IN THE COURT
OF PRINCIPAL JUDGE, -----------
In
the matter of:
--------- ….Petitioners
Versus
------ ...Respondent
AN APPLICATION UNDER SECTION 125 OF THE CR.P.C FOR INTERIM MAINTENANCE AND EXPENSES OF PROCEEDINGS.
MOST RESPECTFULLY SHOWETH:
1. That the accompanying petition U/s 125 Cr.P.C. has been filed by the petitioner and the contents of the above said petition may kindly be read as part and parcel of this application and the same are not repeated herein for the sake of brevity.
2. That the balance of convenience as well as prima facie case goes in favour of the petitioner and against the husband/respondent.
3. That the petitioner is a legally wedded wife of the husband/respondent and she has been deserted by the husband/respondent since ----- and since then the husband/ respondent had not paid any amount to the petitioners for her maintenance.
4. That the respondent has not made any provisions for the maintenance of the petitioner and her baby since the date of separation. The husband of the petitioner is enjoying very comfortable life and earning Rs. ---- per month from his job in ---.
5. That the Petitioner/wife is an house-wife and is not in position to earn, and even she has no movable or immovable property in her name and she is not in position to earn for maintaining herself. The Petitioner/Wife is legally wedded wife of the Respondent and the Respondent has not paid even a single penny towards maintenance to the Petitioner/wife till date nor he has made any provision for her maintenance. Whereas, the Respondent is legally, morally and ethically bound to do so but he intentionally and deliberately neglected Petitioner-wife. All of the jewellery, istridhan, personal belongings and all articles of the Petitioner/ wife are still lying under the illegal custody and control of the Respondent and his family members. The Petitioner is living at the mercy of her parents.
6. That the Petitioner-wife has a right to lead the life as per the status/standard of the respondent and as such she needs atleast Rs. ----- per month as maintenance pendente-lite to maintain herself and her baby.
PRAYER:
It is, therefore, most respectfully prayed that this Hon'ble Court may kindly be pleased to direct the husband/respondent to pay Rs. ------per month to the petitioners for her interim maintenance, in the interest of justice.
Pass
any other order or relief(s), which this Hon'ble Court may deem fit and proper
in the facts and circumstances of the present case in favour of the petitioner.
Petitioners
Through:
Counsel for the Petitioners
Dated:
IN THE COURT
OF PRINCIPAL JUDGE, -----------
In the matter of:
--------- ….Petitioners
Versus
AFFIDAVIT
I, ----- W/o -----R/o ---------, do hereby solemnly affirm and declare as under: -
1. That the deponent is the petitioner in the above-mentioned case and is fully aware with the facts and circumstances of the present case thus competent to swear the present affidavit.
2. That the accompanying application for interim maintenance under Section 125 Cr.P.C has been drafted by my counsel under my instructions, the contents of the same are true and correct.
3. That the Contents of the accompanying application may kindly be read as part and parcel of the present affidavit as the same are not being repeated herein for the sake of brevity.
Deponent
Verification:-
Verified at Delhi on this ____ day of
----- that the contents of my above affidavit are true and correct and nothing
material has been concealed therefrom.
Deponent
