IN THE HON’BLE COURT OF LD.

CHIEF JUDICIAL
MAGISTRATE, DWARKA COURTS, NEW DELHI

DOMESTIC VIOLENCE CASE NO._____ OF 2025

IN THE MATTER OF :
SUMAN …AGGRIEVED PERSON/APPLICANT

VERSUS

KULDEEP CHAUDHARY …RESPONDENT

INDEX

SL.NO. PARTICULARS PAGES C/FEE

1. MEMO OF PARTIES.

2. APPLICATION UNDER SECTION

12, 18, 19, 20, AND 22 OF
PROTECTION OF WOMEN FROM
DOMESTIC VIOLENCE ACT
ALOGNWITH AFFIDAVIT.

3. AFFIDAVIT UNDER SECTION

23(2) OF PROTECTION OF
WOMEN FROM DOMESTIC
VIOLENCE ACT.

4. APPLICATION UNDER SECTION

23 OF PROTECTION OF WOMEN
FROM DOMESTIC VIOLENCE
ACT, FOR INTERIM RELIEF
ALONG WITH SUPPORTING
 AFFIDAVIT

5. DETAILS OF DOMESTIC
VIOLENCE

6. DETAILED AFFIDAVIT OF THE

AGGRIEVED PERSON

7. LIST OF DOCUMENTS ALONG

WITH DOCUMENTS
8. VAKALATNAMA

NEW DELHI:
DATED : /02/2025 FILED BY:

(RAKESH BAIRWA)
ADVOCATES
CHAMBER NO.556,
DWARKA COURTS COMPLEX,
SECTOR-10, DWARKA,
NEW DELHI-110075
M-8130541806
 IN THE HON’BLE COURT OF LD. CHIEF JUDICIAL
MAGISTRATE, DWARKA COURTS, NEW DELHI

DOMESTIC VIOLENCE CASE NO._____ OF 2025

IN THE MATTER OF :
SUMAN …AGGRIEVED PERSON/APPLICANT

VERSUS

KULDEEP CHAUDHARY …RESPONDENT

MEMO OF PARTIES

SUMAN
W/O MR. KULDEEP CHAUDHARY
D/O MR. LACHHE RAM VASHIST
R/O 335-A, D-BLOCK, AJAY PARK
NAJAFGARH, NEWDELHI-110043

CURRENTLY RESIDING AT:

BUILDING NO. 18, VIRBHADRA
SWAMI NILAYA, 3RD MAIN, 20TH CROSS,
MANAL ROAD, RAJIV GANDHI
NAGAR, HSR SECTOR 7,
BANGALORE-560068 …AGGRIEVED PERSON/
APPLICANT

VERSUS

KULDEEP CHAUDHARY
S/O LATE. MALKHAN SINGH
R/O 301, 3 R D FLOOR, 5 T H CROSS ROAD,
HSR LAYOUT, SOMASANDRA PALYA,
BENGALURU, KARNATAKA-560102 …. RESPONDENT
NEW DELHI:
DATED : /02/2025 FILED BY:

(RAKESH BAIRWA)
ADVOCATES
CHAMBER NO.556,
DWARKA COURTS COMPLEX,
SECTOR-10, DWARKA,
NEW DELHI-110075
M-8130541806
 IN THE HON’BLE COURT OF LD. CHIEF JUDICIAL
MAGISTRATE, DWARKA COURTS, NEW DELHI

DOMESTIC VIOLENCE CASE NO._____ OF 2025

IN THE MATTER OF :
SUMAN …AGGRIEVED PERSON/APPLICANT

VERSUS

KULDEEP CHAUDHARY …RESPONDENT

P.S.: NAJAFGARH
APPLICATION UNDER SECTION 12,18,19,20 & 22 OF
PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE
ACT, 2005 (43 OF 2005)

MOST RESPECTFULLY SHOWETH

1. It is submitted that the application Under Section

12,18,19,20 and 22 of Protection of Women from

Domestic Violence Act, 2005 (43 of 2005) is being filed

by aggrieved person/applicant against the respondent

along with affidavit and domestic incident report .

a) Aggrieved person:

SUMAN
W/O MR. KULDEEP CHAUDHARY
D/O MR. LACHHE RAM VASHIST
R/O 335-A, D-BLOCK, AJAY PARK
NAJAFGARH, NEWDELHI-110043
AND
 BUILDING NO. 18, VIRBHADRA
SWAMI NILAYA, 3RD MAIN, 20TH CROSS,
MANAL ROAD, RAJIV GANDHI
NAGAR, HSR SECTOR 7,
BANGALORE-560068

b) Protection Officer:

c) Any other person on behalf of the

Aggrieved person:

2. It is respectfully prayed that this Hon’ble Court may be

pleased to take cognizance of the complaint (attached

with the complaint) and pass all/any of the orders, as

deemed necessary in the circumstances of the case.

a) Pass Protection order U/S 18 and/or

b) Pass Residence order U/S 19 and/or

c) Direct the Respondent to pay monetary relief U/S 20

and/or

d) Direct the respondents to grant compensation or

damages U/S 22 and/or
e) Pass orders to grant interim and ex-parte orders U/S

23(1) & (2) and/or

 f) Pass any other or further order/s as deems fit in with the

circumstances of the case.

ORDERS REQUIRED

(i) Protection Order Under Section 18

(a) Prohibiting acts of domestic violence by granting an

injunction against the Respondent from repeating any

of the acts mentioned in statements of facts/ domestic

incident report of the application.

(b) Prohibiting any form of communication by the

respondent with AGGREIVED PERSON/APPLICANT .

(c) Prohibiting alienation of assets by the respondent.

The Respondent No.1 is having one house measuring

about 750 sq. Yards in Chandenakoli,Saharanpur and

agricultural land about 22 bighas.

N.B.: The aggrieved person/applicant has been residing in rented

accommodation at the above-mentioned address since 04.06.2024.

The aggrieved person/applicant also came to know that the

Respondent are in process to sale that house and there is an

apprehension that they may sale that property. It is prayed that

the Respondent may kindly be restricted to sale the property and

assets.

(d) Any other order(s), please specify:

Order may be against the Respondent restraining them from

any of the acts mentioned above because domestic violence

as defined under Section 2(g) read with Section 3 of the Act

has unrestricted become the order of day.

(ii) RESIDENCE ORDER UNDER SECTION 19

An Order restraining Respondent from: -

(a) Dispossess and thrown out the applicant/aggrieved

person from the shared household.

The aggrieved person/applicant is presently living in

rented accommodation i.e. BUILDING NO. 18, VIRBHADRA
SWAMI NILAYA, 3RD MAIN, 20TH CROSS, MANAL ROAD, RAJIV
GANDHI NAGAR, HSR SECTOR 7, BANGALORE-560068.
(b) Entering that portion of the shared household in which

the AGGREIVED PERSON/APPLICANT/ aggrieved

resided.

The respondent and his associates are restrained from

entering the accommodation, where the Aggrieved

person/Applicant is currently residing i.e. BUILDING

NO. 18, VIRBHADRA SWAMI NILAYA, 3RD MAIN, 20TH

CROSS, MANAL ROAD, RAJIV GANDHI NAGAR, HSR

SECTOR 7, BANGALORE-560068 and disturbing the

aggrieved person/applicant.

(C) Renouncing his rights in the shared household.

An order directing Respondent to: -

(a) Secure same level of alternate accommodation or pay

rent for the same.

(b) Any order restraining respondent from alienating/

disposing/ encumbering the shared

household/matrimonial house and any property or

agricultural land.
 Therefore, an ex-parte order is very necessary, and this

Hon’ble Court may kindly direct the Respondent not to dispose of

his assets. The aggrieved person/applicant is residing in rented

accommodation and is at the mercy of parents, friends and

relatives for her daily expenses . That the Respondent be directed

not to dispose of any kind of security i.e. Share, Debenture, Bond

etc. stands in the name of Respondent. The Respondent may also

be directed to disclose their assets by filing a list of the same

duly supported by an affidavit.

The Respondent never allowed the aggrieved person to

have access to her personal belongings such as her jewelry,

costly clothes and other household articles. Those articles are in

the possession of the Respondent which have been given by the

parents of the aggrieved person to the respondent and his family

members after the marriage. Therefore, the Respondent may

kindly be directed to return personal belongings/Istridhan of the

aggrieved person to her.

The Respondent may kindly be directed not to dispose, sell,

alienate their moveable and immoveable properties.

