IN THE COURT OF MS. DEEPTI DEVESH LD. MM KARKARDOOMA COURTS, .

Complaint No.293/2019

In Re:

Smt. Wife Name ...Complainant

Versus

Sh. Husband Name & Ors. ...Respondents

D.O.H. 20.02.2021

APPLICATION ON BEHALF OF THE RESPONDENT UNDER

SECTION 91 CRPC

MOST RESPECTFULLY SHEWETH:-

1. That the above said case is pending before this Hon'ble

Court and the same is fixed for XXXX

2. That the petitioner has filed the petition under Domestic

Violence act and has prayed for Maintenance by showing

herself as a housewife and nonworking lady before this

Hon’ble court.

3. That the petitioner has been misleading and

misrepresenting the court by presenting the distorted

facts in order to take undue advantage from this Hon’ble

Court. The petitioner has not come to the court with

clean hands and is trying to mislead the court so that

she can avoid her responsibilities towards the

Respondent. 4. That the petitioner in her petition as well as in her

detailed affidavit has concealed the material facts from

the Hon’ble Court the she previously worked with “Name

of Organization” as an Tele-Sales Executive & currently

she is working in Dena Bank as Assistant Manager, and

is earning Rs.50,000/- (Approx) per month and this

information of the same has been concealed by the

petitioner.

5. That the petitioner herself has admitted in case u/s

498A/406/34 IPC PS Seemapuri in FIR No.786/2020,

that she is doing private service in her two statements

u/s 161 Cr. P.C. on 7.09.2020 and 31.12.2020

respectively, and the same facts has been concealed by

the petitioner in her petition.

6. That the petitioner herself denied to join the company of

respondent a statement in this regard was recorded by

the Family Court, of Delhi u/s 9 HMA, on dated

21.01.2020 the before Learned Principal Judge Family

Court. (Copy of order alongwith statement is enclosed

herewith in the list of Documents (page No.26-28) for

kind perusal of this Hon’ble Court.

7. That to in order to bring the truth and avoid the

confusion and unnecessary delay the respondent seeks

to summon why she does not wish to lead a conjugal life with respondent and actual financial status of the

petitioner, following records may kindly be summoned :- a) Record clerk of MaxBupa health Insurance Company

Limited, 2nd Floor, the centerstage mall shop no.18 & 28,

mezzanine floor/2nd floor, Plot No.1, /block L Sector 18,

Noida, Gautam Budh Nagar, Uttar Pradesh – 201301

with complete record of offer letter/joining letter,

monthly gross and net salary, TA/DA/HRA and other

benefits and incentives, designation and details of bank

accounts in which the salary is/was being transferred to

Ms. Wife Name D/o Sh. Wife Father Name R/o 14/2,

Address______, Delhi – 110051. b) Record clerk of Axis Bank Ltd. 4th Floor, Tower 2, Axis

House, Jaypee Wish Town, Sector 128, , Uttar

Pradesh – 201304 with complete record of offer

letter/joining letter, monthly gross and net salary,

TA/DA/HRA and other benefits and incentives,

designation and details of bank accounts in which the

salary is/was being transferred to Ms. Wife Name D/o

Sh. Father Name R/o Address______– 110051. c) The complete details/ entire record of working of Ms.

Wife Name D/o Sh. Wife Father Name R/o Address

______, Delhi – 110051 from the office of

employees provident funds organization ministry of

labour and employment govt. of through regional PF Comiisiionor-1, employees provident fund

organization regional office master Tara Singh Nagar,

opposite govt. girls school, laddo wali road, Jalandhar,

Punjab. d) The complete details/ entire record of State Bank of

India, Accounts No. 00000000000, Branch ,

Delhi of Ms. Wife Name D/o Sh. Wife Father Name R/o

Address______, Delhi – 110051 from the

State Bank of India since the date of account opening to

till date, along with entire documents used to open the

account, along with the debit or credit card issued to

Ms. Wife Name. e) The complete details / entire record of November 2019

from Noor Mehal five star Hotel, Karnal, Haryana of Ms.

Wife Name D/o Sh. Wife Father Name R/o Address

______, Delhi – 110051, check-in and

check-out, with all the booking details and payment

details and mode of payment. f) The petitioner may kindly be directed to furnish the

details of her other bank accounts / Paytm accounts

and all other moveable and immovable properties and

assets in her name.

Prayer It is, therefore most respectfully prayed that this

Hon’ble Court may kindly be pleased to allow to summon

the witnesses with relevant records in order to bring the

truth before this Hon’ble Court and Pass any other order,

direction or relief which this Hon’ble Court deem fit in the

favor of the respondent and against the petitioner in the

interest of justice.

It is prayed accordingly.

Delhi Respondent

Dated______Through

Advocate

Advocate Name or Party in Person Name IN THE COURT OF MS. DEEPTI DEVESH LD. MM SHAHDARA DISTRICT KARKARDOOMA COURTS, DELHI.

Complaint Case No. ______/2019 In Re: Smt. Wife Name …Complainant Versus Sh. Husband Name & Ors. ...Respondents D.O.H. 20.02.2021 Affidavit

I, Husband Name S/o Father Name R/o House No.2520,

Aazad Colony, , 121005, Haryana, do hereby solemnly affirm and declare as under:

1. That I am the petitioner in the above noted matter and

am well conversant with the facts and circumstances of

the case and also competent to file the present affidavit.

2. That the accompanying application u/s 91 Cr. P.C. has

been drafted by my counsel under my instructions, I

have gone through contents of the same and the same

are explained in vernacular and are true and correct to

the best of my knowledge and belief. The same may be

read as part and parcel of this affidavit.

DEPONDENT

VERIFICATION:-

Verified at Delhi on this 19th day of February, 2021, that the contents of above affidavit are true and correct to my knowledge and nothing material has been concealed therefrom.

DEPONDENT