IN THE COURT OF JUDICIAL MAGISRTATE FIRST CLASS
DISTT. NORTH WEST.ROHINI COURTS, DELHI
Complaint no ………
IN THE MATTER:
NISHA @BHAWNA COMPLAINANT
VERSUS
ANIL KUMAR & ORS. RESPONDENTS
P.S .BHARAT NAGAR
INDEX
S.NO PARTICULARS COURT PAGES
FEES
1. MEMO OF PARTIES
2. COMPLAINT U/S 12 FOR
MAINTENACE ALONG WITH
SUPPORTING AFFIDAVIT
3. APPLICATION U/S 144(2) BNSS FOR
INTERIM MAINTENACE ALONG WITH
AFFIDAVIT
4. AFFIDAVIT OF NON AVILABILTY OF
MARRIAGE CARD
5. INCOME AFFIDAVIT OF ASSETS AND
LIBILTIES OF THE PETITIONER
6. LIST OF DOCUMENT ALONG WITH
DOCUMENTS
7. VAKALTNAMA
DELHI COMPLAINANT
DATED THROUGH COUNSEL
IN THE COURT OF JUDICIAL MAGISRTATE FIRST CLASS
DISTT. NORTH WEST .ROHINI COURTS ,DELHI
Complaint no………
IN THE MATTER OF:
Nisha @ Bhawna COMPLAINANT
VERSUS
Anil Kumar & ORS. RESPONDENTS
MEMO OF PARTIES
NISHA @ BHAWNA
W/O Anil Kumar D/O
Sh. Ashok Kumar r/o K- 9
Sawan Park, Ashok Vihar, Phase-III
Delhi-110052
COMPLAINANT
VERSUS
1. ANIL KUMAR S/O
SOHAN PAL, R/O A-42,
NANDA ROAD, ADARSH NAGAR,
2. DELHI-110033
3. SOHAN PAL , R/O A-42,
4. NANDA ROAD, ADARSH NAGAR,
5. DELHI -110033
6. BHUDEVI W/O SOHAN PAL,
7. R/O A-42, NANDA ROAD, ADARSH NAGAR
8. DELHI -110033
9. SONIYA D/O SOHAN PAL
10.R/O A-42, NANDA ROAD, ADARSH NAGAR
11.DELHI -110033
12.KISHAN PAL S/O SOHAN PAL
13.R/O A-42, NANDA ROAD, ADARSH NAGAR
14.DELHI-110033
15.RESPONDENTS
DELHI COMPLAINANT
DATED: THROUGH COUNSEL
IN THE COURT OF JUDICIAL MAGISRTATE FIRST CLASS
DISTT. NORTH WEST .ROHINI COURTS ,DELHI
Complaint 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
COMPLAINANT
VERSUS
1. ANIL KUMAR S/O
SOHAN PAL, R/O A-42,
NANDA ROAD, ADARSH NAGAR,
DELHI-110033
2. SOHAN PAL , R/O A-42,
NANDA ROAD, ADARSH NAGAR,
DELHI -110033
3. BHUDEVI W/O SOHAN PAL,
R/O A-42, NANDA ROAD, ADARSH NAGAR
DELHI -110033
4. SONIYA D/O SOHAN PAL
R/O A-42, NANDA ROAD, ADARSH NAGAR
DELHI -110033
5. KISHAN PAL S/O SOHAN PAL
R/O A-42, NANDA ROAD, ADARSH NAGAR
DELHI-110033
RESPONDENTS
P.S. BHARAT NAGAR
COMPLAINT U/S 12 PROTECTION OF WOMEN FROM
DOMESTIC VOILENCE ACT, 2005
Sir,
MOST RESPECTFULLY SHOWETH:-
1. That the complainant is peace loving and law abiding citizen of India and
at present residing at the above mentioned address.
2. That the complainant was married with the respondent no. 1 on 12-07-
2013 according to Hindu rites and ceremonies at Ashok Vihar, Delhi and
after the marriage the respondent no .1 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).