(C) Any other order please specify:

 The Respondent may be directed to return Istridhan articles

including gold and silver jewelry articles of the aggrieved

person/ applicant. He may also be directed not to repeat the

violence (physical, mental and sexual etc.) threat of selling

properties and assets including share, debenture, bond etc.

adopting any sort of torturing tactics on the aggrieved

person/applicant and also the Respondent may be directed to stop

violence and totally deprive himself from acting any other

act/omission, which lead to the hurdles/disturbances to the

peaceful life of the aggrieved person/applicant.

Any such order or further orders as this Hon’ble Court may

deem fit in the facts and circumstances of the case and in the

interest of justice.

(iii) MONETARY RELIEF UNDER SECTION 20

Loss due to destruction/damage or removal of property from of

the aggrieved person.

Amount Claimed Rs.20,00,000/- (Rupees Twenty Lac Only).

Any other loss or physical or mental injury as specified in

Statement of facts.
 Any other amount in the form of damages, which this

Hon’ble Court deems fit in the facts and circumstances of the

case, may also be passed.

(iv). MONETARY RELIEF UNDER SECTION 20

Directing Respondent to pay the following monthly expenses as

monetary relief:

1. Food, clothes, shelter, medication, Allowance, for other

basic amenities : Rs.25,000/-

2. Other Expenses : Rs.15,000/-

Total : Rs.40,000/

Any other order may be incurred by the aggrieved person from

time to time during the trial of this case.

(vi) COMPENSATION UNDER SECTION 22:

The Respondent be directed to pay Rs.10,00,000/-(Rupees Ten

Lac only) to the aggrieved person/applicant for mental torture

and emotional distress caused by the acts of domestic violence.

3. DETAILS OF PREVIOUS LITIGATION:

The AGGREIVED PERSON/APPLICANT has filed one

complaint dated 04.01.2023 to DCP, SPVWAC, Nanakpura,

New Delhi-110021.
 PRAYER

It is, therefore, most respectfully prayed this Hon’ble Court

be pleased to grant the relief(s) claimed therein paragraph 2 and

3 of this application and pass such order or orders as this Hon’ble

Court may deem fit and proper under the given facts and

circumstances of the case for protecting the aggrieved person

from domestic violence and in the interest of justice.

Any other or further order as this Hon’ble Court may deem fit
and proper may also be passed in favour of the aggrieved
person/applicant and against the Respondent.

NEW DELHI:
DATED : .02.2025 AGGRIEVED PERSON/
APPLICANT

(SUMAN)

THROUGH
(RAKESH BAIRWA)
ADVOCATES
CHAMBER NO.556,
DWARKA COURTS COMPLEX,
SECTOR-10, DWARKA,
NEW DELHI-110075
M-8130541806
VERIFICATION:

I, SUMAN, the above-named aggrieved person/applicant

verified that the content of Paras No. to of the above

application are true and correct to the best of my knowledge and

information received and believed to be true and nothing material

has been concealed therefrom.

Verified at NEW DELHI on this day of February 2025

AGGRIEVED PERSON/
APPLICANT

(SUMAN)
 IN THE HON’BLE COURT OF LD. CHIEF JUDICIAL
MAGISTRATE, DWARKA COURTS, NEW DELHI

DOMESTIC VIOLENCE CASE NO._____ OF 2025

IN THE MATTER OF :
SUMAN …AGGRIEVED PERSON/APPLICANT

VERSUS

KULDEEP CHAUDHARY …RESPONDENT

APPLICATION UNDER SECTION 23 OF PROTECTION OF

WOMEN FROM DOMESTIC VIOLENCE ACT, 2005 (43 OF
2005) FOR GRANT OF INTERIM AND EX-PARTE ORDERS

MOST RESPECTFULLY SHOWETH:

1. That the applicant/aggrieved person SUMAN has filed

accompanying application Under Section 12 of the

Protection of Women from Domestic Violence Act, 2005

against the Respondents. The contents of the same may be

read and taken as part and parcel of present application for

the sake of brevity.

2. That the applicant seeks the ad-interim relief of seeking the

directions of this Hon’ble Court to the Respondent for the

grant of Rs.40,000/- (Rupees Forty Thousand only) per

monthly allowance to maintain herself and also a direction

 to the Respondent not to dispose of his assets as has been

mentioned with the application Under Section 12 of the Act

and also not to leave the country without the permission of

this Hon’ble Court, inter alia on following grounds:

A. That the applicant/aggrieved person has no other source

of income for her living and to meet her daily needs and

is totally dependent for the same upon the parents,

friends and relatives of the applicant.

B. That the Respondent is not exerting/ fulfilling any of his

responsibilities.

