That marriage between the parties solemnized on 26/5/2006 at rajpur court followed by saptapadi

in radiant public school arranged by friends so this way petitioner and respondent is husband and
wife

1. After marriage petitioner started residing at jaora near Ratlam with the respondent where
they both use to work as teacher at Gokuldas public school and respondents mother use to
live with unmarried daughter in Aurangabad maharashtra
2. That the petitioner always gave respect to the respondent and his family members
,respondent and his family never gave proper respect to the petitioner and always neglected
her and started abusing her in the first few months of marriage ,conduct of the petitioner
was indecent and used to pick quarrels with the petitioner on trivial matters which showed
petitioners bad temper
3. Respondents mother visited them at jaora for 15,20 days after petitioners marriage with
respondent and due to her high temper she use to harass petitioner by using abusive
language and taunting about not bringing dowry and constantly reminding her that she does
not like petitioner and use to fight with her and causing her mental torture in just first few
months itself
4. In 2006 petitioner became pregnant and in 2007 petitioner delivered baby girl on 8th April
whom they named as Alisha(Gungun.)Respondent and his mother from the beginning
expected baby boy so after girl was borne they weren’t happy
5.

That the Respondent mother once again visited them and started treating her badly with
abusive language and taunting her about not giving son to their family and also kept
complaining about caesarean delivery which have costed them more than normal delivery
which wasn’t in petitioners hands and respondent was also party to this and caused
petitioner mental cruelty and made her life miserable during her 20days stay at respondents
place when petitioner was going through postnatal period which isn’t easy for any woman.
6. That the Respondent is a habitual drinker and abuse petitioner by taunting about not being
good beautiful wife to him not bringing dowry whereas he was getting good proposals from
his community girls etc petitioner and respondents marriage was love marriage where both
parties were jointly involved
7. That the respondent and petitioner moved to Rajkot in 2011 where respondent got job in s n
k school as an English teacher and they resided at street no 2 vimalnagar ,After moving to
Rajkot the petitioner took up job in sunflower school due to constant harassment by the
respondent that she is of no help to him but due to her daughter she could not manage and
had to leave the job.
8. That the respondents sister in 2013 got married and whole family went to Gaya bihar for
wedding ceremony there also respondent his mother and sister dint treat her respectfully
and used abusive language and constantly insulted the petitioner on small issues like on her
clothes ,looks.
9. That the petitioner in 2013 once again took up a job at tapsee school due to respondents
torture and after that she decided to pursue B.E.D so she can get good salary but respondent
neither supported her emotionally nor financially so she took loan from her sister for her
 B.E.D fees and simultaneously she worked as a teacher in Nirmala convent school for a year
time where she was paid 9000 as a monthly salary
10. That the respondent and petitioner jointly purchased flat in ambika township and started
residing there , after finishing B.E.D petitioner took up a job as a hindi teacher in sunshine
school in 2015 and there she was paid 13500 in the beginning and at present she is getting
15500 in hand.
11. That the respondents mother shifted to Rajkot after her daughter’s wedding to live with
them at ambika township in 2015, respondents mother soon started fighting with the
petitioner on petty issues with abusive language with petitioner as well as building residents
and one day the respondent mother abused petitioner and slapped her 4,5 times on her face
due to this petitioner went to the mahila police station to file complain about the same after
this incident respondent left the petitioner alone on her own and moved to shree shine
building munjka with his mother and daughter without supporting her emotionally or
financially ,petitioner time and time again tried to reconcile with the respondent to make
their marriage life work but the respondent never paid any attention to it and did not come
back ,daughter Gungun kept visiting the petitioner on holidays and whenever she wished to.
12. That the respondent returned almost after two and half years with his daughter back to
ambika townsip where respondent was living on her own ,respondent left back his aged
mother as even he could not bear with his mother’s high tempered nature , petitioner
welcomed him whole heartedly and tried to make things better between them and made
efforts to make relations smooth , initially respondent behaved nicely but soon showed his
bad nature and started fighting like earlier and caused mental cruelty to the petitioner even
by beating and abusing her and by imposing himself physically at his wish and interest still
petitioner tolerated him to make marriage life work.
13. That the petitioner was getting very tired due to long hours of the school timings and had to
manage household chores as well as shopping for every small things required to manage
house and family and requested respondent if she could leave the job and take up tutions to
be helpful to manage family expenses but due to this respondent got angry and started
fighting again and again ,after respondents sisters divorce procedure he started fighting
more with petitioner and started distancing more from petitioner and petitioner could not
understand what all respondent had in his mind.
14. That the respondent had malafide intention of sending away petitioner so he started
explaining her about selling their ambika township house and moving to rented place but
the petitioner explained him that instead of paying rent they can use that money to pay EMI
but respondent had malafide intention to leave petitioner by selling the property when his
tricks did not work he again started giving her mental stress and served her with notice on
5/12/2020 ,buy petitioner was shocked by this and tried to explain him not to do all this and
try to make their marriage life work but the respondent did not listen to her and started
behaving badly with abusive language and he was very much living with her under one roof
at the time of serving the notice and left her once again after 1month to a rented place
separately at102 aaksah apartment motamauva and after few days took daughter Alisha
with him, meanwhile respondent sister called the petitioner from U.S and threaten her that
they would kill her ,nobody would support her and the respondent would divorce her and
would drag her to the court therefore the petitioner tried to seek mahila police stations help
and filed application against the respondent and his sister ,the respondent lied about
petitioner earning 28000 per month as salary from the school to mahila police. Petitioner
character is very good and she is a docile lady which can be known by the fellow staff
members
15.
16. That the respondent to torture my client to threaten her gave application in taluka police
station to fulfill his malafide intention so she would get scare and leave the house which is
not possible as she does not have any other place to go
17. That the respondent has been neglecting the petitioner to maintain and to provide basic
necessities of day to day life and has deserted her more than once in her salary of 15500 she
cant provide for her petrol ,electricity bill, gas, medical expenses, vegetables, wifi connection
for online classes, milk, provision stores bills etc moreover petitioner does not have any
brother they are 3 sisters in total so have responsibility to maintain her old parents aged
around 75,80 years.
18. That the respondent lied about maintaining her expenses , he never paid single penny to her
when he deserted her for two and half years earlier and now too.. Daughter Alisha is
studying in the same school where respondent works so he does not have to pay very high
fees, moreover daughter Alisha visited the petitioner from morning to evening till 5th of
march 2001. That the respondent lied about not having husband and wife relations with
her, respondent time and time again very much had such relations with her at his own
interest and will ,they even did kanyadaan of respondent sister at her wedding happily in
2013 and even resumed relations after moving back with her in 2018 till beginning of 2020
and after that they did not have relations as he thought to punish her for not complying to
his wishes and deprieved the petitioner of wifes rights in everyways.
19. Prayer
(1) It is most respectfully prayed that this honourable court may kindly be pleased to direct
the respondent to pay Rs 10000 to the petitioner per month as maintenance .
(2) Rs 30,000 as litigation expenses as provided under section 125 crpc keeping in view the
status and icome of the respondent.
(3) Any order which this honourable court deem fit and proper be also passed in favour of
the petitioner and against the respondent.

Rajkot …………………….
Dt Petitioner