IN THE COURT OF LD.

CMM COURT, EAST

DISTRICT, KARKARDOOMA COURT, DELHI.

DOMESTIC VIOLENCE CASE NO._________/2021

IN THE MATTER OF:

SMT. REGIS ………….COMPLAINANT

VERSUS

SH.PRAVEEN@RINKU & OTHERS ...………RESPONDENTS

PS :- MANSAROVAR PARK

INDEX

S. No. Particulars Pages C.F.

1. Memo of Parties

2. Complaint U/s 12 of Domestic

Violence Act, 2005 along with

Affidavit

3. Application U/s 23(2) of

Domestic Violence Act, 2005

along with Affidavit

4. List of documents with

documents

5. Vakalatnama

COMPLAINANT

DELHI THROUGH

DATED:

[RAJKUMAR RAJE & ASSOCIATES]

Advocates

Ch. No.563-A, W. Wing,

Tis Hazari Court, Delhi-110054

Mob. 9871837630. 8076320768

Email:-rajkumarraje80@gmail.com
 IN THE COURT OF LD. CMM COURT, EAST
DISTRICT, KARKARDOOMA COURT, DELHI.

DOMESTIC VIOLENCE CASE NO._________/2021

MEMO OF PARTIES

SMT. REGIS

D/O LATE VIJAY PAL SINGH

W/O SH. PRAVEEN @ RINKU

R/o A-55 GALI NO. 7,

NEW JAGAT PURI EXTN, SHAHDARA,

NORTH EAST, DELHI 110093 ……COMPLAINANT

VERSUS

1. SH. PRAVEEN @ RINKU

2. RAM BABU

3. GEETA DEVI W/O RAM BABU

4. PRIYANKA D/O RAM BABU

5. MONA D/O RAM BABU

6. NIRANJAN LAL
 7. VIJAY KUMAR

8. VINOD KUMAR

9. BUNTY S/O NIRANJAN

R/O ITI COLONY, POWER

HOUSE NEAR PETROL PUMP CHANDOSI

DISTRICT SHAMBAL U.P ………RESPONDENTS

DELHI THROUGH

DATED:

[RAJKUMAR RAJE & ASSOCIATES]

Advocates

Ch. No.563-A, W. Wing,

Tis Hazari Court, Delhi-110054

Mob. 9871837630. 8076320768

Email:-rajkumarraje80@gmail.com
 IN THE COURT OF LD. CMM COURT, EAST
DISTRICT, KARKARDOOMA COURT, DELHI.

DOMESTIC VIOLENCE CASE NO._________/2021

MEMO OF PARTIES

SMT. REGIS

D/O LATE VIJAY PAL SINGH

W/O SH. PRAVEEN @ RINKU

R/o A-55 GALI NO. 7,

NEW JAGAT PURI EXTN, SHAHDARA,

NORTH EAST, DELHI 110093 ……COMPLAINANT

VERSUS

1. SH. PRAVEEN @ RINKU

2. RAM BABU

3. GEETA DEVI W/O RAM BABU

4. PRIYANKA D/O RAM BABU

5. MONA D/O RAM BABU

6. NIRANJAN LAL

7. VIJAY KUMAR

8. VINOD KUMAR

9. BUNTY S/O NIRANJAN

R/O ITI COLONY, POWER

HOUSE NEAR PETROL PUMP CHANDOSI

DISTRICT SHAMBAL U.P ……RESPONDENTS

APPLICATION U/S 12, 18, 19, 20 AND 22 OF PROTECTION

OF WOMEN FROM DOMESTIC VIOLENCE ACT,

2005(AMENDED UPTO 43 OF 2005)

MOST RESPECTFULLY SHOWETH:

1- That the application Under Section 12, 18, 19, 20 and 22 of

Protection of Women from Domestic Violence Act, 2005 (43

of 2005) is being filed by the aggrieved person/applicant

against the respondent along with domestic incident report.

a) Aggrieved person:

SMT. REGIS

D/O LATE VIJAY PAL SINGH

W/O SH. PRAVEEN @ RINKU

R/o A-55 GALI NO. 7, NEW JAGAT PURI EXTN,

SHAHDARA, NORTH EAST DELHI 110093

2- It is prayed that this Hon’ble Court may be pleased to take

cognizance of the complaint (attached with the complaint)

and pass all/any of the orders, as deemed necessary in the

circumstances of the case.

a) Pass Protection order U/S 18 and/or

b) Pass Residence order U/s 19 and/or

c) Direct the respondent No.1 to pay monetary relief U/s 20

and or

d) Direct the respondents to grant compensation or damages

U/s 22 and/or

e) Pass orders to grant interim and ex-parte orders U/s 23(1) &

(2) and/or

f) Pass any other or further order/s as deems fit in the

circumstances of the case.

ORDERS REQUIRED

(i) Protection Order under Section 18.

(a) Prohibiting acts of domestic violence by granting an

injunction against the respondents from repeating any of the

 acts mentioned in statements of facts/ domestic incident

report of the application.

(b) Prohibiting any form of communication by the respondents

with applicant/aggrieved person.

(c) Prohibiting alienation of assets by the respondents.

3. Any other order(s), please specify;

Order may be against the respondents restraining them from

any of the acts mentioned above under clause (3) because domestic

violence as defined under Section 2(g) read with Section 3 of the

Act has unrestrictedly become the order of day.

(ii) RESIDENCE ORDER UNDER SECTION 19

(a) Dispossess and thrown out the applicant/aggrieved person

and her husband from the shared household. The aggrieved

person/applicant is presently living with her parents at A-55

GALI NO. 7, NEW JAGAT PURI EXTN, SHAHDARA NORTH

EAST Delhi-110092 and the applicant/aggrieved person is

entitled for her share in her matrimonial house situated in ITI

COLONY, POWER HOUSE NEAR PETROL PUMP CHANDOSI

DISTRICT SHAMBAL U.P.

(b) Entering that portion of the shared household in which the

applicant/aggrieved person resides.

(c) The respondents and their associates be restrained from

entering disturbing the applicant/aggrieved person from her

living house at ITI COLONY, POWER HOUSE NEAR

PETROL PUMP CHANDOSI DISTRICT SHAMBAL U.P.

(d) Renouncing their rights in the shared household.

(e) Secure same level of alternate accommodation or pay rent

for the same to the applicant/aggrieved person.

(f) Any order restraining respondents from alienating/disposing

encumbering the shared household/ matrimonial house and

the plots.

Therefore, an ex-parte order is very much necessary and this

Hon’ble Court may kindly direct the respondent No. 1 and 9

to dispose their assets. The respondent No.1 and 9 may also

be directed to disclose their assets by filing a list of the same

duly supported by an affidavit.

The Respondent No. 1 to 9, never allowed the aggrieved

person/applicant to have access to her personal belongings

such as her gold and silver jewellery, Stridhan and other

articles worth Rs. 2 lakhs, which have been given by the

 parents of the aggrieved person to the respondents at the

time of marriage. Therefore, the respondents may kindly be

directed to return personal belongings and amount cheated

by respondents to the aggrieved person/applicant to her as

per list of articles.

g) The Respondent No. 1 to 9 may kindly be directed not to

disposed sell, and alienate their moveable and immovable

properties.

h) Any other order please specify;

The respondents may be directed to return stridhan articles

including Gold and Silver jewellery articles of the aggrieved

person/applicant worth Rs.2 lakhs. They may also be

directed to not repeat the violence (physical, mental and

sexual etc.) threat of selling properties and assets etc.

adopting any short of torturing tactics on the aggrieved

person/applicant and also the respondent may be directed to

stop violence and totally deprive themselves from acting any

other act/omission, which lead to the hurdles/disturbances to

the peaceful life of the aggrieved person/applicant.

i) Any such order of further orders as this Hon’ble Court may

deem fit in the facts and circumstances of the case and in the

interest of justice.

