IN THE COURT OF ADDL.

CHIEF METROPOLITAN MAGISTRATE,

DISTT-NORTH EAST, KARKARDOOMA COURTS, DELHI

COMPLAINT CASE NO. OF 2023

In the matter of :

SUMAN GUPTA
…
…COMPLAINANT/AGGRIEVED PARTY

Versus

NARENDER SINGH & ORS.

…Respondents

PS: Bhajanpura

INDEX
S.No PARTICULARS PAGE NO
1. Memo of Parties
2. Court Fees
3. APPLICATION UNDER SECTION 12
READ WITH SECTION 18 & 19 OF
PROTECTION OF WOMEN FROM
DOMESTIC VIOLENCE ACT, 2005
ALONG WITH AFFIDAVIT.
4. APPLICATION UNDER SECTION 23 OF
THE PROTECTION OF WOMEN FROM
DOMESTIC VIOLENCE ACT, 2005
ALONG WITH AFFIDAVIT.
5 ANNEXURE P1 COPY OF AADHAR
CARD OF THE COMPLAINANT
6. ANNEXURE P2 COPY OF MARRIAGE
REGISTRATION CERTIFICTE DATED
10.03.2023
7. ANNEXURE P3 COPY OF THE
MEDICAL DOCUMENTS
8. ANNEXURE P4 COPY OF THE CAW
COMPLAINT DATED
9. ANNEXURE P5 COPY OF THE OLD
RATION CARD
10. VAKALATNAMA
11. PROOF OF SERVICE

COMPLAINANT
Through
DEVVRAT YADAV
ADVOCATE
Chamber No. 460,
Lawyers Block -1
Delhi High Court
8285815626
devvrat.yadav@yahoo.com

DELHI
DATED:
IN THE COURT OF ADDL. CHIEF METROPOLITAN MAGISTRATE,

DISTT-NORTH EAST, KARKARDOOMA COURTS, DELHI

COMPLAINT CASE NO. OF 2023

In the matter of :

SUMAN GUPTA

…COMPLAINANT/AGGRIEVED PARTY

Versus

NARENDER SINGH & ORS.

…Respondents

PS: Bhajanpura

MEMO OF PARTIES

SUMAN GUPTA
A-70, GALI NO-8, A BLOCK
BHAJANPURA
DELHI-110053

…COMPLAINANT/AGGRIEVED PARTY

VERSUS

1. NARENDER SINGH
A-70, GALI NO-8, A BLOCK
BHAJANPURA
DELHI-110053
2. CHARANJEET SINGH
A-70, GALI NO-8, A BLOCK
BHAJANPURA DELHI-
110053
 3. RAJJNEET KAUR
A-70, GALI NO-8, A BLOCK
BHAJANPURA DELHI-
110053
4. GURSHARAN KAUR
A-61, GALI NO-8, A BLOCK
BHAJANPURA DELHI-
110053

…RESPONDENTS

COMPLAINANT

Through

DEVVRAT YADAV
ADVOCATE
Chamber No. 460,
Lawyers Block -1
Delhi High Court
8285815626
devvrat.yadav@yahoo.com

DELHI
DATED
IN THE COURT OF ADDL. CHIEF METROPOLITAN MAGISTRATE,

DISTT-NORTH EAST, KARKARDOOMA COURTS, DELHI

COMPLAINT CASE NO. OF 2023

In the matter of:

SUMAN GUPTA
…Applicant/aggrieved party
Versus

NARENDER SINGH & ORS.

…Respondents

PS: Bhajanpura

APPLICATION UNDER SECTION 12 READ WITH

SECTION 18, & 19 OF THE PROTECTION OF
WOMEN FROM DOMESTIC VIOLENCE ACT, 2005
ALONG WITH SUPPORTING AFFIDAVIT

MOST RESPECTFULLY SHOWETH:

1. That the complaint U/s 12 of The Protection Of
Women From Domestic Violence Act, 2005 is
being filed the details of which are as follows:
a) Aggrieved Person: The Complainant
b) Protection officer: N/A
c) Any other person on behalf
Of Aggrieved Person: N/A
2. That the applicant, Suman Gupta, aged about 32
Years also known as Sonia, is a married women
permanently residing with her husband and in-
laws at A-Block, Street No.8, House No. 70,
Bhajanpura, Delhi – 110053. The applicant is a
respectable, educated, law-abiding citizen and
peace-loving citizen of India. Copy of
 Aadhar Card is attached as a proof of
residence.
ANNEXURE P1
3. The applicant has been made a victim of
Domestic Violence, Harassment and torture by
her in-laws. She is on the verge of being kicked
out from her matrimonial home after numerous
incidents of domestic violence being committed
on her. The severe domestic violence, mental
harassment, demand of dowry, physical torture
is perpetrated on regular basis in order to force
and coerce me to move out from my matrimonial
home by my in-laws namely Narender
Singh(Father-In-Law), Rajjneet Kaur(Sister-In-
Law),Charanjeet Singh (Brother-In-Law), Smt.
Gursharan Kaur(Neighbour), Mother Of Sister-
In-Law. The applicant submits that there are
specific allegations against the Respondents
which have been specified in the following
paragraphs.

4. That the applicant was married to Mr. Ranjeet

Singh on 10th March 2023 after a courtship of
1-2 years. Marriage was performed under
special marriage act in the office of District
Magistrate ( Karawal Nagar ) under Special
Marriage Act. The applicant is a Hindu by faith
while her Husband and in-laws belong to a Sikh
family by faith. It was felt at that time, that the
marriage was with the visible consent of all
family members of both sides at that time i.e. of
brides family as well as of Grooms family, but
that was not the fact, in-fact deep down they
were not happy with the marriage. The true
colour of the in-laws was shown by them only
after marriage. The in-laws of the applicant had
consented to the marriage only because the
husband of the Applicant was supporting the
whole family economically. The marriage
 registration certificate along with marriage
photographs is annexed as ANNEXURE P2.

5. That after the marriage the complainant started

living in her matrimonial home with her
husband and other in-laws. The Complainant is
currently residing in the ground floor of her
matrimonial home. The ground floor is built to
be used as Parking & Guest area and therefore
no ventilation or other amenities are available.

6. That in the marriage all the expense was made

by the husband of the complainant and the in-
laws did not spend a single penny as they were
not intended internally for this marriage. In-
laws also refused to perform Anantkaraj (A
ritual before marriage in Sikh family) 4-5 days
before marriage.

7. That The responding in-laws also meekly

supported the marriage as they were
apprehensive that if they will not support the
marriage then there flow of money which was
coming through the complainants husband will
be closed. Owing to this exigency only they
supported the marriage and were never happy
from inside with the ongoing marriage. They were
also not happy that husband of the complainant
is loving and caring person, who prioritise the
complainant at every step in his life. They were
not happy with the healthy relationship of the
Complainant and her Husband.

8. That the complainants husband spent a lot on

lavish wedding reception and every household
was brought by the complainant in her marriage
to her matrimonial home. But the respondents
were not happy with whatever she has brought
in the marriage. Just after few days they started
 taunting and saying unpleasurable things to her
directly or in an indirect way. They passed ugly
and inhuman remarks against the complainant
and status of her parents after few days of
marriage.

10. That the complainant after marriage had hoped

that she would lead a happy and married life in
her matrimonial home, however , after seeing
the true colours of the respondents the
complainant felt cheated and depressed, her
dreams of a happy matrimonial home were
shattered. She has only very hardly been able to
manage all these mental and emotional trauma
being inflicted upon her by respondents.

11. That no child is yet born out of this

wedlock, but it is pertinent to mention that
applicant is pregnant of 6 Months and delivery
is expected to be in Feb 2024 if everything goes
normal and as expected.
12. That in the Complainants family there are
five (5) members. Her father in law Mr. Narender
Singh, her brother in law Mr. Charanjeet Singh,
her sister in law Mrs. Rajjneet Kaur, applicants
husband Ranjeet Singh and applicant herself.
The other members who are almost like family
who interferes a lot in the applicant’s
Family matters are Gursharan Kaur. The
second floor owner of the same household Mr.
Satvinder Singh also interferes a lot in
complainant’s family matters as he is a friend of
Brother-in-law of the complainant.
13. That it is pertinent to mention that after the
reception was done on 12 Feb 2023,
complainant’s father-in-law said that we should
not come to our matrimonial home as there are
too many relatives present at the moment in the
house due to the reception. They need to be
 taken care of and therefore we should go and
live in some hotel. We accordingly followed his
direction and lived in the hotel for 3/4 days as a
goodwill gesture and also due to crunch of
space. The expenses of the hotel were borne by
Complainant’s husband from his own pocket.

