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BEFORE THE HON'BLE COURT OF DISTRICT AND SESSION JUDGE (Central Distt. ) TIS HAZARI COURTS, DELHI
IN THE MATTER OF:
STATE V/s A
S/O Sh. B
(HUSBAND OF COMPLAINANT)
R/O H. No. 1, K road, Ward- , Sonipat -
NAME OF THE COMPLAINANT
C W/o Sh. A and D/o Sh.D resident of H. No. 6, ___________________, New Delhi- 110005.
Ist APPLICATION FOR ANTICIPATORY BAIL U/S 438 Cr.P.C. ON BEHALF OF ABOVE NAMED APPLICANT.
MOST RESPECTFULLY SHOWETH:-
1. That the applicant is a peace loving and law abiding citizen of India and residing at the aforesaid address, and earning for his livelihood.
2. That on dated ____________ the marriage between the applicant and the complainant was solemnized according to Sikh rites and ceremonies at Delhi which was duly consummated, However, no issue was born out of said wedlock.
3. That the conduct/behavior of the complainant remained all right, hardly for few days after marriage, towards applicant and his family. After that her conduct was changed and she started misbehaving with the applicant and his family members and started torturing the applicant mentally by pressurizing the applicant to live separately from his family members. All the misbehavior was done on the instigation of her parents, who always instigate the complainant not to stay in the matrimonial house like a dutiful wife. Complainant never discharged the duties of dutiful wife with applicant and also as dutiful daughter- in- law towards applicant’s family. Further complainant prevented applicant from freely talking with his family members and restrained him from having any attachments with his family members, as complainant never liked them. This action of complainant has caused mental agony and harassment to applicant as well as to his family. Moreover, complainant is extremely fashionable and extra modern type of woman and highly extravagant. She demands money from applicant without any need for unnecessary issues. She used to pressurize applicant to bring new and costly clothes, Jewelery, make up items etc. for her. She always makes such demands from applicant, which were beyond his limit. She wants to live a luxurious life but applicant is a middle class person and he cannot fulfill such demands of complainant. Applicant always tried his level best and also tries to fulfill demands of complainant just to save his matrimonial life and keeping in view the bad health status of his old age parents. Complainant used to leave her matrimonial house on petty matters and stayed here and there for many days and then came back to applicant. Whenever applicant enquire about her outside stay she felt sorry from applicant and assured him that the same will never happen again and applicant always apologize her keeping in view the matrimonial life and with hope that her attitude will improve towards him on one day or other. However her attitude never improved. Complainant always ill treated parents of applicant and used filthy and harsh language towards them. She never provides food to parents of applicant. Health status of applicant’s father goes down due to ill treatment and lack of proper care by complainant. Being daughter in law, it was her duty to properly take care of parents of applicant especially father as he is a CANCER patient but she never obeyed her duty and always ill treated them. Father of applicant was forced to open a tea stall, to earn his livelihood, despite of his old age and disease, by complainant as she used to told them if they do not earn money then she will throw them out of the house. It is also pertinent and highly important to mention here that the complainant refused to conceive when the applicant told him to increase family. She told to applicant that it will destroy her figure and beauty if she gave birth to a child and flatly refused to conceive. She many times refused to establish physical relation with the applicant whenever he shows his desire for the same. From the above stated facts it is crystal clear that how much steel hearted she was towards applicant. But, applicant is yet ready to keep complainant with him just to save his matrimonial life and for his old age sick parents.
4 That the complainant on dated _____________ left the company of applicant after quarreling with him and the applicant also lodged a complaint in concerned police station regarding the same but the matter was then solved upon interference of elders of both families and the complainant returned back to her matrimonial home and she assured applicant and his family that she will not do the same again ever. Then after hardly 10-12 days, on dated __________________ the complainant again quarreled with applicant and called her family. Then complainant’s mother reached applicant’s home and then they both (applicant herself and her mother) gave him severe beatings. The applicant make complaint in this regard before police but said complaint was not registered and later on complainant and his family members felt sorry for the same and assured applicant that they will never do the same again and complainant will stay with him with peace and love. On this, applicant, keeping in mind his matrimonial life and old age sick parents, forgive them and kept the complainant with him.
