PETITION CLAIMING PAYMENT OF MAINTENANCE

Before the Learned Chief Metropolitan Magistrate, Calcutta
Case No………………of 2005
                     versus
Sri. Z, son of ML residing at……………………….
Police Station………………………
District:……………………………
              Opposite Party
To
The Learned Chief Metropolitan Magistrate, Calcutta
The humble petition of Smt. AB, the applicant above-named most respectfully
Sheweth:
1. The applicant and the opposite party are Hindus and are governed by Dayabhaga School of Hindu Law.
2. The applicant is a legally married wife of the opposite party. The applicant's marriage with the opposite party was solemnised on……………………….
3. Soon after the marriage of the applicant the opposite party and his parents and sisters started harassing the applicant for not bringing sufficient dowry. The applicant was constantly pressurised to bring further moneys from her parents.
4. The applicant's father is a small earner and working as a clerk in a Government Office having no other source of income. His total salary is Rs. 2000 net. The applicant's father is unable to satisfy the unreasonable demands of further moneys by way of dowry made by the opposite party, his parents and sisters.
5. The applicant repeatedly expressed her father's inability to pay further sums as dowry as he had no other source of income or any assets out of which such further dowry could be paid.
6. With a view to put further pressure and to extort money from the applicant's father on……….. the opposite party, his mother and two sisters assaulted the applicant and threw her out of the matrimonial house on the threat of not to come again without sufficient dowry.
7. The applicant with great humiliation with a heavy heart and with difficulty could manage to reach her parental house.
8. Thereafter the applicant made several requests to the opposite party to take her back home and not to demand any further dowry. This the opposite party has refused to do.
9. The applicant thereafter requested the opposite party to pay her something for her maintenance and upkeep. The opposite party knew that the applicant had no other source of income and yet the request was ignored.
10. The opposite party is an officer in the Excise Department and draws a salary of Rs. 10,000 per month. He has a house property from which he gets rent of Rs. 2000 per month. His father is also earning. The opposite party has no dependant member or any other known liability.
11. The applicant has no means to support her while as stated above the opposite party has sufficient means to maintain the applicant.
12. The applicant, therefore, humbly prays this Learned Court for a direction on the opposite party to pay Rs. 1500 per month to the applicant towards her maintenance.
Place: Calcutta                                                      Signature of the applicant
Date:                                                                Signature of Advocate for applicant