Evidence by Way of Affidavit

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IN THE COURT OF HON’BLE SH.

MANISH KHURANA
PRINCIPAL FAMILY JUDGE, DISTRICT EAST, FAMILY COURT,
KARKARDOOMA, DELHI

MAINTENANCE PETITION NO. 1045 OF 2018

IN THE MATTER OF:

POOJA GUPTA AND ORS .... PETITIONER

VERSUS

SACHIN GUPTA .... RESPONDENT

EVIDENCE BY WAY OF AFFIDAVT ON BEHALF OF THE PETITIONER

I, Mrs. Pooja Gupta, aged 36 years, wife of Mr. Sachin Gupta, residing at E-
139, New Ashok Nagar, Delhi-110096, do hereby solemnly affirm and
declare as follows:
1. That the deponent is the Petitioner in the above captioned matter and

is filing the present Evidence by Way of Affidavit before this Hon’ble

Court. She is well acquainted and conversant with the facts of the

case deposed to below.

2. That the deponent further states that the facts are being placed and
the Documents relied upon are being exhibited by way of this Affidavit
in the foregoing paragraphs which are as under.
3. The marriage of petitioner no.1 (myself) and the respondent was solemnized
on the 23rd day of April 2004, at Makhan Lal Dharamshala, Rampur, U.P.,
according to Hindu rites and customs. The parents of petitioner had spent
approximately Rs.4 Lacs on the wedding. Copy of Marriage Photo is
attached herewith and marked as Exhibit PW 1/1.
4. The family members of the petitioner solemnized her marriage with the
respondent with great pomp and show, as per the demands of the respondent
and his family members. The parents of the petitioner spent a significant
amount on her marriage and also gave valuable gifts to the respondent and
his family.
5. That, resulting from this union, two children were born: Tanmay Gupta on
26.07.2005 (petitioner no.2) and Mahi Gupta on 14.09.2007 (petitioner
no.3). Copy of Adhar card of petitioner and children are attached herewith
and evidence being Exhibited as marked as Exhibit PW 1/1, Exhibit PW
1/2 and Exhibit P 1/3.
6. Both the children living with the petitioner at Delhi and they also studying
in delhi school, the copy of marksheet of children attached with this as
Exhibit P 1/4, as Exhibit P 1/5.
7. That the petitioner has living rented with children Delhi – 110094 from
2018 to 2023 , currently the petitioner living at address E-139, New Ashok
Nagar, Delhi-110096
8. That in the aftermath of the marriage, the respondent and his family
members initiated a campaign of taunting and verbal abuse, maliciously
alleging insufficient dowry. This hostile environment swiftly transformed
into relentless physical and mental harassment.
9. That since the year 2008, the respondent and his family members have
persistently subjected me to physical and mental torture. Despite seeking
refuge at my parents' home on numerous occasions, the relentless
harassment has persisted.
10.That on the 13th day of February 2018, the respondent and his family
members issued explicit threats of violence and demanded my immediate
evacuation from the matrimonial home.
11. That on various occasions, the respondent physically assaulted our children.
On 25.02.2018, the sister-in-law explicitly threatened harm if we did not
vacate our home.
12.That on the 12th day of May 2018, the respondent, his mother, and father
subjected me to physical assault without any provocation. When the police
were involved, no legal action was taken against them.
13.That, as a homemaker with no independent income or property, I am
entirely dependent on my parents for support and living on rent in Delhi
since 2018. Copy of Rent Agreement is attached herewith and marked
as Exhibit P 1/6.
14.That the respondent is currently operating a General Store, generating an
approximate monthly income of Rs.60,000/-.
15.That the respondent, being legally and morally bound, has neglected his
responsibility to maintain me and our children.
16.That I affirm that the contents of this affidavit are true to the best of my
knowledge, belief, and understanding.
17. That the deponent further states that the documents relied upon and
filed along with the Evidence is being exhibited herewith and marked
as EXHIBIT NO. PW 1/1, EXHIBIT NO. P 1/2, EXHIBIT NO. P 1/3,
EXHIBIT NO. P 1/4, Exhibit P 1/5 and Exhibit P 1/6 to this evidence
filed in support of the contention, pleas raised before this Hon’ble
Court.
18.That the deponent further states that it is most expedient in the interest of
justice that this Hon’ble Court may graciously be pleased to allow the
petition by this Hon’ble Court.
19. I swear, verify that the contents of paragraph nos.1 to 16 of the
present Evidence by way of Affidavit is based on personal knowledge,
information received by me, record and legal advice rendered to me.
No material bearing fact is false and concealed therefrom.

DEPONENT

VERIFICATION;-

I, Mrs. Pooja Gupta, do hereby verify that the contents of this affidavit are true and
correct to my knowledge and belief. No part of it is false, and nothing material has
been concealed therein.
DEPONENT

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