BEFORE THE COURT OF DISTRICT JUDGE TIS HAZARI COURT DELHI Application no _______of 2010 In Re:GUDDI DEVI W/o

Sh Umesh Kumar R/o , Uttam Nagar , New Delhi VERSUS State ( Govt of NCT of Delhi ) RESPONDENT FIR No- NOT KNOWN U/s 498-A , 406 IPC CAW CELL P.S UTTAM NAGAR

PETITIONER

PETITION

UNDER

SECTION

438

CrPC

FOR

GRANT

OF

ANTICIPATORY BAIL

Respectfully Showeth :-

1.

That the applicant is the MOTHER ,who is a House Wife , the applicant is law abiding lady and residing at the above said address permanently for the last about 10 years .

2.

That the applicant is a well reputed lady and belongs to a very respectable family . That the applicant has been falsely implicated in the said case . That the complainant is a resident of Okhla and living separately with her husband for the last about 9 months . It is important to mention that that the complainant abandoned her Matrimonial House after two months of her marriage .

3.

4.

That the said complaint is the counter-blast of the case filed by the applicant and her son , which is pending in the court of Ms Shelly Arora MM Delhi , in which the allegations on the complainant are of very serious in nature .

5.

That as per law the registration of the said case requires the prior permission of DCP . That the complainant has lodged a false complaint . The allegations made in the said complaint are false . The applicant is innocent and belongs to a respectable family . That in the year 2009 the complainant matrimonial home on the pretext to ceremony and went to her parents house . left the Rakhi

6.

7.

attend

8.

That after various Phone calls and reminders , after one week the son of the applicant visited at the house of complainant and requested her to come back at her matrimonial house. That on the same day and after dinner the son of the applicant , who is the Husband of the complainant went to asleep on the first floor of the said house , he shocked when he saw at around 1 AM that the complainant was not available in the room which was situated on first floor , immediately he came on down stairs and saw ( doing sex ) the complainant in compromising position with other person named as Rajesh & Rakesh in the room situated at Ground floor ,when he agitated all the three

9.

persons including the complainant after putting aside all sense of decorum started quarrelling with him in a most indecent manner by using filthy and abusive language . The complainant had flatly stated ,that she has provided a shelter / permitted her neighbors who are the cousin brother of complainant to live in her house .

10.

That at the same time the complainant went to the extent of giving threats to the applicant and his son them in a false Criminal Case . The to involve complainant . That the

threatened that she will end her life by consuming poison in case the said matter shall be disclosed complainant openly declared that she is the master of her own . That the complainant was taken away by Rajesh & Rajesh, who are living in same locality , due to the previous intimacy/friendship between them from that period the complainant is residing with them. That after the said incident the complainant filed a complaint against Rajesh and Rakesh , surprisingly the said report was taken back by the complaint after the compromise between the Rakesh and Rajesh in which the complainant took huge amount from them to settle the matter . 12. That after filing a complaint before Police Authorities the applicant has filed a case u/s 200 CrPC , and after investigations under 156 (3) CrPC , the Invistigation Officer found the police complaint by the complainant before Okhla Police Station in which the complainant stated that the Rakesh has committed a rape . 13. That after the said settlement the complainant is behind the applicant and his son to extort more money and filed a false against the applicant . That the applicant apprehend any time on the basis of Against Women Cell . That the applicant is not previously convict person and or is involved in any criminal case . That the applicant is the mother of five children . that she may be arrested by Crime

11.

14.

registration F.I.R

15.

16.

