BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE

________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
Pqr & Anr …Respondents

INDEX

S. No. Particulars Pg. No.

1. Memo of Parties

2. Complaint under Section 12 r/w Section 17, Section 18, Section

19, Section 20 Section 22 and Section 23 of the Protection of
Women from Domestic Violence Act, 2005 with supporting
affidavit.

3. Application under Section 17 read with Section 23 of the

Protection of Women from Domestic Violence Act, 2005 with
supporting affidavit.

4. Application under Section 18 read with Section 23 of the

Protection of Women from Domestic Violence Act, 2005 with
supporting affidavit.

5. Application under Section 20 read with Section 23 of the

Protection of Women from Domestic Violence Act, 2005 with
supporting Affidavit.

6. Application under Section 22 read with Section 23 of the

Protection of Women from Domestic Violence Act, 2005 with
supporting Affidavit.

7. List of Documents
 8. Vakalatnama

Complainant / Applicant
Through
Adv.
Counsel for Complainant / Applicant
Date:
Place:
 BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE
________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
Pqr & Anr …Respondent

MEMO OF PARTIES

Abc,

_____,

_____ …Complainant / Applicant

Versus

Pqr,

________ …Respondent

Complainant / Applicant
Through
Adv.
Counsel for Complainant / Applicant
Date:
Place:
 BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE
________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
Pqr & Anr …Respondents

COMPLAINT UNDER SECTION 12 R/W SECTION 17, SECTION 18, SECTION

19, SECTION 20, SECTION 22 AND SECTION 23 OF THE PROTECTION OF
WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

MOST RESPECTFULLY SHOWETH:

The Complainant has preferred has filed the instant Complaint under Section 12 r/w
Section 17, Section 18, Section 19, Section 20 Section 22 and Section 23 of the
Protection of Women from Domestic Violence Act, 2005 due to being aggrieved by the
cruelty inflicted upon her by the Respondents in the form of mental and physical torture
and harassment, social and financial abuse and after suffering at the hands of the
Respondents the Complainant has no other choice but to seek redress before this Hon’ ble
Court. The torture and cruelty faced by the Complainant cannot possibly be coined in
terms and be provided with a complete sum up of events, however the Complainant
proceeds to provide the accounts of cruel treatment she was meted out to by the
Respondents, hereafter:

1. The marriage between the Complainant and the Respondent was solemnized on
26.11.2020 at Stardom Hotel in Noida, Uttar Pradesh, pursuant to which the
Complainant started residing with the Respondent at her matrimonial home i.e.
________ and the marriage was duly consummated there due to which a son was
 born out of the wedlock on 06.09.2021. A copy of the invitation card and marriage
photographs is marked and annexed hereafter as “ANNEXURE C-1”

2. The Respondents had even before marriage, exhibited through their words and
actions that the Complainant and her family was unequal to them in terms of status
and reputation, therefore in order to be accepted as in their family the Respondents
had asked the Complainant to bring in a hefty dowry and their demands were duly
met by the Complainant’s family since they had no other option left but to either
fulfill the Respondents’ demands or get the marriage rescinded and stand ashamed
in the society. Therefore in furtherance to the dowry demands made the parents of
the Complainant provided Rs. 10, 00, 000/- in cash, 5-7 Kg’s of gold jewelry with
substantial quantity of household items. The gold jewelry and the Complainant’s
stridhan were taken by the Respondents and hidden post marriage and till date she
has not been informed about the whereabouts of the same neither have been
returned the same. To topple all the aforesaid distressing acts, the Respondent also
did not provide the Complainant with the photographs of marriage even after his
wife’s numerous requests and only the ones which were taken by mobile phones
are the one that have remained with her. This itself makes it evident that the
Respondent never truly accepted the Complainant and considered her unequal to
him which created the roots to the Respondent’s torturous acts towards the
Complainant.

