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 .