14. That after the marriage for few days

everything went well and in a happy way till the
family members were present in the household
after the reception i.e. just for around a month.
After that one month was over everything
changed for the worst that Complainant could
have ever dreamt of and nothing as portrayed by
the in-laws then remained same. Since then
Complainant have been subjected to severe
physical abuse, mental abuse, economic abuse
and have been coerced on multiple occasions to
do the activities which she would have not done
otherwise.

15. That, Complainant’s husband works in an MNC

Company and is employed there since 2018. He is
working as Manager. He is the main bread and
butter earner for the family. He earns bread and
butter for the family since a long time ago i.e.
even before he got married to Complainant. All
major expenses of the family are borne by
Complainant’s husband from his own salary like
construction of house in ancestral village in
Punjab, fittings of kitchen, furniture in the home
and buying vehicles for the. home. Complainant’s
husband used to arrange funds from his salary
whenever the family needs them. He spent
around 15 lacs in the house that was built on the
instructions of my father-in-law.

16. That, Complainant’s husband was like a goose

that laid golden eggs for the family Until April
2023, when it all started, when Complainant’s
father-in-law had gone to Punjab for some
personal work. Father-in-law goes there regularly
as his other extended family members live there
in his ancestral village. Complainant’s husband
had given a credit card to Complainant’s father-
in-law having the details as XXXX XXXX XXXX
3138 (Add On Card of 1142) of CITI Bank. The
credit card was abruptly damaged due to regular
use, and EMV-CHIP was gone faulty. So
sometimes it worked and sometimes due to fault
in EMV chip does not work. When father-in-law
tried to use the card somewhere and card did not
work then, my father-in-law started abusing
Complainant’s husband and Complainant from
Punjab over phone calls. He said that it is
because of Complainant that her husband has
blocked the Credit Card which was given to him
for his expenses. When he returned back, he
misbehaved with Complainant and abused
Complainant publicly in front of all family
members. Complainant was taken aback by all
this and was very frightened as before this she
was never subjected to such verbal abuse and
mental torture before in her life
17. That, in between intervening months a lot
of petty issues kept on happening where
Complainant was constantly being abused
verbally and mentally by her In-laws. All of
them together along with Smt. Gursharan Kaur
planned and plotted against Complainant at
every step so that Complainant along with her
husband leave her matrimonial household.
18. That, on 28th April 2023, all the limits were
broken when Complainant’s mother-in-law
started continuously asking her for money in
different ways for example as we need to pay the
loans, we need to buy bed and furniture for
Punjab house, and other day to day expenses
because the Credit Card wasn’t working. So, they
wanted Complainant to arrange money for them.
When this situation reoccurred many times, then
Complainant spoke to her husband about this,
then he went upstairs and started asking why
you are asking money from her. Then they clearly
told my husband and me that they wanted dowry
of 20-25 Lakhs & a Brand New Car as the
Complainant did not brought these items in her
marriage. Then Complainant’s husband started
arguing that it’s not a rightful act and should not
be done to her. Then they threatened him as well
if this not going to happen, you also will face
consequences. After some arguments regarding
this, all the family members and relatives came to
our house next morning to discuss the situation.
In front of all of them, Complainant’s in-laws
went silent and behaved like nothing has
happened. The in-laws did not showed there true
colours when any one was around.
19. That, on 13th May 2023, Complainant’s
brother-in-law lost the keys of the Scooty and
blamed Complainant and her husband that they
took the key, Complainant’s father-in-law came
downstairs and started knocking the door loudly
along with abusive language for asking the
whereabout of Scooty keys, the Complainant gave
in-laws the spare keys which they had to calm
down the situation, but they kept constantly
shouting on Complainant in front of family
members and neighbours. After this they
threatened Complainant to leave the house right
now, as father-in-law didn’t wanted Complainant
to stay in this shared household. At night,
Complainant was mentally disturbed due to these
problems occurring again and again, so
Complainant talked to her mother-in-law and to
talk about the incident and asked her to prevent it
from occurring again as she is mentally unable to
cope up with all the mental, physical and
emotional abuse. At that very moment Father-in-
law came in an inebriated state at that time, he
started misbehaving and abusing Complainant,
then Complainant shouted for help. On hearing her
screams mother-in-law and husband came and
rescued her from the clutches of her father-in-
laws.
20. That after this horrific incident and violence
committed by father-in-law upon the
complainant, she was in a state of despair and
mental shock for the next three days, she didn’t
went upstairs to the common dining area for
food and water, as the kitchen is on the 1st floor.
Meanwhile, no one asked how the complainant
was living without food and water.

