C/ INTHE COURT OF FAMILY JUDGE, BHUBANESWAR CRPNO. 236 oF 2022 In the matter of: 4. Smt. Gayatri Pani & Another Petitioners Versus: Si Asit Kumar Purohit Opp Party ADDRESS STATEMENT OF THE PETITIONERS. 41. Smt, Gayati Pani ‘Aged about 30 years, Wio Sri Asit Kumar Purohit, lo Sri Pramod Kure Pani Rio At-K-9-A MIG 284 Kalinga Nagar, Patrapaca Bhubaneswar - 751019 (Odisha). 2. Mester Triyuth Purohit Aged about 1 year Slo Sri Asit Kumar Puroit Rio At K-S-A MIG 264 Kaiinga Nagar, Patapada Bhubaneswar - 751019 (Odisha), (Being represented through Mother Guardian) Petitioners BHUBANESWAR By the Peiitioners through, DATE, 27-10-2022, we a ‘Advocate “Cpe tonix COPY IN THE COURT OF FAMILY JUDGE, BHUBANESWAR CR.P NO, A OF 2022 In the matter of: ‘An application Under Section 125 of Cr.P.C. for grant of maintenance. “And: In the matter of: 1. Smt. Gayatri Pani ‘Aged about 30 years, ‘Wo Sri Asit Kumar Purohit, Dio Sti Pramod Kumar Pani Rio At K-8-A MIG 284 Kalinga Nagar, Patrapada Bhubaneswar - 751019 (Odisha). 2. Master Triyuth Purohit ‘Aged about 1 year Slo Sri Asit Kumar Purohit Rio At-K-9-A MIG 284 Kalinga Nagar, Patrapada Bhubaneswar - 751019 (Odisha). (Being represented through Mother Guardian)... Petitioners Versus Sri Asit Kumar Purohit, Aged about 34 years, Slo Late Govinda Chandra Purohit Rlo Plot no.284, Baikurtha Niwas Patrepada, Bhubaneswar- 751019 And also at: Kelenda, P.O. Salepai P.S- Melchamunda Bargarh(Odisha - 768036) Opp Paty And also at: SELCO Foundakion, A~S0, Nilakantha Ne 4a Nayapattc, Brrabansew As.012. RO &RS Nowapalli%& The humble petition of the Petitioners above named, MOST RESPCTFULLY SHEWETH 1. That the Petitioners are filing the present application under Section 425 of Cr-P.C. for grant of maintenance. 2, That Petitioner nos.1 and 2 are mother and son respectively Petitioner no.1 got married to the Opp.Party on 12.05.2017 and the marriage was held in Hotel Crown at Bhubaneswar as per the Hindu rites and customs, 3. That the Petitioner no. and the OppParty met end developed intimate feelings for each other and subsequently decided to get married to each other and the marriage was a love-cum-arranged marriage. 4, That the Petitioner no.1 and Opp Party got married at Bhubaneswar ‘on 12.05.2017 @s per Hindu rituals and with the consent of Petitioner 1o.1's parents and relatives. The marriage was attended by the parents and relatives of Petioner no.1 and opp.paty. 5, That immediately after their marriage, Petitioner no.1 and Opp Party started residing together in a rented accommodation at Bhubaneswar and started their conjugal Ife. As the opp.party is from Bargarh both the patitioner no.1 and opp.party used to visit Bargath and petitioner no. did all her best to satisfy and take care of her in-laws at Bargarh, 6. That on 27.03.2021 Peiitioner no.2 was bom from the wedlock in Ahana Gynaecare Pvt Ltd., Chandrasekharpur, Bhubaneswar and the petitioner no.1’s father initially made all the payments for the medical expenses and hospital bils which was subsequently reimbursed by the petitioner no.t's Company through Insurance. Cpogodl ni Tonkak - 3B 7. That the petitioner no.1 is a BTech Engineer in Electrical & Electronics Engineering and was doing a job at the time of manage but however, after the bith of petitioner no.2 she had to quit her job as had to take care of the new born baby. Likewise the opp party is also B.Tech in Agricultural Technology and is presently working with SELCO foundation as Programme Manager having office at A-S0, Nilakentha Nagar Nayapall, Bhubaneswar. 