C. That the Respondent is creating each and every illegal

and unethical acts to create disturbance in the life of the

applicant/aggrieved person, torture her mentally and

physically and made her life miserable and hell.

D. That the Respondent has committed series of acts which

are covered under definition of “DOMESTIC

VIOLENCE” of the Act.

 E. That the Respondent is not paying any amount so as to

fulfill the basic needs of the applicant/aggrieved person,

which is covered under the definition of “ ECONOMIC

ABUSE” under Section 3 of the Act.

F. That the Respondent has deprived the aggrieved person

from her legitimate rights and threatened that he will

very soon dispose of all his assets and business

establishment in India including the shared house and

leave the country.

G. Any other ground that may be taken with the due

permission of this Hon’ble Court during the Course of

Arguments in the present application.

H. That the applicant/aggrieved person has not filed any

other application/petition seeking similar relief under

this Act before any Court of Law.

PRAYER

It is, therefore, most respectfully prayed that in view of

the above-mentioned facts, circumstances and grounds, this

Hon’ble Court may be pleased to:

(A) direct the Respondent to pay an ad-interim ex-parte

amount of Rs.40,000/-(Rupees Forty Thousand only)

per month to the applicant/ aggrieved person for the

maintenance of herself.

(B) Direct the Respondents not to dispose of his assets and

business establishments in India.

(C) Direct the Respondent to return the Istridhan articles

including jewelry of the aggrieved person.

(D) Direct the Respondent to arrange alternative rented

accommodation or to pay Rs. 15,000/- per month as

rent.

(E) Direct the Respondent not to leave the country without

the permission of this Hon’ble Court.

(F) Direct the Respondent not to enter in the house

occupied by the applicant/ aggrieved person where she

is residing and also not to interfere and disturb her in

her personal day-to-day life.

(G) Direct the Respondent not to harass the

applicant/aggrieved person in the portion of the

 property where the applicant/aggrieved person is

presently residing.

Pass any other or further orders which this Hon’ble

Court deems fit and proper in favour of the applicant/

aggrieved person and against the Respondent.

NEW DELHI:
DATED : .02.2025 AGGRIEVED PERSON/
APPLICANT

(SUMAN)

THROUGH
(RAKESH BAIRWA)
ADVOCATES
CHAMBER NO.556,
DWARKA COURTS COMPLEX,
SECTOR-10, DWARKA,
NEW DELHI-110075
M-8130541806
 IN THE HON’BLE COURT OF LD. CHIEF JUDICIAL
MAGISTRATE, DWARKA COURTS, NEW DELHI

DOMESTIC VIOLENCE CASE NO._____ OF 2025

IN THE MATTER OF :
SUMAN …AGGRIEVED PERSON/APPLICANT

VERSUS

KULDEEP CHAUDHARY …RESPONDENT

LIST OF DOCUMENTS

1. MARRIAGE PHOTOGRAPHS
2. PHOTOCOPY OF THE MARRIAGE REGISTRATION
CERTIFICATE
3. PHOTOCOPY OF AADHAR CARD OF AGGRIEVED
PERSON
4. PHOTOCOPY OF COMPLAINTS FILED BY THE
AGGRIEVED PERSON BEFORE C.A.W. CELL,
5. ANY OTHER DOCUMENT/S WITH THE
PERMISSION OF THIS HON’BLE COURT.

NEW DELHI:
DATED : .02.2025 FILED BY:

(RAKESH BAIRWA)
ADVOCATES
CHAMBER NO.745,
DWARKA COURTS COMPLEX,
SECTOR-10, DWARKA,
NEW DELHI-110075
 DETAILS OF DOMESTIC VIOLENCE

1. That the marriage was solemnized between the Aggrieved

person/Applicant and the Respondent on 21 s t July 2018, in

Najafgarh, New Delhi according to Hindu Rites and

ceremonies and the marriage was consummated at Najafgarh

and no issue was born out the wedlock.

2. Ever since, i.e. for the last 6 and half years, the Complainant

has been suffering physical and mental abuse, pain,

helplessness, unhappiness and anger on account of the

Respondent. Eventually, being unable to bear with the trauma

and agony, the Aggrieved person/Applicant fearing for her

life, being destitute without any money and stridhan has been

constrained to file the present complaint.

3. It is submitted that the marriage between the Aggrieved

person/Applicant and the Respondent was a love marriage.

