PETITION BY WIFE UNDER SECTION 125, CR PC FOR MAINTENANCE





In the Court of.................... Judicial Magistrate No.



Case No. ........... under s. 125, Cr PC



Petitioner W (wife)

Daughter of...........

Village....................

Thana ..................

Occupation ............ Opposite Party H (husband)

versus



Son of...........................

Village ..............................

Thana..............................

Occupation ...................

In the matter of maintenance petition of petitioner W from the husband H per s. 125, Cr PC

The above name petitioner.

Respectfully shewoth:

1. Petitioner W being married wife of opponent party, they married according to the Hindu rites on.

2. The opponent party H being a clerk on the staff of AB & Co. Ltd. holding a responsible position and drawing salary of Rs. 8000 per month.

3. The opponent party strongly attacked the petitioner on ................... and drove her away from the matrimonial house on............................. before various gentlemen of the vicinity.

4. That the opponent party leading a life of drunkenness and habitual lewdness. He is besides a man of uncertain temperament and become enraged season and out of season without any reason whatever. He has lost all sense of decorum and uses abusive language.

5. Petitioner after having being driven out of the house by the opponent party, came to her father's place on same day and staying there in his family members.

6. The opponent party was served with a pleader's notice for remitting petitioner Rs. 900 monthly for maintaining her but without effect. Having regard to violent temper of H and his inhuman type of beating petitioner she does not dare to go back to the place of the opposite party.

Petitioner hence prays that Your Honour may be pleased to issue notice on the opponent party and after leading evidence of both sides be pleased to order the opponent party for paying petitioner maintenance at the rate of Rs. 900 monthly. And petitioner, as in duty bound, shall ever pray.

Verification



I, W, daughter of MN resident of.......................... do hereby solemnly affirm on oath say as under:

1. I being petitioner above-named and I know the facts/circumstances of the case and I am able to depose thereto.

2. The statements in the paragraphs 1, 2, 3, 4, 5 and 6 of the foregoing petition are true to my best knowledge and that I have not suppressed any material fact.

Solemnly affirmed by the said Mrs. Won the ............ day of.........in the Court House at Bombay.

Before me

Notary