8. That the opp party's company is of high repute having its head office ‘at Bangalore and primarily dealing with Solar Lightings. The present salary of the opp party is around Rs.90,000! and over and above the salary it being a touring job also gets T.A, D.A and other allowances hence, total salary per month is around Rs. 1,25,000)-, 9. That atthe time of mariage there being huge demand for dowry the petitioner no.t's parents being middle class salaried person had lot of dificult in arranging the funds for meeting the demands of opp.party and his family. In all around Rs.50,00,000/- was spent by the petitioner no.1's parents which included gold jewelery worth around Rs.15,00,000%, further made payment to the opp party by cash in various dates amounting Rs, 7,70,000/- around Rs.10,00,000'- for catering as around 600 quest were invited from both sides and 10 ac rooms were booked for 3 days to be used by the Barats, each room consisting around Rs.3,000/- each per day besides the above expenses many other miscellaneous expenses were incurred by giving dress materials to the entire family members of the ‘opp.party which was around 50 of them. Further during engagement ceremony huge amount of money was spent by the parents of the pettioner no.1 9s per the requirements spelled out by the opp party 40, That for the first two years of the marriage the petitioner no.1 and ‘opp.party hed a cordial marital relationship and both had ‘tremendous love and affection towards each olher. The opp.party never objected to the pettioner no.1 continuing with her job but however, since 2020 the on Cyagodni Sec- 4- Opp party's atttude towards the peiitiner no 1 gradually changed and he Started neglecting the petitioner no.1/ wife. 11. That by the passage of time the attitude of the opp party / husband also changed towards the petitioner no.1’s parents and he started ‘making further demand for. ‘Gowry and the petitioner no.1 on ‘showing her inability in bringing more dowry she was alvays mentally and physically tortures by ‘the opp.party which made the petitioner no.1 suffer badly. 12, ‘That the petitioner no.1 on ‘refusing to bring dowry the opp. party besides neglecting her also avoided and stayed away from having physical relationship with the petiioner no.t/wie. Further since the bith of Petitioner no.2/son on 27.03.2021 the opp party has totaly stopped having any kind of physical relationship with the petitioner no, ite. Hence, there 's hardly any marital relationship let between the parties. On being asked about such change in behaviour and distancing himself from her, he used to abuse and behave badly with the petitioner no.1 and he also used to tell her that he is having an affair with one of his lady colleague in his ofice and is no more interested in the petitioner no. t/wife. 13. That the petitioner no.t/wife time and again has caught the opp party being in the company of the said lady and was always chatting / ‘messaging the said lady late through the night. The petitioner no.1 on ‘enquiry from the opp.party’s office learnt that the opp party and the seid lady colleague used to avai leave on the same day in multiple occasions. !t was also learnt by the petitioner no. wife of both the opp partythusband ‘and the lady colleague took leave forthe same period and went to Nepal for holidaying 14. That Petitioner n0.1 on being misbehaved and tortured by the opp.party had to leave her job as there was no one to take care of the petitioner no.2 minor son and finally she wes thrown out ofthe matrimonial home by the opp.party on 20.09.2022 and since then she has beente a staying with her parents with the minor child. Since the petitioner no.1 was asked to leave the matrimonial home the opp party has stopped paying any money forthe day-to-day expenses of the pettonerno.1 and neither for the minor son! petitioner no. 2 45. That the petitioner no.1's father having already retired and having no pension benefits henoe, it is @ big burden on him to maintain the peitioner no.1 & 2. Futher the ptiionerno.t being an independent lady does not want to be a burden on her