IN THE HON’BLE METROPOLITAN MAGISTRATE 44TH

COURT AT ANDHERI, MUMBAI.

D.V. APPLN. NO: _ OF 2024

AAFREEN ABDUL RASHID SHEIKH )

Aged 34 years, Occupation: house wife
Adullt Indian Citizen
R/O: Room no.502 building no. R13
Awadham Society Near Centic City, Ram
Mandir,Goregaon West, 400062.
Complainant
V/s.

1. ABDUL RASHID ABDUL MAJID SHAIKH )

Age: 41yrs Occupation: Business )
R/o: Khatri B-104, Khatri House,
)
Behind Meghani school,
Behraum baug, jogeshwari west, 400102 )
2. ABDUL MAJID SHAIKH ) Accused no.1
Age: 70 yrs Occupation: Business
)
R/o: Khatri B-104, Khatri House,
)
Behind Meghani school,
Behraum baug, jogeshwari west, 400102 )
3. SHABHNAM ABDUL RASHID SHAIKH ) Accused no.2
Age: 29yrs Occupation: House Wife
)
R/o: Khatri B-104, Khatri House,
) Accused no.3
Behind Meghani school,
Behraum baug, jogeshwari west, 400102 )
 APPLICATION U/s 12 OF THE PROTECTION OF
WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

MOST RESPECTFULLY SHOWETH

1. That the present application is being filed by the complainant herein under

section 12, and 19(f), 20(i)(b) and (d), 22 and 23 of the protection of

women from Domestic Violence Act, 2005.

2. The numerous incidents of physical abuse, verbal abuse, emotional abuse

and economic abuse committed by the Accused on the Complainant are as

described hereunder:

3. That the complainant and the Accused are Muslim and domiciled in the

State of Maharashtra. The marriage between the complainant and accused

was solemnized on 14/11/2006, in accordance with Islamic Rites and

Customs in presence of respective parents, relatives, friends and well-

wishers. The said marriage was registered with the concerned Mosque at

Hyderabad District Basti (Uttar Pradesh). The said Nikahnama certificate

is in the possession of the Accused. During the initial five years of their

marriage, the complainant and accused lived in their matrimonial home

located in Behrambaug, Jogeshwari West, Mumbai.

4. In 2008, the complainant and accused have 3 daughters out of the said

wedlock one, Ayesha Abdul Sheikh (2nd May,2008) and 2nd daughter 14th

May,2014, with their second daughter, Ayra Abdul Sheikh, and on 1st
 May,2020 third daughter, Anaya Abdul Sheikh. Hereto annexed and

marked Exhibit “A” are the copies of Birth Certificates of the children.

5. The complainant says accused no.1 is the son of her father’s elder brother.

The parents of the accused who were comparatively well settled asked the

hand of the complainant for the son. Assuring the parents of the

Complainant of a better life and lots of love and care. The father of the

complainant convinced by his brother’s words agreed for the marriage and

the marriage took place.

6. That the complainant says, after a few months she shifted to her in laws

house. She started facing harassment for not bringing enough dowry. She

was astonished by listening to their sudden wishes after coming to the

matrimonial home with great hopes to start a new family. The complainant

got betrayed by their false impersonation as a decent, modest family and

made a grave mistake trusting their affectionate behaviour earlier.

Throughout her stay with the in-laws, she had faced torture in the

matrimonial house for the reason of not bringing enough dowry to the

satisfaction of the Accused’s family.

7. The Complainant says that unlike of the promises made by her in-laws

parents, the complainant started facing harassment at her in-laws home

within a month of the marriage. The Complainant who came here with

dreams of living a happy married life saw herself struggling to live in

hostile environment. Very soon the Accused family started showing

 displeasure towards the Complainant for not bringing enough dowry. The

Father in law and (Late) Mother in law started taunting and urging the

Complainant to bring dowry from parents. The Complainant’s father was

also shocked by the behaviour of his own elder brother. The Complainant’s

parents thought this to be a passing phase and asked the Complainant to

remain patient and be more humble and obedient towards the in-laws and

husband. The Complainant in any case had no choice so she became more

submissive and accepted the situation.

