IN THE HON`BLE COURT OF ILLAQA MAGISTRATE , AMRITSAR.

CASE NO.________________
DATE OF FILING._____________
DATE OF DECISION______________

JASLEEN KAUR VERSUS DAVINDER SINGH BHULLAR

(APPLICATION UNDER SECTION 125 CR.P.C.)

INDEX

SR. NO. PARTICULARS PAGES. COURT FEE

1.
2.
3.
4.
5.
6.

……………APPLICANT

Through counsel

DATE:

PLACE: AMRITSAR AMIT MONGA

ADVOCATE,
AMRITSAR
P/1209/2005
(M) 98761-82455
 IN THE COURT OF ILLAQA MAGISTRATE, AMRITSAR.

JASLEEN KAUR AGED 28 YEARS DAUGHTER OF AMARJEET SINGH

W/O DAVINDER SINGH BHULLAR R/O 19-A, RANI KA BAGH,
AMRITSAR. …..…….PETITIONER

VERSUS

DAVINDER SINGH BHULLAR S/O JARNAIL SINGH BHULLAR

RESIDENT OF H.N. K-14/16, NEW GOKAL KA BAGH, 100FT. ROAD,
P.S. ‘B’ DIV, AMRITSAR.

2nd Address:

“INTELLIGIA”, S.C.O. 355, SECTOR 9, PANCHKULA- 134109

(HARYANA)

3RD ADDRESS:

HOUSE NO. 242, 1ST FLOOR, PHASE-II, MOHALI.

........…..RESPONDENT

PETITION UNDER SECTION 125 OF CRIMINAL PROCEDURE

CODE FOR THE MAINTENANCE OF THE PETITIONER

Sir,
 The petitioner respectfully submits as under:

1. That marriage of the petitioner was solemnized with the respondent

on 29-12-2014 at FESTERN ERA, Amritsar according to Sikh Rites
and traditions and marriage was solemnized with great pump and
show and huge amount was spent by the parents of the petitioner
beyond their status and at the time of marriage dowry articles as
well as gold articles were given to the them and their other
relatives. After the marriage both petitioner and respondent
cohabited together as husband and wife at various places.
2. That before the solemnization of marriage ROKA CEREMONY was
performed on 15-08-2014 at HOTEL BEST WESTERN, Amritsar.
The shagun ceremony was also performed before marriage on
27.12.2014 at Grewal Resorts, Amritsar. Lavish arrangement was
organized by the parents of complainants as demanded by the
respondent and his family members. At that time, parents of the
petitioner had given lot of gifts, clothes and gold articles to the
culprits and their relatives in the shape of dowry articles. List of
dowry articles is attached herewith as Annexure A-1)
3. That when all these articles were given to the respondent and his
family members it was specifically told to them that these articles
are istridhan of the petitioner and are for exclusive use in her
matrimonial house. The respondent and his family members also
assured that they will hand over the said istridhan of the petitioner
to her in her matrimonial house for her exclusive use.
4. That the mother and sister of the respondent took all the gold
ornaments of the petitioner in their possession on the pretext to
keep the same in safe custody. On 30.12.2014 when the petitioner
was ready to go for Phera ceremony in the parental house and she
demanded the gold ornaments and cash of Rs. 1,50,000/- from
mother in law, the mother of respondent replied that she kept the
ornaments in her safe custody and out of 1.5 lacs they had utilize
Rs. 1.25 for their own use and further, mother of the respondent
 assured the petitioner the said amount will be returned to the
petitioner.
5. That after the solemnization of marriage petitioner and respondent
culprit cohabited together as husband and wife in the matrimonial
house of the petitioner and soon after the marriage of the petitioner
with respondent, behavior and attitude of the respondent and his
family members was not good towards the petitioner and he used to
taunt, maltreat and tease her. The respondent and his family
members were not satisfied from the dowry articles which were
given by the parents of the petitioner to the respondent and his
family members. Even thereafter, the family members used to
torture by saying that they expect for much more dowry and the
articles which her parents had given to them is of inferior quality
and as such they demanded dowry from the petitioner.
6. That on many occasions when a family member or a relative of the
petitioner used to visit the matrimonial house of the petitioner, the
respondent and his family members began to shout upon the
petitioner and her family members for no reasons. They used to
hurl abuses on the petitioner and her family members in front of the
visiting friends, family members or relative.
7. That After the few days of marriage, petitioner was tortured on
account of demand of dowry by respondent and is family members .
The respondent demanded Hyundai Verna car and cash of Rs.
25,00,000/- for purchasing of new flat in Mohali. When petitioner
told to the respondent that her parents are not in a position to fulfill
the aforesaid demands as they have already spent so much money
in the marriage ceremony and on listening these words from the
mouth of the petitioner, petitioner gave severe beatings. After 15
days of marriage, petitioner and respondent shifted at Mohali and
the behaviour and attitude of the respondent remained the same.
8. That the respondent culprit is habitual drunkard. He used to drink
liquor 2-3 times in a week and gave merciless beatings to the
 petitioner without any reason. In the month of April`2015 the
respondent gave merciless beating to the petitioner and left
shoulder of the petitioner was dislocate due to the severe beating
by the respondent. Thereafter, in the month of Sept`2015, the
petitioner gave merciless beating and turned out of her matrimonial
house at night in three wearing apparels and respondent told to the
petitioner that in case the petitioner wants to live in her matrimonial
house you have to bring car and cash from the parents. At that
time, the petitioner take shelter in the house of her friend and next
day the parents of petitioner reached there and narrated all the
facts to her parents then with the help and intervention of the
respectable and her uncle(mama), petitioner was allowed to live in
her matrimonial house and respondent assured to the parents and
the respectable that he will not taunt and harass to the petitioner
and will not demand for any kind of things. Whenever, parents of
the petitioner came to the matrimonial house of petitioner to meet
her and when they give gave some money to petitioner to spend,
respondent snatched the money and articles from petitioner. The
respondent used to withdraw the money from saving account of
petitioner on various occasion. Petitioner had requested to
respondent many a times but the respondent did not listen the
genuine requests of the petitioner.

