkanna, in that
Panchayath my husband promised that he will change his attitude and he will spend
with our family and subsequently he shifted our family to Hyderabad for livelihood.
5. It is further submits that after shifting at Hyderabad some days only we lived
approached the S.H.O., P.S. Ashwapuram and lodged a written complaint against him,
the Police registered a Criminal case against respondent vide Crime No.51/2021 on
26.3.2021 Under Section 498 (A), 324 of IPC and 3 & 4 of D.P. Act the said case is
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directly filed a false Divorce petition vide FCOP No.1465 of 2021 before Hon’ble
Family Judge Court, Ranga Reddy District at L.B.Nagar and due to reorganization of
Districts the said case was disposed and transferred from L.B. Nagar to Principal
District Judge Court –Cum Additional Family Court at Malkajigiri the same is
8. It is submits that my husband always says that he don’t have money for
family and he never supports in anything financially for kids even for kids school I
meager amounts and my husband herein is getting handful amounts. He do not have
any burden and on the other hand he forgotten duty cast upon him to maintain to his
own wife and two sons as such I am seeking the indulgence of this Hon’ble court may
be pleased to award the maintenance to myself and petitioner No.2 & 3 (i.e. wife and
minor sons) total Rs.50,000/- i.e., at the rate of Rs.10,000/- to each petitioner x 3 =
Rs.30,000/- P.M. and Rs.20,000/- for Petitioner No.2 & 3 School Fee etc. and
petitioners Medical and other needs. The same amount is not a burden to the
business including real estate with new car etc) and if the same is not considered, we
will struggle for starvation and the little boys i.e. Petitioner No.2 & 3 will have to ruin
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their bright future and remain as child labors for getting their livelihood, which is a
10. It is further submitted that the Petitioner No.2 & 3 are growing children and
with great trouble I am not in a position to maintain all their expenses and day-to-day
needs and requirements of the minor child’s. Hence, being the husband and natural
father of petitioner no.2 & 3, he is liable and under obligation to pay the maintenance
to the all Petitioners. That the my husband ill-treated and neglected us.
such he is doing regular businesses on commission basis and his income is above
IN
Between:
AND
….Respondent
Between:
A. PERSONAL INFORMATION
DECLARATION
3. I understand that any false statement in this affidavit, apart from being
contempt of Court, may also constitute an offence punishable upto seven years
and fine and Section 209 of Indian Penal Code punishable with imprisonment
up to two years and fine. I have read and understood sections 191, 193,
199and 209 of the Indian Penal Code., 1860
DEPONENT
VERIFICATION
DEPONENT
Place: Malkajgiri
Date: -11-2022.
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