5 That things remained silent for hardly few days and complainant again started misbehaving with applicant on petty matters. She said that she cannot live with the applicant, as she is not happy and satisfy with the earnings and simple lifestyle of applicant and she didn’t even liked her profession and openly stated that the applicant is not in her comparison. It is worth to mention here that at the time of marriage, all facts were clearly disclosed to complainant and her family members regarding education and profession of applicant and they all agreed to this.
6 That on dated ______________, when the applicant went on his job, the complainant left her matrimonial home silently without telling to anyone taken away Rs. 100,000/- in cash along with all jewellary of herself and also other jewellary, which was given by applicant’s family to her. The applicant tried to call her many times but she didn’t pick up his phone. Then the applicant called her parents and they told him that the complainant is there at delhi and now she will not come back ever and if you want to settle the matter then gave us Rs. 25,00,000/- else be ready to face dire consequences. At this the applicant makes complaint at police station. Then on dated ______________ the brother of complainant called applicant and threat him that “if you will not give us Rs. 25,00,000/- then we will kill you and your family. Complainant and his family members also threatened them if they didn’t give Rs. 25,00,000/- then she will indulge them in some false cases of dowry etc.
7 That then the applicant called her many times but she refused to talk him. Applicant also called parents of complainant many times for bringing complainant back to his house but they just ignored his requests. Then on dated ______________ complainant called father of applicant telephonically and told him that he want to take complainant to his home but he flatly refused to send her with him and also threatened him that if he came here he will not go back alive. The complainant is adamant and not admitted the genuine request of the applicant and threatened to involve the applicant and his family members in some false cases of dowry etc. Since _______________, the complainant is residing at her parental home.
8 That it is also important to mention here that applicant belongs to a poor/middle class but respectable family. He works as an artist in jagrans and other cultural types of programs and earns sufficient amount but most of his earnings was spent on illness of his father, who is suffering from CANCER and remaining apent on unnecessary items by the complainant. (Medical report of father is attached herewith as annexure A1). He has one unmarried brother and two married sisters. It is also pertinent to mention here that father of applicant is suffering from cancer and is under treatment and yet he is bound to run a tea stall as the complainant told him if he will not earn money she will throw her out of the house and will not bear his medical expenses.
9 That the applicant received summons issued by the office of CAW Cell, PS ______________, Delhi on the false and frivolous complaint of the complainant against the applicant and his family who have no concern or connection with the matrimonial life of the complainant.
10 That the office of CAW Cell, PS _____________, Delhi referred the case to the mediation center Govt. of NCT Delhi, PS ______________, Delhi, in which now next date is fixed as ______________.
11 That the applicant explain the fault of the complainant before the IO of the CAW Cell, PS ________________, Delhi, but the police officers of CAW Cell threatened the applicant to falsely implicate him on the basis of false and frivolous complaint of the complainant.
12 That the applicant has got genuine apprehension that he may be arrested by the concerned police officers.
13 That the applicant is ready to join the investigation as an when required by the I.O./SHO concern.
14 That the applicant is ready to produce the surety to the entire satisfaction of this Hon'ble Court/IO/SHO concern.
It is, therefore, most respectfully prayed that this Hon'ble Court may graciously please to direct to I.O./SHO of P.S. CAW Cell, PS _______________, Delhi to release on bail in the event of his arrest in the interest of justice.