9. That the respondent always pressurizes and threaten the petitioner

that he will commit the suicide if the parents of the petitioner will
not fulfill the un-genuine demands and also threaten the petitioner
that he will spoil the future of the petitioner. The respondent used
to lock the petitioner in one room and he did not provide food to the
petitioner. The petitioner had requested to respondent many times
but he did not listen the genuine requests of the petitioner.
10. That it was on 29.11.2015 when petitioner was beaten mercilessly
by the respondent and was turned out the matrimonial house, then
 petitioner came back to house of her parents and she narrated
incident to her parents and then parents of the petitioner along with
respectable had gone to the house of accused to reconcile the
matter but the respondent flatly refused to keep the petitioner with
him and he defame the parents of petitioner and respectable and
also declared that he will not return the dowry/istridhan belonging
to petitioner and had given threats of dire consequences if any one
came to him with such demands and he will also commit suicide by
given the all the names of parents of petitioner.
11. That the family members of the respondent started to pick up
quarrels with the petitioner on petty matters and started abusing
the petitioner and his family. The mother in law and sister in law
picked up quarrels with the petitioner and hurled abuses over the
most frivolous matters on account of which the petitioner had given
merciless beatings to the petitioner. In order to fulfill their illegal
demands they tortured, humiliated and harassed the petitioner
12. That Petitioner has tolerated all the above-said high handedness of
the Respondent and his family members with the hope that better
sense may prevail upon the mind of the Respondent and his family
members but all in vain.

13. That since November` 2015 petitioner is living with her parents at
Amritsar and she has no any movable or immovable property in her
name and she is unemployed and has got no other source of income
to maintain herself and meet the expenses of litigation and all the
expenses and other ancillary expenses borne by the parents of the
petitioner. The petitioner is residing on the mercy of her parents.
14. That the respondent is a man of means he has private job and is
working as a pproject Manager in “INTELLIGAIA” which is
Multinational company situated at Panchkula and is getting salary
more then Rs.70,000/- Per Month beside this respondent is having
other movable and immovable properties in his name. The
 respondent is also having two residential plots in his name and well
furnished Kothi . the respondent is leading luxury life and The father
of the respondent is doing the business of property and earning
very handsome money. The respondent has no liability towards any
of his family member except towards the petitioner.
15. That the respondent has without any reasonable and sufficient
cause has refused and neglected to maintain the petitioner though
he is under moral as well as statutory obligation to maintain the
petitioner according to his status and standard. As such, the
petitioner is entitled to maintenance at the rate of Rs.35,000/- per
month and respondent is directed to directed to pay the same to
the petitioner from the date of filing the petition along with the
litigation expenses. The claimed maintenance and litigation
expenses are very moderate and genuine as prices of everything
are touching the sky and the petitioner requires all the amenities of
life and she is to live according to the status of the respondents.
16. That the petitioner is residing within the jurisdiction of this Hon’ble
court as such this Hon’ble court has got the jurisdiction to entertain,
try and decide this petition.
17. That the requisite court fee is affixed on the petition.

