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IN THE ADDL. CHIEF METROPOLITAN

MAGISTRATE’S COURT AT BORIVALI, MUMBAI
DOMESTIC VIOLENCE COMPLAINT NO. OF 2023
Mrs. Sana Altaf Taibani )

D/o Salim Dokadia )

Aged: 20 years, Occu: Nil, )

Currently residing at: C/o. Iqbal )

Mohammad Kalawadia, 203, )

Merigold Building, Building No. 6 )

2nd Floor, Dattamandir Road, )

Malkani Estate, Malad (East), )

Mumbai – 400 097 )

Mobile No. 8369721296 )… Complainant

Vs

1. Altaf Nasir Taibani )

Age: 24 years, Occu: Business, )
Residing at: Firdaus Building, )
Flat No. 301, GangaComplex, )
Nayanagar, Mira Road (E), )
Thane – 401 107 )
Mobile No. 7977561240 )

2. Nasir Isa Taibani )

Age: 50 years, Occu: Business, )
Residing at: Firdaus Building, )
Flat No. 301, Ganga Complex, )
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Nayanagar, Mira Road (E), )

Thane – 401 107 )

3. Samina Nasir Taibani )

Aged about: 47 years, Occ: Housewife)
Residing at: Firdaus Building, )
Flat No. 301, Ganga Complex, )
Nayanagar, Mira Road (E), )
Thane – 401 107 )
4. Salma Zakir Taibani )
Aged about: 42 years, Occ: Housewife )
Residing at: Firdaus Building, )
Flat No. 202, Ganga Complex, )
Nayanagar, Mira Road (E), )
Thane – 401 107 ) … Respondents

COMPLAINT UNDER SECTION 12, 18, 19, 20,

AND 22 OF THE PROTECTION OF WOMEN
FROM DOMESTIC VIOLENCE ACT, 2005.

MAY IT PLEASE YOUR WORSHIP:-

1. The Complainant states that the Complainant is the duly

wedded wife of Respondent No. 1. The Respondent No.2 is the
father, Respondent No.3 is the step-mother and Respondent No.
4 is the aunt of the Respondent No.1 respectively. The
Complainant states that the Respondents No. 1 and 2 along with
brother of Respondent No. 1 have multiple business.
Additionally, Respondent No. 1 had also opened a shop of
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Mobile Accessories near Kandivali West railway station for

which Respondent No. 1 had taken the amount of Rs. 50,000/-
from grand- mother of the Complainant. Both the Complainant
and the Respondents are Muslim by religion.

2. The Complainant states that Complainant has to currently

reside with her maternal grandfather at aforementioned address.
The father of the complainant drives an auto-rickshaw and her
mother work as a domestic help. The Complainant has
studiedonly 11th standard with the financial help of her grand-
father and their Zamat in spite of having interest in further
education and in pursuing a course of Web Designing she could
not finish her further education due to marriage.

3. The Complainant states that the Complainant had received

a marriage proposal from the Respondent Nos. 2 & 3 through one
of the relatives of the Complainant named Juluben. The
Complainant states that the Respondents No. 2 & 3 did not show
any hesitancy and stated that the Complainant can pursue further
education after the marriage if she desires so. The Complainant
was also informed that Respondent No. 1 & 2 along with
Respondent No. 2’s another son run a business together and have
a factory. Apart from that the Respondent No. 1 also runs a
business of fruits and coconuts at Kandivali West. It was states
that Respondent No. 1 alone earns more than Rs. 1 Lakh a
month. The Complainant further states that Respondent No. 2 &
3 claimed that they are looking to buy a new apartment for
Respondent No. 1 but the Complainant’s family will have to plan
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a grand wedding and all the expenses would be borne by the

Complainant’s family.