That the applicant undertakes to join the investigations as and when required. It is therefore most respectfully prayed that at the event of arrest the applicant be enlarged on Anticipatory Bail . Any other conditional order as may deem fit and proper be also granted. Prayed accordingly Delhi SMT GUDDI DEVI W/o Sh Umesh R/o Uttam THROUGH: H-KAMAL BEDI Nagar New

Kumar Dated Delhi

( Advocate) For the Applicant M- 14 ,Dewan House Ajay Delhi 18 Enclave New

Cruelty has not been defined in the Act. It is certainly not restricted to physical cruelty. Words, at times, do cause more damage than physical violence. The element of intention is a sine qua non for establishing a case for divorce on ground of cruelty. Besides intention other factors have relevance in determining the question. The considerations of entire, facts, circumstances of the particular case including the culture, temperament and status in life of the parties are other factors. Where one of the parties to the marriage tie indulges in reprehensible conduct and depart from the normal standards of conjugal kindness, a finding of cruelty against it, may be recorded so, where intention to be cruel can be found as a fact the importance of its relevance, can not, be denied. In petition under Section 13 (1) (ia), only those allegation of cruelty can be looked into, which have been pleaded in the pleadings. Evidence of those instances of cruelty will not be considered, which have not been put forward in pleadings. There should be specific allegations of cruelty with sufficient details averred in pleadings to as to enable the other party to meet those allegations. It must be pleaded that respondent created and caused such conditions which became so intolerable that it was impossible for the petitioner to continue to live with the respondent.

Hindu marriage from its inception is considered to be Sanskar based upon Karma and is irrevocable. The woman folk in general fund the Hindu woman in particular in this country has all along been treated as chattels,. In order to protect the rights of the weaker section of the society and forced by socio-political upheavals in the world generally and in the country particularly the State was forced to enact, amend, modify and codify law relating to marriage amongst Hindus. The Central Hindu Marriage Act was passed which regulated the marriages of Hindus, which

concerned

certain

rights

and

imposed

certain

obligations.

Keeping in view the peculiar socio-political economic system in the country, provision was made that no party to marriage is allowed to take the advantage of his or her own wrong and defeat the very concept of Hindu Marriage Act which was before the enactment of the Act, a Sankar based upon karma.

Section 23 (1) (b) of the Act provides that if the Court was satisfied that any ground for granting relief existed and the petitioner was not in any way taking advantage of his or her own wrong or disability for the purpose of the relief and where the ground of the petition was cruelty, the petitioner had not in any manner condoned the cruelty, then the Court could pass the decree for the relief sought by the petitioner. The section casts a duty on the Court before whom the proceedings under the Act are pending to satisfy itself that the conditions of Section 23 (1) (b) does not exist before granting any decree. The Court is not absolved of its duty even in proceedings which are taken ex-parte. The principle contemplated by this section is based on the rule that wrong doer should not be permitted to take advantage of his or her own wrong or disability while seeking relief at the hands of the court. It is also based upon wellestablished principle of Matrimonial Law that decrees relating to a marriage should be based upon strict proof.

The words if the Court is satisfied, cast a duty upon the Court to satisfy not only with respect to the claim of the petitioner under a particular section of the Act but also that the petitioner was not in any way disentitled to the relief prayed for.

It follows therefore, that in a proceedings for obtaining a relief of divorce on ground of cruelty the petitioner has to prove firstly the existence of the facts upon which he or she claims divorce and secondly to satisfy the Court that he/she was not taking advantage of his/her own fault and had not incurred disability by condoning the act (s) complained of. Hindu Marriage Act, 1955 Delhi High Court Rules (Practice and Procedure) Rule 9 makes it mandatory on the petitioner to file an affidavit with the

petition that the act of cruelty has not been condoned. The rule is framed by the High Court in exercise of the powers conferred by Sections 14 and 21 of the Act. The Rule has been framed to regulate the proceedings under the Act.

