Maintainence U/S 125 CrPC- Gita Devi. V. Ramesh Jain

FAMILY COURT

In the court of …………  

Case No. …………u/s 125 Crpc

Mrs.  Geeta Devi w/o Late. Dharmesh Jain, Age 75 year  

Presently Residing at House no. 2/3 Airforce Road Ratanada , jodhpur.  

                                                   PETITIONER 

Verses

• Mr. Ramesh Jain s/o Mr. Dharmesh Jain Age 50

• Mr. Suresh Jain s/o Mr. Suresh Jain Age 45

House no. 12/13 Ganesh Pura Ratanada  jodhpur

                                          RESPONDENT

Sir,

The humble request to you please that

1. That the petitioner is the mother of respondent. She is presently staying at one of their relatives.
2. That the Respondent No.1 is the eldest son and Respondent No.2 is the youngest son of petitioner. Both of them are staying at their ancestral house acquired by Respondent No.1 and Respondent No.2. 
3. That the petitioner was employed as a teacher in a private school and retired at the age of 65 yrs. in 2012. They are not employed anywhere and they does not have any residential address ( residential address was acquired by the Respondents). 
4. That the ancestral property was transferred by the petitioner to both the Respondents. But, since the said transfer the Respondents are not looking at basic necessities of the petitioner. 
5. That after the said property was transferred to the respondents, the petitioner was thrown out of their house and since then she was staying at their relative house.
6. That the petitioner was deprived from their medical facilities and other expenses of Rs. 10000.
7. The Respondent no.1 is an Government employee and earning a monthly income of Rs. 50000 and the Respondent no. 2 is employed in a private company and earning a monthly income of Rs.30000. 
8. That the petitioner has no source of income for her livelihood and to maintain herself. At present the petitioner was leaving with their relative and is totally dependent on them for her livelihood.
9. That the petitioner submits their relatives are financially unstable and are struggling a lot for their livelihood. Their income is very merger and their income is hardly sufficient for their basic needs. The petitioner submits that she does not want to depend on their relatives and she needs to maintain herself.
10. That the petitioner pleased to grant maintenance of rs.20000 from both Respondents No.1 and Respondents No.2 to fulfil their basics needs including food, clothes, medical treatments, 

residence.

GROUNDS

1.The petitioner is widow, so maintenance should be granted to her by both Respondent no.1 and Respondent No.2

2.The petitioner was forced to leave the house which belonged to her by the respondents and his wife, and so she had to live with her relatives.

3. The respondent is the son of petitioner so, the Respondents should be awarded the maintenance to the petitioner.

4.The petitioner’s statement that she was treated badly by the respondents and his wife is supported by evidence.

5.The petitioner should be awarded maintenance of  Rs.20000 p.m.  each by both the Respondents. 

                         PRAYER

The petitioner, therefore prays the Honourable Court in the interests of justice that the Honourable court may be pleased to direct the respondents:

1.  To pay a sum of Rs. 20000/- (rupees Twenty Thousand only) per month to the petitioner towards her maintenance,
2.  To pay costs of the petitioner
3.  To Grant such other relief or reliefs as the Honourable courts deems fit and proper in the circumstances of the case.

 Date ;                                                   Deponent      

Jodhpur                                              

VERIFICATION

That I Mrs. Kavita Devi the above name deponent to hereby verify and declare that the facts 1 to 3 stated above are true and correct to the best of my knowledge, belief and information 

Date;                                                                                                     Deponent                                                             

jodhpur

AFFIDAVIT

I Mrs Geeta Devi  w/o Late. Dharmesh Jain residing at H. No. 2/3 Airforce Road Ratanada jodhpur.  To hear by solemnly affirm on oath say as under:

1. That I being petitioner above name and I know the facts /circumstances of the case and I am depose thereto
2. That the statement in the paragraphs 1 to 10 and  grounds of the foregoing petition are true to my best knowledge and that I have not suppressed any material facts.

Date ;                                                                                                            Deponent

Jodhpur

VERIFICATION

That I Mrs. Kavita Devi the above name deponent to hereby verify and declare that the facts  1 to 2 stated above are true and correct to the best of my knowledge, belief and information 

Date;                                                                                                     Deponent                                                             

jodhpur