4. The Complainant states that the marriage between

Complainant and Respondent No. 1 was solemnized on or about
02nd January, 2022 at Shagun Hall, Malkani Estate, Datta Mandir
Road, Malad East, Mumbai – 400097 as per their religious
customs and same is registered with “Noor Masjid”, Malkani
Estate, Malad East, Mumbai – 400 101. Thereafter, the
Complainant was residing at her matrimonial house at Mira Road
with her in laws and Sister in law and brother in law. The
Complainant further states that on 30 th December, 2021 the Haldi
ceremony took place at her maternal uncle’s house. The overall
expenditure including the gold jewelry, Clothes, Furniture,
Utensils, hospitality of the guests, wrist watches, washing
Machine etcRs. 1,50,000/-, spent upon engagement Rs. 50,000/-
was spent upon the Haldi Ceremony and the expenditure over the
wedding was somewhere around Rs. 5,00,000/-. All of the above
expenses were borne by the Complainant’s family. Hereto
annexed and marked EXHIBIT – A( Colly) are the copies of the
Marriage Certificatedated 02nd January, 2022 issued by Sunni
Hanfi Jama Masjid Furqania, Maladeast, Mumbai – 400 097 and
Copies of wedding photographs of the Complainant and
Respondent No. 1.

5. The Complainant states that in March 2022 i.e. 2½ months

after their marriage, Complainant and Respondent No. 1 travelled
to Matheran for honeymoon for 3 days. During the stay there,
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Respondent No. 1 revealed it to the Complainant that Respondent

No. 1 had an affair with a girl named Shahista and she was well
educated. However, Respondent No. 2 and 3 were not consensual
to this relationship of Respondent No. 1 because Respondent No.
3 had made it clear that she will not accept an educated woman
as her daughter-in-law.

6. The Complainant states that Respondent No. 1’s whole

family resides together as a joint family, Respondents had rented
a flat in the adjacent building named Kausar Building, flat no.
402 on two years agreement and were paying rent of Rs. 10,000/-
per month for Respondent No. 1 and Complainant. However,
being a joint family, Respondent No. 1 to 3 and Complainant
spent most of their time at Flat No. 301, Firdaus building, Naya
nagar, Mira Road, Thane and Complainant and Respondent No. 1
would only go to their rented flat to sleep at night.

7. The Complainant states that once during the end of the

month of March 2022 the Complainant tried to discuss about her
desire to continue her further studies and wanting to admit in 12 th
grade, the Respondent No. 3 shockingly became enraged at the
Complainant and asked her that why did she get married to
Respondent No. 1 in the first place if she wanted to pursue
further studies. Further she stated that Respondent No. 1 has only
studied till 7th grade and the Complainant will bring dishonor to
her husband by studying further. The Complainant replied to her
saying Respondent No. 2 had promised her that she would be
allowed to pursue further education and that is the reason why
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she had also taken out her leaving certificate from her college.
The Respondent No. 3 further put on a hysteria and started
getting angry at the Complainant and Respondent No. 1 stating
that there is no need for the Complainant to study further and she
better looks after the household work and bear children and raise
children. She further taunted Respondent No. 1 by saying that he
better control his wife i.e., Complainant or else she will only
bring disgrace to the whole family. This whole conduct was
utterly shocking for the Complainant.

8. The Complainant further states that in April 2022,

Complainant’s sister-in-law named Shabana was admitted to
Tanvar hospital at Mira Road due to some medical emergency.
Her treatment cost somewhere around Rs. 5 – 6 Lakhs. Later, in
September 2022, Respondent No. 2 was admitted to Apex
Hospital in Borivali and his treatment further cost them Rs. 4 – 5
Lakhs. Thereafter, Respondents No. 2 & 3 started to taunt the
Complainant by calling her a jinx upon the family and their well-
being.

9. The Complainant further states that the Respondent No. 3

loathed all the household responsibilities upon the Complainant
alone. The Complainant was made tocookbreakfast and meals for
6 people, wash dishes and clothes, cleaning the floors of the flat
regularly and Respondent No. 3 also denied her daughter to help
the Complainant with these daily chores addressing that the there
is no need to help this wretched woman, let her carry out the
work belonging to her status and taunting to Complainant i.e.
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“iske vajase hamare ghar me bimari aai aur lakho ka kharcha

huwa hain.”The Respondent No. 3 again and again would keep
taunting the Complainant about the weak financial condition of
her parents and would go on calling Complainant sterile and not
being able to bear child falsely alleging that the Complainant has
diabetes and Complainant’s parents have cheated on Respondents
by hiding this from them. If the Complainant retaliated then the
Respondent No. 3 would start hurling abuses at the Complainant.

10. The Complainant states that pursuant to the false

allegations by the Respondent No. 3, on 07 th September, 2022 the
Complainant underwent Pelvic Sonography and obtained blood
test reports that wereboth normal. The Complainant handed over
zerox copies of the said reportsto the Respondent No. 3 as a
proof.Hereto annexed and marked as Exhibit- B(Colly) are the
copies of the Sonography report and blood reports of the
complainant.

