IN THE COURT OF MS. DEEPTI DEVESH LD. MM SHAHDARA DISTRICT KARKARDOOMA COURTS, DELHI.
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 Saket 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, Noida, 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 India 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 Laxmi Nagar,
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, Faridabad, 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