In
the Court of……………..Judicial Magistrate 1st Class
Case No……………………under s. 125, Cr PC
Petitioner W (wife) Opposite Party H (husband) Daughter
of…………..
versus
Son of…………………..
Village ……………… Village…………………
Thana………………..
Thana…………………. Occupation…………. Occupation…………….
In the matter of
petition for maintenance of petitioner W from the husband H under s. 125, Cr PC
The humble petition of W (wife), the
petitioner above-named Most Respectfully Sheweth:
Your petitioner
W is the married wife of the opposite party. The marriage between them was
solemnised according to the Hindu rites on the opposite party H is a clerk on
the staff of AB & Co. Ltd. holding a responsible position and drawing
salary of Rs. 8000 per month.
The opposite
party severely assaulted the petitioner on …………… and drove her away from the
matrimonial house on………………..in presence of several gentlemen of the locality.
That the
opposite party leads a life of drunkenness and debauchery. He is besides a man
of uncertain temperament and would fly into rage in season and out of season
without any reason whatsoever. He has lost all sense of decorum and would use
extremely filthy language.
Your petitioner
after being driven out of the house by the opposite party came over to her
father's place on the same day and has been staying at father's house with his
family members.
The opposite
party was served with a pleader's notice to send your petitioner Rs. 900 every
month for her maintenance but with no result. Having regard to the violent
temper of H and his inhuman way of beating your petitioner she does not venture
to go back to the place of the opposite party.
Your petitioner,
therefore, prays that Your Honour may be pleased to issue notice on the
opposite party and after taking evidence of both sides be I pleased to order
the opposite party to pay the petitioner maintenance at the rate of Rs. 900 per
month. And your petitioner, as in duty bound, shall ever pray.
I, W, daughter
of MN residing at…………. do hereby solemnly affirm and say as follows:
I am the petitioner above-named and I know
the facts and circumstances of the case and I am able to depose thereto. The
statements in the paragraphs 1, 2, 3, 4, 5 and 6 of the foregoing petition are
true to my knowledge and that I have not suppressed any material fact. Solemnly
affirmed by the said
Mrs. Won
the……..day of………. 2010 in the Court House at Mumbai
Before me Notary
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