PETITION BY WIFE UNDER SECTION 125, Cr PC FOR MAINTENANCE
IN THE COURT OF ____________ JUDICIAL MAGISTRATE 1ST CLASS
Case No. ___________ under Sec. 125, Cr PC
Petitioner W (wife) _______________
Daughter of _______________
Village _______________
Thana _______________
Occupation _______________
Opposite Party H (husband) _________
VERSES
Son of _______________
Village _______________
Thana _______________
Occupation _______________
In the matter of maintenance petition of petitioner W from the husband H per sec. 125, Cr PC the above name petitioner.
Respectfully:
1. Petitioner W being married wife of opponent party, they married according to the Hindu rites on.
2. The opponent party H being a clerk on the staff of AB & Co. Ltd. holding a responsible position and drawing a salary of Rs. 8000 per month.
3. The opponent party strongly attacked the petitioner on _______________ and drove her away from the matrimonial house on ____________ before various gentlemen of the vicinity.
4. That the opponent party leading a life of drunkenness and habitual lewdness. He is beside a man of uncertain temperament and become enraged season and out of season without any reason whatever. He has lost all sense of decorum and uses abusive language.
5. Petitioner after having being driven out of the house by the opponent party came to her father's place on the same day and staying there in his family members.
6. The opposition party was served with a pleader's notice for remitting petitioner Rs. 900 monthly for maintaining her but without effect. Having regard to the violent temper of H and his inhuman type of beating petitioner she does not dare to go back to the place of the opposite party.
Petitioner hence prays that Your Honour may be pleased to issue notice on the opposing party and after leading evidence of both sides is pleased to order the opponent party for paying petitioner maintenance at the rate of Rs. 900 monthly. And petitioner, as in duty bound, shall ever pray.
VERIFICATION
I, (W), daughter of _________________ resident of ____________ do hereby solemnly affirm on oath say as under:
1. I being petitioner above-named and I know the facts/circumstances of the case and I am able to depose thereto.
2. The statements in the paragraphs 1, 2, 3, 4, 5 and 6 of the foregoing petition are true to my best knowledge and that I have not suppressed any material facts.
Solemnly affirmed by the said Mrs. (W)on the _________ day of _______ in the Court House at (Name of Place).
Before me
Notary