The Procedure Rules regarding the filling of affidavit can not be said to be mandatory in nature so as to render a petition under the Act not maintainable as the rights of the parties are to be determined not on mere technicalities or procedural law but on the provisions of the substantive law governing them. Moreover the Rules of Procedure serve as a hand mind of justice and cannot be allowed to penalize the parties. When the petition contains assertions regarding non-condonation of the respondents acts of cruelty and the petition stands duly verified, the omission of filing the affidavit in respect of assertions fades in to significance and can not be allowed to adversely affect the maintainability of the petition as the object of Rules and Procedure is to decide the rights of the parties and not to punish them for their mistakes or short-comings. Pleadings are not statutes and legalism is not verbalism. Common senses should not be kept in cold storage when pleadings are construed. It is too plain for words that petition were in writing. So, the law should not be stultified by courts by sanctifying little omissions as fatal flaws. Parties win or loose on substantial questions, not technical tortures and courts cannot be abettor. Thus the omission in respect of filing the non-condonation affidavit along with the divorce petition does not appear to be fatal to the petition because the filling of an affidavit in only a matter of procedure and it looses its rigour when the petition itself makes a specific averment and verification is appended to the petition. Rules of procedure are meant only as a handmaid of justice and not to inflict causality thereto.

IN THE COURT DISTRICT JUDGE DELHI In Re :GIRISH KUMAR .. Petitioner

VERSUS REENA & others .Respondents

INDEX

S.R NO . 1 2 3 4

PARTICULARS MEMO OF PARTIES PETITION FOR DIVERCE AFFIDAVIT IN SUPPORT LISTOF DOCUMENT WITH

PAGE NOS.C/F

DOCUMENTS 5 VAKALATNAMA

IN THE COURT DISTRICT JUDGE DELHI

MEMO GIRISH KUMAR S/o Umesh Kumar

OF

PARTIES

BOTH RESIDENT OF R/o L-3/29, Mohan Garden Uttam Nagar New Delhi .. Plaintiff VERSUS 1. REENA W/o Girish Kumar R/o H-1/107, Sanjay Colony Okhla Mandi New Delhi Rajesh Kumar R/o H-1 Sanjay Colony Okhla Mandi New Delhi Rakesh Kumar R/o H-1 Sanjay Colony Okhla Mandi New Delhi

2.

3.

.Defendants

IN THE COURT SHE NARINDER KUMAR ADJ DELHI In Re :GIRISH KUMAR .. Petitioner VERSUS REENA & others .Respondents

AFFIDAVIT I , Girish Kumar S/o Umesh Kumar aged about ___ years

R/o L-3/29 , Mohan Garden , Uttam Nagar New Delhi, do hereby solemnly declare and affirm as under :1. That the deponent is the petitioner in the accompanying petition . The marriage of the deponent was solemnized with the respondent on 10.11.2008 , at Okhla New Delhi . That the deponent has read the accompanying petition for divorce under section u/s 13 (1) ( ia) read with section 13 (1) i of of the Hindu Marriage Act as amended by Marriage Laws Act , 1976. 3. 4. That the act of cruelty has not been condoned by the deponent . The contents stated therein may be read as a part and parcel to this affidavit.

2.

5.

Deponent

states

that

there

is

no

improper

and

unnecessary delay in instituting the present petition. 6. Deponent states that the petition is not presented in

collusion with the respondent. 7. Deponent states that there has not been any unnecessary or improper delay in filing the petition . 8. Deponent states that there is no other legal ground why relief should not be granted. 9. Deponent states that there has not been any previous proceeding with regard to the marriage by or on behalf of any party.

DEPONDNT D

VERIFICATION Verified at delhi on this ..day of .2010. The contents of paras 1 to 8 of the above affidavit are true and correct to my knowledge and belief and nothing therein is false.

DEPONENT

IN THE COURT DISTRICT JUDGE DELHI HMA NO ____OF 2010

In Re :GIRISH KUMAR S/o Umesh Kumar BOTH RESIDENT OF R/o L-3/29, Mohan Garden Uttam Nagar New Delhi .. Plaintiff VERSUS REENA W/o Girish Kumar R/o H-1/107, Sanjay Colony Okhla Mandi New Delhi .Defendant

Petition for dissolution of marriage by decree of divorce u/s 13 (1) ( ia) read with section 13 (1) i of the Hindu Marriage Act as amended by Marriage Laws Act , 1976.

Sir, The petitioner prays as follows :

1.

