125 crpc petition format | Petition for Maintenance under Section 125 of CrPC for claiming Maintenance to Wife, Children and Parents | Interim maintenance petition format| Application maintenance under section 125 CrPC format| maintenance under section 125 crpc
IN THE COURT OF DISTRICT JUDGE, FAMILY COURT,
___________
1-
Smt.
Shabana wife of Shahrukh
2-
Baby
Aaisa aged about 2 ½ years D/o Shahrukh
3-
Baby
Raiba aged about 5 months D/o Shahrukh
Minor petitioners No.2 and 3 through their
mother next friend and natural guardian Smt. Shabana wife of Shahrukh
All residents of ____________________________________________
………….Petitioners
Versus
Shahrukh son of Sh. ___________________, R/o __________________.
……….Respondent
PETITION UNDER SECTION 125 CR.P.C. FOR GRANT OF MAINTENANCE ALLOWANCES TO THE PETITIONERS.
Respectfully Showeth:-
1-
That the petitioner No.1 was married with the respondent on 22-06-2007
according to muslim rites and ceremonies at and out of this wedlock petition
no. 2 & 3 were born out.
2-
That the parents of the petitioner No.1 had spent about Rs.
3,00,000/- in this marriage and had given sufficient dowry to the respondent
and his family members according to their capacity.
3- That since the very day of the marriage the respondent and his
family members were not happy and satisfied with the dowry articles and as soon
as the petitioner No.1 reached at her matrimonial home on the same day the
respondent had beaten the petitioner No.1 black and blue and had clearly
threatened the petitioner No.1 until and unless her parents does not fulfill
the demand of Rs. 1,50,000/- cash and Alto car they are not going to keep her
with them.
4-
That on the same night the respondent had again beaten the
petitioner No.1 by first and blows and when the petitioner No.1 started crying
due to injuries and pain the family members of the respondent had come there
and they had also beaten the petitioner No.1 and threatened her if she cries in
her loud voice she would be killed.
5- That the petitioner No.1 had disclosed the factum of demands of
the respondent and his family members and her physical and mental harassment
caused by the respondent and his family members to her parents when she came
back to her parental home after the marriage. Upon this the parents of the
petitioner No.1 had organized a Panchayat of respectables of the society at the
house of the respondent where the respondent and his family members have
clearly told to the parents of the petitioner No.1 as well as to the members of
the Panchayat that they were expecting of Rs. 1,50,000/- cash and Alto Car in
the marriage but their this demand has not been fulfilled but somehow they were
ready to keep the petitioner No.1 with them due to the pressure of the
Panchayat.
6-
That the respondent and his family members had been continued to
harass and torture the petitioner No.1 and made the life of the petitioner No.1
complete a hell and treated her nothing more than a maid servant and forced her
to do all the menial work and kept on pressurizing the petitioner No.1 that
until and unless their demand is not meted out she will be treated like this.
7-
That the petitioner No.1 continued to bear the torture inflicted
upon her by the respondent and his family members for the sake of the respects
of her parents and as well as in the hope that some day her life might be
settled and in the meanwhile the petitioner No.1 was got pregnant.
8-
That when the petitioner No.1 was at the advance stage of
pregnancy then the respondent and his family members had shunted her out of her
matrimonial home and told the petitioner No.1 that you give birth to the baby
at your parental home and thereafter if our demands are satisfied then we will
bring you back.
9-
That the petitioner No.1 had given birth to her elder
daughter at her parental home and after the birth the parents of the petitioner
No.1 had given two buffaloes each worth Rs. 35000/- were given to the
respondent and his family members then only they had taken back the petitioner
No.1 with them.
10- That in the
meanwhile the respondent and his family members started planning to have a
second wife for the respondent in collusion with each other
and when the petitioner No.1 objected to it she was shunted out from her
matrimonial home about 7 months ago and even at this time the petitioner
No.1 was at an advance stage of pregnancy and she has given birth to her
second daughter namely at her parental home only.