21. That, on 17th June 2023, in an unfortunate and

horrific accident Complainant’s mother-in-law
and 10 months old son of Complainant’s brother-
in-law expired in an accident when Complainant’s
family was returning from Punjab to Delhi. In this
accident my sister-in-Law got bed ridden due to
injury in the back area of her body. When
Complainant’s went to the funeral of her mother-
in-law, Complainant was not allowed to take part
in the rituals which are supposed to be performed
by the daughter-in-law i.e. Complainant.
Complainant was again verbally abused in front of
many people including family members who had
come for the funeral. I was told by my in laws that
“tere pair kharab hain isliye ye accident hua,
tujhse shadi na karte to ye nhi hota”.
Complainant was made responsible for the death
of the two family members in the accident. On
Same day Complainant had to return from that
ancestral house in Punjab as a lot of verbal
abusing and mental torture was done to me and
Complainant was being considered as
Inauspicious for the family. This left Complainant
with severe mental trauma for so many days and
Complainant couldn’t sleep or eat peacefully for
days to come. Then similarly on Tehranvi
Complainant was not allowed to indulge in any
ritual. Afterwards, my father-in-law asked me to
leave the Punjab house immediately.
22.That after this horrific and unfortunate accident
Complainant’s father-in-law doesn’t go to Punjab
anymore and lives in Delhi on 1st floor of
Complainant’s matrimonial home. Since 17th June
2023 Complainant’s father-in-law in connivance
with and on provocation by sister-in-law and
mother of sister-in-law is only creating issues out
of very small things and constantly keeps abusing
Complainant on petty matters. Complainant even
cannot think of going outside of her room
whenever her father-in-law is in the house as
Complainant get targeted by him the moment, he
sees her. The complainant is not allowed to use
anything in kitchen also where eventually
everything was fitted with the money of the
complainant’s husband. He abuses Complainant
and try to intimidate her to do smething so that he
can beat and abuse her.
23.That Complainant has wished so many times that
may god take my life instead of giving her such a
life where she is constantly living in a Jail like
home. Complainant does not let her husband go
anywhere because she is always afraid of her life
and limb due to presence of her father-in-law
around her and his aggresive behaviour towards
her. Father-in-law has misbehaved and abused
Complainant very badly many times publicly and
always tries to beat Complainant whenever she
opposes his inhuman behaviour.
21.That in the above-mentioned accident Car was
totally crushed and could not be used further
without full overhaul repair of the Car. After this
accident the in-laws of the complainant are
demanding that father or brother of Complainant
should buy the Car for in-laws because as per
the in-laws the cause of the accident was
Complainant’s inauspiciousness. The in-laws are
demanding from Complainant and her father or
 brother any car costing between 10-15 lacs. They
say that Since Complainant has not brought
anything in dowry and therefore should
compensate them by offering a Car as the family
of in-laws. The repaired Car cannot be used
because that has also became Inauspicious.
Apart from this father-in-law, brother-in-law
sister-in-law and mother-of-sister in law are
pressurising Complainant to repay loan of
around 15 lacs that was taken by her father-in-
law to construct the home in Delhi apart from
the monetary help received from her husband.
They are also demanding 15 lacs from
Complainant and her husband just for living in
this ancestral home which was bought by the
grandparent of her husband. And apart from
that Complainant’s father-in-law is asking for 25
lacs if Complainant want to get the floor
permanently i.e. to include my husband’s name
in the property shares/papers.
24. That recently on 2nd September 2023
Complainant’s Father-in-law unleashed violence
on her, when during a usual altercation she was
beaten by her father-in-law and later her father-in-
law threw her off on the scooty that was standing
nearby. She fell over scooty and due to this pain
started in her abdominal area, the whole night she
cried because she was bleeding. Next day morning,
Complainant went to the doctor to get the complete
checkup and found that she was getting blood
spots & this was a critical situation for the
pregnant Complainant and her yet to be born
baby. Only with great mental and physical
difficulty Complainant withstood that severe pain
for the whole night. In the Hospital, Doctor said
that Complainant will be needing Critical Care as
there are chances of miscarriages due to the severe
 fall and consequential injury in the abdominal area
and on head. Copy of the Medical Documents is