That the marriage of petitioner and defendant was solemnized at Okhla New Delhi ,according to Hindu rites and ceremonies on 10.11.2008.

2.

The status and place of residence of parties to the marriage before the marriage and at the time of filing the petition were as follows:

Husband Status Place of residence residence 1.Before marriage Okhla New Delhi 2.At the time Married ___ 1/107 Sanjay Colony of filing the New Delhi petition 3. ''do'' Bachelor ___L-3/29,Mohan Garden Uttam Nagar N.Delhi Age Place of

Wife Status Age

Spinster _____

H-1/107 Sanjay Colony

Married _____ HOkhla

That after the marriage both the parties to the petition lived together as Husband and Wife at L3/29, Mohan Garden Uttam Nagar New Delhi.

4.

That the parties to the petition were Hindu at the time of Marriage and they continued to be so at the time of filing the present petition .

5.

After the marriage the behavior of the respondent was quite normal for few days, but after fifteen days of the marriage the respondent came in her true colours . The respondent started misbehavior and illtreatment with the petitioner on trivial matters. .The respondent was too-much under the influence of her parents and was dancing to their tune and had no voice of her own . The petitioner many times requested the respondent to mend her bad habits , but every time she gave her deaf ears open for all these . The petitioner had stated to the respondent that he is the son and it is his prime duty to look after his family .. On diverse occasions the petitioner had made complaints to the parents of the respondent about her acts but they did not give any positive response to the petitioner . Instead of giving proper advice to the respondent they started misbehavior with the petitioner and used threatening language to the petitioner. The parents of the respondent used very filthy and abusive language against the petitioner and his family member , in presence of the respondent . The petitioner had been tolerating the acts of respondent and her family with the dire hope that one day a better sense will prevail upon the respondent and her family , but with no result.

6.

That at the time of wedding night the respondent denied / refused sexual intercourse with the petitioner and stated that the marriage was forced on her by her parents and relations and did not allow to touch her . The respondent refused to co-operate with him with regard to sexual matters as also other matters and it was with great difficulty that once or twice in a month the respondent would permit the petitioner to have sexual intercourse with her . That the petitioner hoped that in course of time respondent would reconcile to the marriage and

there will be consummation ,but with not result .That one day the respondent after putting aside her all sense of decorum started quarrelling with the petitioner in a most indecent manner by using filthy and abusive language . The respondent went to the extent of giving threats to the petitioner and his family members to involve them in a false Criminal Case . The respondent threatened that she will end her life by consuming poison in case her demands are not fulfilled . She openly declared that she is the master of her own to visit at her parents house as an when she wants to go . After the said incident the respondent started neglecting the petitioner by not preparing food and not doing any household job .

7.

That in the year 2008 the respondent

left the

matrimonial home on the pretext attend Rakhi ceremony and took all her jewelry and valuable with her and went to her parents house and took away the clothes of the respondent by saying that the respondent will live for a weak in her parents house . That after various Phone calls and reminders , after one week the petitioner visited at the house of

8.

respondent and requested her to come back at her matrimonial house.

9.

That on the same day and after dinner the petitioner & respondent went to asleep on the first floor of the said house , that the petitioner shocked when he saw at around 1 AM that the respondent was not

available in the room which was situated on first floor , immediately the petitioner came on down stairs and

saw that the respondent in compromising position with other person named as Rajesh & Rakesh ( doing sex ) in the room situated at Ground floor ,when the complainant agitated the respondent no 1 and

respondent no 2 & 3 after putting aside all sense of decorum started quarrelling with the petitioner in a most indecent manner by using filthy and abusive language . The respondent no 1 had flatly stated

,that she has provided a shelter / permitted her neighbors who are the cousin brother of respondent to live in her house .

10.

That at the same time respondent no 1 ,2,3 went to the extent of giving threats to the petitioner involve them in a false Criminal Case . to The

respondent no 1 threatened that she will end her life by consuming poison in case the said matter shall be disclosed by the petitioner . That the respondent no 1 openly declared that she is the master of her own , That the respondent no 1 was taken away by respondent no 2 & 3, who are living in same locality , due to the previous intimacy/friendship between

them from that period the respondent no 1 is residing with respondent no 2 & 3 .