11- That since then
a number of Biradari Panchayats have been convened but the respondent and his
family members are adamant upon their demand for Rs. 1,50,000/- cash and an
Alto Car and are not taking back the petitioner No.1 to her matrimonial home
and have been threatening that they will get a second marriage for the
respondent and if the petitioner No.1 is sent back to them then she will face
dire consequences.
12- That a period
of 7 months has been elapsed and the petitioner No.1 has been residing at her
parental home at village ___________________ with her two minor daughters i.e.
the petitioners No.2 and 3 who are hardly able to support her and her two
daughters and the life of the petitioner No.1 has become a complete hell and
the respondents are not ready and willing to take back the petitioner No.1 and
to maintain her and her minor daughters and our lives have been completely
spoiled.
13- That the
petitioner No.1 has also filed a complaint against the respondents before the
Office of ______________ which is being investigated by the police. The copy of
the complaint is enclosed herewith.
14- That the petitioner
No.1 has no individual source of income and she is not skilled and is
illiterate lady. The petitioner No.1 does not know any work and she is unable
to maintain herself as well as two minor daughters i.e. the petitioners No.2
and 3 and she is fully depending for food, shelter and clothes on her adopted
parents who are unable to maintain herself.
15- That the respondent is
having sufficient source of income as the respondent alongwith his family
members are owners of stone mines and as well as the respondent is running a
Milk Dairy and also having about 5 Acres of the agricultural land from which he
is handsomely earning and his father is also in the business of stone mining
and the total income of the respondent is about Rs. 50000/- per month The
respondent has refused to maintain and keep the petitioner No.1 and her minor
daughters i.e. the petitioners No.2 and 3 without any reasonable cause and
without any reasonable justifiable cause just for the reason that their demands
of dowry as has been desired by them has not been meted out. The respondent has
no liability except the liability of the petitioners.
16- That the cause of
action to file the present petition accrued from time to time when the
respondents had mercilessly beaten the petitioner No.1 and even threatened to
kill her and demanded an alto car and cash Rs. 1,50,000/- cash and an Alto Car
from her and her parents. The cause of action accrued when the respondent
refused to keep and maintain even in front of the respectable of the Panchayat
and kept adamant upon their demands. The further arose on 20-08-2010 when the respondent
and his family members turned out from her matrimonial home and it finally arose on 28-02-2011
when the respondent finally refused to keep and maintain the petitioners.
17- That the petitioner is residing at _________
within the territorial jurisdiction of this Hon’ble court hence this Hon’ble
court has got the jurisdiction to entertain and try the present petition.
18- That the fixed court
fee has been affixed on the petition.
PRAYER
It is, therefore, prayed that the petition of the petitioners may kindly be accepted and the respondent may kindly be directed to pay Rs. 15,000/- per month as maintenance allowances to the petitioners from the date of filing of the petition along with costs of the petition
Petitioners
VERIFICATION
Verified that the contents of
the Paras No.1 to 17 of the Petition are true and correct and true to the best
of our knowledge and Paras No. 18 & 19 of the Petition are true to best of
our knowledge as per the information derived from the records. The last Para is
the prayer before this Hon’ble court.
Verified at ____________ Petitioners
IN THE COURT OF SHRI DISTRICT JUDGE, FAMILY COURT, _____
Smt. Shabana etc. Vs. Shahrukh
PETITION UNDER SECTION 125 CR.P.C. FOR GRANT OF MAINTENANCE ALLOWANCES TO THE PETITIONERS.
Affidavit.
I, Smt. Shabana wife
of Sharukh, R/o ______________________ do hereby solemnly affirm and declare as under:-
1- That the deponent has filed the petition Under Section 125 Cr. P.C. today before this Hon’ble court, the contents of which have been read over to me by my counsel in simple Hindi which are true to best of my knowledge and be read as part and parcel of this affidavit for the sake of brevity and avoidance of repetition.
Deponent
Verification:
Verified that the contents of my above affidavit are true to best of my knowledge and belief and nothing has been concealed therein. Verified at ________
Deponent
IN THE COURT OF DISTRICT JUDGE, FAMILY COURT, _____
Smt. Shabana etc. Vs. Shahrukh
PETITION UNDER SECTION 125 CR.P.C. FOR GRANT OF MAINTENANCE ALLOWANCES TO THE PETITIONERS.
