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IN THE COURT OF JUDICIAL MAGISTRATE I CLASS,

JODHPUR

Maintenance Petition No. ... / 2017

BETWEEN:
1. Mrs. RANI SHARMA w/o SHAMA SHARMA
2. Master ROSHAN SHARMA s/o SHAMA SHARMA
R/O Jalori Gate, Jodhpur, Rajasthan ........................... Petitioner

AND

Mr. SHAMA SHARMA s/o O.P. SHARMA

R/O Shastri Nagar, Jodhpur, Rajasthan .......................... Respondent

PETITION UNDER S. 125 CR P C, 1973 FOR THE GRANT OF

MAINTENANCE

The aforementioned petitioner respectfully state as under:-

1. That the petitioner is the wife of the respondent, their marriage had been
solemnized at Jodhpur on 10/1/2010 according to the Hindu customs and rites
and one male child (Petitioner no. 2) was born out of this wedlock on
15/02/2011.

2. That Rs. 10,00,000 was spent on the marriage of the petitioner No. 1 and
sufficient dowry articles were given to the respondent and his family members
according to their status but the respondent and his family members were not
satisfied, thus the respondent started to ill-treat the petitioner for unlawful
demand of property from petitioners father by way of additional dowry and for
his failure to meet respondents demand, the petitioner has been beaten and
subjected to cruelty. He (Respondent) was constantly threatening to kill the
petitioner and was torturing her.

3. That the petitioner No. 1 was tortured and humiliated time and again and
ultimately she was thrown out of her matrimonial home in wearing clothes
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along with petitioner No. 2. Since then, the petitioner No. 1 is living with her
parents.

4. That meanwhile the relatives of the petitioner tried to persuade the respondent
to lead a family life with dignity with his wife and minor child too needed his
fathers care and attention. But all the efforts to change the Respondents
attitude towards his wife and child were in vain.

5. That the petitioner No. 1 also visited to the CAW Cell for settlement of her
married life but the respondent refused to maintain the petitioners. Then a case
under section 498A/34 IPC under the FIR No. _________ was registered
against the respondent.

6. That the respondent is not giving any maintenance to the petitioners and the
Parents of the petitioner No. 1 are very poor person. The petitioner No. 1 has
neither any source of income from any side nor she has any movable or
immovable properties in her own name.

7. The Petitioner No: 1 is a household lady, not having any skilled qualification
and due to extreme emotional stress the petition is not able to pursue any job, as
well unable to maintain herself and her son by self.

8. That the respondent is employed in XYZ Company and is drawing a salary of

Rs. 50,000/- per month, and even though he has sufficient means, the
respondent has refused and neglected to maintain the petitioner.

9. That the petitioner No. 1 has require Rs.10,000/- per month for her maintenance
and Rs.10,000/- for her minor child as the petitioner No. 2 is attending school
and expenses have to be made regarding his tuition fee, transport and cost of
books etc. apart from other necessary expenses.

10.That the petitioner served upon the respondent a notice, on 20/10/16 calling
upon him to pay to the petitioner a maintenance allowance @ Rs. 20,000/- per
month, but the respondent neither replied the notice nor cared to come forward
to maintain or make any provision for the maintenance of his wife and minor
child and hence this application.

11. That in such circumstances the respondent has sufficient cause to live
separately with her child.
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12.That the petitioner resides within the local limits of the jurisdiction of this
Court, and the marriage between the petitioner No. 1 and respondent had taken
place here, hence, this honble Court has jurisdiction to try and decide this
petition.

13.That this petition being chargeable with a fixed rate of Court fee, the same is
paid herewith.

14.That the petitioner, therefore, prays that

a) This application be kindly allowed, and the respondent be ordered to pay to

the petitioners maintenance allowance @ Rs. 20,000/- per month from the
date of this application;

b) The Costs of this application be awarded from the respondent;

c) Any other orders in the interest of justice be kindly passed.

Place: Jodhpur Petitioner No. 1

Date: 27/02/2017

Petitioner No. 2
(Being Minor Represented By Pet: 1)

COUNSEL FOR THE PETITIONER

VERIFICATION

I, above named petitioner, do hereby verify that the contents from paras 1 to 14 are
correct and true to the best of my knowledge and personal belief and no part of it is
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false and nothing material has been concealed therein. Affirmed at Jodhpur this 27 th
Day of February, 2017.

Place: Jodhpur Petitioner No. 1

Date: 27/02/2017

Petitioner No. 2
(Being Minor Represented By Pet: 1)

COUNSEL FOR THE PETITIONER