IN THE COURT OF _____________, LEARNED METROPOLITAN MAGISTRATE, MAHILA COURT, __________ COURTS, NEW DELHI
COMPLAINT CASE NO. ____ OF 20__
IN THE MATTER OF :
________________________________ COMPLAINANT
VERSUS
________________________________ RESPONDENT
WRITTEN ARGUMENT ON BEHALF OF THE COMPLAINANT IN APPLICATION U/S 12 R/W SECTION 17, 18, 19, 20, 22 OF PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005 FOR GRANT OF RIGHT TO CONTINUE RESIDING IN THE MATRIMONIAL HOUSE WITHOUT INTERFERENCE AND THREAT, PROTECTION ORDERS, MONETARY RELIEF, COMPENSATION AND ANY OTHER RELIEF WHICH THIS HON'BLE COURT MAY DEEM FIT AND PROPER.
MOST RESPECTFULLY SHOWETH:
1. That the above noted complaint is pending adjudication before this Hon'ble Court and is fixed for hearing on ____________.
2. That the summons of the complaint has already been issued to the defendants and the defendants have also put in appearance in the matter.
3. That the Defendant has filed his reply to the complainant and the Complainant has filed rejoinder to it on ______.
4. That the Complainant has filed affidavit showing income and expenditure as per the format prescribed by the Hon'ble High Court of Delhi in Kusum Sharma Vs. Mahinder Kumar Sharma on _______.
5. That the Defendant has also filed his affidavit showing income and expenditure on __________, but not filed copy of Latest Income Tax Return i.e. for Financial Year __________).
6. The Complainant most respectfully submit the following written arguments in support of contentions, submissions and facts already placed and submitted on the records and the oral arguments so adduced.
7. That the Complainant got married to the Respondent on ____________ in accordance with Hindu rites and ceremonies at _____. No issue was born from this wedlock.
8. That the Respondent is working as Manager with ___________ India Ltd at __________. The Complainant came to live in the matrimonial home at New Delhi with the Respondent after Marriage.
9. The father of the Complainant had given Rs. ______ in Tilak to the Respondent. In addition to this, an __ car was given. The marriage was a lavish affair. Lots of gifts, jewellery etc was given by her father who is a retired school teacher and had to sell some property, borrow from others and exhaust all his savings to arrange the marriage of the complainant.
10. That the respondent husband, his father and sister were not happy with the Dowry and other gifts. They have showed their annoyance soon after marriage.
11. The Respondent started tormenting her almost immediately after marriage. He used to poke and provoke her and instigated her to react to his misdemeanor and later record the same on his mobile phone.
12. That as per the affidavit the Respondent is earning Gross income of Rs. _________/- per year. The Respondent not yet produced his income tax Return for the Financial Year _____ to ascertain his current income. Even though the Respondent is earning huge salary the complainant had to starve for money even for her basic needs. Her father used to help her by sending money even for the daily necessaries.
13. That the Complainant had no history of illness of any kind before marriage. The Respondent/husband by his cruel and atrocious behavior, assisted by his sister tormented her so much that she went into depression.
14. That the complainant was the target of unprovoked physical and mental abuse by the Respondent. The father in law of the complainant had also created very embarrassing and inexplicable situations at times.
15. That the respondent constantly made indecent and vulgar comments about the sister of the complainant, who still leaves with her as she has not come out of depression completely and the doctor advised that she should not be left alone.
16. That the Respondent has denied conjugal relations to the Complainant. He says that the complainant does not meet his level of liking. The respondent picks up quarrels on the flimsiest of excuses.
17. That on _______, the respondent
