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In the court of Sub Divisional Judicial Magistrate, Bahadurgarh

Smt. Sushma aged 49 years W/o Ram Niwas S/o Sh. Mange Ram R/o
H.No. 616 Ward No. 18, Opposite Old Bus Stand Bahadurgarh, Delhi-
Rohtak Road, Bahadurgarh-124507, Distt. Jhajjar.
Mobile No. 8708565733.

Aggrieved Person/Complainant

Versus

Ram Niwas S/o Sh. Mange Ram permanent resident of H.No. 616 Ward
No. 18, Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road,
Bahadurgarh-124507, Distt. Jhajjar, presently residing at M/s Oasis Global
School located at 3rd Milestone, Dadri Road, Loharu, Distt. Bhiwani.
Mobile No. 8168584573.

Accused/respondent
PS: City Bahadurgarh

Complaint/petition on behalf of the aggrieved person Smt.

Sushma under Section 12, read with Section 18, 19, 20, 22
and 23 of the Protection of Women From Domestic Violence
Act, 2005.

R/Madam,

The aggrieved person/complainant submits as under:-

1 That the parties to the complaint are permanent residents of H.No.616

Ward No. 18, Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road,
Bahadurgarh-124507, Distt. Jhajjar.
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2 That the marriage of the petitioner was solemnized with the respondent as
per Hindu Rites and rituals on 22-02-1991 at Maharaja Aggarsain
Dharamshala, Railway Road Bahadurgarh. The parties to the marriage
lived together as husband and wife at H.No.616 Ward No. 18, Opposite
Old Bus Stand Bahadurgarh, Delhi-Rohtak Road, Bahadurgarh-124507,
Distt. Jhajjar and cohabitated with each other and out of this wedlock, two
children i.e. one daughter namely Oasis was born on 30-09-1999 and one
son namely Sane was born out on 26-08-2002 respectively, who are in the
custody of the petitioner.

3 That the accused before marriage had informed the complainant and her
parents that accused is residing in a rented premise in Sector-6,
Bahadurgarh and running Bharat T.V Training Centre therein and is
earning more than Rs.20,000/- per month and have good ratio of
agricultural land/plots in his native village Chandi, Tehsil Meham, Distt.
Rohtak.

4 That the marriage of the complainant was solemnized by her parents in a

decent manner and handsome dowry articles were given to the
accused/respondent and a huge amount to the tune of Rs.2,50,000/- was
spent by the parents of the complainant in the marriage on food,
decoration, arrangement, dowry articles, Lagan-Sagai etc.

5 That the complainant’s parents had given one golden and silver ring, one
2.5 gram golden chain, one branded watch and nearly eight pairs of
branded clothes and shoes to the accused, one golden ring for father of
accused, one pair of golden ear-rings for the mother of the accused,
branded clothes to accused and their other family members as per their
choice, 51 kitchen utensils and an amount of Rs.50,000/- for furniture as
sufficient dowry and even more than their economic position/status to the
accused at the time of the marriage but the accused/respondent was not
satisfied and was asking/insisting for more dowry including cash.

6 That the parents of the complainant gave her four golden rings, four pairs
of ear-rings, three set of golden chain, one golden pendent, four pairs of
silver anklet, one silver pierced belly chain, five pairs of silver toe-ring
among others were given by friends and relatives of the complainant at
the time of her marriage along with 51 expensive ladies suits and two big
suitcases for carrying clothes.

7 That accused/respondent gave one golden Mangalsutra, two golden

bangles, two set of golden necklace, two pair of golden ear-rings, one
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golden ring and five pairs of silver toe-ring and anklets respectively as
part of their custom and rituals for the newly bride when she visited her
matrimonial house for the 1st time after the wedding ceremony.

8 That within a year of the marriage true identity of the accused was got
revealed before the petitioner wherein it came to her knowledge that on
one hand the accused had extra marital affair and on the other hand he
was drunker and under the influence of alcohol he started to humiliate,
maltreat and torture her for not bringing sufficient dowry.

9 That during the stay with the accused/respondent after marriage, the
complainant was given beatings many times by the dowry greedy and ill-
mannered accused/respondent who behaved in a very erratic manner and
picked up quarrels every now & then with the complainant without any
provocation. The complainant was taunted for not bringing sufficient
dowry. She was harassed, humiliated and was not given proper food. The
complainant tolerated all that with the hope that good sense may prevail
within the accused/respondent with the lapse of time but all in vain.

