IN THE COURT OF {Judge} {Place}
COMPLAINT CASE NO. {case no.}
IN THE MATTER OF:
{name} COMPLAINANT
VERSUS
{name} RESPONDENTS
APPLICATION U/S 340 READ WITH SECTION 195 CrPC ON BEHALF
OF THE RESPONDENT NO.1
MOST RESPECTFULLY SHOWETH:w
w
That the above named complainant has filed a complaint under {name the
case with case no.} the complaint is pending before this Hon'ble Court
and the same is fixed for {NDOH}
That the petitioner has filed the petition with accompanying affidavit for
grant of maintenance, along with other reliefs against the respondent. A
copy of the application moved by the Petitioner in the case {name of the
other case} is attached herewith and is marked as Annexure ¢,
That in the above said matter: the complainant filed the income affidavit
before this Hon'ble Court. The copy of the income affidavit is annexed
herewith as Annexure ‘B? for kind perusal of this Hon'ble Court.
That the complainant has committed perjury by deliberately omitting the
material facts, concealing the fact of her income in her supporting affidavit
wherein she has misstated her income.That the Petitioner during the course of judicial proceedings has
deliberately and consciously furnished the false information on affidavit
and verification clause with the sole intention to mislead this Hon'ble
court for undue, unjust. unwarranted gain and relief from her main petition
and to take undue advantage of the provisions.
That the Petitioner has concealed the following material facts and
information from this Hon'ble Court which was in the actual andconstructive knowledge of the Petitioner and the Petitioner did not
disclose the same. The following are the concealment of material facts:-
a. {mention facts}
b. {mention facts}
It is, therefore, most respectfully prayed that the contempt proceedings be
initiated against the complainant and the application w/s 340 read with
section 195 CrPC be taken into consideration and FIR be registered
against the Petitioner for not disclosing the tme facts to the court.
Any other order which this Hon'ble Court may deem fit and proper
under the facts and circumstances may kindly be passed in favor of the
Respondent and against the complainant.Any other order which this Hon'ble Court may deem fit and proper
under the facts and circumstances may kindly be passed in favor of the
Respondent and against the complainant.
DELHI. Respondent no.1
DATED THROUGH
ADVOCATE