3. The Complainant submits that motherhood is the most cherished phase in every
woman’s life, the journey for a woman from conceiving till delivery of the baby is
filled with volatility and struggle, since everyday and every moment brings new
challenges from physical changes to mental endurance, however this journey is
nonetheless joyous for a mother because of the belief that all the pain suffered will
bear fruits of celebration, of bringing a new life into this world, this joy grows
many folds with the support and assistance of the woman’s partner / husband and
 times like pregnancy, test the strength of a marital bond, the assistance and support
of a husband is the only thing that helps a woman cross the perils of pregnancy.
However in the case of the Complainant this was the time when she expected
complete and unquestioned support of the Respondent but received nothing but
harassment and torture, the Complainant in order to manage herself and her
expenses, since she received inadequate maintenance from the Respondent worked
as a Collection Manager in HDFC Bank, Agra for the whole period of her
pregnancy, although working in her pregnancy which in itself was an arduous task,
the Complainant still fulfilled her duty as a wife and daughter in law and used to
take leaves to travel to her matrimonial home but the Respondent extended no
support to her in her condition even though he resided with her in Agra but his
residence with her was owing to ulterior reasons than that of supporting her, the
reason he was residing with her in Agra was to keep an eye on her because he used
to suspect and doubt the character of the Complainant and believed that she was
cheating on him, such restriction of privacy and creating an air of uncomfortability
had really distressed the Complainant.

4. The Complainant submits that the Respondent during her pregnancy would start
arguments and quarrels for no rhyme or reason and harass the Complainant, due to
being pregnant the Complainant’s heartbeat rate would remain elevated to 130-140
even while resting however the Respondent showed no concerns for the same and
would argue with her over trifling issues and taunt her with bitter remarks, the
Respondent even disregarded her employment and efforts to earn her own
livelihood by commenting “Do kaudi ki naukri karti hai aur mujhe dikhawa karti
hai, aur aurton ko dekho unhone kya baccha paida nahi kia? Ye tum koi anokhi
maa ban rahi ho?” such comments of the Respondent would really break the spirit
of the Complainant and the same would depress her. Furthermore, as pregnancy
progresses, the effects become all the more visible on a woman’s body and
sickness or weakness is quite common, the Complainant in her third month, due to
 weakness would feel sick, weak and used to have vomiting multiple number of
times such as 7-10 times in a day but this pitiful condition of the Complainant had
no appeal over the Respondent’s stone cold heart and he would make her do the
rigorous house chores even in such condition, if she failed or delayed in her tasks
he would verbally abuse her and threaten to hit her, the acts of Respondent created
new rifts of harassment everyday and the Complainant could not believe what she
was reduced to due to marrying a violent and uncaring man.

5. The Complainant submits that on 31.08.2021 she experienced a sharp pain in her
stomach which was due to labor pain which had put the Complainant under the
impression that her water would break soon, however her water did not break
which led to her suffering severe pain therefore she was rushed to her nearby
Hospital i.e. New Agra Hospital, wherein a gynecologist examined her and
conducted an Ultra Sound test from which she learned that the baby had came
down (a general term used for the medical terminology for when the baby settles
lower in the pelvis which occurs when the due date of delivery approaches) and
the Doctor advised that a C-Section was necessary, however the Respondents
wasted a week’s time in consulting with several specialists to obtain a varied
advise in order to save their expenses since C-Section surgery is commonly
expensive compared to a normal delivery even though the Complainant was not in
the condition of a normal delivery, this had put the Complainant in utter shock that
her husband and in-laws were ready to put her life in jeopardy to save their money,
this indicates that the Respondents’ greed knew no bounds. Finally the
Complainant’s parents seeming the incompetence of the Respondents to take care
of their pregnant daughter took her to the Gynecologist who had examined her
initially and had to bear the brunt of the doctor for the inability of the in laws of
being so careless and suggested immediate surgery since the Baby’s head was
tilted and the baby had moved upside down in the womb which is hazardous for
the mother as well as the baby’s life therefore C-Section surgery was performed on
 06.09.2021 and the baby was delivered, to the shock and dismay of the
Complainant the Respondents showed no happiness of support to the weak
Complainant and her family took complete care of the duo.