(iii) MONETARY RELIEF UNDER SECTION 20

Loss due to destruction/damage or removal of property from

the aggrieved person/applicant.

Amount Claimed Rs. 10, 00,000/- (Rupees Ten lac only).

Any other amount in the form of damages, which this

Hon’ble Court deems fit in the facts and circumstances of

the case, may also be passed.

iv). MONETARY RELIEF UNDER SECTION 20

Directing respondent no.1 to pay following monthly

expenses as monetary relief:

1. Food, clothes, shelter, medication, allowance, for other

basic amenities Rs. 20,000/- (Rupees Twenty Thousand

only).

2. Any other order as may be incurred by the aggrieved person

from time to time during the trial of this case.

(vi) COMPENSATION UNDER SECTION 22

 The respondents be directed to pay of Rs. 10, 00,000/-

(Rupees Ten Lakhs only) to the aggrieved person/applicant

for mental torture and emotional distress caused by the acts

of domestic violence committed by the respondents.

DETAILS OF DOMESTIC VIOLENCE

The Petitioners respectfully submits as under:

1. That the marriage between the Petitioner and the respondent

was solemnized on 28/04/2019, according to Hindu rites and

ceremonies at Delhi.

2. That the marriage between the petitioner and respondent was

consummated and the both lived as husband and wife.

3. That the petitioner was welcomed in the matrimonial house,

but after some time the attitude /behavior of the respondent

and his family members changed/turned towards the

Petitioner and started abusing and harassing the Petitioner on

one pretext or the other.

4. That the respondent has been ill-treated the petitioner in all

respect to spoil the matrimonial life of the petitioner.

5. That petitioner is always maltreated by respondent and his

family members ,sister in laws of the petitioner told her that

you are not allow to do anything without our permission even

 you are not allow to take/made food. That the respondent is a

habitual drunker, he daily drunk the alcohol/liquor and beats

the petitioner without any reason and rhyme.

6. That the respondent and his family members always harass

the petitioner for less dowry, and mother in laws and sister in

laws maltreat the petitioner for child.

7. That the respondent even sleep with other family members

except petitioner still all respondent harass or torture the

petitioner you are not capable for give birth to child.

8. That the petitioner tolerate all atrocities, humiliations,

harassment, mental and physical pain and agony in the hope

that everything will be alright one day.

9. That the respondent leading a luxury life and he is private

teacher and take tuition at home his monthly income is about

Rs. 40,000/-but respondent never pay single penny to the

petitioner.

10. That the conduct of the respondent and his family members

towards petitioners were very cruel and unbearable in all

respect.

11. That the respondent has no other liability except to maintain

the Petitioners, also the respondent is legally and morally

 bounded to maintain the Petitioners as he is competent to pay

the sufficient amounts for the maintenance to Petitioners, but

the respondent/ husband is ignoring the same. Hence the

petitioners are living hard life.

12. That the Petitioners require maintenance the respondent is

capable to pay the same.

13. That the cause of action arose on several occasion to file this

present petition as mentioned above.

14. That the petitioners are now living with parents R/o A-55

Gali No. 7, New Jagat Puti Extn, Shahdara, Mandoli North

East Delhi - 110093 which lies in the territorial jurisdiction of

this Hon’ble Court and the marriage was also solemnized

within the jurisdiction of this Hon’ble Court. Hence this

Hon’ble Court has the jurisdiction to try and entertain the

present petition.

15. That the petition is not presented in collusion with

respondent.

16. That there is no other legal impediment to the relief claimed

by the petitioners.

17.That no similar petition is pending in any other courts.

 18.That the aggrieved person/applicant has in this regard filed

the several complaints against the Respondent No.1 to 9 by

no action had been taken by the police or administrations.

The applicant have filed the following complaints against the

respondents, which are given below:-

1. Complaint to C.A.W, SEEMA Dated 24.09.2021

PURI

2. Complaint to S.H.O , PS- Dated 24.09.2021.

MANSAROVAR PARK, DELHI

The copies of the Complaints of the applicant are annexed

herewith as ANNEXURE.

19. That the respondent no.1 to 9 since last month, has been

harassing abusing and intimidation complaint to withdraw

complaint which is filed against the respondents at Police

Station Mansarovar Park and C.A.W, SEEMA PURI,

otherwise she will have to face serious consequences. The

respondents have been committing acts of domestic violence

against the applicant.

20. That during the stay of complainant at her matrimonial

home, the respondents in connivance and in collusion with

 each other have committed domestic violence upon the

complainant mentally, physically, sexually and emotionally

and have subjected her to mental, physical and economic

abuse for which the complainant claims a sum of

Rs.10,00,000/- as compensation.

21. That the aggrieved person/applicant is residing at the

abovementioned address i.e. A-55 GALI NO. 7, NEW

JAGAT PURI EXTN, SHAHDARA, MANDOLI NORTH

EAST DELHI 110093 which falls within the jurisdiction of

this Hon’ble Court, hence this court has the jurisdiction to

try and entertain this petition.

PRAYER

It is, therefore, most respectfully prayed that this Hon’ble

Court may be pleased to grant the protection order U/s 18(a), (b),

(c), (d), (e) and (f) be passed thereby prohibiting the respondents

from committing, aiding or abetting in the commission of acts of

Domestic Violence, alienating her Stridhan without the leave of the

magistrate and causing violence to other relative or any person who

given the assistance to the aggrieved person and prohibiting the

respondents from attempting to communicate in any form, with the

complainant and prohibit the respondents from entering in her hare.

And the relief(s) claimed therein and pass such order or orders as

this Hon’ble Court may deem fit and proper under the given facts

and circumstances of the case for protecting the aggrieved person

from domestic violence and in the interest of justice.

It is further prayed that the protection U/s 19 be passed and

complainant be given right of residence at her shared household as

the complainant wants to reside at her shared matrimonial house.

The respondents be also prohibited from dispossessing or throwing

the complainant and her articles from jointly owned household and

also prohibit the respondents from alienating/ dispossessing the

shared household.

It is further prayed that the protection orders U/s 22 be

passed and respondents be directed to pay a compensation to the

tune of Rs. 10,00,000/-to the complainant for the injuries causing

mental and physical torture, emotional distress, harassment,

humiliation, economic abuses and agonies caused by the acts of

Domestic Violence committed upon the complainant by the

respondents.

Any other order which this Hon’ble Court deems fit and

proper may also be passed in favour of the complainant and against

the respondent No. 1 to 9.

COMPLAINANT

DELHI THROUGH

DATED:

[RAJKUMAR RAJE & ASSOCIATES]

Advocates

Ch. No.563-A, W. Wing,

Tis Hazari Court, Delhi-110054

Mob. 9871837630. 8076320768

Email:-rajkumarraje80@gmail.com

VERIFICATION:

Verified at Delhi on this ____ day of Sept-2021, that the

contents of the complaint are true and correct to the best of my

knowledge and nothing material has been concealed therefrom.

COMPLAINANT
 IN THE COURT OF LD. CMM COURT, EAST
DISTRICT, KARKARDOOMA COURT, DELHI.

DOMESTIC VIOLENCE CASE NO._________/2021

IN THE MATTER OF:

SMT. REGIS ……..COMPLAINANT

VERSUS

SH. PRAVEEN@RINKU AND OTHERS ….. RESPONDENTS

AFFIDAVIT

I Smt. Regis W/O Parveen @ Rinku D/o Late. Sh. Vijay Pal R/o

A-55 , Gali No- 7, New Jagat Puri Extn, Shahdara , North East

Delhi- 110093, do hereby solemnly affirm and declare as under:

1. That deponent is the complainant in the above noted petition

and well conversant with the facts and circumstances of the

case and as such competent to swear this affidavit.

2. That the accompanying Complaint U/s 12 of DV Act, 2005

has been drafted by my counsel under my instructions and

has been read over and explained to me in vernacular

 language in Hindi and same are true and correct to the best of

my knowledge and same may kindly be treated as a part and

parcel of this affidavit too and as such the same is not being

reproduced herein for the sake of brevity.

DEPONENT

VERIFICATION

Verified at Delhi on this ___ day of December 2021, that the

contents of para No.1 to 2 of my above affidavit are true and

correct to the best of my knowledge and belief and nothing has

been concealed therefrom.

DEPONENT
 IN THE COURT OF LD. CMM COURT, EAST
DISTRICT, KARKARDOOMA COURT, DELHI.
0C

DOMESTIC VIOLENCE CASE NO._________/2021

IN THE MATTER OF:

SMT. REGIS ……..COMPLAINANT

VERSUS

SH. PRAVEEN@RINKU AND OTHERS ….. RESPONDENTS

APPLICATION UNDER SECTION 23 OF

PROTECTION OF WOMEN FROM DOMESTIC

VIOLENCE ACT FOR INTERIM AND EX-

PARTE ORDER/RELIEF.

MOST RESPECTFULLY SHOWETH:-

1. That the applicant has filed a complaint under section 12 of

protection of women from domestic violence Act. The

contents of the same may kindly be read as part and parcel of

this application as the same are not repeated herein for the

sake of brevity.
2. That the respondent No.1 is doing private work as a teacher

and tuition at home is earning about Rs. 40,000/- per month.

He is enjoying all the comforts of a luxurious life.

3. That the respondent no.1 is not paying anything to the

complainant for day to day needs and requirements. Now the

complainant is living on the mercy of others.

4. That now the complainant requires at-least a sum of

Rs.20,000/- towards the maintenance to herself.

5. That the accompanying complaint/ application prima-facie

discloses that respondents are committing and has

committed acts of domestic violence. So through the

medium of present application, applicant prays that an ex-

parte order be granted U/s 18, 19, 20 and 22 of the Act

against the respondent.

PRAYER

It is, therefore prayed that an ex-parte order may kindly be

passed in favor of the complainant and against the respondents U/s

18,19,20 and 22 of the protection of women from domestic

violence Act;

Pass any other order as this Hon’ble Court may deem fit and

proper under the given facts and circumstances of the case for

protecting the aggrieved person from domestic violence, in the

interest of justice.

APPLICANT/COMPLAINANT

DELHI THROUGH

DATED:

[RAJKUMAR RAJE & ASSOCIATES]

Advocates

Ch. No.563-A, W. Wing,

Tis Hazari Court, Delhi-110054

Mob. 9871837630. 8076320768

Email:-rajkumarraje80@gmail.com
 IN THE COURT OF LD. CMM COURT, EAST
DISTRICT, KARKARDOOMA COURT, DELHI.

DOMESTIC VIOLENCE CASE NO._________/2021

IN THE MATTER OF:

SMT. REGIS ……..COMPLAINANT

VERSUS

SH. PRAVEEN@RINKU AND OTHERS ….. RESPONDENTS

AFFIDAVIT

I Smt. Regis W/O Parveen @ Rinku D/o Late. Sh. Vijay Pal R/o

A-55 , Gali No- 7, New Jagat Puri Extn, Shahdara , North East

Delhi- 110093, do hereby solemnly affirm and declare as under:

1. That deponent is the complainant in the above noted petition and

well conversant with the facts and circumstances of the case and

as such competent to swear this affidavit.

2. That the accompanying Application U/s 23 of DV Act, 2005 has

been drafted by my counsel under my instructions and has been

read over and explained to me in vernacular language in Hindi

 and same are true and correct to the best of my knowledge and

same may kindly be treated as a part and parcel of this affidavit

too and as such the same is not being reproduced herein for the

sake of brevity.

DEPONENT

VERIFICATION

Verified at Delhi on this ___ day of December 2021, that the

contents of para No.1 to 2 of my above affidavit are true and

correct to the best of my knowledge and belief and nothing has

been concealed therefrom.

DEPONENT