11. The Complainant states that Respondent No. 4 once

visited Respondents’ home in and around November 2022and
inquired withRespondent No. 3 as to why has Complainant not
given any good news yet while referring to Complainant not
being pregnant yet. In response to that, Respondent No.
3referring to the Complainant answered that ever since this
sterile woman has entered into their lives, her family’s life is
struck with misfortune. In retaliation, Complainant said that she
has given copies of medical reports to the Respondent No. 3,
which clearly state that Complainant is not sterile. The
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Respondent No. 3 lost of her temper over this and slapped the
Complainant and dragged her to the floor by yanking her hair and
then kicked her repeatedly. The Respondent No. 3 went on
hurling abuses and threatened the Complainant that if she ever
speaks of this to her family, she will turn her life to hell. The
Respondent No. 3 further confiscated the Complainant’s phone
and did not let her attend phone calls from her family and if
required, the Complainant was to speak in front of the
Respondent No. 3.The Complainant was also not permitted to
visit her maternal home anymore and the Respondent No. 3
threatened her by claiming that if she tried to meddle with her
then she would get the Respondent No. 1 remarried to someone
else. Even after knowing all these facts and situation, the
Respondent No. 1 only fed the Complainant with false hopes by
tellingher to tolerate for few more months until they will move
their owned a new flat.

12. The Complainant states that the Respondent No. 1 started a

Mobile Accessories store near Kandivali Railway station,
Kandivali Eastin December 2022, for the rent of Rs. 10,000/-.
Per month.The Complainant further states that despite of being
aware about the financial condition of Complainant’s family, the
Respondent No. 1 urged the Complainant to take Rs. 2 lakhs
from her grandmother so as to help Respondent No. 1 to expand
his business. However, it was not possible for her to gather such
a huge amount but the Complainant still managed to get Rs.
50,000/- from her grandmother and handed it over her husband.It
is pertinent to note that the Respondent No. 1 asked the
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Complainant not to tell about their businessto his parents i.e.,

Respondents No. 2 & 3. Hereto annexed and marked as
‘EXHIBIT – C’are the copies of screenshots taken of pictures
uploaded by Respondent No. 1 as his status on WhatsApp of the
mobile accessories of the store.

13. The Complainant states that one day after a year had
passed to the marriage of the Complainant and the Respondent
No. 1 i.e., in January 2023, the Respondent No. 2 asked
Respondent No. 1 that it has been over a year to his marriage and
the Complainant still has not conceived a child, is he not
interested in her? If it is so he can get him remarried to another
woman and send the Complainant back to her maternal home so
he does not need to worry about that. The Complainant further
states that on addition to that the Respondent No. 3 threatened
the Complainant that if she ever visits her maternal home, she
will not be allowed to enter this home again. The Respondent No.
1 also rather than supporting Complainant, warned the
Complainant by saying that she shall obey what Respondents No.
2 & 3 say.

14. The Complainant states that the Respondent No. 1 earns

well and lives a lavish lifestyle. The Respondent No. 1’s personal
expense is around Rs. 20,000 – 25,000/- per month but still he
had taken an amount of Rs. 8,000/- from the Complainant for the
mobile accessories shop business which she had received from
her grandmother. On asking to return her money, the Respondent
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No. 1 would refuse the Complainant to give her the money

stating that Respondent No. 2 & 3 have restricted him to do so.

15. The Complainant states that the Complainant was suffering

through the taunts and tortures from the Respondents invariably.
The Complainant had lost her appetite and she was sleep
deprived due to her anxieties and apprehension. The Complainant
was constantly falling ill experiencing high temperature and
dizziness but no one from the family would even bother to take
her to the hospital or even to give her medicines.

16. The Complainant further states that in march 2023, the

Respondent No. 3 took the Complainant for her medical check-
up to one doctor named Dr. Vaishali Chaudhari. The
Complainant also underwent Pelvis (TA) sonography and
obtained her blood reports and again all the reports came normal.
The doctor also suggested that the Complainant is capable of
conceiving a child and her husband i.e., Respondent No. 1 might
have to get checked up. It is pertinent to note that the Respondent
No. 3 while visiting the doctor with the Complainant gave
Complainant’s maternal surname Hereto annexed and marked as
Exhibit- D is the copy of pelvis (TA) sonography report.