6. The Complainant submits that she was being subjected to regular torture,
Respondent would just avail every opportunity he got to embarrass or harass the
Complainant, a month after the Complainant’s delivery her father had retired
however the Respondent was quite adamant to know how much of retirement
funds had her father received and where had he used it, he further complained to
the Complainant as to why no money was given to him from the retirement funds
since he was his son in law and gave illogical and fantastical examples of how
other families treated their son-in-law’s similar to an incarnation of god, on such
queries of the Respondent the Complainant requested him to mind his own life
since it was her father’s money and the Respondent had no rights to enquire about
the same but this request was met with abuses, furthermore the Respondent had
purchased a house in Gulshane Ikbana, Noida for which he acquired a loan facility
from his bank, it was quite shocking for the Complainant to learn that the house
purchased was purchased by the Respondent in his name and the Complainant’s
name was not entered in the title deeds and sale deed, however he had the audacity
to ask the Complainant for money to pay off the loan which seemed completely
illogical to the Complainant. After purchase of the said house, a warm welcoming
ceremony was kept “Grah Pravesh”, since the Complainant was on maternity leave
in order to recuperate from the delivery, she could not bend or do any task of
speed, however the Respondent embarrassed her in public by making fun of her,
which left her feeling belittled and embarrassed, the Respondent thus made sure to
taint the image of the Complainant in public.

7. The Complainant submits that the Respondents had even troubled the new born
baby of the Complainant, since the Complainant was weak after surgery and the
 baby could not be content just by the milk of the Complainant therefore the
doctor’s had advised the Complainant as well as the Respondents to feed the new
born with lactogen milk, which is a product containing milk solids for the
consumption of infants and toddlers and the same is to be fed after diluting the
product with water, this lactogen milk mimics real milk since it has almost
identical components to that of which are present in organic milk and is a healthy
milk substitute for new born babies, further this product is certified by physician
labs and FSSAI therefore it can be termed safe for feeding, however the
Respondents showed disagreement over feeding the baby lactogen milk and rather
kept the baby hungry then to let him drink the lactogen milk by hiding the box of
lactogen, very well knowing that the same was prescribed by doctors because the
Complainant could not produce enough milk for the baby, this reflects, that the
Respondents harassment was severe and extended even towards a new born baby.
Furthermore the Respondent has failed to fulfill his duties towards his new born
baby, he is not only a careless but also a negligent father who has never extended
any sort of assistance to the Complainant to help in the baby’s growth, whenever
the baby used to get sick the Respondent would avoid confronting or caring for the
baby and would not tolerate the crying of the baby as he had no bond with his own
child.

8. The Complainant submits that there are a set of vaccinations that are necessary to
be administered to a new born within for a certain period with intervals regarded
to the baby’s growth, the Respondents did not pay for the vaccinations of the baby
rather the parents of the Complainant, the Respondent always avoided the
vaccinations quoting that he had other sorts of vaccines for the child, this used to
give rise to many arguments and quarrels between the parties and in January, 2022
during one such fight which continued from 10.00 Pm to 1.00 Am the Respondent
thrashed the complaint and pushed her, then while she was lying on the floor he
grabbed of her arm and twisted it which gave her cramps in her arm muscles, then
 he called his family members and asked them to take the Complainant away with
him as he did not wanted to breathe the same air the Complainant breathed, the
Complainant’s brother came to receive her and took her to Agra.

9. The Complainant submits that not only at one but the Respondent had physically
assaulted her multiple times. It is apropos to mention that when the Complainant
had went to her house after the last assault committed with her, the Respondent
had approached her and begged her to forget past mishaps and forgive him and go
back to his home with him with their baby, believing that the Respondent had
finally realized his mistake and was apologizing for his misbehavior she gave him
another opportunity since she did not wished to be the egoistic person due to
whom their bond of marriage could end up jeopardized therefore she followed
him. However to her utter shock and misfortune only after a week later, when she
was in her matrimonial home, the Respondent in an inebriated state approached
the Complainant and started a baseless argument following which he verbally
abused her and thrashed her inhumanly on the face and body, he hit her to the
extent that she fell on the ground almost unconscious and was unable to get up, the
Complainant was battered and could not contemplate as to what made her deserve
such inhumane treatment, following such treatment she again called her brother to
pick her up and take her to her maternal home, when the brother of the
Complainant came to get her, the Respondent kept laughing at her condition, this
reflects that the Respondent had no remorse in his heart for the Complainant and
is a sadistic person by nature.

10. The Complainant submits that, even though she went to her maternal home but she
could not stay there forever and had to return to her husband as staying at her
home was not in any way a resolution to the problems faced, and to save her
family reputation and marital bond she could not approach the police for any help
with the hope that things may get better by passage of time, however situation
 rather escalated than being resolved, she was subjected to physical assault every
second day, belittling comments and hurling abuses had became the Respondent’s
habit, when the Complainant complained about his beatings and assault to the
mother of the Respondent, but she would rather silent the Complainant by saying,
that its nothing big, her husband would beat her habitually too and that physically
assaulting women was in the nature of men, such confrontation of the Respondent
No.2 very well shows that the environment of the matrimonial home was
absolutely toxic.