It is, therefore, prayed that respondent may kindly be

directed to pay Rs. 35,000/- per month to the petitioner as
maintenance allowance from the date of petition along with Rs.
25,000/- as litigation expenses may also be granted in favour of

petitioner and against the respondent in the interest of justice,

equity and fair play against the respondent.

…………Petitioner
Date: JASLEEN KAUR

Place: Amritsar. Through counsel

AMIT MONGA, ADVOCATE

AMRITSAR
Verifications:-

Verified that the contents noted above are true to the best of my
knowledge and belief and as per information received and believed.
Verified at Amritsar on ______

(Petitioner)
 IN THE COURT OF ILLAQA MAGISTRATE, AMRITSAR.

AFFIDAVIT

JASLEEN KAUR AGED __ YEARS DAUGHTER OF AMARJEET

SINGH W/O DAVINDER SINGH BHULLAR R/O 19-A, RANI KA
BAGH, AMRITSAR. …..…….PETITIONER

VERSUS

DAVINDER SINGH BHULLAR S/O JARNAIL SINGH BHULLAR

RESIDENT OF H.N. K-14/16, NEW GOKAL KA BAGH, 100FT.
ROAD, P.S. ‘B’ DIV, AMRITSAR.

2nd Address:

“INTELLIGIA”, S.C.O. 355, SECTOR 9, PANCHKULA- 134109

(HARYANA)

3RD ADDRESS:

HOUSE NO. 242, 1ST FLOOR, PHASE-II, MOHALI.

........
…..RESPONDENT
 PETITION UNDER SECTION 125 OF CRIMINAL
PROCEDURE CODE FOR THE MAINTENANCE OF THE
PETITIONER

AFFIDAVIT

I, JASLLEN KAUR DAUGHTER OF AMARJEET SINGH W/O DAVINDER

SINGH BHULLAR AGED _____YEARS R/O H. NO. 19-A, RANI KA BAGH,
AMRITSAR.DO HEREBY SOLEMNLY AFFIRM AND DECLARE AS UNDER

1. That marriage of the petitioner was solemnized with the

respondent on 29-12-2014 at FESTERN ERA, Amritsar

according to Sikh Rites and traditions and marriage was

solemnized with great pump and show and huge amount was

spent by the parents of the petitioner beyond their status and

at the time of marriage dowry articles as well as gold articles

were given to the them and their other relatives. After the

marriage both petitioner and respondent cohabited together as

husband and wife at various places.

2. That before the solemnization of marriage ROKA CEREMONY

was performed on 15-08-2014 at HOTEL BEST WESTERN,

Amritsar. The shagun ceremony was also performed before

marriage on 27.12.2014 at Grewal Resorts, Amritsar. Lavish

arrangement was organized by the parents of complainants as

demanded by the respondent and his family members. At that

 time, parents of the petitioner had given lot of gifts, clothes

and gold articles to the culprits and their relatives in the shape

of dowry articles. List of dowry articles is attached herewith as

Annexure A-1)

3. That when all these articles were given to the respondent and

his family members it was specifically told to them that these

articles are istridhan of the petitioner and are for exclusive use

in her matrimonial house. The respondent and his family

members also assured that they will hand over the said

istridhan of the petitioner to her in her matrimonial house for

her exclusive use.

4. That the mother and sister of the respondent took all the gold

ornaments of the petitioner in their possession on the pretext

to keep the same in safe custody. On 30.12.2014 when the

petitioner was ready to go for Phera ceremony in the parental

house and she demanded the gold ornaments and cash of Rs.

1,50,000/- from mother in law, the mother of respondent

replied that she kept the ornaments in her safe custody and

out of 1.5 lacs they had utilize Rs. 1.25 for their own use and

further, mother of the respondent assured the petitioner the

said amount will be returned to the petitioner.

5. That after the solemnization of marriage petitioner and

respondent culprit cohabited together as husband and wife in

the matrimonial house of the petitioner and soon after the

marriage of the petitioner with respondent, behavior and

attitude of the respondent and his family members was not

good towards the petitioner and he used to taunt, maltreat

and tease her. The respondent and his family members were

not satisfied from the dowry articles which were given by the

parents of the petitioner to the respondent and his family

members. Even thereafter, the family members used to

torture by saying that they expect for much more dowry and

the articles which her parents had given to them is of inferior

quality and as such they demanded dowry from the petitioner.