17. The Complainant states that one evening, after she had
received her medical reports, the Respondent No. 4 visited their
home and learned that the doctor has advised the Respondent No.
1for a medical check-up. The Respondent No. 4 upon hearing
this insisted the Respondent No. 1 to not visit for a medical
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check-up and further went on making a controversial statement

addressing Respondent No. 2 saying if he allows and
Respondent No. 1 keep quietthen she can conceive a child for
Respondent No. 1 within nine months and the Respondent No. 2
responded hopelessly. The Complainant was present during these
conversations and was jolted upon hearing such things being said
and her family reacting to it timidly. All of this was getting
overwhelming for the Complainant and when she tried to
retaliate against the Respondent No. 4’s statement, the
Respondent No. 3 started hurling abuses at her. The Respondent
No. 1 would never take a stand for her and only used to pacify
her by giving her false promises that they will soon move out to a
new flat in Kandivali and tell to Complainant to stay keep quite
for few days and don’t tell anything to your parents home
otherwise everything will get worse,

18. The Complainant states that around 10 th March, 2023

Respondent No.1 confronted Respondent No. 2 falsely states that
the Complainant wanted to move out to a new flat. This triggered
the temperament of the Respondent No. 3 and she blasted with
anger upon the Complainant. The Respondent No. 3 made wild
statements claiming that she is Respondent No. 1’s step-mother
and the Complainant has not witnessed her audacity and
stubbornness. The Complainant went to state that how she had
harassed and thrown out the Respondent No. 1’s real mother and
separated her from Respondent No. 2 and she did not let either of
them even meet her till her last breath. The Respondent No. 3
resorted to her usual habit of hurling abuses and threatening the
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Complainant to throw her out of the house just like she did with
Respondent No.1’s real mother.

19. The Complainant states that following the above incident,

the Complainant responded by saying that she had never made
any such wish. The Respondent No. 1 lost his temper over this
and to shut the Complainant since his lie would have gotten
caught, he hurled abuses at the Complainant and slapped her 2-3
times.

20. The Complainant states that the following the above

incident the Complainant’s life change drastically and her life
collapsed into living hell. The Complainant was being abused
like an object at her matrimonial home and was subject to regular
taunts and foul language. The Respondents would demean her by
mentioning her parents’ poverty and never ceased an opportunity
to humiliate her. The Complainant was even apprehended to
approach her old grandparents since she did not want them to
suffer due as they would not be able to digest this condition of
the Complainant. Same with her parents, since they were already
going through hardships in their life. The Complainant had found
herself in a deep, dark hole and she had nowhere to go.

21. The Complainant states that on 19 th March, 2023, while

out shopping with the Respondent No. 1 and his family during
the month of Ramazan, the Complainant lost her mobile phone
which was a gifted from Respondent No. 1 she received at time
of marriage. The Respondent No. 3 got an opportunity to again
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get angry at the Complainant. After reaching home, the

Respondent No. 2 & 3 put up a drama and called out the
Complainant. They blamed the Complainant for bringing
misfortune to the family and threatened her to throw her out of
their house since she has been demanding a new home. The
Complainant retaliated by stating that she has never put up such a
demand, but once again the Respondent No. 1 shut her up and
stated if she has forgotten the beating given by him. The
Respondent No. 2 & 3 stated that if the Complainant wanted to
live with her husband i.e. Respondent No. 1 then she can arrange
Rs. 5 lakhs and then they will think about buying a new house for
Respondent No. 1 and the Complainant. The Respondent No. 2
even said that he will stop paying the rent for the flat which they
had rented for the Complainant and the Respondent No. 1 and
Respondent No. 2 further said to the Complainant to give
remaining months/next years rent from her parents otherwise go
to your parents home. The Complainant was helpless and left in
shock. She had no one to approach to and the Respondents were
clearly bent upon harassing her.

22. The Complainant states that on 05 th April, 2023 prior to

dropping her off at her grandparents’ house the Respondent No. 1
gave her an old mobile phone of Realme Company with a sim
phone number 8369721296. The Respondent No. 1 threatened
the Complainant by saying that if she does not manage to gather
Rs. 5 lakhs and rent for rest of the month for the rented flat his
family will not accept her in any circumstances. It is pertinent to
note that prior to leaving from her matrimonial home, the
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Complainant asked the Respondent No. 3 for the gold ornaments

belonging to Complainant however, the Complainant request
refused by alleging that she could not find the keys to the
cupboard where the jewellry is kept.