10 That the accused behavior towards the complainant started deteriorating

with the passage of time with frequent demand of dowry from his end.
The complainant was made to do household work continuously like a
laborer and whenever the complainant use to eat food accused mother use
to mix some powder like herbs in her milk due to which the complainant
fainted and collapsed being unconscious and whenever the complainant
sit down the fan to escape from sizzling heat accused used to disconnect
complainant room electricity as a result of the said acts the complainant
was not only made to suffer physical trauma at the hands of the accused
but she was even mentally tortured for not fulfilling accused person
demand of dowry.

11 That the accused frequently used to turn out the petitioner from her
matrimonial house after merciless beatings without any fault attributable
on her part under the influence of alcohol for demand of dowry, therefore,
the complainant was treated with cruelty by the accused/respondent and
the parents of the petitioner in order to save her daughter married life had
even given dowry to the tune of Rs.10,000/- at one time and thereafter
Rs.5,000/- and Rs.3,500/- respectively to the accused by going out of
their pocket/economic status.

12 That due to the un-warranted and unjustifiable conduct on part of the

accused of behaving in erratic manner, picking up quarrels without
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provocation, giving merciless beatings, torture, endangering her life, limb

and of not providing daily needs for demand of dowry during her stay in
the company of the accused, living of the complainant with the accused/
respondent become unbearable and she decided to end her life and
consumed zinc sulphate (poison) but by the grace of god she was saved by
the doctors and thereafter an FIR no.94 dated 14-04-1995 under Section
498-A, 306 & 511 IPC was registered at P.S. City, Bahadurgarh against
the accused and he was subjected to trial before the competent court.
Copy of said proceedings attached herewith.

13 That with the passage of time and intervention of respectable from the
society, near/dear ones and other relatives of the parties the matter was
compromised after accused promised that he will not humiliate, maltreat
and torture the petitioner going forward for demand of dowry, as a result
in the aforesaid case the accused was acquitted of all the charges by the
court of Sh. J. R. Chauhan, Sub Divisional Judicial Magistrate,
Bahadurgarh vide judgment dated 29-08-1995. Copy of judgment dated
29-08-1995 is attached herewith.

14 That for some time thereafter the accused behaved properly with the
petitioner and refrained from his habit of drunkenness and associating
himself with other women and a house bearing no.616 Ward No.18,
Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road, Bahadurgarh-
124507, Distt. Jhajjar (hereinafter referred to as the matrimonial house)
was purchased by the joint income of both the parties being in fiduciary
relationship vide sale deed no.210 dated 16-04-1996 Copy of sale deed
no.210 dated 16-04-1996 is attached herewith.

15 That the petitioner thereafter conceived and gave birth to a daughter

named Oasis on 30-09-1999 but the accused was not happy on the birth of
a girl child and soon started to act in his usual manner and again started to
humiliate, harass and subject the petitioner to both physical and mental
cruelty which not only had a serious impact on the mind of the petitioner
but had a far devastating effect on the upbringing of her child but for the
betterment of her daughter the petitioner drunken blood tears by deciding
not to part way with the accused and halted her ways and pushed her to
continue her life in that fate.

16 That in the year 2002 the petitioner gave birth to a boy named Sane but
even after the birth of a male child the accused didn’t not part away from
giving merciless beatings to the petitioner under the influence of alcohol
which became a day to affair in the life of the petitioner down the line in
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years to come and she occasioned and tolerated all this for her children
life and limb.

17 That for securing a better future for her children and to stand on her own
footings the petitioner started running a play school with the name of style
of M/s Oasis Public School in her matrimonial house and by the grace of
god the school received overwhelming response and soon made its place
in one of the best pre-schools in the vicinity of Bahadurgarh. However the
accused neither supported the petitioner nor provided any helping hand in
her work but started to mis-utilize her assets earned from the school
earnings and whenever the petitioner tried to make him understand and
asked him to refrain from such acts he used to torture and humiliate the
petitioner in front of school staff.