6. That on many occasions when a family member or a relative of

the petitioner used to visit the matrimonial house of the

petitioner, the respondent and his family members began to

shout upon the petitioner and her family members for no

reasons. They used to hurl abuses on the petitioner and her

family members in front of the visiting friends, family

members or relative.
7. That After the few days of marriage, petitioner was tortured on

account of demand of dowry by respondent and is family

members . The respondent demanded Hyundai Verna car and

cash of Rs. 25,00,000/- for purchasing of new flat in Mohali.

When petitioner told to the respondent that her parents are

not in a position to fulfill the aforesaid demands as they have

already spent so much money in the marriage ceremony and

on listening these words from the mouth of the petitioner,

petitioner gave severe beatings. After 15 days of marriage,

petitioner and respondent shifted at Mohali and the behaviour

and attitude of the respondent remained the same.

8. That the respondent culprit is habitual drunkard. He used to

drink liquor 2-3 times in a week and gave merciless beatings

to the petitioner without any reason. In the month of

April`2015 the respondent gave merciless beating to the

petitioner and left shoulder of the petitioner was dislocate due

to the severe beating by the respondent. Thereafter, in the

month of Sept`2015, the petitioner gave merciless beating

and turned out of her matrimonial house at night in three

wearing apparels and respondent told to the petitioner that in

 case the petitioner wants to live in her matrimonial house you

have to bring car and cash from the parents. At that time, the

petitioner take shelter in the house of her friend and next day

the parents of petitioner reached there and narrated all the

facts to her parents then with the help and intervention of the

respectable and her uncle(mama), petitioner was allowed to

live in her matrimonial house and respondent assured to the

parents and the respectable that he will not taunt and harass

to the petitioner and will not demand for any kind of things.

Whenever, parents of the petitioner came to the matrimonial

house of petitioner to meet her and when they give gave some

money to petitioner to spend, respondent snatched the money

and articles from petitioner. The respondent used to withdraw

the money from saving account of petitioner on various

occasion. Petitioner had requested to respondent many a times

but the respondent did not listen the genuine requests of the

petitioner.

9. That the respondent always pressurizes and threaten the

petitioner that he will commit the suicide if the parents of the

petitioner will not fulfill the un-genuine demands and also

threaten the petitioner that he will spoil the future of the

petitioner. The respondent used to lock the petitioner in one

 room and he did not provide food to the petitioner. The

petitioner had requested to respondent many times but he did

not listen the genuine requests of the petitioner.

10. That it was on 29.11.2015 when petitioner was beaten

mercilessly by the respondent and was turned out the

matrimonial house, then petitioner came back to house of her

parents and she narrated incident to her parents and then

parents of the petitioner along with respectable had gone to

the house of accused to reconcile the matter but the

respondent flatly refused to keep the petitioner with him and

he defame the parents of petitioner and respectable and also

declared that he will not return the dowry/istridhan belonging

to petitioner and had given threats of dire consequences if any

one came to him with such demands and he will also commit

suicide by given the all the names of parents of petitioner.

11. That the family members of the respondent started to pick up

quarrels with the petitioner on petty matters and started

abusing the petitioner and his family. The mother in law and

sister in law picked up quarrels with the petitioner and hurled

abuses over the most frivolous matters on account of which

the petitioner had given merciless beatings to the petitioner.

 In order to fulfill their illegal demands they tortured,

humiliated and harassed the petitioner

12. That Petitioner has tolerated all the above-said high

handedness of the Respondent and his family members with

the hope that better sense may prevail upon the mind of the

Respondent and his family members but all in vain.

13. That since November` 2015 petitioner is living with her

parents at Amritsar and she has no any movable or immovable

property in her name and she is unemployed and has got no

other source of income to maintain herself and meet the

expenses of litigation and all the expenses and other ancillary

expenses borne by the parents of the petitioner. The petitioner

is residing on the mercy of her parents.

14. That the respondent is a man of means he has private job and

is working as a pproject Manager in “INTELLIGAIA” which is

Multinational company situated at Panchkula and is getting

salary more then Rs.70,000/- Per Month beside this

respondent is having other movable and immovable properties

in his name. The respondent is also having two residential

 plots in his name and well furnished Kothi . the respondent is

leading luxury life and The father of the respondent is doing

the business of property and earning very handsome money.