11. That the Complainant belongs to a noble and well educated background, her
marriage was supposed to be a happy one until her fate took an ill turn due to the
Respondent’s interference in her work life fueled by illogical suspicion over his
wife’s character, she was employed with the HDFC Bank, Agra as a Collection
Manager, a prestigious position which the Complainant had earned after years of
hard work, dedication and commitment, however the same was unbearable to the
Respondent and where a husband supports perhaps even encourages his spouse to
thrive in her employment the Respondent in 2022 started actively forcing her to
change her job and coerced her into obtaining a job at a company of his choosing,
surrounded with people of his circle and connection at an NBFC by the name and
style of Tata Capital located at Noida Sector 143. This demotion from a leading
banking company to an NBFC had far reaching as well as diverse effects on the
Complainant’s career and life however the Complainant was forced to join the said
job since her husband i.e. the Respondent had an undue influence upon her, it is
pertinent to mention that right to an occupation of self choosing is a right
guaranteed to every citizen of India by Article 19(1)(g) of the Constitution of India
which is to be read with Article 21, a bedrock through which right to life and
personal liberty emanate and flow instilling and harnessing the spirit behind
various other fundamental rights guaranteed by the Constitution. Not to mention
this move of the Respondent also affected the pay and subsequently the expenses
 of the Complainant. He would often taunt her that he she was a woman of such
low dignity that she could sleep with any man, he would even ask his friends to
spy on the Complainant and inform him if she was cheating on him, he would
even obtain her call records without her consent to further ensure if she was
cheating on him, however no such evidence came forward and the Complainant
thus proved that she never had cheated on the Respondent but this proved another
point that the Respondent had no trust over his wife and had a habit of suspecting
her.

12. The Complainant submits that the Respondent had purchased a land near Sikandra,
Agra and had asked the Complainant to financially help him and provide him with
2, 50, 000/-, after regular pestering the Complainant gave him the said amount but
to her shock and dismay the land purchased by the Respondent was solely in his
name and the Complainant was given no share in it. The Respondent would oust
the Complainant from the matrimonial house almost every month and would taunt
her to care for her own self and he shall care for himself without minding that the
Complainant also had a baby to take care of. Even the new job that was also
troubling to the Complainant as it was very restrictive in nature and the work
pressure was immense due to which the Complainant and Respondent used to
always fight. In January 2023, the baby fell severely sick and kept on crying
continuously which irritated the Respondent and he forced the Complainant out of
the house with the baby in that pitiful condition, the Complainant had to look for a
Paying Guest room and since then has been residing in the paying guest room.

13. The Complainant submits that such acts of the Respondent has immensely tortured
her mentally, socially and have not only affected her mental peace but have also
violated her person and liberty, and the makers of our Constitution had ensured
that every citizen of India had the liberty to live peacefully and with dignity, the
same is ingrained in the very preamble of our Constitution and the Respondent by
 assaulting her physically and torturing her mentally have not only contravened the
provisions of the Protection of Women from Domestic Violence Act, 2005 but
also the spirit of our Constitution which grants various liberties to an Indian
Citizen. The Complainant is therefore left with no other option but to approach
this Hon’ble Court.

14. The present Complaint is not being presented in collusion with the Respondent
husband.

15. The Complainant has not condoned the acts of cruelty of the Respondent in any
manner whatsoever.

16. There have been no proceedings with regards to the marriage on behalf of the
Complainant.

17. The Complainant is residing at _______ therefore this Hon’ble Court has the
jurisdiction to take cognizance of this case, order its trial and adjudicate the case in
accordance with the provisions of the Protection of Women from Domestic
Violence Act, 2005.

18. The court fees is affixed by way of Court fees stamp and the Complainant
undertakes to make good of any deficiency in the Court fees.

19. The Complainant reserves her right to add or amend any part of this Complaint I
future if needed.

PRAYER
In view of the abovementioned facts and circumstances, the Complainant most
humble prays this Hon’ble Court to:
1. Pass residence Order under Section 17 read with Section 19 of the Protection
of the Women from Domestic Violence Act, 2005 restraining the Respondent
from alienating or disposing off the shared household or encumbering the
same.