18 That the accused is not a man of words and is indulged in habit of

drinking from the time of marriage, as a result under the influence of
liquor he continued to torture and harass the petitioner in different manner
and subjected her to both physical and mental cruelty.

19 That with the great success of running pre-school and proper management
the petitioner was appraised by fellow workers and other interested groups
who were keen to open up a 10+2 grade school on the same pattern in
conjunction with the petitioner, a which after rounds of discussion and
advice the petitioner along with others formed a society and started up a
10+2 grade school with the name and style of M/s Oasis Global School
located at 3rd Milestone, Dadri Road, Loharu, Distt. Bhiwani by investing
her entire life savings in the year 2019.

20 That the school received overwhelming response in its starting days but
soon due to the corona epidemic surging wave in the vicinity and entire
country across the world the project suffered heavy loss and could not
survive running due to monetary insufficiency at which the accused
blamed the petitioner for her inability and maltreated, scolded and
harassed her in front of her children.

21 That when the acts of cruelty, harassment and torture of the petitioner at
the hands of the accused went out of tolerance, in the April, 2022 a
complaint was made by the petitioner against the accused in the nearest
police station for subjecting the petitioner to domestic violence wherein
the accused on being summoned by the police and on being confronted
acknowledged his mistake and promised that he will not subject the
petitioner to acts of domestic violence going further, on which the said
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complaint was withdrawn by the petitioner under pressure of near and

dear relatives of both the parties and seeing future matrimonial aspects of
her grown-up children.

22 That seeing no other alternative a Biradari Panchayat of near and dear

relatives from both sides was called on 01-05-2022 and in that Biradari
Panchayat all the acts of cruelty, harassment and physical and mental
torture of the petitioner at the hands of the accused were laid before the
members of the Panchayat. After a lot of hustle-bustle a decision was
reached according to which the petitioner and her children would live
separately at H.No. 616 Ward No. 18, Opposite Old Bus Stand
Bahadurgarh, Delhi-Rohtak Road, Bahadurgarh-124507, Distt. Jhajjar and
their maintenance expenses would be borne out by the accused on a
monthly basis to the tune of Rs.25,000/- per month and the accused
agreed to live separately at M/s Oasis Global School located at 3 rd
Milestone, Dadri Road, Loharu, Distt. Bhiwani thereafter and it was also
agreed that the accused would not dispossess, alienate, mortgage and
change the nature of the matrimonial house for meeting out his immoral
activities.

23 That the petitioner along with her children is residing peacefully and is in
physical possession of the matrimonial house. The accused though not
interrupted the peaceful living of the petitioner and her children thereafter
but never paid any maintenance amount as agreed in the Biradari
Panchayat due to which the petitioner had to struggle hard each day to
maintain herself and her minor children for necessities of life in and after
corona epidemic era which is the self-telltale story of every household.

24 That suddenly in a hurried manner on 31-05-2023 the accused came to the

matrimonial house in the absence of the petitioner and showcased the
same to some prospective purchasers and threatened the children of the
petitioner that he will alienate the said house and would dispossess them
soon therefrom which has attributed not only mental harassment towards
the petitioner and her children but has also swung in a fear of
homelessness among them which amounts to cruelty.

25 That further adding to his atrocities the accused had masterminded a

conspiracy against the petitioner and her children in order to make them
addicted door to door, satisfy his extra marital lust and other immoral
activities, he by suppressing material facts from prospective purchasers
and in collusion with them thereby acting completely in furtherance of his
authority without the consent of petitioner and other society members
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during the ensuing corona epidemic wave surge entered into an agreement
to sell the entire school building located at 3rd Milestone, Dadri Road,
Loharu, Distt. Bhiwani along with abutting land and had received alleged
consideration thereof in respect of same and is threatening to alienate the
said property every now and then and seeing no other alternative the
petitioner had to institute a civil suit against the accused and his
accompanied prospective purchasers before the competent court at Loharu
which is pending adjudication in the court of Sh. Jitender Singh,
ACJ(SD), Loharu.

26 That in-spite of assurance given by the accused to the petitioner in

Biradari Panchayat held on 01-05-2022 of not alienating the matrimonial
house and not to dispossess the petitioner and her minor children
therefrom, the accused has betrayed by backing out from his words and is
acting selfishly by searching prospective purchasers for alienating the said
house and is threatening to dispossess forcibly and illegally the petitioner
and her children from the same in order to meet out his illegal acts
whereas he has no legal right to do so, thereby crossing limits of
committing harsh cruelty towards petitioner and her children.