11.

After the said incident the petitioner came back and started living in a his house with Mental shock / agony .

12.

That after the said incident the petitioner with other relatives had contacted the parents of the

respondent no 1 and narrated the entire incident , but instead of listening the petitioner and his started

mother , the parents of the respondent

misbehavior with the petitioner and his mother and also used a very filthy and abusive language towards the petitioner and her mother.

13.

That it was another shocking news on 21.2.2010 the petitioner ( mother ) has received a telephone call from Police Station Okhla , that the respondent no 1 has filed a complaint u/s 376 IPC , committing a Rape against respondent no 1 & 2 . That after the said

incident the petitioner clearly stated that we dont want to develop and further relation with the respondent no 1 , at the same time after hearing that the respondent no 1 has compromised the matter with respondent no 2 & 3 and started blackmailing the petitioner and his mother and demanding Rs 20 lac failing which the respondents threatened the petitioner to implicate the petitioner and his mother in a false Dowery Case .

14.

The respondent no 1 is not of Good Character also has an illicit relations with respondent no 1 & 2 . The respondent no 1 ,2,3 are demanding Rs 20 lacs from

the petitioner . The said matter was reported to the police station Okhla & Uttam Nagar on the

23.2.2010 .

15.

That on 4.3.2010 petitioner has

filed

a complaint

before Ms Shelly Arora M.M Delhi against the respondents , in which the investigatigation are still pending as per the orders the M.M held that the offence is Cognizable as per the report of I.O . 16. The petitioner is not presented in collusion with the respondent. 17. There has not been any unnecessary or improper delay in filing the petition . 18. There is no other legal ground why relief should not be granted. 19. There has not been any previous proceeding with regard to the marriage by or on behalf of any party. 20. The petitioner and respondent are lastly resided with in the territorial jurisdiction of this Hon'ble Court hence this Hon'ble Court has the jurisdiction to try , hear and to grant relief claimed herein below . 21. That the proper court fee has bee affixed on the petition .

PRAYER It is therefore most respectfully prayed that a decree for dissolution of marriage by decree of divorce be passed in favour of the petitioner and against the respondent no 1 . Any other relief as this Hon'ble Court may deem fit and

proper under these circumstances be granted in favour of the petitioner . DELHI PETITIONER

THROUGH DATED COUNSEL

VERIFICATION I Girish Kumar the abovenamed petitioner states on

solemn affirmation that paras 1 to _____ of the petition are true and correct to my knowledge and belief and those of the contents of para ______to _____are also true and correct upon the information received to me. Last para is prayer to this Hon'ble Court , which is also correct. Verified at Delhi on this ______day of 2010.

PETITIONER

Sir, The COMPLAINANT abovenamed most respectfully submits as under :-

22.

That the marrage of complainant no 1 and accused no 1 was solemnized 10.11.2008 in Okhla Delhi . New

23.

That after marriage both complainant and accused no 1 were living together as Husband and Wife in

Uttam Nagar New Delhi .

24.

That in the month of August i.e on the eve of Raksha Bhandan the accused went to her mother home in Okhla but did not return thereafter .

25.

The Complainant no 1

had stated to the accused

that he is the only son and it is his prime duty to look after her the mother , and there is no body to look after

mother of the petitioner. To harass and

humiliate the complainant no 1 and his mother , the accused no 1 had started visiting her parents house almost after two or three days without any prior information to the complainant no 1 & 2 .

26.

That on diverse occasions the complainant no 1 & 2 had made no 1 complaints to the parents of the accused

about her acts but they did not give any .

positive response to the complainant no 1 & 2

Instead of giving proper advice to the complainant they started misbehavior with the complainant no 1 & 2 and used threatening language to the

complainant no 1 & 2 .

27.