attached as ANNEXURE P3.
25. That Complainant’s sister-in-law and her mother-
in-law with neighbours help constantly provoke
and instigate her father-in-law to abuse and beat
Complainant. Mother of sister-in-law visits home
regularly and regularly lives in the matrimonial
home of the Complainant for several days. Sister -
in-law verbally abused Complainant during all
those events previously told. She provokes father-
in-law so that Complainant can be thrown out by
the father-in-law, so that she can have all the
space for herself and her husband. She does not
like the Complainant at all and regularly uses
taunting and provocative language against the
Complainant.
26. That Complainant’s Father-in-law, neighbour
Smt. Gursharan kaur along with Complainant’s
sister-in-law say that Complainant is
inauspicious for this home and since the day
Complainant have come to this home nothing
good has happened and his 10 months old
grandchild was killed in car accident because
Complainant was inauspicious. This is mentally
and emotionally traumatic for the complainant
and makes Complainant’s life miserable
27. That my sister-in-law wants to give one floor of
the property to her mother so that she can live
with her permanently and on account of this
reason she keeps on instigating and provoking
father-in-law to abuse the complainant verbally
& physically and takes jibes at her regularly.
Sister-in-law along with Smt. Gursharan Kaur
and her mother constantly tells Complainant
that she did not brought dowry to the
matrimonial home while sister-in-law brought a
 lot of things in her marriage, she also tells
Complainant that even now things can be made
good if Complainant bring dowry/money and
repay the loan and bring a car.
28. That Complainant was not even allowed to touch
or use anything in the matrimonial home’s kitchen
even though every fitting in the kitchen was done
by the money given by Complainant husband.
Complainant is making her food in a makeshift
arrangement that she has made in the ground
floor. There is no ventilation neither any outlet for
the smoke to go out, because the ground floor
was built more as a guest and parking area than
being used as a kitchen. It was made in a
fashion that though neither anyone can live at
the ground floor neither the food can be made
their due to absence of the kitchen room it does
not have its separate existence.
29. That Complainant’s brother-in-law constantly
keeps threatening her and her husband of dire
consequences if Complainant do not follow what
her father-in -law and sister-in-law tells her to
do. He threatens Complainant that If she did not
follow orders of other in-laws then he will beat
her and her husband. He also provokes
Complainant’s husband to get in a fight with him
either verbally or physically. He also provokes
father-in-law by saying various bad things about
Complainant. He also says to Complainant’s
husband that he will get her husband beaten by
his Goonda friends, if he did not vacated the
property within a month.
30. That on 2nd September 2023 when Complainant’s
husband was beaten by a neighbour named as
Karandeep Singh whom Complainant’s brother-in-
law and father-in-law supported. Complainant
 was not able to get the complaint registered on
that day against this person i.e. Karandeep
Singh as we were told by him that if Complainant
will make an issue out of it then Complainant
will never remain safe and anything dire could
happen either to Complainant or to her husband.
Therefore, Complainant got frightened and was
in a severe mental trauma. Therefore, we did not
approached police on 2nd September 2023.
31. That it is pertinent to mention the role of Smt.
Gursharan Kaur who lives in vicinity in all these
events that have happened, she is a neighbour
lives around Complainant’s matrimonial house
since last 30-40 years and comes to her
matrimonial home every day and remains in
there house for full day. She has a huge
interference in our domestic matters. She
provokes Complainant’s father-in-law against us
so that we leave the place. She also treats
Complainant as inauspicious and have a say in
everything that happens in our home. She is a
culprit in every sense as she takes jibes on
Complainant in every activity that Complainant
does and whatever she cooks. She also spread
rumours about Complainant.
32. That, when for the first time Complainant’s family
members came for marriage discussion, then her
in-laws were totally in a mood to say No but they
did not said because Complainant’s husband was
the only person who was handling all expenses
and loans. After that they started asking for dowry
in implicit ways like stating that Complainant’s
sister-in-law brought gold chains and etc. even
when the demand was not made.
33. The circumstances have created an environment
of fear and helplessness for complainant. She
fear’s for her safety and well-being.

