IN THE COURT OF SH.

VIVEK CHAUDHARY, JMIC, FARIDABAD

COMPLAINT CASE NO. _____ OF 2019

IN THE MATTER OF:

PRERNA CHOPRA …………………………………………COMPLAINANT

VERSUS

KAUSHAL CHOPRA & ORS……………………………….RESPONDENTS

APPLICATION UNDER SECTION 23(1) OF THE PROTECTION OF

WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

Respectfully Showeth :

1. That the Applicant/Complainant has filed the accompanying complaint

U/s 12 of the Act and the facts stated therein may be read as part of this

application and the contents thereof are not being reproduced herein for

the sake of brevity and convenience.

2. That the Applicant has a lawful right to residence and maintenance for

herself and her minor children as regards their medical treatment, clothes,

food , jewellery, istridhan and other usual household expenses and other

expenses of usual nature.

3. That the Applicant has a strong prima facie case on merits and the

balance of convenience also lies in the favour of the Applicant and

against the Respondents.

4. That unless the Applicant is granted the interim reliefs as prayed for in

the accompanying complaint, the applicant and her minor children shall

continue to suffer from exploitation and oppression by the Respondents

and are denied right to equal and economic and social status.

5. That the Respondents No.1, 2 and 3 have a flourishing business and have

various properties in Delhi, Noida and Faridabad.

6. That the Respondents are enjoying a lavish lifestyle and the Complainant

and her minor children are also entitled to enjoy similar status and

facilities.

P R A Y E R:

It is, therefore humbly prayed that in view of the aforesaid, this Hon’ble

Court may be pleased to pass and ex-parte ad –interim order thereby

directing the respondents:

(a) to provide ad-interim maintenance of Rs. 1,00,000/-(Rupees One

Lakh) to meet the expenses of the Complainant and her minor children

and also to provide for accommodation for residence to the

Complainant and her minor children at House No. 1131,First Floor

Sector-17, Faridabad alongwith access to all the common areas of the

house.

(b) to provide access and custody to the belongings including clothes,

personal articles, furniture, kitchen articles and appliance, jewellery,

Istridhan and usual household goods and articles that have been taken

away from the Complainant.

(c) to provide maintenance for the school fees, tuitions and other school

related expenses and medical expenses for Aarush and Aarav and also

a car in working working condition.

(d) to pass protection order(s) from any sort of domestic violence or

oppression any any manner and appropriate directions may be issued

to the protection officer/ local police in that regard.

(e) and to pass such other order or orders as may deem fir and proper in

the facts and circumstances of the case pending disposal of the

accompanying complaint case.

COMPLAINANT

Through

SUMEDHA TULI
(Advocate)
Plot No.1, Basement,
Sector-8, Faridabad