IN,

The Court of Principal Judge

Family Court, MUZAFFARPUR
Maintenance CaseNo. 208 of 2016
Abhiruchi------------------------------ Petitioner
Versus
Amit Kumar Sinha------------------- Opposite Party

The humble petition under Section 106 of

Indian Evidence Act, 1872on petitioner named
above:-------behalf of the
Most Respectfully Sheweth:----------
1. That the Petitioner has filed this casefor grant of maintenance which
is pending before this Hon’ble Court.
2. That the Opposite Party has lead evidence on his behalf. In his
deposition before this Hon’ble Court the Opposite Party has
informed that he is earning a meagre sum of Rupees 5500 per month
and as such he is unable pay anything to his wife and daughter.
3. That the Opposite Party has deliberately concealed his income and
has misrepresented his income before this Hon’ble Court to evade
payment of maintenance to his wife and daughter.
4. That the Opposite Party earns more than three lacks per month on
average and he has made false statements regarding his income and
assets.
5. That after herculean efforts the petitioner has come to know about
some sources of his income and some of assets. The Opposite Party
has following Bank Accounts and assets---
(A) Assets in the name of Amit Kr Sinha
(i) HDFC Bank A/C No—04771090000017
April 2013----deposited 9500 Dollars
14-8-2015-----deposited Rs 9,60,000
O5-10-2015---deposited Rs 5,68,000
23-10-2015---deposited Rs. 5,59,000
(ii) IDBI Bank current A/C No.---0720102000003940
For Kamakhya Enterprises run by Amit Kr Sinha
March 2017-----deposited Rs.1,50,000
March 2017---- deposited Rs. 1,30,000
(iii) Canara Bank Savings A/C No.---1761101016385
Available Balance in June 2017---Rs 14861
(iv) SBI A/C No.—20120212817
Available Balance in June 2017----Rs. 11237
(v) SBI PPF A/C balance in June 2017 Rs. 562072
(vi)LIC Policy No.----539762947
(vii) LIC Policy No.----521909507
(viii) ICICI Prudential Insurance No. 09154066
(ix) A three bedroom residential flat in KOLKATA
At Basundhara Enclave, Parnasree Pally Road No. 1
Ward No.—131
P.O. and P.S.----ParnasreeBehala, KOLKATA
Distt.---24 Pargana South, West Bengal
(x) A residential plot in Shivajinagar ,Katihar near the house of the
 O.P.
(xi) Kamakhya Enterprises a business house run by Amit Kr Sinha
(Photograph attached)
(B) Assets in the name of parents of O.P.-----
(xii) SBI A/C No.( Anil+ Amita Sinha)—20042818144---
balance Rs. 69001
(xiii) SBI A/C No..( Anil+ Amita Sinha)—106753311469---
BalanceRs. 260517
(xiv) SBI A/C No. (Amita Sinha)- 34390997764-Balance Rs
116661
(xv) SBI A/C No (Amita Sinha)-35525942130-Balance
Rs320514
(xvi) SBI A/C No (Amita Sinha)-35393239756-Balance
Rs320784
(xvii) PPF A/C No. (Amita Sinha)-32690109173-balance
Rs381920
6. That the O.P. has many more accounts and assets which is not within
the knowledge of the petitioner. The O.P. has deliberately transferred
his money and assets in the name of his parents and other relatives to
evade paying maintenance to the petitioner and her daughter.
7.That it is submitted most humblythat after the petitioner was forced
to leave her sasural, the Opposite Party has even not cared to have any
amicable settlement and has not given any single pie to the petitioner
for her maintenance as well as for her daughter. And as such the O.P.
has breached the obligatory marital duties and obligations to maintain
the petitioner and her daughter.
8. That in view of the circumstances mentioned above it is
submitted most humbly that the Opposite Party be directed to file
details of his assets and liability on affidavit supported by
documents. He may be directed to file account statements of the
abovementioned accounts and other accounts also.
9. That it is submitted most humbly that the Opposite Party
regularly goes on ship. The petitioner suspects that the Opposite
Party has gone to ship on duty at present. It is therefore submitted
hereby to direct her to file his Original CDC and Passport to
ascertain his ship going period and his income. He may be directed
to file his current salary Account no. for ascertainment of his real
income. Details about his ship going are as under—
INDOS No.—04NL2074
CDC NO.—CH51835
D.O.B—15-06-2083
PAN No---EDWPS0260K
PASSPORT NO.--- 23010408
Ship going period---
21-06-2015 to 20-09-2015
24-11-2015 to 07-04-2016
25-06-2016 to 12-07-2016

It is, therefore, prayed that Your Honour

maygraciously be pleased to allow this
petition and direct the opposite party to
file detailed statements on affidavit
supported by documents about his assets
and also his CDC and Passport in original
for ascertainment of income of O.P.AND
It is prayed further to pass such other
order which this Hon’ble Court thinks fit
 and proper in the facts and circumstances of
this case.

And for this the petitioner shall ever pray.

PETITIONER
IN,
The Court of Principal Judge
Family Court, MUZAFFARPUR
AFFIDAVIT
I, Abhiruchi, w/o Amit Kumar Sinha, aged about 25 years,resident of Mohalla--
Shivajee Nagar, Laliyahi, Katihar, Ward No.-10 P.S.—Sahayak(Katihar)Distt.----
Katihar(Bihar), at present residing with my father Sudhesh Kumar in the house of
Kumar Abhilekh, Opposite Muktinath Temple at Mohalla—Ramdayalu Nagar,
Muzaffarpur P.S.-KaziMohammadpurDistt.—Muzaffarpur do hereby solemnly
affirm and state as follows-------
1. That I am the petitioner of this case and as such am well acquainted with the
facts and circumstances of this case.
2. That I have read and understood the contents of the petition attached
herewith. I have not filed any petition earlier before this court for similar
reliefs.
3. That the contents of this affidavit as well as the petition attached herewith
are true to the best of my knowledge and belief.

Hence this affidavit.

Deponent

I know the deponent who has signed in my presence.

Advocate