The parents of the accused

used very filthy and . The

abusive language against the complainants complainant had been tolerating

the acts of

accused no 1 and her family with the dire hope that one day a better sense will prevail upon the accused no 1 and her family , but with no result.

28.

That in the month of August i.e on the eve of Raksha Bhandan the accused no 1 , went to her parents home in Okhla by , but did not return thereafter .

29.

That after various Phone calls and reminders , the complainant no 1 visited at the house of his wife ( accused no 1 ) and request her to come back at her matrimonial house went to the home of accused no 1 .

30.

That on the same day and after dinner complainant & accused no 1 went to asleep on the first floor of the said house , that the complainant shocked when he saw at around 1 PM that the accused no 1 (wife of the complainant ) was not available in the room

situated on first floor , immediately the complainant came on down stairs and saw that accused no 1 ,2,3 in compromising position ( doing sex ) in the room situated at Ground floor ,when the complainant agitated the accused no 1 with accused no 2,3 after putting aside her all sense of decorum started

quarrelling with the complainant in a most indecent manner by using filthy and abusive language . The accused no 1 had flatly stated ,that she has provided a shelter / permitted her neighbors who are the

cousin brother of accused no 1 to live in her house .

31.

That at the same time accused no 1 ,2,3 went to the extent of giving threats to the complainant to involve them in a false Criminal Case . The accused no 1 threatened that she will end her life by consuming poison in case the said matter shall be disclosed by the complainant ( husband ) . That the accused no 1 openly declared that she is the master of her own , That the accused no 1 was taken away by accused no 2 & 3, who are living in same locality , due to the previous intimacy/friendship between them from

that period the accused no 1 is residing with accused no 2 & 3 .

32.

After the said incident the complainant ( husband ) came back and started living in a his house with

Mental shock / agony .

33.

That after the said incident the both the complainant with other relatives had contacted the parents of the accused no 1 and narrated the entire incident , but instead of listening the complaint and his mother , the parents of the accused started misbehavior with the complainant and her mother and also used a very filthy and abusive language towards the

complainant ( husband ) and her mother.

34.

It is important to mention that the accused no 1 left the matrimonial home on Raksha Bandan and took

all her jewelry and valuable with her and went to her parents .

35.

That it was another shocking news on 21.2.2010 the complainant ( mother ) has received a telephone call from Police Station Okhla , that the accused no 1 has filed a complaint u/s 376 IPC , commiting a Rape against accused no 1 & 2 , when the complainant

clearly stated that we dont want to develop and further relation with the accused no 1 , very surprisingly the accused no 1 has compromised the matter with accused no 2 & 3 and started

blackmailing the complainant and his mother and demanding Rs 20 lac failing which the accused threathned the implicate the complainant and his mother in a false Dowery Case . 36. The accused no 1 is not of Good Character also has an illicit relations with accused no 1 & 2 . The accused no 1 ,2,3 are demanding Rs 20 lacs from the complainants . police The said matter was reported to the on the

station Okhla & Uttam Nagar

23.2.2010 .

37.

That the accused no 1 alongwith pressure of accused no 2 & 3 threatened the complainant to

involve them in a false Criminal Cases , including a case of dowry . They also threatened to kill the

complainant ( mother ) damage the property etc.

and also threatened to

38.

That the complainant resides with in the jurisdiction of this Honble Court . The cause of action arose within the jurisdiction of this Hon'ble Court therefore this Hon'ble Court has the jurisdiction the present complaint. to entertain

The complaint is within the limitation period as prescribed under the law.

It is most respectfully prayed that the Enquiry U/s 156 (3)may please be initiated through area SHO .

It is further most respectfully prayed that the abovesaid accused be summoned and tried for the offence committed by them u/s 354/376/406/497/120-B/498 IPC.

Prayed accordingly.