27 That the petitioner is in peaceful physical possession over the matrimonial

house since the very beginning, i.e. from the time of marriage of the
petitioner whereas the accused has no concern whatsoever with the
possession of the property in question and has not legal right to alienate
the same. The said house falls under the category and in the definition of
share household between the parties to the complaint and without the
consent of the petitioner and her children accused has no legal right, title
and interest to alienate and dispossess them therefrom.

28 That the petitioner has further come to know from reliable sources that the
accused has illegally and unlawfully executed an agreement to sell the
matrimonial house as well with some anti-social elements prevailing in
the city who are well acquainted with the fact that there is ongoing dispute
between the petitioner and the accused and the said house is the only
place of livelihood for the petitioner and her children.

29 That the complainant is an unemployed lady at the moment and is not able
to maintain herself and her children. The paternal family members of the
complainant are also unable to bear the expenses of the complainant due
to their poor financial position.
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30 That the accused/respondent is legally and morally bound to maintain the

petitioner and her children as per law of the land and possesses sufficient
means to bear their expenses but he has neglected and refused to maintain
them without any sufficient cause in order to make them addicted door to
door and to satisfy his extra marital lust and other immoral activities.

31 That the complainant is not earning a single penny and is not having any
source of income of her own and her life has come to starvation position.
The complainant is totally dependent on the mercy of her paternal family
members who being poor person are not in a position to provide food and
clothes to the petitioner/complainant.

32 That the aggrieved person had suffered mental and physical cruelty at the
hands of the accused/respondent and the life of the aggrieved person is in
danger and is not safe at the hands of the accused/respondent.

33 That the complainant is presently residing at H.No. 616 Ward No. 18,
Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road, Bahadurgarh-
124507, Distt. Jhajjar with her children, within the territorial jurisdiction
of this Hon’ble court, hence the Hon’ble court has jurisdiction to try and
decide the present complaint.

34 That a requisite court fee of Rs.50/- has been paid along with the
complaint.

It is, therefore, most respectfully prayed that the cognizance of

the complaint may be taken, the complaint of the aggrieved person may be
accepted and the following urgent relief may kindly be awarded to the
complainant:-

a) Pass a protection order in favour of the aggrieved person and against the
respondent prohibiting the respondent from committing, aiding or abetting
any act of domestic violence against the aggrieved person;

b) Pass an order in favour of the aggrieved person and against the respondent
to pay monthly maintenance to the aggrieved person @ Rs.25,000/- per
month;

c) Pass an order in favour of the aggrieved person and against the respondent
directing him to pay compensation to the aggrieved person for the mental
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torture and emotional distress caused by the acts of the domestic violence
by the respondent;

d) Pass an order in favour of the aggrieved person and against the respondent
to pay to the aggrieved person litigation and other incidental expenses
arising out of this application/complaint in a sum of Rs.33,000/-;

e) Pass an order in favour of the aggrieved person and against the respondent
directing the respondent to return the Istridhan’ of the aggrieved person;

f) Pass an order in favour of the aggrieved person and against the respondent
directing him to pay monetary relief amounting to Rs.10,00,000/- to meet
out the expenses incurred and losses suffered by the aggrieved person as a
result of Domestic Violence;

g) Pass an order in favour of the aggrieved person and against the respondent
directing him to pay compensation amounting to Rs.2,50,000/- which was
spent in marriage ceremony;

h) Pass an order in favour of the aggrieved person and against the respondent
restraining the respondent from alienating any assets, operating bank locker
or bank account used or held or enjoyed by both the parties, jointly by the
aggrieved person and the respondent or singly by the respondent, including
her Istridhan or the matrimonial house situated ta H.No. 616 Ward No. 18,
Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road, Bahadurgarh-
124507, Distt. Jhajjar held either jointly by the parties or separately by
them without the leave of the Hon’ble court;

i) Pass an order in favour of the aggrieved person and against the respondent
directing him not to cause any act of violence towards the aggrieved person
or any other relatives or any person who may provide assistance from the
domestic violence to the aggrieved person;

j) Pass an order under section 17 of the Domestic violence act in favour of the
aggrieved person and against the respondent directing the respondent or
any of his relatives from alienating or dispossessing the aggrieved person
from the shared household i.e. H.No. 616 Ward No. 18, Opposite Old Bus
Stand Bahadurgarh, Delhi-Rohtak Road, Bahadurgarh-124507, Distt.
Jhajjar.
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It is further prayed that an ex-parte interim relief as prayed

above in view of the provisions of Section 23 of the Act may be awarded to
the aggrieved person in the interest of justice. An affidavit is attached
herewith.