2. Pass Protection Order under Section 18 read with Section 23 of the Protection
of Women from Domestic Violence Act, 2005 prohibiting the Respondent
from alienating the stridhan that is still in the possession of the Respondent at
their residence and granting injunction against the Respondents from repeating
any of the Acts of violence mentioned in the complaint of the Complainant and
prohibiting any form of communication by the Respondent and other relatives,
friends and associates with the Complainant and pass necessary directions in
the concerned SHO for the protection of the Complainant.

3. Direct the Respondent to grant monetary relief under Section 20 read with
Section 23 of the Protection of Women from Domestic Violence Act, 2005 and
reimburse all the expenses incurred by the Complainant and her family during
the wedding function and monetary assistance provided by the Complainant to
the Respondent during purchase of properties, moreover, direct Respondent to
reimburse Complainant and her family for all gifts, jewellery and clothes that
were given as gifts to Respondent and his family.

4. Direct the Respondent to grant compensation or damages to the Complainant

under Section 22 read with Section 23 of the Protection of Women from
Domestic Violence Act, 2005 for mental injuries, emotional distress caused by
the acts of the Respondent and for the severe domestic violence committed by
the Respondent against the Complainant.

5. Pass any further such interim Orders as the Court may deem fit and proper.
 6. Pass any such other orders which this Hon’ble Court may deem fit and proper
under the given facts and circumstances of the case for the protection of the
Complainant.

Complainant / Applicant
Through
Adv.
Counsel for Complainant / Applicant
Date:
Place:

BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE

________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent
 AFFIDAVIT

I Abc , aged: , W/o: , residing at: do hereby solemnly affirm and

declare as under:
1. That I am the Complainant / Applicant in the abovementioned complaint and well
conversant with the facts of the case and as much competent to swear this
affidavit.

2. That the accompanying Complainant under Section 12 of the Protection of

Women from Domestic Violence Act, 2005 has been drafted by my counsel under
my instructions. The contents of the same have been read over and understood by
me.

3. The contents of the Complainant may kindly be read over as part and parcel of this
affidavit as the said contents are not repeated herein for the sake of brevity.

Deponent
VERIFICATION
Verified on this ___ day of ______, 2023, I the Complainant hereby solemnly
affirm that the contents of the Affidavit are true and correct to the best of my
knowledge and nothing material has been concealed thereof or therefrom.
Deponent
 BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE
________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

APPLICATION UNDER SECTION 17 READ WITH SECTION 23 OF THE

PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

MOST RESPECTFULLY SHOWETH:

1. That the Complainant / Applicant has filed the present complaint under Section 12
of Protection of Women from Domestic Violence Act, 2005 Act and the contents
of the Application may kindly be read with as part and parcel of the present
application which are not being repeated herein for the sake of brevity.

2. That the Complainant / Applicant is filing the present Application under Section
17 read with Section 23 of the Protection of Women from Domestic Violence Act,
2005 requesting this Hon’ble Court direct the Respondent to let the Complainant
reside in the shared household and restrict the Respondent from alienating,
encumbering, selling or disposing of the household in any manner whatsoever.

3. That the Complainant / Applicant kindly requests the Hon’ble Court to prohibit the
Respondent from evicting or excluding the Complainant from the shared
household or any part of it.

PRAYER
In view of the abovementioned facts and circumstances, the Complainant most humbly
prays this Hon’ble Court:

1. Allow the present Application and grant the Complainant / Applicant protection
under Section 17 read with Section 23 of the Protection of Women from Domestic
Violence Act, 2005.

2. Pass any such further orders as this Hon’ble Court may deem fit and proper in the
interests of justice.

Complainant / Applicant
Through
Adv.
Counsel for Complainant / Applicant
Date:
Place:

BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE

________
 CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

AFFIDAVIT
I Abc , aged: , W/o: , residing at: do hereby solemnly affirm and
declare as under:
4. That I am the Complainant / Applicant in the abovementioned complaint and well
conversant with the facts of the case and as much competent to swear this
affidavit.

5. That the accompanying Application under Section 17 read with Section 23 of the
Protection of Women from Domestic Violence Act, 2005 has been drafted by my
counsel under my instructions. The contents of the same have been read over and
understood by me.