DELHI THROUGH DATED

COMPLAINANT

H.KAMAL BEDI ADVOCATE

BEFORE CHIEF METROPOLITAN MAGISTRATE TIS HAZARI COURT DELHI Complaint no _____of 2010 In Re : GUDDI DEVI & ANOTHER .. Complainant VERSUS REENA & OTHERS ..Accused

AFFIDAVIT I Girish Kumar S/o Sh Umesh Kumar R/o L 3/29 A ,

Mohan Garden Uttam Nagar R/o New Delhi , do hereby solemnly declare and affirm as under :-

1.

That the

deponent is

the

respondent

hence

fully

competent to sign and swear the present affidavit .

2.

That the deponent has read the complaint .The contents of the same may be read as part and parcel to this affidavit. DEPONENT VERIFICATION Verified at delhi on this ____day ______ 2010. That the contents of the above affidavit are true and correct to my knowledge and belief.

DEPONENT

To,

The S.H.O OKHLA PHASE I NEW DELHI

SUB:- THE PLIGHT OF A MOTHER AGE 37 YRS , COMPLAINT AGAINST MY DAUGHTER-IN LAW REENA , RAJESH & ROSHAN .

Sir,

Most humbly and with due respect. I the undersigned Mrs Guddi Devi W/o Umesh Kumar R/o L-3 /29 ,Mohan Garden , Uttam Nagar New Delhi beg to state the FACTS AND THE TRUTH AS FOLLOWS.

A VICITIM OF TREACHERY , BETRAYAL , MENTALLY TORTURE , AGONISIED, BREACH OF TRUST AND UNFAITHFULL ACTS OF DAUGHER-IN LAW REENA RAJESH & ROSHAN LIVING IN OKHLA . . MY

The root cause is the, lust/unfaith-fullness by my daughter-in-law Reena , Rajesh & Roshan ( The main Culprit ) hatched a conspiracy against my son to black-mail him without any cause .

I , Guddi Devi W/o Sh Umesh Kumar R/o L-3/29 Mohan Garden Uttam Nagar New Delhi . That the marriage of my son ( Girish ) was solominized with Reena on dated 10.11.2008 .

That

after 3 or 4 month after marriage i.e on Rakesh Bandhan my

daughter-in-law Reena went to her house in Okhla but did not return thereafter .

That after 3 or 4 days back my son went to the house of Reena ( his wife ) and after dinner all went to sleep , after 1 PM my son woke up and saw her wife Reena , Rajesh & Rakesh in compromising position ( doing Sex ) on the ground floor room , at the same time my son warned Reena to accompany him but she refused .

That my daughter-in-law Reena was taken away by Rajesh & Roshan , who are living in the same locality , due to the previous intimacy between them from that period she is residing with them .

That when I complaint about the same to Reena & her mother with Rajesh & Roshan have demanded a sum or Rs 20 lacs from us , they threatened to me and my son that they shall implicate us in a false Dowry Case .

That on 21/2/2010 I have received a call from Police Station ( Okhla Phase I ) , they intimated that the your daughter-in-law has filed a

complaint against Rajesh & Roshan , at the same time I clarify that we dont want to develop any relations with Reena , later on we come to know that all Reena / Rajesh/ Roshan have compromised the matter and trying to Black Mail me .It is important to mention that Reena is not of Good Character . They all hatched a conspiracy against me and my son to usurp everything .

I was physically tortured , by my daughter-in-law , Rajesh & Roshan .

This attitude of Reena , Rajesh , Roshan HAS RUINED MY LIFE & THE LIFE OF MY SON , THE CRIMINALS GOT THE OPPORTUNITY TO MINUPLATE PEOPLES . THE SITUATION AND DESTROY THE LIFE OF INNOCENT

MY PRAYER TO YOUR LORDSHIP is for immediate relief action.

THANKING YOU, YOURS FAITHFULLY GUDDI DEVI R/o Garden L-3/29,Mohan

COPY TO : 123D.C.P SOUTH Astt Commissioner of Police Okhla Honble Commissioner of Police Delhi

Uttam Nagar,New Delhi

39.

That the marrage of complainant no 1 and accused no 1 was solemnized 10.11.2008 in Okhla Delhi . New