8. Despite, the Complainants humility and obedience the situation did not

improve and the Complainant further says the Accused no. 2 and Accused

no.1’s late mother started harassing her on the dowry as well as for every

little thing. They would not like dishes prepared by the Complainant and

throw the hot meals on the Complainant’s legs on the pretext claiming that

it is inadequately cooked. Many a times, the hot meals burnt her and gave

blisters. The Complainant says upon such situations when she would look

up to her husband (Accused no.1) for some support and compassion, he

would support his parents actions. In the privacy when the complainant

no.1 would plead her husband to protect her and give her some congenial

environment to live peacefully, the Accused no.1 ignored or made false

promises that he would take care of the situation and make her life easier

in the matrimonial house. The moment he would go out of the room he

would be a changed person and joined the in-laws in the harassment. The
 things were descending and the cruel acts were continued by the Accused’s

family relentlessly. For every little issue the Accused no.1’s parents that is

Accused no.2 and his now deceased wife, would shout at the Complainant

at times would beat her and ask her to leave the house. As the Complainant

is coming from a poor family background wouldn’t want to be a burden on

her family she would bear all the battering and violence at the hands of her

in laws hoping for the better days.

9. The Complainant says, the situation aggravated when she gave birth to the

eldest daughter Ayesha Abdul sheikh on 2nd May, 2008. They always

wanted a male child to be born first and when Ayesha came in and the

Accused’s family was extremely unhappy. When Ayesha Abdul sheikh

was 3 years old the accused no 2’s constant bickering became unbearable

that the Complainant did not give birth to a baby boy and on one such day

in great rage he threw hot food on complainant and asked her to leave the

house in front of Accused no.1 and his sister and other family members.

The complainant was begging the Accused and his family not to throw her

out of the house, and they spared the Complainant for that day.

10. The Complainant says she got scared with the situation and thinking that

this might repeat again, she called her father from the village to Mumbai.

The father of the Complainant came, stayed for few days and watched the

situation of his daughter at her home. When complainant’s father heard the

expletives from the Accused no.2 being given to his daughter and
 witnessed hitting of his daughter by his own elder brother who was his

daughter’s father in law, he was shocked.

11. The Complainant says her father in law, the Accused no 2 started hitting

her legs with ice cold water bottles, her father was heartbroken and

intervened. The father in law sternly asked the complainant’s father to take

his daughter away. The complainant’s father took the complainant along

with him to Hyderabad (Ayodhya). She stayed at her parent’s home for a

year taking care of the eldest daughter (Ayesha). During this period, the

Accused no.1 never tried to make up the scarring hearts, assured and

convince complainant no.1 to come back to her matrimonial home. Then

the relatives mediated and convinced the Complainant’s parents to send

back the complainant and her daughter to Accused no 1. The Father of the

Complainant who had witnessed the violence of Accused no 2 and

aggression of Acccused no 1 and whole family agreed to send his daughter only

if the Accused no 1 lives with her in separate house. The Complainant says

after enduring five years of prolonged harassment, the couple eventually

relocated to a rented residence with help of complainant’s maternal uncles

at chawl in Gulshan Nagar, Mumbai. The complainant’s maternal uncles

bought the required household items for the Complainant to start as a new

life.

12. The complainant says, the Accused No .2 owns a successful scrap business and

the Accused no 1 is a partner in the business and has been working

 with Accused no.2 in his scrap business for around 25 years and would get

regular income from the said business. In the year 2021 the Acccused no

1’s share of income from this business was Rs 70.000/-. The Complainant

says after the complainant and the Accused no.1 started living in an

individual rental house the Accused no would not give any penny to run

the house but would bring grocery and kitchen items. There had been times

when he would not bring anything home and children would sleep hungry.

The 2nd daughter was baby then and needed baby food which he would not

provide. The Complainant would do some odd jobs and make some money

for the baby. There was no respite in life.

13. The Complainant says the accused no.1 took an auto on loan, The Accused

no 1 made down payment by forcefully taking the jewellery of the accused

no 1 selling 5 tolas of her gold and selling it to the jeweller . The

Complainant says the auto was given by the Accused no 1 for plying to

others but as there was not good enough earnings and the Accused no.1

could not pay the monthly EMI’s so the bank took away the auto.