parents hence, wants to move out and stay in @ rented accommodation with her minor son fr which she needs money for her maintenance as well as for their son. The patitoner ‘no.1 though educated but is presently unemployed and has no source of income, further the petitioner no.2/son being less than 2 years ‘old hence it is not possible on her part to take up a job forthe next couple of years 2 she has to look after the minor chi 46. That the peiioners having no oer source of nome ae fored 0 file the present petition before this Honble Court for mainiaining herself and also for the minor child. 47. That the Opp Party being the husband / father is legally bound to take care ofthe petitoners by providing monthly meinienancs and ase ying itigain expenses 10 the Palioner f.1 for conducting her matrimonial cases: 48, _ That the Peitonerno.1 has ted her all vt efforts to convince the opp Partyfhusband for providing adequate maintenance to them but the pp Paty has ceased all contact wih the Petitioner no.1, henoe the present application for maintenance 49, That the cause of action for ing te present application rose in september 2022 wien the ope. Paty totaly withdrew rom the company of the patuoners and stopped main nem" allways.~ Gor 20. That as the ‘marriage was held at Bhubaneswar and both the parties Bresenlly staying at Bhubaneswar hence tis Honble Court hes jursdition to entertain the present application for ‘maintenance. PRAYER 'n view of the aforesaid facts and circumstances, its prayed tha this Hon'ble Court may be pleased to allow the present applcalion and direct {he OppParty to pay @ maintenance of Rs.40,000/- (Rupees Forty ‘housand only) per month inthe proportion of Rs 30,000! (Rupees Thirty {housand only) to Pettioner no.t and Rs.10,0000- (Rupees Ten thousand only) to Petitioner no.2 from the date of filing the present application to the Pelitiners and Rs.20,000/- (Rupees Twenty thousand only) towards Iiigation expenses and may pass any other ordevorders as deemed just and proper. ‘And for this act of kindness, the petitioners shall, as in duty bound, ever pray, BHUBANESWAR By the petioners trough DATE: 21. 10. 20. Noor? eas vocate DOCUMENTS RELIED UPON 1. Mariage photographs 2, Baby birt certificate of petitioner no.2ison 3. Invitation card 4. Adhar card copy of the pettioner no.1 5.Passport size photo & x iA VERIFICATION Sit, Gayatri Pani, Aged about 30 years, Wio Sri Ast Kumar Purohit, Dio Sri Pramod Kumar Pani, Rlo At- KA MIG 284, Kalinga Nagar, Paltrapada, Bhubeneswar - 751019 (Otisha), Do hereby verify that the facts as stated in this petition and above are true to the best of my knowedge and belief and | sign this verification being present in my Advocates chamber at Bhubaneswar on his day. Goqutti fon ‘VERIFICANT AFFIDAVIT |, Smt. Gayatri Pani, Aged about 30 years, Wio Sri Asit Kumar Purohit, Dio Sri Pramod Kumar Pani, Rlo At: K-9-A MIG 284, Kalinga Nagar, Patrapada, Bhubaneswar - 751019 (Odisha), do hereby solemnly affirm and state as follows:- 1) That | am the Petitioner no.t in this case and as a mother guardian | ‘am competent to swear this affidavit on behalf of Petitioner no.2. 2) That the facts stated in this petition and above are true to the best of my knowedge and belie. Identified by yore Segal fai. ‘Advocal DEPONENTGOVERNMENT OF ODISHA I DEPARTMENT OF HEALTH AND FAMILY WELFARE [Bhubaneswar Munllpal Corporation CERTIFICATE OF BIRTH | Issued under Section 1217 the Resirotion of Bits an ests A 149 end ales of ahs ‘This t cary that folowing iformaton nas been eke ram ne origina! ecards of ith which isn De foaicer or Bhubsneswar Municipal Corporation of Tahasl SHUGANESWAR ‘fDistict KHOROHA of Siete ODISHA Date oF Birth sexan Pecmanent Address... AT KEMENDAL 20: Sex MALE, SALEPALI PS: MELCHWASIUNDA, BARGARE, Name, TRIYUTH PUROHIT ODISHA.ANDIA, 7403s Name of Father ASHT KUMAR PUROMIT Place of Bit... ANANA GYNAECARE MYELTD, ame of Mother. GAYATRE PAM HMUBANESWaR, Date OF Rexisteaion Registration No.....