W/o Karan, R/o CF300, Alpha 1, Greater Noida

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PETITION BY WIFE UNDER SECTION 125, CRP.C.

FOR MAINTENANCE

In the Court of Gautam Buddha Nagar, Uttar Pradesh

Maintenance Case No. 422 under s. 125, Cr PC

Akshita

w/o Karan, r/o CF300, Alpha 1, Greater Noida


……. Petitioner
versus

Karan

s/o Rajesh, r/o 8/452,Gama, Greater Noida ……. Respondent

APPLICATION FOR MAINTENANCE BY WIFE UNDER SECTION 125


(1)(2), CR.P.C

The petitioner above named respectfully states as under:

1. That applicant is legally married wife of the respondent; both of whom lived as
husband and wife for seven years at Gama and by such marriage two child was born
to them and on the date this petition their age is 4 years and 2 years respectively.
2. That after few years of the marriage, the Respondent is acting rudely towards the
petitioner and the child. He came into contact with a lady named Shalini and she got
attracted towards her, before marriage also they both knew each other and the
applicant has been subjected to cruelty and also the respondent has been in adulterous
relationship. He (Respondent) used to stay out of the city for multiple days and on
enquiry it was found out that there was no official reason for it.
3. That the respondent had stopped paying anything for house hold expresses unable meet
the other expense of both the child and when the applicant demanded money from the

respondent on 7th August, 2019 she was subjected to harassment infront of the
neighbours and he started abusing her.
4. That ultimately applicant was turned out of her matrimonial house by the respondent
on 17th August, 2019. Applicant and along with the children somehow reached her
parents’ house on 24th August, 2019 and from then towards the petitioner is staying in
her parents’ house at CF300, Alpha along with her children.
5. That meanwhile relatives of the applicant tried to persuade the respondent to know the
reason of such conflict and lead a family life with dignity with his wife and minor
child two needed his father’s care and attention. But all the efforts to change the
Respondent’s attitude towards his wife and child were in vain.
6. That unable to maintain herself and her minor son, parents being old, and in an utter
state of poverty, the petitioner issued a legal notice to respondent on 9th September,
2019 demanding separate maintenance for herself and her minor child, which was
received by the respondent on 11th September, 2019 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.
7. That respondent is the lone male member of the family after his father and has the
earning capacity of Rs 50000 per month, along with the rent which comes from
village near Barabanki of around 20000 and has no other liabilities apart from the
present applicant and he leads a lavish lifestyle.
8. That petitioner is unable to maintain herself and the minor child being illiterate she is
unable to get herself any job.

In the circumstances the respondent has sufficient cause to live separately with her child and
prays that your Honour may be graciously pleased to order the respondent to make a monthly
allowance for maintenance of the applicant and her minor child at the rate of Rs.50000 per
month or at such rate as your Honour may deem fit and proper. Form the date of this
application.

Place: New Delhi


Dated: - 10/11/2019 Petitioner

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