IN THE COURT OF THE JUDGE: FAMILY COURT:

AT INDORE: MADHYA PRADESH

F.C. O.P. NO. 77 of 2019

BETWEEN:

• Smt. Kamini,

W/o. Shri Aaditya Rai,

Aged about 29 years,

Occupation: Housewife

Address: RJ COLONY, P-11

Indore, M.P.

• Abhay Rai & Kundan Rai

S/o. Sri Aaditya Rai,

Aged about 3 years,

Minor rep. by Mrs. Kamini Mother &

Natural Guardian Address: RJ COLONY, P-11

Indore, M.P.

…….Petitioner 1 & 2
AND

Mr. Aaditya Rai,

S/o. M.G. Rai,

Aged about 34 years, Hindu,

Occuption: Sales Manager,

Address: H.No. j 51/5, Ramiya nagar,

Bhopal.

……..Respondent

PETITION FILED UNDER SECTION 125 Cr.P.C. ON BEHALF OF

PETITIONER

Addresses for service of summons, notices, etc. on the above named

Petitioners are the same as that their counsel Shri Kumar Abhishek,
Family Court Premises, Indore, M.P.
Address for service of summons, notices etc. in respect of the respondent
is the same as that mentioned in the cause title.
The above named Petitioner humbly submits as follows:
• The petitioner No.1 is the wife of respondent and the petitioner No.
2 is minor children of both the first petitioner and the respondent.
The parties to the marriage have been living happily since they
were married in 2008 till 2018 when the respondent has allegedly
developed illegal intimacy with one of his female official
colleagues by name Janki Lal in March, 2019. The respondent is
transferred to Bhopal and he is presently staying in Bhopal. Since
 then he has totally failed to maintain the petitioner herein and they
were looked after by the first petitioner’s parent ever since.
• It is humbly submitted that the petitioner No.2 is studying in the 3rd
Standard. The monthly fee payable for both the children are about
Rs. 2500/-. The petitioner No. 1 has no other earning and living
source except the income of her husband who has now failed to
maintain her and her children.
• It is humbly submitted that the respondent gets a monthly salary of
Rs. 60,000/- and has been maintaining the family with good
standards of living while they were living together at Indore
happily.
• It is humbly submitted that the parents of the petitioner No.1 are
poor people and they cannot maintain the petitioner and her child
any more with their meager income.
For the reasons mentioned above it is humbly prayed that this
Hon’ble Court may be pleased to pass an order directing the
respondent to pay a monthly maintenance amount of Rs. 1500/- for
the petitioner and Rs. 7000/- for the maintenance of children and for
their expenses towards education and medical aid etc. in the interest
of justice.
…….Petitioner
Place: Indore Kumar Abhishek
Date: 06.3.2019 (Counsel for the petitioners)
VERIFICATION

I, Mrs. Kamini, on my behalf and also on behalf of the petitioner 2&3 do

hereby declare that the facts stated above in the paragraph 1to 4 are true
and correct to the best of my knowledge, information and belief. Hence,
verified.
……..Petitioner
Place: Indore Kumar Abhishek
Date: 06.3.2019 (Counsel for the petitioners)
 IN THE COURT OF THE JUDGE: FAMILY COURT:
AT INDORE: MADHYA PRADESH
F.C. O.P. NO. 39 of 2019

BETWEEN:

Smt. Kamini and others versus Mr. Aaditya Singh

Affidavit in support of application under section 125(3) Cr.P.C.

I, Smt. Kamini, W/o. Shri Aaditya Rai, Aged about 29 years,

Occupation: Housewife Address: RJ COLONY, P-11, Indore, A.P.
…..Deponent
Do hereby solemnly affirm and state on oath as under:

1.That the contents of my accompanying application under section 125

(3) of Cr.P.C in paragraph 1 to 4 are true and correct to the best of my
knowledge and belief. No part of it is false and nothing material has
been concealed there from. The contents of the accompanying
application has been read over and explained to me in vernacular.

2. That the contents of my above affidavit in paragraph 1 are true and

correct to the best of my personal knowledge and belief. No part of it is
false and nothing material has been concealed there from.
…..Deponent

VERIFICATION

I, Mrs. Kamini, on my behalf and also on behalf of the petitioner 2 do

hereby declare that the facts stated above in the paragraph 1to 2 are true
and correct to the best of my knowledge, information and belief. Hence,
verified.
……..Deponent
Place: Indore Kumar Abhishek
Date: 06.3.2019 (Counsel for the petitioners)