£47208. Signaturegalid DR BASANTA KUMAR Mashing Tesi Auton Regina Bt ang \| eieecae SUBANESHARMUNE AL SSthoe ation | ren ea itn ei at ers rst hn iS henna || Br ogee’ raiaia qsusale aeiqes aS qr qq. 671 Goo ae @isdug aca! 694 srAovgt_—___————————— gi gerne gee ale QALAIAE-ITY, BACT AIA, AIGAGI, a na Ea Ea QRSAAA-OFLOLC EEA-CYTONOMNG, CVNIMET VWI ane ee & ealGicalet: avern WheBr eagerrnC gdtcat anges dg Qasrisee ad aisdig ago, 0} 51 29.8.9029 Ga Cageiay Gore aSguar-ewg e9 aday (62IEER BiAR, QEERER) 81 89.8.9029 a aga) ‘OM -e.M0 ALO | (EE SPIGSR Glan, qesnqa Sae-c¥moMor ane, cyMoNrrexs @ 4h 1 Fer OAM EG ABSA GAgYCE ESA ASEM ABAA RagGR PAR. @ MN Aelassa, ose aaisiyjasisiey, of 6716 6909 6oY9 QaaS ASOORE Crag 91.09.8.9089 Ga genase AA RIE carne ePmITIET BATHE 41 9EAIC GAA Be eeMIG aau eggs SNA|I CAdaya GA@IAS! EaAg For arial qsaite 6 AEC caida Pa QsaREe eFE go AGIA AAS QAI (SqVe ag qe-ageag S860 anGaisen eRe EE | <4, 280m eREO, addgeR aidige’ eRAIAI BGR eagom 20 iawa aidisa gosngage saissR giag oI ogeade a0-0ng gaidiaio asaai ag: 019 Fie 6989 | MAC Aare O61, a1. QSIE GAIA ad a] MAS PAUge Aa, gi QeIs gia ad, aIdAea Od AKarEN Be SIAC! qaial GOGH, gi Gala aA, asae iFiot teat Goes rs > AaIar's1 09, 6 AdeIN eC | aI eedsoin ad co SESSIASSCASSATSSAARRAE SadeiaoadnnssissesssawaeAIRE AaRia ee ° Governm nt of India ag! AG 5 GAYATRI PANI el: genie gria ard Father : PRAMOD KUMAR PANI 8G GIGA / DOB : 25/05/1992 ARQ! Female Unique Identification Authority of India Sear: Address: A 40S 284, aigasi, aseIega, MIG 284, PATRAPADA, AIgAei, Eee, BSal, 751019 Bhagabanpur, Patrapada, Khordha, Odisha, 751019 2 & 1800 $00 1947 heip@ uidal govin2) care’s oh. (8 jo ep Pwerrargruno > Urea ance | oa ES SS Sint aad VAKALATNAMA INTHE COURT OF = THE FAMILY JUDGE, BAUBAN ESWwAR, CRP No of 2022— BETWEEN SN. GrANATRA PAN | Appellants / Petitioners -VERSUS- J Opp. Parti Br Harr OMReaCUTS Rie Respondents / Opp. Parties Know all men by these presents, that by this Vakalatnama wie Sort GayaTnt Pant wlo Gre Arik Kumar Rarelrst, cto Sx Prawnved Kath Pout, verha aah, Ka, MIG 284, Kialionga Nagar, Patanpadkae 2.151018, aged Bees (30. Yann Anpoiani(s\Pettone(sesponden(s/pposie —‘Pary(es) =n the Cfo RevisionpettoniAppealICastSuit do hereby apoin and retain r,(Ms.) Besura Das, En, No.1011/2005, Ph.9337258688, Mr. Tara Prasad Acharya, Mr.K.M.Patro, Mr. Dusmanta Ku. Naik, Mr. D.P. Mishra, Mr. Nikhilosh Baik, Mrs. Adishree. Mishra, Sasmita Pradhan ‘Advocate(s) to appear for mefus in the above case and to conduct and prosecute (or defend) the same and al proceedings that may be taken in respect of any application connected wih the same or any dectee or coder passed therein including all applications for turn of documents for receipt of any money tat may be payable to melus inthe said case and also in applications for leave to appeal to Supreme Court Ie authorize myfour Advocates) to admit any compromise ial in the sid case, DATED THE. 24,2.1Q.2... 20% 2 Received from the executanis(6) satisfied and accepted as | hold no bref for the other side Accepied as above or, oY: Das ‘Révocale a Geel Luni ‘Accepled as above Agéapted as above i: SIGNATURE OF EXECUTANTS ENRL Ne. ~ D[ YouT| Zou Peete i ee = AMBBOBSTYS, Serie BOO cere te blr S , cwceate ma ag 504e5E56 ‘Acharya & Co CUTTACK Advocates & Solicitors BHUBANESWAR ‘egannath Batov Plot No.1753/1 Cuttacke759001 Mahebahu Enclave Pala, BhubaneswarIn THE COURTOF THE FAMILY COURT, BHUBANESWAR, CRE | 2022. IN THE MATTER OF + — Smt. GAYATRI PANT PetitioNeR, VERSUS — SRI. ASIT KUMAR, PURORIT .. RESPONDENT Meno che Petition’ Sone ‘ne precess ecend Dow : 27.10.2022 5 we Plone: Grubesniowor. wer CAadvouate For Petiticnten