14. The Complainant says understanding the complainant’s situation, the

brother of the complainant no.1 came forward and gave some money to the

Accused no.1 for the household expenses. The Accused no.1 used to spend the

money for himself to drink alcohol and womanise and waste the money. He

would not spend the money on household expenses, and on daughters’.The

Accused no.1 never showed interest, accountability or responsibility

 to pay back the money to the complainant’s brother. When the complainant

no.1s brother noticed his behaviour, he started giving the money to the

complainant no.1. The Complainant says when the Accused no.1 observed

this he assaulted the complainant no.1 and took away the money. Then

when no choice was left the complainant no.1 started asking for adhoc

work from the neighbours and ended up doing basic sewing of the clothes

from the tailors nearby their home. The complainant no.1 says she is not

proficient with sewing, so she would just do cloth cutting. The Accused

no.1 slowly started pushing all the responsibilities on the complainant. As

the complainant was not skilled in the tailoring work, she had to put lot of

efforts for precision and in order to pay the bills, started working day and

night and was unable to give required attention to daughters. The life was

difficult. But continued with extreme struggle and half fed stomach.

15. The complainant says, the Accused no.1 forced her to have physicalrelation

with him and assault violently on refusal when she was on periodsor when

unwell and made the complainant very depressed and disheartened with life.

The Accused no.1 started repeatedly telling her that, the Acccused’s family

wouldn’t accept her unless she gives birth to a baby boyand then life will be

smoother for her to survive in the matrimonial house. When the Accused

no 1 was un-relentless, the complainant conceived again and started

praying out of fear for a baby boy. Ironically It was destined for

complainant to have a baby girl again. The daughter Ayra

 Abdul Sheikh was on born on 14 th May, 2014. During the delivery time and

the postpartum expenses were all taken care again by the complainant’s

sister and her family who also paid hospital expenses. The Accused no.1

when heard of the daughter, he was disinterested to come to see the little

girl. The Complainant says after 2.5 months, when some relatives prevailed

upon the Accused no.1 he asked the Complainant to come back to Mumbai

as he shifted to another rental house.

16. The Complainant says the Accused no.1 and complainant no.1 started

living in that rental house again at Gulshan nagar. During this time when

complainant no. 1’s brother came down to Bombay for working, initially

he started living with Accused no.1 and complainant in their rental house.

The Accused no.1 started taking money from him and refused to pay him

back. Gradually, the complainant no.1’s brother ended paying the bills -

the rent, house hold expenses and school fees for the children and is doing

so till date. The brother still continues to pay all the expenses as on today.

Though, the complainant’s brother shifted to office accommodation, he

continued to bear the expenses.

17. The complainant says, while this is going on the Accused no.1 regardless

of the family condition, would invite his friends to their home frequently,

which would make complainant uncomfortable. The Accused no.1 would

order complainant to cook for them and look presentable and pleasant in

front of them. The Accused no.1 was least bothered when the complainant
 complained about their inappropriate behaviour with her and the Accused

no.1 used to brush off by saying “Isko itna issue mat banao ye sab chalta

hei ….. chaltha hai yaar”. The complainant seeing the un-understanding

attitude of accused no.1 on this issue had to simply bear it and tolerate.

18. The complainant says, when the complainant no.1’s father sold a piece of

land for Rs.4 lakhs in their village the Accused no.1 started to pester the

complainant no.1 and her father for the share from that Rs.4 lakhs. when

the complainants father refuse to give the money he started to assault the

Complainant frequently till the complainant no.1’s father seeing the

daughter’s condition agreed to give the money. The Accused no.1. The

Accused no.1 after receiving the money did not spend any penny on the

household expenses instead he started spending on the alcohol, his friends

and started going to prostitutes and staying/spending time with them during the

nights. The complainant was devastated after knowing his new habits. In

this overwhelming situation, the Accused no. 1 again started to force the

complainant no.1 for the 3rd child on the condition that she has to give birth

to a son failing which he threatened to divorce her. The complainant no.1

was not ready to bring one more life in this world, because she knew her

condition that she was unable to feed the 2 daughters and fulfil their needs,

to bring 3rd child would mean a lot of burden as she would not be able to

feed the 2 daughters and fulfil their need from one side and bring a 3rd child
 would be a metaphoric sin. The Complainant says the Accused no.1 would

not listen to her and assaulted her for not having unprotected conjugal

relationship with him. The complainant no.1 conceived and the third time

also the Accused no.1 was not ready to pay the medical bills. The

complainant has to ask her sister to pledge her gold kangan and paid for

the hospital bills.