The parties come from very different backgrounds. The

Aggrieved person/Applicant belongs to a closely knit family

with a lot of family values and culture. On the other hand, the

Respondent belongs to a family where he had been living

separately from his family for past many years and is driven

only by money and materialistic things.

4. It is further submitted that the first incident relating to

domestic violence occurred in Mussoorie, July 2018, when the

Aggrieved person/Applicant went for honeymoon with the

Respondent. The Respondent got a call from his brother-in-

law and asked the Respondent to transfer about the 1.5 Lakh

rupees to his account. When the Aggrieved person/Applicant

inquired about the above-mention ed amount which he was

giving to his brother-in-law, the Respondent got furious and

started slapping and abusing the Aggrieved person/Applicant

and asked to mind her own business. Aggrieved

person/Applicant was shocked to see his behaviour towards

her and that too on their honeymoon. It is pertinent to mention

here that the Respondent lied to the Aggrieved

person/Applicant before marriage about the informal loan

from his brother-in-law. He told the Aggrieved

person/Applicant that he had an informal loan of Rs. 5.5 Lakh

which he already settled.

5. Later, the Complainant found out that the Respondent has

lied to her. The actual amount for the informal loan was about

12 lakh rupees. Upon being confronted by the Complainant,

she was repeatedly abused and beaten up by the Respondent.

6. It is also pertinent to mention that the Respondent after

abusing the Aggrieved person/Applicant physically and

mentally, pushed the Aggrieved person/Applicant into the bed

and forced her to stay there without clothes. When the

Aggrieved person/Applicant asked the Respondent to give her

clothes to wear, he again abused her and asked her to sit

quietly in the bed without clothes. After, some time, the

Respondent apologized the Aggrieved person/Applicant and

said that he would repeat the same.

7. It is also submitted that the Aggrieved person/Applicant had

suffered multiple miscarriages on the account of violent and

barbaric nature of the Respondent. It is submitted that the the

Aggrieved person/Applicant had her first miscarriage on 27 t h

October 2018. It is submitted that when the the Aggrieved

person/Applicant informed the Respondent of her pregnancy,

the Respondent asked her to go for abortion as the Respondent

did not want to have a baby. It is submitted that the

Respondent was not employed at the time of marriage .

8. It is pertinent to mention that the Respondent told the

Aggrieved person/Applicant that he would not be able to

afford the expenses of a child. However, the the Aggrieved

person/Applicant filled with joy of being a mother, did not

 want to abort her unborn child. This led to an argument

between the Aggrieved person/Applicant and the Respondent.

It is submitted that the Respondent stood up on the bed and

started to shout and hurl abuses on the Aggrieved

person/Applicant. When the Aggrieved person/Applicant tried

to calm the Respondent down and went to him on the bed as

well but to no avail. It is submitted that the Respondent is

strong physically and has a bad temper. In the ensuing chaos,

the Respondent pushed down the Aggrieved person/Applicant

from the bed so badly that the Aggrieved person/Applicant

had a sever pain in the stomach and the bleeding followed.

This incident led to the Complainant’s first miscarriage three

days later of the incident on 27 t h October 2018.

9. It is submitted that the Respondent requested the Aggrieved

person/Applicant that she should not inform anyone about the

said incident as it was unintentional, and it happened in the

heat of the moment and the Aggrieved person/Applicant

forgave him didn’t say anything to anyone. It is pertinent to

mention that later, the Respondent was even audacious enough

to mock the Aggrieved person/Applicant and revealing that he

had pushed the Aggrieved person/Applicant intentionally.

10. It is further submitted that for nearly a month, the Aggrieved

person/Applicant experienced continuous bleeding and

excruciating pain. Despite repeated requests by the Aggrieved

person/Applicant for medical attention, the Respondent coldly

refused, claiming that he had no money as he was

unemployed. Also, when the Aggrieved person/Applicant, in

desperation, asked the Respondent to seek financial help from

his family, whom he regularly supports with his farming

income, the Respondent refused with complete indifference,

declaring that it was his money, and he would use it as he

pleased.

11. It is further submitted that the Respondent forced the Complainant to

seek medical assistance at a government health centre. The respondent

accompanied the Complainant but displayed gross inappropriate

behaviour. It is submitted that when the Complainant, weak and in

pain, arrived at the hospital with the Respondent, he did not

offer her support but instead used the moment to torment her

further. The Complainant was too weak to stand in the queue, so

the Respondent stood in line on her behalf. However, instead of

showing care, he made inappropriate gestures, indicating that

another woman was standing too close to him, deliberately

 trying to provoke the petitioner’s already fragile emotional

state.