New Delhi, IndiaProperty LawCriminal LawCriminal Acts
Bengaluru, IndiaIndirect Taxes/GST/VATDomestic ViolenceWill
Mumbai, IndiaIndirect Taxes/GST/VATCriminal LawCriminal Acts
Bengaluru, IndiaIndirect Taxes/GST/VATDivorceAlimony
Gurugram, IndiaIndirect Taxes/GST/VATAlimonyProperty Law
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Advertisements, promotional material, or watermarks on images, photos or videos.
Information which belongs to another person and to which the REGISTERED USER does not have any right to.
Information which infringes any patent, trademark, copyright or other proprietary rights.
Information which deceives or misleads the addressee about the origin of the messages or communicates any information which is grossly offensive or menacing in nature.
Information which threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign states, or public order or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting any other nation.
Information containing software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource.
Information violating any law for the time being in force.
All Documents/ Advices should be appropriately and accurately classified to the most specific location available. Incorrectly classifying Documents/ Advices is prohibited.
Documents/ Advice titles, Documents/ Advice descriptions, and bullets must be clearly written and should assist the customer in understanding the Documents/ Advice. .
All Documents/ Advice images must meet SoOLEGAL general standards as well as any applicable category-specific image guidelines.
Using bad data (HTML, special characters */? etc.) in titles, descriptions, bullets and for any other attribute is prohibited.
Do not include HTML, DHTML, Java, scripts or other types of executables in your detail pages.
Prohibited REGISTERED USER Activities and Actions
SoOLEGAL.com REGISTERED USER Rules are established to maintain a transacting platform that is safe for buyers and fair for REGISTERED USERS. Failure to comply with the terms of the REGISTERED USER Rules can result in cancellation of listings, suspension from use of SoOLEGAL.in tools and reports, or the removal of transacting privileges.
Attempts to divert transactions or buyers: Any attempt to circumvent the established SoOLEGAL Transactions process or to divert SoOLEGAL users to another website or Transactions process is prohibited. Specifically, any advertisements, marketing messages (special offers) or "calls to action" that lead, prompt, or encourage SoOLEGALusers to leave the SoOLEGAL website are prohibited. Prohibited activities include the following:
The use of e-mail intended to divert customers away from the SoOLEGAL.com Transactions process.
Unauthorised & improper "Names": A REGISTERED USER's Name (identifying the REGISTERED USER's entity on SoOLEGAL.com) must be a name that: accurately identifies the REGISTERED USER; is not misleading: and the REGISTERED USER has the right to use (that is, the name cannot include the trademark of, or otherwise infringe on, any trademark or other intellectual property right of any person). Furthermore, a REGISTERED USER cannot use a name that contains an e-mail suffix such as .com, .net, .biz, and so on.
Unauthorised & improper invoicing: REGISTERED USERS must ensure that the tax invoice is raised in the name of the end customer who has placed an order with them through SoOLEGAL Payment Systems platform . The tax invoice should not mention SoOLEGAL as either a REGISTERED USER or a customer/buyer. Please note that all Documents/ Advices listed on SoOLEGAL.com are sold by the respective REGISTERED USERS to the end customers and SoOLEGAL is neither a buyer nor a REGISTERED USER in the transaction. REGISTERED USERS need to include the PAN/ Service Tax registration number in the invoice.
Inappropriate e-mail communications: All REGISTERED USER e-mail communications with buyers must be courteous, relevant and appropriate. Unsolicited e-mail communications with SoOLEGAL , e-mail communications other than as necessary and related customer service, and e-mails containing marketing communications of any kind (including within otherwise permitted communications) are prohibited.
Operating multiple REGISTERED USER accounts: Operating and maintaining multiple REGISTERED USER accounts is prohibited.
In your request, please provide an explanation of the legitimate business need for a second account.