6. The contents of the Application may kindly be read over as part and parcel of this
affidavit as the said contents are not repeated herein for the sake of brevity.

Deponent
VERIFICATION
Verified on this ___ day of ______, 2023, I the Complainant hereby solemnly
affirm that the contents of the Affidavit are true and correct to the best of my
knowledge and nothing material has been concealed thereof or therefrom.
Deponent

BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE

________
 CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

APPLICATION UNDER SECTION 18 READ WITH SECTION 23 OF THE

PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

MOST RESPECTFULLY SHOWETH:

1. That the Complainant / Applicant has filed the present complaint under Section 12
of Protection of Women from Domestic Violence Act, 2005 Act and the contents
of the Application may kindly be read with as part and parcel of the present
application which are not being repeated herein for the sake of brevity.

2. That the Complainant / Applicant is filing the present Application under Section
18 read with Section 23 of the Protection of Women from Domestic Violence Act,
2005 requesting this Hon’ble Court that the Respondent be prohibited from
alienating his assets, operating bank accounts used or held by both the parties and
further be prohibited from alienating any property owned by the Complainant
including her stridhan that still remains in the custody of the Respondent.

3. That the Complainant / Applicant kindly requests the Hon’ble Court to prohibit the
Respondent from entering her current residence and the maternal house of the
Complainant / Applicant. Further, the Complainant / Applicant requests this
Hon’ble Court to prohibit the Respondent from attempting to communicate with
the Complainant including personal, oral , written, electronic or telephonic
contact.
 4. That the Complainant / Applicant requests this Hon’ble Court that the
Respondents be prohibited from causing violence particularly verbal and
emotional abuse to the dependents and other relatives of the Complainant /
Applicant herein who have been assisting her against grave injustice inflicted upon
her by the Respondent.

PRAYER

In view of the abovementioned facts and circumstances, the Complainant most humbly
prays this Hon’ble Court:

1. Allow the present Application and grant the Complainant / Applicant protection
under Section 18 read with Section 23 of the Protection of Women from Domestic
Violence Act, 2005.

2. Pass any such further orders as this Hon’ble Court may deem fit and proper in the
interests of justice.

Complainant / Applicant
Through
Adv.
Counsel for Complainant / Applicant
Date:
Place:

BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE

________
 CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

AFFIDAVIT
I Abc , aged: , W/o: , residing at: do hereby solemnly affirm and
declare as under:
1. That I am the Complainant / Applicant in the abovementioned complaint and well
conversant with the facts of the case and as much competent to swear this
affidavit.

2. That the accompanying Application under Section 18 read with Section 23 of the
Protection of Women from Domestic Violence Act, 2005 has been drafted by my
counsel under my instructions. The contents of the same have been read over and
understood by me.

3. The contents of the Application may kindly be read over as part and parcel of this
affidavit as the said contents are not repeated herein for the sake of brevity.

Deponent
VERIFICATION
Verified on this ___ day of ______, 2023, I the Complainant hereby solemnly
affirm that the contents of the Affidavit are true and correct to the best of my
knowledge and nothing material has been concealed thereof or therefrom.
Deponent
 BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE
________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

APPLICATION UNDER SECTION 20 READ WITH SECTION 23 OF THE

PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

MOST RESPECTFULLY SHOWETH:

1. That the Complainant / Applicant has filed the present complaint under Section 12
of Protection of Women from Domestic Violence Act, 2005 Act and the contents
of the Application may kindly be read with as part and parcel of the present
application which are not being repeated herein for the sake of brevity.

2. That the Complainant / Applicant is filing the present Application under Section
20 read with Section 23 of the Protection of Women from Domestic Violence Act,
2005 requesting this Hon’ble Court to kindly grant monetary relief for financial
abuse faced by the Complainant.

3. That the Complainant / Applicant kindly requests the Hon’ble Court to direct the
Respondent to reimburse all the expenses incurred by the Complainant and her
family during the wedding function and monetary assistance provided by the
Complainant to the Respondent during purchase of properties, moreover, direct
Respondent to reimburse Complainant and her family for all gifts, jewellery and
clothes that were given as gifts to Respondent and his family.
 4. That the Complainant / Applicant requests this Hon’ble Court to kindly direct the
Respondent orders for granting monetary relief to the Complainant / Applicant to
meet the expenses incurred and losses suffered by the Complainant / Applicant.