19. The complainant says, she was again blessed with a baby girl. The

complainant named her Anaya abdul sheikh. Born on 1st May, 2020. When

the complainant no.1 came along with 3 daughters and her sister to their

home at Mumbai, the Accused no.1 became furious and was pressurising

her to abandon or give away the new born. The Accused no.1 only wanted

son and not daughters. The Complainant refused to abandon or to give

away her daughter to anyone. The complainant with lots of efforts

somehow protected the girl. This whole incident scared the complaint’s

sister and the complainant. The complainant took all of them back to their

village where she stayed for 2 months.

20. The Complainant says the Accused no.1 said that he do not want to take

any responsibility for this family. When the complainant no.1 did not agree

to abandon or give away the new born. The Accused no 1 was raging with

anger. The Accused no 1 took the complainant no.1 her sister and their

children all of them to their village in Ayodhya to her mother’s place and

they lived there for two months. The complainant says the Accused no.1
 came to complainant’s maternal home and stayed there with the

complainant for two months. During this period the Accused no.1 lived off

on complaints father’s money.

21. He was least bothered to take the responsibility of complainant and their

daughters including 3rd new born baby girl. The complainant and her family

took care of the 3rd child. Even the postpartum expenses were not taken

care by Accused who is the child’s’ father. It was the complainant’s brother

who ended up paying all bills and taking responsibilities of the all expenses of

complainant, her daughters and also Accused no.1’s all the time during their

stay at complainant’s maternal home. The Accused no 1 is physicallyfit and

young man still he showed no interest to do any work to earn.

22. The complainant says, During the Accused no.1’s stay at complainant’s

house in ayodhya, his mother’s health became serious due to Covid. At that

time the Accused no.1 was showing reluctance to go visit his mother while

she was on deathbed. It was the complainant’s family who forced the

Accused no.1 to go to his home and take care of his mother and

subsequently in the last week of July he left back to his home to Mumbai.

The Accused no.1’s mother expired on 30th Sept, 2020.

23. The complainant says, On 12th December 2020, the complainant came back

to Mumbai and started living with the Accused no.1 in a rented house.

Though Accused no.1 & complainant were staying together in the same

house, the Accused no.1 never supported the complainant financially.

 When the bills were not paid for the long time, the complainant had no

choice but to continue the sewing work, despite the fact her health was not

good because of the post-partum. The complainant says that, she just had

to work so she could feed her daughters and all this right after 5 to 6 months of

of her 3rd child delivery. The Accused no.1 had always had weird sexual

desires and forced the complainant for the same. Whenever the

complainant resisted, the Accused no.1 would beat her. He would continue

the physical violence till she agreed to submit to his demands.

24. The Complainant says the Accused no.1 started neglecting the household

responsibilities totally and started spending most of his time outside the

house and would come home according to his will. Whenever the

complainant questioned regarding his activities with women or about the

work the Accused used to torture the complainant with expletives and

assault her. Though accused no.1 and complainant lived in the same home

they gradually stopped interacting much with each other.

25. The complainant says, the Accused no.1 started the same topic on getting

pregnant and giving birth to a baby boy. The Accused no.1 again started to

push the complainant for the fourth child in order to get a son. The Accused

no.1 started fighting and forcing for the unprotected sex with him and get

pregnant again. The complainant understood that all this is on a repetition.

The complainant tired of facing physical and sexual abuse and demand of

baby boy wanted to runway from the situation but had nowhere to go.
26. The complainant says, when the physical and sexual violence became

unbearable she was forced to go to Rajasthan and take shelter with her

sister’s family in the month of December, 2020. She could not stay with

the sister’s family for long and had to come back to Mumbai after a week.

Also Accused no.1 gave assurance to the complainant that he would work

and provide for the family and that she should comeback. Thus the

complainant came back on December 2020. After the complainant came

back along with her daughters from Rajasthan she started to expect things

as promised that the Accused no.1 would start doing any work as he

promised the complainant. When she was in rajasthan. The fact is nothing

changed and the torture and assaults continued.

27. That the complainant says, in the month of January 2021, the Accused no.1

started beating the Complainant for not getting into physical relation with

him and said talak 3 times by mouth. And then later on 9th feb he started

beating the complainant for the same reason. When she refused to have sex

with him he again said “talak talak talak……” more than 10 to 12 times

and asked her to get out of the house along with daughters. The

complainant had nowhere to go so she did not move from there. The

Accused no.1 started to threaten the complainant that if she do not leave

his house along with the kids he would make her and her kids naked and

drag them on the road in front of the public. The Accused gave her 2 days
 time to leave his house along with the children. The complainant got scared

for her and her daughter’s dignity and left the place along with daughters.