3. That was arranged marriage and was solemnized with great pom and
show and in the said marriage the parents of the complainant spent huge
amount beyond their capacity. It is submitted that the parents of the
complainant have gave all the household goods ,gold, jwellery, furniture
to the respondent no. 1 on the demand of respondent.1 . An Affidavit to
Non- Availabiliy of marriage card for the complainant is also annexed as
ANNEXURE-C.
4. That on dated 16-07-2023 the respondent 2 and respondent no.3
humiliated the complainant in front of all relatives and they said to the
complainant “ 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 no 2 took all the jwellery
of the complainant and said “ JAB KAHIN JANA HO TO LE LENA,
WESE BHI KON SA TERI MAA NEI KARORO KI JEWLLERY DI
HAI”.
5. That on dated 05-11-2013, when the respondent no .1 was out of home
and respondent no 3. came into the room of the complainant and said to
the complainant that “ TERI MAA NEI KUCH NAHI DIYA , HAMSE
GALTI HO GAYI, TUJHE IS GHAR MAI LAKAR”. After listening
those words complainant 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 no. 1 came to home , the
complainant told about the day of incident to the respondent no.1 scolded
the complainant 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 respondent
no.1 the complainant tried to convince him then the respondent no.1
abused and slapped the complainant and respondent no -4 hold the hairs
of the complainant and throw her on the floor and the respondent no-3
kicked her on chest.
6.That the Month of April, 2014 when the complainant was pregnant, the
respondent no.1 used to fight and beat the complainant on petty issues. And the
respondent no.1 said that he/she is not my child after listening all the things the
complainant started to cry but complainant did not inform to her family because
her father is no more and her mother arranged huge amount for her marriage.
7. That on 16.04.2024, the respondent no.1 left the complainant 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 complainant mother and on 31-
12-2024 the mother of the complainant got admitted the complainant into
Hindu Rao Hospital then the complainant gave birth baby boy. The
respondent no.1 did not give a single penny to the complainant and her
mother for the delivery. The respondent no.1 , took the complainant and
child in own house. That the mother of complainant gave all the clothes
and clothes/jewllery to the child, despite the fact that the complainant.
The respondent no.3 scolded the complainant.
8. That the respondent no. 1 behavior was getting wrose day by day on
pretext of complainant son ill health, the respondent no.1 started getting
black magic done by Tanktriks. One day respondent no.1 crossed all the
limits and told that “I have a friend who does black magic”.
9. That the respondent no.1 assure the complainant 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 no.1 friend has
kept a condition for me that he want to spend a night with you. The
complainant was shocked that what is the respondent no.1 saying that the
complainant clearly refused that it will not do anything wrong on this
respondent no.1 got angry and beat the complainant very badly. The
respondent no.1 trying to make complaint have illicit relation and make
run away from petitioner’s in law’s house.
10.That on 09.04.2020 the respondent no.1. beat the complainant 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.
11.That the incident of May,2020, the respondent no.5 came to the house of
complainant and said to send Lavyansh with me and by engaging me in
conversation took away son from the complainant . After that
complainant called many times and he abused me. The complainant tried
many times bring my son but the scolded me and throw out. After that
complainant went to in-law house on 11-08-2024 to take his son back and
the respondent no.2, respondent no.-3, respondent no.4abused the
complainant.
12.That after that all the respondents no. 1 started threatening complainant
with utmost cruelty and domestic violence.
13.That thereafter the complainant made a complaint date 13-08-2024 to
CAW CELL, Rani Bagh, Delhi, no action has been taken against the
respondents.
14.That the respondent is neglecting and avoiding to maintain the petitioner
and even he refused to maintain the petitioner with his means and
income.
15.That the complainant 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 complainant for a long period.
16.That on the other hand the respondent no. 1 is man of means leading a
luxurious life. The respondent no.1 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 complainant .
17.That since the day of separation the respondent no.1 has not given a
single penny amount to the complainant towards her maintenance his
legally wedded wife therefore the complainant is legally entitled to get
maintenance from the respondent as per law.
18.That the complainant 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.
19.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.
20.That the complainant 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 complaint.
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 PETIRIONER
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 this Hon’ble Court, nothing has been
concealed from the court in the petition .
Verified this petition on this …….. day of 2024 at Delhi.
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