34. That complainant has tried her level best to settle

her matrimonial life in the company of aforesaid
in-laws but they are persons of greedy nature and
are hell bent to ruin my matrimonial. The other
family members of the extended family also tried to
settle the issue but nothing came out of this.
36. That one complaint was filed in CAW Cell Nand
Nagri by the complainant but no relief has yet
been given to the complainant. The father-in-law
had come to the proceeding on 14.11.2023 and
made a statement that I will not change my ways
and if complainant is really aggrieved, she should
file a DV complaint in the appropriate court. The
father in-law also threatens to get the portion of
the house demolished by MCD if complainant
does not adhere to whatever he is saying.
Copy of the CAW complaint is being attached as
ANNEXURE P4.

37. That the complainant is residing at ground floor

at A-70, GALI NO-8, BHAJANPURA, DELHI-
110053 i.e. her matrimonial home with her
husband and in-laws. The old ration card copy
is being annexed as ANNEXURE P5.

38. That the place of residence of the complainant

falls under PS Bhajanpura and is within the
Jurisdiction of this Hon’ble Court, hence this
Hon’ble Court has the Jurisdiction to try and
entertain the present complaint.

39. That appropriate court fees has been affixed.

PRAYER

a. Pass an Order under section 18 thereby

Prohibiting acts of domestic violence being
perpetrated by respondents by granting an
injunction against the respondents from
repeating any of the acts of domestic violence as
mentioned above;
b. Pass residence order under section 19, directing
respondents to not dispossess and throw out
the applicant from her matrimonial
home/shared household;
c. Pass an order restraining the respondents from
creating any third party rights in the shared
household/matrimonial home;
d. Pass an order directing respondents to not enter
the portion of the shared household in which
applicant reside;
e. Pass an order thereby directing the concerned
police to provide appropriate protection to the
applicant and appoint protection officer for her;
d. Pass an order under section 22 thereby
directing the respondents to pay compensation
or damages of Rs 5,00,000 to the complainant,
as the acts of the respondents has treated the
complainant with utmost cruelty, physical,
mental and emotional Violence which are still in
continuance, and also the litigation cost
involved in the present matter;
e. Pass any other order or relief which this hon’ble
Court may deem fit and proper in the view of
abovementioned facts and circumstance.

AND FOR THIS ACT OF KINDNESS THE APPLICANT

SHALL EVER PRAY.

COMPLAINANT
Through
DEVVRAT YADAV
ADVOCATE
Chamber No. 460,
Lawyers Block -1
Delhi High Court
8285815626
devvrat.yadav@yahoo.com
IN THE COURT OF ADDL. CHIEF METROPOLITAN MAGISTRATE,

DISTT-NORTH EAST, KARKARDOOMA COURTS, DELHI

COMPLAINT CASE NO. OF 2023

In the matter of:

SUMAN GUPTA
…Applicant/aggrieved party
Versus

NARENDER SINGH & ORS.

…Respondents

PS: Bhajanpura

AFFIDAVIT
I, Mrs. SUMAN GUPTA aged about 32 W/o. Mr.
RANJEET SINGH R/o. A-70, GALI NO-8, A BLOCK
BHAJANPURA DELHI-110053, do hereby solemnly
affirm and declare as under:-

1. That I am the complainant in the accompanying

application under Section-12 of the Protection of
Women from Domestic Violence Act, 2005 filed
against the respondent and the contents of the
said complaint may kindly be read as part and
parcel of this Application /Affidavit as the same
are not repeated here for the sake of brevity .
2. That being conversant with the facts and
circumstances of the case I am competent to
swear this affidavit.
3. That the details provided in the present
complainant for the grant of relief under
Section-12 of the said Act have been entered
into by me/at my instructions.
 4.That the contents of the said complaint have been
read over and explained to me in my vernacular
language.
5.That the contents of the said complaint may be read
as part of this affidavit.
6.That the facts mentioned herein are true and correct
to the best of my knowledge and belief and nothing
material has been concealed therefrom.