28. The complaint says her brother made an arrangement of roof for her and

her daughters in a chawl at Ram mandir area. On 24 th Feb 2022, the

Accused no.1 brought some papers and asked the complainant to sign the

papers and threaten if she do not sign them he would abduct the daughters

and throw them in the flesh trade. The complainant was shaken with

incidents that were happening and was scared of the Accused and also

scared for her daughters’ modesty. She agreed to sign the papers. The

Accused asked the complainant to come with one witness near the court at

Bandra to sign the khulanama papers. To protect the daughters modesty the

complainants under a lots of force pressure and coercion took one person

with her to sign whatever papers the Accused wanted to get signed. This is

how on 24th Feb, 2022 the Accused forcefully acquired the signatures of

the complainant on khulanama.

29. The complainant says the khulanama was obtained by force but presently

the issues are bigger issues about daughters education their maintenance

and family sustenance. As per the khulanama, the Accused agreed to pay.

For the maintenance, education, residence and all expenses of their

daughters till their marriage. Hereto Annexed And Marked As The

Copy Of Khulanama As EXHIBIT – “B”

30. The complainant says presently she and her daughters are been maintained

by her brother. The Accused had not honoured to what he agreed to in the

khulanama. The Accused has paid very small negligible amount of few

thousand0 rupees till date that to he has not paid anything since august

2023. The complainant could hardly raise 4 to 5 thousand rupees in a

month. The brother will be getting married soon and will be having his own

responsibilities and may not be helping the complainant and her daughters.

The complainant says that she is extremely worried as to how to meet the

expenses of the daughters and herself in the coming times.

31. The complainant says that, when she tried to connect on whatsapp with the

accused no.1 the accused no.3 had started using explicit words and texting

the complainant. The screenshot is HERETO ANNEXED AND

MARKED AS EXHIBIT “C”. The Complainant tried to approach the

Accused no.1 several times but in vain. The Accused has blocked the

complainant on his phone and there is no way she can communicate with

him she has tried all her ways to make sure he takes his responsibilities

failing she is approaching this hon’ble court so that she and her daughters

can have a life of dignity. The complainant says after asking the accused

no 1 several times to pay for thechildren and family, the Accused no.1 sent

money through google pay to the complainant’s neighbour. The Accused

no.1 had sent a few times small amount of 2000 – 3000 Rs. only on

neighbour’s google pay application.. The neighbour withdrew the money

and gave the complainant in cash. To avoid an interaction with the

complainant and the daughters, the Accused no.1 used to send money to
the Complainant’s neighbour. So he could avoid meeting the complainant

and the daughters. The Accused no.1 did

 not show interest, love affectionate on the daughters. The Accused no.1

never telephoned the Complainant to know the whereabouts of the

daughters or to know about their wellbeing. He never spoke to the

daughters either. Whenever the daughters tried to call the Accused no 1 he

would often not take their calls or revert the calls and on rare occasions

when he did and the daughters asked for money for their livelihood. The

Complainant further says there were times when there was no food at home

they would plead their father for help but the Accused no.1 would yell at

them saying that “mere paas tum logon ke liye koi paisa nahin hai tum log

ko jo karna hei karo mein paisa nahi dedunga”.

32. The complainant says, On july 2023, when the complainant pleaded the

Accused no.1 about complainant no. 2 (Ayesha 1st daughter) education fees

who is studying in the Durga Devi Sharaf college 1 st year commerce. The

complainant asked for the tuition fees which was in total was 10,000 Rs.

After much persuasion, the Accused no.1 paid 4000 Rs. as a fee and refused

to pay further.. After that the Accused did not take any responsibility of the

daughter and gave no money at all till date.

33. The complainant says, On july 2023 end of the month the complainant had

sent Ayra 2nd daughter to the Accused no.1’s house as the complainant was

unable to feed the daughters and bear expenses of their education. The

complainant mother knew well that the Accused father was keeping the

child unwillingly and even the daughter lived there under fear but there
 was no other way as she wanted the daughter to get education and her

necessities be taken care of. The Complainant mother would bring the

daughter Ayra to home on the weekends.