12. The Complainant politely requested the woman to maintain some

space, but instead of understanding, she was met with hostility

and rudely dismissed. The Respondent sided with the woman,

abandoning the Complainant emotionally in a place where she

already felt so vulnerable and exposed. However, the

Respondent’s cruelty did not stop there.

13. It is submitted that the Respondent, in a fit of rage, started

hurling abuses and tore the Complainant’s medical prescription.

After destroying her prescription, the Respondent left the

Complainant stranded at the hospital. He drove away, refusing to

answer her calls, leaving her physically weak, emotionally

shattered, and completely abandoned. It is further submitted

that at the time of the incident, the Respondent, was not giving

any money to the Complainant.

14. This is to submit that on 18 th March 2019, we were residing in a rented

apartment in Najafgarh. This is to submit that on the above mentioned

date, when the Respondent came back from his office in the evening, the
 Complainant saw his phone ringing continuously. Upon asking the

Respondent about the same, she was dismissed by telling that it is a call

from the office and is not of significant importance. This created a doubt

in the mind of the complainant. When the phone rang the next time, the

Complainant picked up the call and to her utter shock the call was not

from the Respondent’s office but from a girl claiming to be Respondent’s

girlfriend. The girl on the other end asked the complaint as to who she is

and when the complaint told her that she is the wife of Respondent

Kuldeep Chaudhary, she was also shocked. Upon asking the Respondent

about her, the respondent grabbed the leg of the Complainant and pulled

the complainant on the ground making her fall from the bed and started

to beat her mercilessly. The Complainant ran downstairs and locked

herself in the downstairs neighbour’s house. The Respondent repeatedly

knocked on the door, shouting in the building.

15. The Respondent, on the pretext of that he will tell the

complainant everything and even will take the complainant to

meet the girl on phone, asked the Complainant to come out of

the neighbour’s house. The Complainant believing him came

out and was again beaten by the belt by the Respondent.

However, Complainant, while she was in the neighbour’s

house, had called Police on 100. Luckily, the Police arrived

on time and a complaint was registered against the

 Respondent where he admitted that he was indeed in a

physical relationship with the girl on the phone, even before

the marriage and continued his affair even after the marriage.

16. The complainant spoke to the girl and found out that she was

19 years old and the Respondent had told her that he is a

singer and is of 21 years of age.The Respondent apologised to

the Complainant and took her home promising not to repeat

the same again.

17. This is to submit that the Complainant was constantly living

in fear of her life as the Respondent is strong physically and

has a bad temper, was aggressive, loud and completely

unpredictable in his reaction to the situation. It is also

submitted that around September 2019, owing to constant

fights and quarrels, the complainant decided to visit her

maternal home for some time. During this time no attempts

were made by the Respondent to diffuse the situation between

them.

18. On the contrary, the complainant found out that the

Respondent is selling the items of their rented apartment as he

will vacate the house. The respondent also told her that he

will be shifting to Bangalore as he got a job there.

19. The Complainant asked the Respondent to take her with him

but he denied and told her that once he is settled there, he will

call her there. It is also submitted the Complainant didn’t

even knew where the Respondent was working and living.

20. It is also submitted that on 15th December 2019, the

complainant, in lieu of the Respondent’s birthday, went to

Bangalore, in order to surprise and reconcile with him. To the

Complainant’s utter shock, multiple sim cards were

discovered from the Respondent of which the Complainant

had no clue. Upon asking, one of the sim cards was instantly

flushed by the Respondent and the Complainant was again

beaten up by the Respondent, not even allowing her to leave

the home. The Complainant was beaten so badly that she

started bleeding from her mouth. Upon hearing the

commotion, the landlord came up and told them to vacate if

the same was to be continued. Upon that the Respondent

apologised to the land lord and the Complainant and promised

not to repeat the same again.

21. This is to submit that Complainant shifted to Bangalore with

Respondent on 19th October 2020. It is also submitted that the

Respondent lost his job around October 2020 during COVID-

19 pandemic. In lieu of that, Respondent shifted back to New

 Delhi rather than looking for a job. The complainant was left

at her maternal home by the Respondent and was told that

once a suitable accommodation is arranged, the Respondent

will take the Complainant along with him. However, the

Respondent went to the marriage of her sister’s daughter to

which the Complainant was not invited to and spent a sum of

around 1.5 lakh rupees in that. After that, the Respondent

returned and reconciled with the Complainant promising that

he will never hit her again. This is also submitted that in the

month of April 2020, both of them shifted to Bangalore,

expenses of which were managed by the Complainant.