Misuse of Search and Browse: When customers use SoOLEGAL's search engine and browse structure, they expect to find relevant and accurate results. To protect the customer experience, all Documents/ Advice-related information, including keywords and search terms, must comply with the guidelines provided under . Any attempt to manipulate the search and browse experience is prohibited.
of the ratings, feedback or Documents/ Advice reviews: REGISTERED
USERS cannot submit abusive or inappropriate feedback entries,
coerce or threaten buyers into submitting feedback, submit
transaction feedback regarding them, or include personal information
about a transaction partner within a feedback entry. Furthermore,
any attempt to manipulate ratings of any REGISTERED USER is
prohibited. Any attempt to manipulate ratings, feedback, or
Documents/ Advice reviews is prohibited.
are important to the SoOLEGAL Platform, providing a forum for
feedback about Documents/ Advice and service details and reviewers'
experiences with Documents/ Advices and services –
or negative. You may not write reviews for Documents/ Advices or
services that you have a financial interest in, including reviews
for Documents/ Advices or services that you or your competitors deal
with. Additionally, you may not provide compensation for a review
(including free or discounted Documents/ Advices). Review
solicitations that ask for only positive reviews or that offer
compensation are prohibited. You may not ask buyers to modify or
REGISTERED USERS are expected to conduct proper research to ensure that the items posted to our website are in compliance with all applicable laws. If we determine that the content of a Documents/ Advice detail page or listing is prohibited, potentially illegal, or inappropriate, we may remove or alter it without prior notice. SoOLEGAL reserves the right to make judgments about whether or not content is appropriate.
following list of prohibited Documents/ Advices comprises two
sections: Prohibited Content and Intellectual Property
Listing prohibited content may result in the cancellation of your listings, or the suspension or removal of your transacting privileges. REGISTERED USERS are responsible for ensuring that the Documents/ Advices they offer are legal and authorised for Transaction or re-Transaction.
If we determine that the content of a Documents/ Advice detail page or listing is prohibited, potentially illegal, or inappropriate, we may remove or alter it without prior notice. SoOLEGAL reserves the right to make judgments about whether or not content is appropriate.
Illegal and potentially illegal Documents/ Advices: Documents/ Advices sold on SoOLEGAL.in must adhere to all applicable laws. As REGISTERED USERS are legally liable for their actions and transactions, they must know the legal parameters surrounding any Documents/ Advice they display on our website.
Offensive material: SoOLEGAL reserves the right to determine the appropriateness of listings posted to our website.
Nudity: In general, images that portray nudity in a gratuitous or graphic manner are prohibited.
Items that infringe upon an individual's privacy. SoOLEGAL holds personal privacy in the highest regard. Therefore, items that infringe upon, or have potential to infringe upon, an individual's privacy are prohibited.
Intellectual Property Violations
Counterfeit merchandise: Documents/ Advices displayed on our website must be authentic. Any Documents/ Advice that has been illegally replicated, reproduced or manufactured is prohibited.
Books - Unauthorised copies of books are prohibited.
Movies - Unauthorised copies of movies in any format are prohibited. Unreleased/prereleased movies, screeners, trailers, unpublished and unauthorized film scripts (no ISBN number), electronic press kits, and unauthorised props are also prohibited.
Photos - Unauthorised copies of photos are prohibited.
Television Programs - Unauthorised copies of television Programs (including pay-per-view events), Programs never broadcast, unauthorised scripts, unauthorised props, and screeners are prohibited.
Transferred media. Media transferred from one format to another is prohibited. This includes but is not limited to: films converted from NTSC to Pal and Pal to NTSC, laserdisc to video, television to video, CD-ROM to cassette tape, from the Internet to any digital format, etc.
Promotional media: Promotional versions of media Documents/ Advices, including books (advance reading copies and uncorrected proofs), music, and videos (screeners) are prohibited. These Documents/ Advices are distributed for promotional consideration and generally are not authorized for Transaction.
Rights of Publicity: Celebrity images and/or the use of celebrity names cannot be used for commercial purposes without permission of a celebrity or their management. This includes Documents/ Advice endorsements and use of a celebrity's likeness on merchandise such as posters, mouse pads, clocks, image collections in digital format, and so on.
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