Any other relief to which the court deems fit and proper may
also be awarded to the petitioner.

Verification:- Petitioner/complainant

Verified that the contents of para Smt. Sushma W/o Ram Niwas S/o
No 1 to 32 of the complaint are true Sh. Mange Ram R/o H.No.616/18
& correct to the best of my knowledge opp. old Bus Stand Bahadurgarh
and belief and para No 33 & 34 are Delhi-Rohtak road Bahadurgarh
believed to be correct and the last Distt. Jhajjar.
para is a prayer clause.

Place: Bahadurgarh
Dated: 09-06-2023 Through Counsel
M. S. Joon
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In the court of Sub Divisional Judicial Magistrate, Bahadurgarh

Smt. Sushma Versus Ram Niwas

Affidavit

I, Sushma W/o Ram Niwas S/o Sh. Mange Ram R/o H.No. 616 Ward No. 18,
Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road, Bahadurgarh-
124507, Distt. Jhajjar, do hereby solemnly affirm and declare as under:-

1. That the deponent is the complainant/petitioner in the accompanying

complaint/petition, the contents of which may please be read as part
of this affidavit as the same have not been repeated again for the sake
of brevity and to save the time of the Hon’ble court.

2. That the deponent being fully conversant with the facts of the
petition, is competent to depose truly before the Hon’ble court and
nothing has been concealed therein by the deponent.

3. That the contents of para No 1 to 32 of the complaint are true to the

best of my knowledge and para No 33 and 34 of the complaint are
believed to be correct as per legal advice received.

Deponent

Verification:-

Verified that the contents of this affidavit are true and correct to the
best of my knowledge and belief and nothing has been concealed
therein.

Deponent
At: Bahadurgarh
Dated: 09-06-2023
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In the court of Sub Divisional Judicial Magistrate, Bahadurgarh

Smt. Sushma Versus Ram Niwas

List of Witnesses

1. Sushma W/o Ram Niwas S/o Sh. Mange Ram R/o H.No. 616 Ward
No. 18, Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road,
Bahadurgarh-124507, Distt. Jhajjar.

2. Oasis D/o Ram Niwas S/o Sh. Mange Ram R/o H.No. 616 Ward No.
18, Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road,
Bahadurgarh-124507, Distt. Jhajjar.

3. Sane S/o Ram Niwas S/o Sh. Mange Ram R/o H.No. 616 Ward No.
18, Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road,
Bahadurgarh-124507, Distt. Jhajjar.

4. Any other witness with the permission of the court.

Complainant

Place: Bahadurgarh Smt. Sushma W/o Ram Niwas S/o

Dated: 09-06-2023 Sh. Mange Ram R/o H.No.616/18
opp. old Bus Stand Bahadurgarh
Delhi-Rohtak road Bahadurgarh
Distt. Jhajjar.

Through Counsel
M. S. Joon
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In the court of Sub Divisional Judicial Magistrate, Bahadurgarh

Smt. Sushma Versus Ram Niwas

Application for maintenance and stay w.r.t to alienation of shared

household

R/Madam,

The petitioner/complainant submits as under:-

1. That the applicant has filed a complainant under Section 12, read
with Section 18, 19, 20, 22 and 23 of the Protection of Women from
Domestic Violence Act, 2005 against the accused and the same is
pending before the Hon’ble court and is fixed for today i.e.
06-06-2023.

2. That the decision of the complaint is likely to take a long time.

3. That the complainant and accused were married on 22-02-1991 and n

out of this wedlock, two children i.e. one daughter namely Oasis was
born on 30-09-1999 and one son namely Sane was born out on
26-08-2002 respectively, who are in the custody of the petitioner

4. That the complainant’s parents have given sufficient dowry and even
more than their economic position but the accused was not satisfied
and asking/insisting for more dowry. When the complainant showed
her inability to fulfill their repeated demands of dowry, she was
mercilessly beaten, abused using filthy language.