The respondent has no liability towards any of his family

member except towards the petitioner.

15. That the respondent has without any reasonable and sufficient

cause has refused and neglected to maintain the petitioner

though he is under moral as well as statutory obligation to

maintain the petitioner according to his status and standard.

As such, the petitioner is entitled to maintenance at the rate of

Rs.35,000/- per month and respondent is directed to directed

to pay the same to the petitioner from the date of filing the

petition along with the litigation expenses. The claimed

maintenance and litigation expenses are very moderate and

genuine as prices of everything are touching the sky and the

petitioner requires all the amenities of liofe and she is to live

according to the status of the respondents.

16. That the petitioner is residing within the jurisdiction of this

Hon’ble court as such this Hon’ble court has got the

jurisdiction to entertain, try and decide this petition.

17. That the requisite court fee is affixed on the petition.

DEPONENT

VERIFICATION;-

Verified that the contents of above Affidavit are true and correct to

the best of my knowledge and belief and nothing has been

concealed therein.

Verified at Amritsar on ______________

DEPONENT

IN THE COURT OF ILLAQA MAGISTRATE, AMRITSAR

 JASLEEN KAUR versus DAVINDER

SINGH

(Petition Under Section 125 of Cr.P.C..)

APPLICATION FOR GRANT OF INTERIM MAINTENANCE.

Sir,

The petitioner respectfully submits as under:

1. That the above-said Petition is pending in this Honble Court and

is fixed for today.

2. That the detailed facts have been stated in the enclosed Petition ,

contents of which may kindly be read as a part and parcel of this

para.

3. That on account of facts stated in the Petition the Petitioner /

Applicant has got prima facie case to succeed.

4. That the respondent is a man of means he has private job and is

working as a project manager in “INTELLIGAIA” company at

 Panchkula and is getting salary more then Rs.70,000/- Per Month

beside this respondent is having other movable and immovable

properties in his name. The respondent is also having two

residential plot in his name. The father of the respondent is doing

the business of property and earning very handsome money. The

respondent has no liability towards any of his family member

except towards the petitioner..

5. That even otherwise the Respondent is duty bound to maintain

the Petitioner. On the other hand the Petitioner is not doing any

work and is totally dependent upon her father. Moreover the

Petitioner is not having any movable or immovable property in

her name which can yield income.

6. It is, therefore, prayed that respondent may kindly be directed to

pay Rs.50,000/- per month to the petitioner as maintenance

allowance and education expenses from the date of petition

along with Rs. 25,000/- as litigation expenses in favour of

petitioner in the interest of justice, equity and fair play against

the respondent.

…………Petitioner

Date: JASLEEN KAUR

Place: Amritsar.
Through counsel

AMIT MONGA,
ADVOCATE
AMRITSAR

IN THE COURT OF ILLAQA MAGISTRATE, AMRITSAR

KASLEEN KAUR versus DAVINDER SINGH

(Petition Under Section 125 of Cr.P.C..)

APPLICATION FOR GRANT OF INTERIM MAINTENANCE.

AFFIDAVIT
 I, JASLLEN KAUR DAUGHTER OF AMARJEET SINGH W/O DAVINDER
SINGH BHULLAR AGED _____YEARS R/O H. NO. 19-A, RANI KA BAGH,
AMRITSAR.DO HEREBY SOLEMNLY AFFIRM AND DECLARE AS UNDER

1. That the above-said Petition is pending in this Honble Court

and is fixed for today.

2. That the detailed facts have been stated in the enclosed

Petition , contents of which may kindly be read as a part

and parcel of this para.

3. That on account of facts stated in the Petition the Petitioner /

Applicant has got prima facie case to succeed.

7. That the respondent is a man of means he has private job and is

working as a project manager in “INTELLIGAIA” company at

Panchkula and is getting salary more then Rs.70,000/- Per Month

beside this respondent is having other movable and immovable

properties in his name. The respondent is also having two

residential plots in his name. The father of the respondent is

doing the business of property and earning very handsome

money. The respondent has no liability towards any of his family

member except towards the petitioner.

4. That even otherwise the Respondent is duty bound to

maintain the Petitioner. On the other hand the Petitioner is

not doing any work and is totally dependent upon her father.

Moreover the Petitioner is also not having any movable or

immovable property in her name which can yield income.

DEPONENT

VERIFICATION;-

Verified that the contents of above Affidavit are true and

correct to the best of my knowledge and belief and nothing
has been concealed therein.

Verified at Amritsar on ______________

DEPONENT