34. On 22nd August, 2023. The Complainant mother got to know that the

Accused no.1 got married to Accused no.3 Shabnam Abdul Shaikh. The

Accused no.1 and Accused no.3 were in a relationship for a long time and

then got married. After Accused no.3 started living with the Accused no.1

in his home. The daughter Ayra started facing more hostility at her Father’s

home. The Complainant no 3 started treating her as her personal maid. She

would make the 9 year old massage her, rub her feet, bring her food tend

to her small homely work. As if this was not enough The Accused no.3

started teaching the complainant no.2 expletives. The Accused no 3 would

make reels (videos on insta and facebook). The Accused no 3 would make

the little girl photographer for her reels and do her makeup and instigate

her to make reels. She would brainwash the child by telling her not to study

or go to school but make reels as these reels will give money to the child.

When the little girl confided this to her mother, the complainant got very

worried about impact on the tender mind and she brought the child back to

her and despite lack of funds she is keeping the child and trying to undo

the wrong influence on the child. The Complainant also realised that the

Accused no 3 has brain washed the child and tried to turn her against the
 complainant by putting down her simple lifestyle, her aging with time, and

humble living of her mother.

35. The Accused no.3 started corrupting the little girl’s brain. Eventually, the

Accused no.3 even started to give orders to complainant no.2 to do the

household work and started abusing and threatening her and not feeding

the little girl who often remained hungry. The little girl would often insist

on not going back to her father but the complainant assuming she is well

fed in father’s home and getting education would bear her separation and

force her to go back ignorant of the fact what the child was enduring The

complainant was shocked when she heard abusive words from the little

girl’s mouth and then the Pandora box was opened. The Complainant

decided to keep her child with her.

36. The Complainant says later when the daughters when tried to call their

father the accused no1, he yelled at them and blocked the Complainant’s

number. Now there is no contact between the Complainant, her daughters

and the Accused no1. The Complainant says, with the help of her brother,

the Complainant started living along with her daughters in a rental place at

Ram Mandir. She started making tiffin for her brother and his friends and

with it she makes some money which is not even a bare minimum of

sustenance. Her earning per month is around Rs 4500- 5000/-. The

Complainant’s unmarried brother bears all the expenses of her and her

daughters. . The rent of the place is 11,000 Rs per month. Plus the
 electricity bill it totals to 12,500/- grocery expenses and school fees are

paid by the complainant’s brother which amounts to 10,000 house hold

expenses + 13000 for children’s education + medical expenses

approximately is Rs 3000.-4000. Hence for sustenance, the Complainant

and the children needs around Rs 40,000/- 45,000/-.

37. The Complainant says since the day "Khula" was obtained under force to

the present day the complainant has been relying on the support of her

parents and brothers to sustain herself and her children. On the other hand,

Accused no.1, who possesses owns a share in his father’s scrap business

and properties in various locations in Mumbai, has failed with his

responsibilities towards the complainant and their children. This disregard

for their welfare contradicts the principles of natural justice.

38. The Complainant is a destitute woman who have no other way left except

for this Hon’ble Court to knock for kind mercy and justice. The

Complainant has tried all means to see that the Respondent shoulders his

responsibilities, failing which she has approached this Hon’ble Court with

folded hands for justice.

PRAYERS:

a. The Accused be ordered and directed to restrict and prohibit himself and

be restrained from committing any act of the domestic violence upon me,

under the provision of Section 18(a);

 b. Till such time the Accused provides for permanent shelter for the

Complainant and her daughters the Accused no 1 be directed to pay monthly

rent of the flat of the Complainant along with security deposit of Rs

50,000/-

and to pay rent @ Rs.11,000 /- per month as provided under section 19;

c. May this Hon’ble Court kindly grant maintenance of at least Rs. 45,000/-

per month towards food, education, clothes, medicines, daily routine

expenditures, shelter and conveyance etc. for my daughters and Rs.

10,000/- for the maintenance of the complainant.

d. The Complainant be directed to provide permanent residence to the

Complainant /Applicant and her daughters.

e. For interim reliefs in terms of prayers a,b,c and f

f. For ex-parte Orders

g. For cost of this application.

AND FOR THIS ACT OF KINDNESS, I THE ABOVE NAMED

COMPLAINANT SHALL EVER PRAY.

Solemnly affirmed at Mumbai

Dated

Complainant
Advocate for the Complainant