BEFORE THE SUB DIVISION MAGISTRATE INDORA

KANGRA HP

1. Sucha Masih Aged -65 Yrs S/o Sadhu Masih

2. Mrs. Nasim , Aged -62 Yrs w/o Sucha masih  

Both R/o ward no 4 Village new basti dhangupeer po Bhadroya Tehsil

indora distt. Kangra hp .            
                       … Applicant/Parents
                   
V/S

1.  Mr.Mani Masih , Aged -35 Yrs S/o Sucha Masih    

2.  Mrs Vandna Aged -26 Yrs W/o Mr. Mani Masih    
R/o ward no 4 Village new basti dhangupeer po Bhadroya Tehsil
indora distt. Kangra hp .
….. Respondents

Humble Application of Parents under Section 5 of the

Maintenance and welfare of parents and Senior Citizens Act,
2007 praying for Orders/ reliefs Section 9 and sec. 22 for eviction
of respondent any ;

PS – Damtal , Chownki -Dangu Peer

Most Respectfully Submitted :- 

The above-named Applicant/Parents most respectfully state and

submit as follows:

1.  That, Applicants are husband and wife and the Parents of the 
Respondents. The applicants are presently staying at ward no 4
Village new basti Dhangupeer po Bhadroya Tehsil indora distt.
Kangra hp in the house which was owned and possessed by
Applicants .
 3. That, Respondent No. 1 is our son named Mani Masih, aged about 35
yrs and Respondent No. 2 named Vandna, is our Daughter-in-law .
Both
of them are staying at our house which was owned and possessed by
applicants .

3.  That, the facts and circumstances of our grievances are as follows:-

         (a) That the respondents are very force able & greedy nature. They
refuse to give food, clothes, to the applicants and the behavior of
respondents are very bad with the applicants. They always threat to
the applicants from dispossessing to their house. The respondents may
times treated the applicants with cruelty as well as mental harassment.
The applicants much time try to make understand the respondents to
avoid such activities but the respondents always refuse to do so.
(b) That due to the misbehave of respondents with applicants, the
applicants are suffering from the mental torture, harassment, cruelty.
Moreover, the respondents never give respect to the applicants and
neither take care of them in their old age.
(c) That the respondents are staying with the house of applicants
without paying any kind of rent & giving abuse to the applicants
everyday and beating them and also threatening to throw out the
applicants from the house.
(d) That the applicants disown the respondents from any movable &
immovable property on 12/01/2022 by publishing in the Amar Ujala
Newspaper after that, the behavior of the respondents became very
cruel against the applicants. In this regard, the applicants have given
an application to local Police Station.
(e) That the respondents is doing the private job & earning very good
income but they are forcefully living in the house against the will of
the applicants.
(f) That the respondents have no share in the house of applicants &
the applicant does not want to keep them in such house and wants to
evict them from their house, Hence this application.
(g) That the applicants many time requested the respondents to vacant
the house but they refuse to do so, Hence this application.
Under the foresaid facts & circumstances, the applicants pray that to pass the
order:
1. Direct the respondents to vacant the house of applicants.

2. To order for such further and other relief orders and directives as the
nature and circumstances of the case may require or justify or as the
Honorable Court may deem fit and proper in the aforesaid facts and
circumstances of the case;

Verification:-
It is verified that the contents
of the application is true and correct
and best of my knowledge and belief , nothing
has been concealed there in .

Place : Indora
Date: Applicant
Through Counsel
PS Dhanjal Advocate
&

P.K Dhiman Advocate

BEFORE THE SUB DIVISION MAGISTRATE INDORA KANGRA HP

Sucha masih V/S Mr.Mani Masih

  

Application of Parents under Section 5

Affidavit
I, Sucha masih Aged -65 Yrs S/o Sadhu Masih resident of R/o
ward no 4 Village new basti dhangupeer po Bhadroya Tehsil
indora distt. Kangra hp.do hereby solemnly affirm and declare on
oath as under:-

1. That the paras of this complaint are true and correct and best
of my knowledge and belief nothing has been concealed
therein.
Place :- Indora
Dated :- Deponent
I the above named deponent further affirm and declare that
the contents of my above affidavit are true and correct to the best of
my knowledge and behalf and nothing has been kept concealed
therein.
Date:
Place:-Indora Deponent