DEPONENT

VERIFICATION

Verified at Delhi on this day of Nov 2023 that the contents of

complaint are true and correct to the best of my knowledge and belief
and nothing material has been concealed therefrom.

DEPONENT
IN THE COURT OF ADDL. CHIEF METROPOLITAN MAGISTRATE,

DISTT-NORTH EAST, KARKARDOOMA COURTS, DELHI

COMPLAINT CASE NO. OF 2023

In the matter of:

SUMAN GUPTA
…Applicant/aggrieved party
Versus

NARENDER SINGH & ORS.

…Respondents

PS: Bhajanpura

APPLICATION UNDER SECTION 23(2) of

PROTECTION OF WOMEN FROM DOMESTIC
VIOLENCE ACT, 2005 FOR EX-PARTE INTERIM
ORDERS

Most Respectfully Showeth:

1. That the applicant/complainant have filed the

application under section 12 of the Protection Of
Women From Domestic Violence Act, 2005 and
the contents of the same may kindly be read as
part and parcel of this para kindly be read as
Part and parcel· of this para as the same; have
not been repeated herein for the sake of brevity.
2. That the Respondent No. 1 is forcing the
complainant to move out from her matrimonial
home by perpetrating the Domestic violence on
her on a regular basis.
3. That the respondents should be restrained from
committing any act of Domestic Violence
 In view of the above, it is therefore most
respectfully prayed that this Hon’ble Court maybe
pleased to :
a. Pass an Ex-Parte ad interim direction in favour
of the applicant and against the respondents,
thereby restraining the respondents, thereby
restraining the respondents, their agents,
servants attorneys etc from making any kind of
communication i.e. personal, oral, written or
electronic or telephonic or in any other mode
whatsoever from the applicant, her parents and
other family members.
b. Pass an Ex-Parte ad interim direction in favour
of the applicant and against the respondents,
thereby restraining the respondents from not
dispossessing there assets;
c. Pass an Ex-Parte ad interim direction in favour
of the applicant and against the respondents,
thereby restraining the respondents from
creating any third party rights in the shared
household/matrimonial home;
d. Pass an Ex-Parte ad interim direction in favour
of the applicant and against the respondents
thereby restraining the respondents, thereby
restraining the respondents, their agents,
servants attorneys etc. from evicting

AND FOR THIS ACT OF KINDNESS THE APPLICANT

SHALL EVER PRAY.

COMPLAINANT
Through
DEVVRAT YADAV
ADVOCATE
 Chamber No. 460,
Lawyers Block -1
Delhi High Court
8285815626
devvrat.yadav@yahoo.com

DELHI
DATED:
IN THE COURT OF ADDL. CHIEF METROPOLITAN MAGISTRATE,

DISTT-NORTH EAST, KARKARDOOMA COURTS, DELHI

COMPLAINT CASE NO. OF 2023

In the matter of:

SUMAN GUPTA
…Applicant/aggrieved party
Versus

NARENDER SINGH & ORS.

…Respondents

PS: Bhajanpura

AFFIDAVIT
I, Mrs. SUMAN GUPTA aged about 32 W/o. Mr.
RANJEET SINGH R/o. A-70, GALI NO-8, A
BLOCK BHAJANPURA DELHI -110053 , do hereby
solemnly affirm and declare as under:-

1. That I am the complainant in the accompanying

application under Section-23(2) of the Protection
of Women from Domestic Violence Act, 2005 filed
against the respondent and the contents of the
said complaint may kindly be read as part and
parcel of this Application /Affidavit as the same
are not repeated here for the sake of brevity .
2. That being conversant with the facts and
circumstances of the case I am competent to
swear this affidavit.
3. That the details provided in the present
complainant for the grant of relief under
Section-23(2) of the DV Act have been entered
into at my instructions.
4. That the contents of the accompanying
application have been read over and explained
to me in my vernacular language.
5. That the contents of the said accompanying
application may be read as part of this affidavit.
 6. That the facts mentioned herein are true
and correct to the best of my knowledge and
belief and nothing material has been concealed
therefrom.

DEPONENT

VERIFICATION

Verified at Delhi on this day of Nov 2023 that the

contents of complaint are true and correct to the best
of my knowledge and belief and nothing material has
been concealed therefrom.

DEPONENT