5. That the applicant/complainant has no source of income to maintain

herself and to meet the litigation expenses of this complaint as such
the applicant is unable to prosecute the present application/complaint
in an effective manner.
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6. That the accused/respondent is legally and morally bound to

maintain the petitioner and her children as per law of the land and
possesses sufficient means to bear their expenses but he has
neglected and refused to maintain them without any sufficient cause
in order to make them addicted door to door and to satisfy his extra
marital lust and other immoral activities.

7. That the complainant is in the need of Rs.25,000/- per month as

maintenance along with Rs.33,000/- as litigation expenses.

8. That the applicant along with her children is residing peacefully and
is in physical possession of the matrimonial house situated at H.No.
616 Ward No. 18, Opposite Old Bus Stand Bahadurgarh, Delhi-
Rohtak Road, Bahadurgarh-124507, Distt. Jhajjar which is the
matrimonial house of the petitioner and the accused have no concern
with the ownership and possession of the same in any manner.

9. That the said house falls under the category and in the definition of
share household between the parties to the complaint and without the
consent of the petitioner and her children accused has no legal right,
title and interest to alienate and dispossess them there from.

10. That the respondent has threatened the applicant to dispossess the
petitioner over the matrimonial house, from demolishing the
structure over the said house, from alienating the house in favour of
any person and from changing the nature of the house by way of
raising hurried construction thereat and from interfering in the
peaceful possession of the petitioner, forcibly and illegally, without
having any right to do so. This act of the respondent is highly illegal,
null and void, arbitrary, uncalled and not binding upon the applicant.

11. That if the respondent succeeds in his illegal design of dispossession,

demolition, alienation and in changing the nature of the matrimonial
house and interference in the peaceful possession of the petitioner in
that case the applicant shall suffer an irreparable loss, injury and
mental agony which could not be compensated in terms of money.

12. That there is a good prima facie case in favour of the applicant and
against the respondent.

13. That the balance of convenience is also in favour of the applicant and
against the respondent
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It is, therefore, prayed that the application may kindly be

accepted and the accused may be directed to pay Rs.25,000/- per month as
maintenance and Rs.33,000/- as litigation expenses to the
complainant/applicant in the interest of justice.

It is, further prayed that an ex-parte ad-interim

injunction may kindly be granted in favour of the applicant and against the
respondent in view of section 17 of the Domestic violence act restraining
the later respondent from dispossessing the petitioner over the matrimonial
house; from demolishing the structure over the said house, from alienating
the said house in favour of any person and from changing the nature of the
said house by way of raising hurried construction thereat forcibly and
illegally and from interfering in the peaceful possession of the petitioner,
forcibly and illegally forever.

Applicant

Place: Bahadurgarh Smt. Sushma W/o Ram Niwas S/o

Dated: 09-06-2023 Sh. Mange Ram R/o H.No.616/18
opp. old Bus Stand Bahadurgarh
Delhi-Rohtak road Bahadurgarh
Distt. Jhajjar.

Through Counsel
M. S. Joon
 16

In the court of Sub Divisional Judicial Magistrate, Bahadurgarh

Smt. Sushma Versus Ram Niwas

Affidavit

I, Sushma W/o Ram Niwas S/o Sh. Mange Ram R/o H.No. 616 Ward No. 18,
Opposite Old Bus Stand Bahadurgarh, Delhi-Rohtak Road, Bahadurgarh-
124507, Distt. Jhajjar, do hereby solemnly affirm and declare as under:-

1. That I am the petitioner in the present complaint and fully conversant

with the facts ad circumstances of the case. I am competent to swear
this affidavit.

2. That the accompanying application for maintenance and stay has been
drafted by my counsel under my instructions and the content of the
same are not repeated herein for the sake of brevity, however the
same has been explained to me in a vernacular language and the
contents of the same be read as part of this affidavit.

Deponent

Verification:-

Verified that the contents of this affidavit are true and correct to the
best of my knowledge and belief and nothing has been concealed
therein.

Deponent
At: Bahadurgarh
Dated: 09-06-2023