MAINTENANCE PETITION U/S 125 CR.PC.

1. A is legally wedded wife of B. After marriage for a period of five years they lived happily.
During the wedlock period A gave birth to one male child. B got second marriage with Z.
Since the date of second marriage B has neglected the maintenance of A. Draft a petition
filed on behalf of A filed under Section 125 Cr. PC, 1973.

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE.

(A) ..... Petitioners.

Versus

(B) ..... Respondent.

The petitioners respectfully submit as under: —

1. That the petitioner No. 1 is legally wedded wife of the respondent and petitioner No. 2 is
their son, aged 5 years.

2. That marriage of petitioner No. 1 was solemnized with the respondent on according to
Hindu rites. After the marriage, petitioner No. 1 started residing at her matrimonial home.
One year after the marriage, petitioner No. 1 was blessed with male child-petitioner No. 2.

3. That for about four years, relations between petitioner No. 1 and her husband-respondent
were cordial, but thereafter the respondent started treating her with cruelty.

4. That after repeated acts of cruelty at his hands, on the respondent turned out the petitioner
No. 1 and 2 from the matrimonial home and since then she has been compelled to live at her
parental house.

5. That the respondent has never sent any money to the petitioner to meet her expenses and
expenses of the minor child.

6. That the petitioner having no source of income is unable to maintain herself and the child.

7. That the respondent is running a Kiryana shop and earning Rs.20,000 per month.
8. That this Court has the jurisdiction to entertain and try this petition as marriage between
petitioner

No. 1 and the respondent was solemnized here and the petitioners are living within the
jurisdiction of this Court.

In view of the above facts and circumstances, the petitioners pray that the respondent be
directed to pay monthly allowance of Rs. 7,000 by way of maintenance: Rs. 4,000‘for
petitioner No. 1 and Rs. 3,000, for petitioner No. 2., from the date of the application.
Petitioner No. 2 being minor child, petition on his behalf is being filed through his mother
and natural guardian-petitioner No. 1.

(Petitioners)

Verification

The above stated all facts are true and correct to the best of my knowledge, belief and
information.

Petitioner

List of Documents:

1. Marriage certificate
2. Birth certificate of applicant no. 2

List of witnesses: Advocate for Petitioner

1. ............
2. ............

Place: Gaya

Date: 2nd November, 2020