23. The Complainant states that on the 06th April, 2023 that is
very next day the Respondent No. 1 called the Complainant on
the aforesaid mobile No. 8369721296 and threatened her again
that if she does not take the money from her grandparents then
she can loss everthing. The Complainant was shaking and crying
while over the call which was noticed by her grandmother. The
Complainant’s grandmother confronted her and after insisting her
long the Complainant broke down and narrated her grandparents
the whole situation. Upon hearing all this the Complainant’s
grandfather called the Respondent No. 2 to inquire about the
situation and invited him to his house so as to discuss about it but
the Respondent No. 2 stated that he would call back and hung up
the call. The Complainant and her parents tried to call the
Respondent No. 2 multiple times but he never received their calls
nor called.

24. The Complainant states that on 07 th May, 2023 she

received a call from the Respondent No. 1 whereof he got angry
at the Complainant for narrating her situation with her
grandparents and threatened her of dire consequences. Further on
10th May, 2023 the Respondent No. 1 sent a message to the
Complainant on about 11:30 PM on Whatsapp asking her to take
away all her belongings since he has to vacate the flat. Hereto
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annexed and marked as ‘EXHIBIT – E’is the copy of a

screenshot taken from the Complainant’s phone of the message
sent by the Respondent No. 1. The Complainant further states
that the Respondent No. 1 blocked the number 8369721296 on
14th May, 2023 which he had given to the Complainant alongwith
the old mobile phone.

25. The Complainant states that on 11 th May, 2023 the

Respondent No. 3 called the grandmother of the Complainant to
again inform her to take back the belongings of the Complainant
to which the grandmother responded by mentioning that the
Respondent No. 2 was supposed to visit their residence in order
to resolve the situation. The Respondent No. 3 however said that
Respondent No. 2 is not willing to meet them. The Complainant
states that complainant’s grandfather tried calling Respondent
No. 2 multiple times but to no avail. Hereto annexed and marked
as EXHIBIT – F is the copy of List of articles belonging to
Complainant.

26. The Complainant states that in view of such continuous

harassment by Respondents both physically and mentally, the
Complainanthas totally suffered and as such it has become
practically impossible for the Complainant to continue to stay
along with the Respondent No.1 , 2 and 3 is very angry
aggressive and cruel person so Complaint is afraid that they will
threaten her life.
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27. The Complainant states that presently she is not working

anywhere and living in Mumbai at the mercy of her grandparents.
It is great difficulty for the Complainant to maintain herself and
to satisfy her basic needs of life and further the Complainant has
no shelter of her own in Mumbai or anywhere else.

28. The Complainant states that being her lawful husband it is

the duty of the Respondent No.1 to maintain her and to provide
accommodation. The Respondents have with malafide intentions
abandoned the Complainant without any fault and Respondent
No. 2 & 3 plan to get Respondent No. 1 remarried to someone
else.

29. The Complainant states that in the above circumstances the

Complainant addressed a legal notice 8thJune, 2022 addressed to
the Respondent No.1 to 3. Hereto annexed and marked
‘EXHIBIT –G( colly)’ is notice dated 8th June 2022and
acknowledgement receipts . The Respondents however have
refused to accept the said notice.The Complainant thereafter
lodged a written complaint addressed to the Deputy
Commissioner of Police and other authorities, Mumbai and on
28th June, 2023. Hereto annexed and marked as ‘EXHIBIT –H.
is the copy of the Complaint. Accordingly Dindoshi police
Station registered the FIR against the aforesaid Respondents U/s
498A, 406,323,504 and 34 of IPC on 29.10.2023. FIR no. 770
of 2023.
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30. The Complainant states that the Respondents are owning

and in possession of various movable and immovable properties
in Mumbai. The Respondents have multiple businesses and live
decent lifestyle.