22. This is to submit that during the journey back to Bangalore,

the Respondent felt sick and as soon as they reached back, the

Respondent starting taunting the Complainant for his bad

health stating that she is cause of him falling sick. The

complainant fearing of the health of the Respondent, wanted

to take him to the hospital but the same was denied by the

Respondent telling that he will not visit a government

hospital. Upon that, the complainant spent a sum of around

40,000 rupees in the treatment of the Respondent. The

respondent was tested positive for COVID and home

quarantine was done. Around the same time, the Complainant

 also felt sick due to COVID as she was in the close proximity

of the Respondent taking care of him.

23. It is submitted that an argument broke out between the

Complainant and the Respondent when the Respondent’s

family, even after knowing that the Complainant too has got

COVID, failed to share even a shred of compassion towards

her. In the pursuance of this argument, the Respondent beat up

the Complainant and even broke her phone.

24. It is submitted that a call was made to the Police on 100 but

no formal complaint was registered as both the Respondent

and Complainant had COVID and were in home quarantine.

However, an apology was made in front of the Police Officials

and the Respondent promised to repay the medical expenses

and promised again not to beat her up.

25. This is to submit that another incident of domestic violence occurred on

19th August 2021 when the Respondent was leaving the shower, and the

door was opened, the complainant saw the Respondent picking up a sim

card from inside. Upon inquiring by the Complainant, the same sim card

was thrown out of the window. The complainant tried to retrieve it by

going downstairs but yet again was beaten mercilessly.

26. This is to submit that around 6th April 2024, when we were

residing in HSR Layout, Bangalore, the Respondent started to

 come home late very frequently. The Respondent used to be

agitated and used to fight physically and was being constantly

abusive towards the Complainant.

27. In one of the instances, the Respondent blocked the

Complainant from all the points of contact and didn’t came

back for at least 4 to 5 days. When the Respondent returned

back, the Complainant found a ticket confirming that the

Respondent went to Pune.

28. In one of the other instances, while returning from grocery

shopping, the Respondent told the complainant that he won’t

be returning home in the night. Upon inquiring about it, the

Respondent got angry and took the house keys and ran

towards the home leaving the Complainant in the middle in

the car fully knowing that the Complainant does not know

how to drive and would not be able to pursue the Respondent.

When the Complainant reached home, she found the

Respondent packing his belongings and getting ready to leave.

It is also submitted that in the ensuing argument, the

Respondent slapped the Complainant multiple times and even

broke the television set as well.

29. The respondent is earning handsomely. The last known salary

of the respondent was approx. rupees 13 LPA and along with

 that the Respondent also got promoted recently. The current

exact figures are not known to the Complainant.

30. In Six and half years, the Complainant has selflessly given in

this relationship emotionally, physically, mentally, monetarily

and demanded nothing but self-respect, support and love

which she was deprived off.

31. That the complainant has filed various police complaints at

Najafgarh as well as at Bangalore regarding acts of domestic

violence inflicted by the Respondent upon the complainant.

32. The Complainant today is left with no self-respect, no self-

esteem, no confidence and everything has been taken away

from her. The Complainant is mentally and emotionally

shattered today.

33. The Complainant has suffered immense pain and hurt from the

Respondent. The Complainant has not slept one night in peace

for as long as she can remember. The Complainant is

mentally, physically and emotionally scarred/drained and she

is unable to carry on any more like this.

34. It is submitted that the Respondent is having sufficient means

but despite that is neglecting and refusing to maintain the

Complainant. Complainant is unable to maintain herself.

35. It is prayed that the Hon’ble Court may take cognizance of the

Domestic Incident and pass the following orders, as deemed

necessary in the circumstances of the present case.

36. That the Applicant is residing at 335-A, D-BLOCK, AJAY

PARK NAJAFGARH, NEWDELHI-110043 and all the

incidents and acts of domestic violence has taken place at

Najafgarh also and further cause of action has arisen within

the jurisdiction of this Hon’ble Court, hence this Hon’ble

Court has territorial jurisdiction to try, entertain and decide

the present case.

(SUMAN)