PRAYER

In view of the abovementioned facts and circumstances, the Complainant most humbly
prays this Hon’ble Court:

1. Allow the present Application and grant the Complainant / Applicant protection
under Section 20 read with Section 23 of the Protection of Women from Domestic
Violence Act, 2005.

2. Pass any such further orders as this Hon’ble Court may deem fit and proper in the
interests of justice.

Complainant / Applicant
Through
Adv.
Counsel for Complainant / Applicant
Date:
Place:
 BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE
________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

AFFIDAVIT
I Abc , aged: , W/o: , residing at: do hereby solemnly affirm and
declare as under:
1. That I am the Complainant / Applicant in the abovementioned complaint and well
conversant with the facts of the case and as much competent to swear this
affidavit.

2. That the accompanying Application under Section 20 read with Section 23 of the
Protection of Women from Domestic Violence Act, 2005 has been drafted by my
counsel under my instructions. The contents of the same have been read over and
understood by me.

3. The contents of the Application may kindly be read over as part and parcel of this
affidavit as the said contents are not repeated herein for the sake of brevity.

Deponent
VERIFICATION
Verified on this ___ day of ______, 2023, I the Complainant hereby solemnly
affirm that the contents of the Affidavit are true and correct to the best of my
knowledge and nothing material has been concealed thereof or therefrom.
Deponent
 BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE
________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

APPLICATION UNDER SECTION 22 READ WITH SECTION 23 OF THE

PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

MOST RESPECTFULLY SHOWETH:

1. That the Complainant / Applicant has filed the present complaint under Section 12
of Protection of Women from Domestic Violence Act, 2005 Act and the contents
of the Application may kindly be read with as part and parcel of the present
application which are not being repeated herein for the sake of brevity.

2. That the Complainant / Applicant is filing the present application under Section 22
read with Section 23 of the Protection of Women from Domestic Violence Act,
2005 requesting this Hon’ble Court to kindly grant monetary relief for financial
abuse faced by the Complainant.

3. That the Complainant / Applicant kindly requests the Hon’ble Court to kindly
grant the Complainant orders for compensation for the economic abuse that the
complainant has faced by hands of Respondent especially compensate the
Complainant for Rs. ________ exhorted by the Respondent from the Complainant.
 4. In light of the incidents being encountered in the abovementioned application filed
by the Complainant herein. It is evident that the Complainant has suffered severe
physical, emotional, verbal and economic abuse by the hands of the Respondent.

PRAYER

In view of the abovementioned facts and circumstances, the Complainant most humbly
prays this Hon’ble Court:

1. Allow the present Application and grant the Complainant / Applicant protection
under Section 22 read with Section 23 of the Protection of Women from Domestic
Violence Act, 2005.

2. Pass any such further orders as this Hon’ble Court may deem fit and proper in the
interests of justice.

Complainant / Applicant
Through
Adv.
Counsel for Complainant / Applicant
Date:
Place:
 BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE
________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

AFFIDAVIT
I Abc , aged: , W/o: , residing at: do hereby solemnly affirm and
declare as under:
1. That I am the Complainant / Applicant in the abovementioned complaint and well
conversant with the facts of the case and as much competent to swear this
affidavit.

2. That the accompanying Application under Section 22 read with Section 23 of the
Protection of Women from Domestic Violence Act, 2005 has been drafted by my
counsel under my instructions. The contents of the same have been read over and
understood by me.

3. The contents of the Application may kindly be read over as part and parcel of this
affidavit as the said contents are not repeated herein for the sake of brevity.

Deponent
VERIFICATION
Verified on this ___ day of ______, 2023, I the Complainant hereby solemnly
affirm that the contents of the Affidavit are true and correct to the best of my
knowledge and nothing material has been concealed thereof or therefrom.
Deponent
 BEFORE THE COURT OF HON’BLE CHIEF JUDICIAL MAGISTRATE
________
CT CASE NO. OF 2023

IN THE MATTER OF:

Abc … Complainant / Applicant
Versus
________ …Respondent

LIST OF DOCUMENTS

Complainant / Applicant
Through
Adv.
Counsel for Complainant / Applicant
Date:
Place: