IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT
DISTT.NORTH WEST .ROHINI COURTS ,DELHI
Petition no………
IN THE MATTER OF:
Nisha @ Bhawna Petitioner
VERSUS
Anil Kumar Respondent
P.S .BHARAT NAGAR
INDEX
Particulars COURT FEES PAGE NO
Memo of Parties
Petition u/s 144 BNSS for
Maintenance along with
supporting affidavit
Application u/s 144(2)
BNSS for interim
Maintenance along with
affidavit
List of Documents Along
with the documents
Vakalatnama
DELHI PETITIONER
DATED THROUGH COUNSEL
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT
DISTT.NORTH WEST.ROHINI COURTS, DELHI
Petition no………
MEMO OF PARTIES
IN THE MATTER OF:
NISHA @ BHAWNA
W/O Anil Kumar D/O
Sh. Ashok Kumar r/o K- 9
Sawan Park, Ashok Vihar, Phase-III
Delhi-110052 PETITIONER
VERSUS
ANIL KUMAR S/O
SOHAN PAL, R/O A-42,
NANDA ROAD, ADARSH NAGAR,
DELHI-110033 RESPONDENT
DELHI PETITIONER
DATED: THROUGH COUNSEL
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT
DISTT.NORTH WEST .ROHINI COURTS ,DELHI
Petition no………
IN THE MATTER OF:
NISHA @ BHAWNA
W/O Anil Kumar D/O
Sh. Ashok Kumar r/o K- 9
Sawan Park, Ashok Vihar, Phase-III
Delhi-110052 PETITIONER
VERSUS
ANIL KUMAR S/O
SOHAN PAL, R/O A-42,
NANDA ROAD, ADARSH NAGAR,
DELHI-110033 RESPONDENT
P.S. BHARAT NAGAR
PETITION U/S 144 BHARTIYA NAGRIK SURAKSHA SANHITA,2023
FOR GRANT OF INTERIM MAINATAINCE ON BEHALF OF THE
PETITIONER
Sir,
MOST RESPECTFULLY SHOWETH:-
1. That the petitioner was married with the respondent on 12-07-2013
according to Hindu rites and ceremonies at Ashok Vihar, Delhi and after
the marriage the respondent brought the petitioner at her matrimonial
home marriage was consummated there and out of this marriage no issue
was born out. The copy of Aadhar Card is annexed as ANNEXURE-A.
The marriage Photographs are annexed as Annexure-B(Colly).
2. That was arranged marriage and was solemnized with great pom and
show and in the said
Marriage the parents of the petitioner spent huge amount beyond their
capacity. It is submitted that the parents of the petitioner have gave all the
household goods ,gold, jwellery, furniture to the respondent on the
demand of respondent’s. An Affidavit to Non- Availabiliy of marriage
card for the petitioner is also annexed as ANNEXURE-C.
3. That on dated 16-07-2023 the respondent his mother and father
humiliated the petitioner in front of all relatives and they said to the
petitioner “ GARIB GHAR SE LE AYE HAIN MAA NE KUCH DIYA
HI NAHI, HAMNE TO SOCHA THA KI EK HI BETI HAI ACHA
DAHEJ DENGE LEKIN TERI MAA TO KANGLI NIKLI, HAMARE
BETE GAYA ,KANGALO KI BETI LE AYE HUM TOH, HAMARI TO
KISMAT HI KHARAB THI, JO YEH HAMARE PALE PADD GAYI”
and on the same day respondent’s mother took all the jwellery of the
petitioner and said “ JAB KAHIN JANA HO TO LE LENA, WESE BHI
KON SA TERI MAA NEI KARORO KI JEWLLERY DI HAI”.
4. That on dated 05-11-2013, when the respondent was out of home and
mother of the respondent came into the room of the petitioner and said to
the petitioner that “ TERI MAA NEI KUCH NAHI DIYA , HAMSE
GALTI HO GAYI, TUJHE IS GHAR MAI LAKAR”. After listening
those words petitioner had to keep mum because she was newly wedded
daughter-in-law and she had to listen all her lines because she knew that
her father is no more, who will settle the matter if any wrong thing will be
happened. When the respondent and replied “SAHI TOH KEH RAHI
HAI MERI MAA, MUJHE BHI LAGA, TERI MAA BIKE DEGI BUT
TERI JESI LADKI MUJHE HI MILNI THI”. After listening words of
him the petitioner tried to convince him then the respondent abused and
slapped her and the sister in law of the petitioner hold the heirs of the
petitioner and throw her on the floor and the mother-in-law kicked her on
chest.
5. That the Month of April, 2014 when the petitioner was pregnant, the
respondent used to fight and beat the petitioner on petty issues. And the
respondent said that he/she is not my child after listening all the things
the petitioner started to cry but she did not inform to her family because
her father is no more and her mother arranged huge amount for her
marriage.
6. That on 16.04.2024, the respondent left the petitioner to her parental
home for her delivery while saying “MERE PASS PAISE NAHI HAI,
TERI MAA KAREGI TERE, BACHE KA KARC”.All the expenses of
the delivery was born by the petitioner’s mother and on 31-12-2024 the
mother of the petitioner got admitted the petitioner into Hindu Rao
Hospital then the petitioner gave birth baby boy. The respondent did not
give a single penny to the petitioner and her mother for the delivery. The
respondent, took the petitioner and child in own house. That the
petitioner’s mother gave all the clothes and clothes/jewllery to the child,
despite the fact that the petitioner’s mother-in-law scolded the petitioner.
7. That the respondent behavior was getting wrose day by day on pretext of
petitioner’s son ill health, the respondent started getting black magic done
by Tanktriks. One day respondent crossed all the limits and told that “I
have a friend who does black magic”.
8. That the respondent assure the petitioner that my business and your
relation with my mother and sister will improve and there will be
happiness and peace in the house. But the respondent’s friend has kept a
condition for me that he want to spend a night with you. The petitioner
was shocked that what is the respondent saying that the petitioner clearly
refused that it will not do anything wrong on this respondent got angry
and beat the petitioner very badly. The respondent trying to make
petitioner have illicit relation and make run away from petitioner’s in
law’s house.
9. That on 09.04.2020 the respondent beat the petitioner and told that if you
do not make relationship with my friend it will not keep you in the house
and respondent left me and my son outside my house.
10.That the incident of May,2020, the brother -in-law of the petitioner came
to the house of petitioner and said to send Lavyansh with me and by
engaging me in conversation took away son from the petitioner. After
that petitioner called many times and he abused me. The petitioner tried
many times bring my son but the scolded me and throw out. After that
petitioner went to in-law house on 11-08-2024 to take his son back and
the mother in-law ,sister-in-law , father – in- law abused the petitioner.
11.That after that all the respondents started threatening petitioner with
utmost cruelty and domestic violence.
12.That thereafter the petitioner made a complaint date 13-08-2024 to CAW
CELL, Rani Bagh, Delhi, no action has been taken against the
respondents.
13.That the respondent is neglecting and avoiding to maintain the petitioner
and even he refused to maintain the petitioner with his means and
income.
14.That the petitioner has no source of income from any corner and she
unable to maintain herself and at present she is at the mercy of her
mother, who is unable to maintain the petitioner for a long period.
15.That on the other hand the respondent is man of means leading a
luxurious life. The respondent is a business Man and he is running a
shoes Showroom and he is earning about 70,000/- per month and he is
residing in own house (Kothi) in Adarsh Nagar, Delhi and he has no other
liability except to maintain the petitioner.
16.That since the day of separation the respondent has not given a single
penny amount to the petitioner towards her maintenance his legally
wedded wife therefore the petitioner is legally entitled to get maintenance
from the respondent as per law.
17.That the petitioner is required and entitled to a sum of Rs. 25.000-/ per
month as her maintenance allowance from the respondent, considering
the income status of the respondent.
18.That the petitioner has suffered a lot at the hands of the respondent and
his other family members have turned the life of the petitioner into
miserable and beatable life. Now the petitioner has lost all its
expectations and hope of a married life, the utmost cruel acts of the
respondent and his other family members bring the matrimonial tie to an
end and there is no ray of hope for betterment, hence this petition.
19.That the petitioner is residing at Sawan Park, Ashok Vihar, Phase III,
Delhi. Hence this Hon’ble Court has got the jurisdiction to try and decide
the present petition.
Prayer:-
It is therefore most respectfully prayed to this Hon’ble Court may
kindly be pleased to pass:
a) The sum of Rs. 25,000/- per month to petitioners as maintenance
allowance towards food, clothing , medical facilities and other expenses
from the date of filing this petition.
b) The Litigation Expenses the sum of Rs. 25,000/- to the petitioner.
c) Any other order/(s) and relief (s) which this Hon’ble Court may deem
fit and proper may also be passed in favour of the petitioner and against
the respondent in the interest of justice.
DELHI
PETITIONER
DATED:
VERIFICATION:
The petitioner verified that the contents of para no …… to…….. are true
and correct as per personal knowledge and belief, para no …… to………
as per the information , and to para no….. to ……. As per legal advice.
The last of the petition is prayer to tis Hon’ble Court, nothing has been
concealed from the court in the petition .
Verified this petition on this …….. day of 2024 at Delhi.
PETITIONER
I
IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT
DISTT.NORTH WEST .ROHINI COURTS ,DELHI
Petition no………
IN THE MATTER OF:
Nisha @ Bhawna Petitioner
VERSUS
Anil Kumar Respondent
P.S .BHARAT NAGAR
AFFIDAVIT
I Nisha @ Bhawna, aged about 30 years w/o Anil Kumar D/O Sh. Ashok
Kumar, R/O K-9 , Sawan Park , Ashok Vihar Phase III Delhi 110052, do
hereby declare as under:-
1. That the deponent is petitioner in the above notice petition and as well
conversant with the facts of the case competent to swear this affidavit.
2. That the accompanying petition u/s 144 BNSS has been drafted by
counsel under my instructions and the contents thereof are true and
correct to my knowledge and the contents of same has been read over to
me in my vernacular language and are not repeated herein for the sake of
brevity.
DEPONENT
VERIFICATION:-
Verified at Delhi on this ………day of September, 2024 that the contents
of the above affidavit are true and correct to my knowledge and nothing
material has been concealed therefrom.
DEPONENT