Application for grant of Ad-Interim Maintenance Pententelite to the applicants/petitioners
Respectfully Showeth:
- That the petitioner/applicant has filed the above mentioned petition today before this Hon’ble Court the contents of which may be read part and parcel of the this application for the sake of brevity and avoidance of repetition as the same are not being reproduced here for the sake of brevity and avoidance of repetition.
- That the petitioner No.1 has no individual source of income and she is not skilled and is illiterate lady. The petitioner No.1 does not know any work and she is unable to maintain herself as well as two minor daughters i.e. the petitioners No.2 and 3 and she is fully depending for food, shelter and clothes on her adopted parents who are unable to maintain herself.
- That the respondent is having sufficient source of income as the respondent alongwith his family members are owners of stone mines and as well as the respondent is running a Milk Dairy and also having about 5 Acres of the agricultural land from which he is handsomely earning and his father is also in the business of stone mining and the total income of the respondent is about Rs. 50000/- per month The respondent has refused to maintain and keep the petitioner No.1 and her minor daughters i.e. the petitioners No.2 and 3 without any reasonable cause and without any reasonable justifiable cause just for the reason that their demands of dowry as has been desired by them has not been meted out. The respondent has no liability except the liability of the petitioners.
- That the applicants /petitioners are entitled to receive the ad interim maintenance of Rs. 15000/- from the respondent and they are also entitled to receive the amount of Rs. 11,000/- as litigation expenses from the respondent.
PRAYER
It is, therefore, prayed that the application
of the applicants/petitioners may kindly be accepted and the respondent may
kindly be directed Rs. 15,000/- per month as interim maintenance pendentelite
to the applicants/petitioners and the respondent may also be directed to pay
Rs.11,000/- litigation expenses to the applicant till the final decision of the
above petition.
Dated Applicants/Petitioners,
Through counsel :
IN THE COURT OF DISTRICT JUDGE, FAMILY COURT, _____
Smt. Shabana etc. Vs. Shahrukh
PETITION UNDER SECTION 125 CR.P.C. FOR GRANT OF MAINTENANCE ALLOWANCES TO THE PETITIONERS.
Application for grant of Ad-Interim Maintenance Pententelite to the applicants/petitioners
Affidavit.
I, Smt. Shabana wife
of Sharukh, R/o ______________ do hereby solemnly
affirm and declare as under:-
1- That the
deponent has no individual source of income and she is not skilled and is
illiterate lady. The deponent does not know any work and she is unable to
maintain herself as well as two minor daughters i.e. the petitioners No.2 and 3
and she is fully depending for food, shelter and clothes on her adopted parents
who are unable to maintain herself.
2- That the
respondent is having sufficient source of income as the respondent alongwith
his family members are owners of stone mines and as well as the respondent is
running a Milk Dairy and also having about 5 Acres of the agricultural land
from which he is handsomely earning and his father is also in the business of
stone mining and the total income of the respondent is about Rs. 50000/- per
month The respondent has refused to maintain and keep the petitioner No.1 and
her minor daughters i.e. the petitioners No.2 and 3 without any reasonable
cause and without any reasonable justifiable cause just for the reason that
their demands of dowry as has been desired by them has not been meted out. The
respondent has no liability except the liability of the petitioners.
5- That the applicants /petitioners are entitled to receive the ad interim maintenance of Rs. 15000/- from the respondents and they are also entitled to receive the amount of Rs. 11,000/- as litigation expenses from the respondent.
Deponent
Verification:
Verified that the contents
of my above affidavit are true to best of my knowledge and belief and nothing has
been concealed therein.
Verified at ________
Deponent
Affidavit for caste certificate, Character certificate, correction in name, Ration card, scholarship etc.
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4 Comments
Very good detailed information
ReplyDeleteA formal notification between two parties alerting the other before legal action is taken to obtain their due payment is known as a legal notice for money recovery.
ReplyDelete
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