31. The Complainant further states that the Respondents are in

possession of various expensive and valuable immovable items
belonging to the Complainant and now the Respondents do not
answer the phone calls of the Complainant or her maternal
relatives. The Complainant states that the Respondent has already
taken Rs. 58,000/- from the Complainant and the Respondents
are also in possession of numerous items including the gold
ornaments belonging to the Complainant. The Complainant
further states that the Respondents are also in possession of the
Complainant’s School and College certificates, Mark-lists, Birth
Certificate, Leaving Certificate, Aadhar Card etc. and other
original documents are lying with the Respondents.

32. The Complainant has reason to believe that the

Respondents are in the process of alienating many of the

movable properties to third parties with a view to jeopardize the

claims of the Complainant.

33. The Complainant presently maintaining herself with the

mercy of her grandparents and maternal uncle who are also

suffering from financial constraint and the Complainant is

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without having any means of livelihood. On the other hand, the

Respondent No. 1 is running multiple business alone and with his

family and their total income is more than Rs, 3 Lakhs. The

Respondent No. 1 alone earns more than Rs. 1 Lakh. The

Complainant further states that with a view to maintain herself

manner suited to the standard of living of the Respondent No. 1 it

is in the interest of justice to issue further appropriate order and

direction to the Respondent No. 1 to pay a sum of Rs. 50,000/-

per month for the maintenance of the Complainant.

34. In the foregoing facts and circumstances, it is in the

interest of justice that appropriate orders and directions are issued

thereby permanently restraining/prohibiting the Respondent from

committing any Act of Domestic Violence and/or aiding or

abetting such acts of domestic violence.

35. Complainant states that her marriage with the Respondent

is still subsisting which entitles to get the maintenance and

shelter to live her life.

36. Complainant states that presently she is residing in

Mumbai within the Jurisdiction of Dindoshi Police Station, at

address mentioned in the cause title. Therefore,this Hon’ble

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Court has jurisdiction to entertain and decide the present

Case/Complaint.

37. The Complainant states that she has not filed any other

proceedings either in this Hon’ble Court or in any other Court of

law for the same cause of action.

38. The Complainant states that she being women is exempted

from payment of Court fees as per the provision of law;

However, Complainant hereby pays the process-fees by affixing

the same as prescribed under the law.

39. The Complainant will rely upon the documents, a list

whereof is annexed hereto.

40. Complainant therefore prays that:-

a) This Hon’ble Court may be pleased to pass an order

restraining the Respondentsfrom alienating any

assets, both movable and other properties.

b) This Hon’ble court be pleased to direct the

Respondent No.1 to secure the same level of

alternate accommodation for the Complainant as

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enjoyed by her in the shared household;or in the

alternative this Hon’ble court may be pleased to

order for payment of monthly rent at the rate of Rs.

20,000/- or at such other rate as this Hon’ble court

may deem fit and proper and security deposit of Rs.

10,000/- and brokerage for residential Rs. 40,000/-.

c) This Hon’ble Court may be pleased to direct the

Respondent to pay Rs. 50,000/- per month to

Complainant towards the maintenanceof herself;

d) Pending the hearing and final disposal of this

complaintthis Hon’ble Court may be pleased to pass

appropriate order restraining the Respondent from

alienating any properties belonging to the

Complainant.

e) Pending the hearing and final disposal of this

complaintthis Hon’ble court be pleased to direct the

Respondent to secure same level of alternate

accommodation for the Complainant as enjoyed by

her in the shared household, or in the alternative this

Hon’ble court may be pleased to order for payment

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of monthly rent at the rate of Rs. 20,000/- or at such

other rate as this Hon’ble court may deem fit and

proper and security deposit of Rs. 10,000/- and

brokerage for residential Rs. 40,000/-.

f) Pending the hearing and final disposal of this

Hon’ble Court may be pleased to direct the

Respondent to pay Rs. 50,000/- per month to

Complainant towards the maintenance of herself.

h) Any such other and further orders as the nature and

circumstances of the case may require be granted;

AND for this act of kindness and justice the Complainant

shall as in duty bound ever pray.

Mumbai,
Dated on this __ day of December, 2023. Complainant

Advocate for Complainant.

VERIFICATION

I, Sana Altaf Taibani, the Complainant above named, do

hereby solemnly declare that whatever is stated in the foregoing

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paragraphs of the above Complaint is true to my own knowledge

and I believe the same to be true and correct.

Solemnly declared at Mumbai. )

Dated this day of December, 2023) Sana Altaf Taibani

Before me,
Identified & explained by me,

Advocate for Complainant.