MODEL DRAFT: PETITION FOR MAINTENANCE

IN THE COURT OF THE JUDICIAL FIRST CLASS MAGISTRATE

AT VISAKHAPATNAM
M.C. No......... /2018
Between:

1. Smt. Bharati,
W/o Arjun,
Aged 30 years,
Occ: Household,
R/o Visakhapatnam.

2. Amar,
S/o Arjun,
Aged 8 years,
Occ: Student,
R/o.Visakhapatnam.

3. Saritha,
D/o. Arjun,
Aged 6 years,
Occ Student,
R/o.Visakhapatnam.

(Petitioner Nos. 2 & 3 are minors and are represented by their mother and natural
Guardian Petitioner No 1)
....Petitioners
Versus

1. Arjun,
S/o Tata Rao,
Aged: 35 years
Occ Fitter, SC Co. Ltd
R/o.Visakhapatnam. ..Respondent

PETITION SUBMITTED UNDER SECTION 125 OF Cr.P.C

May it please your Lordship,

The Petitioner above named beg to state on oath as follows:

1. That the petitioner No 1 and Respondent were married on.05.05.2009 during their
wedlock, two children, viz. Petitioner Nos. 2 and 3 were begotten.

2. That the Respondent is an employee in S. C. Co. Ltd., working as a Fitter. He draws

Rs.4,000/-monthly salary.

3. That the Respondent used to look after the Petitioner Nos 1 to 3 in the early years
of marriage. From the last four years, the conduct of the Respondent has been
changed due to bad friends. He is now habituated with all vices, viz drinking
alcohol, debauching, etc. From the last one year, he is not providing any provisions
to the Petitioner. He is not giving any money for the education of Petitioner Nos 2
&3. Whenever, the Petitioner No 1 asks for providing provisions and money the
Respondent used to beat her like an animal.

4. That from the last one year or more the parents of Petitioner No 1 are aiding the
Petitioners They are old aged, and the father of the Petitioner No 1 retired from his
job due to old age just two months back. Now there is no scope of getting financial
assistance from the parent’s side too. The petitioner, therefore, pray the honourable
Court to order the Respondent to pay @ Rs 1000/- per month per each petitioner
from the date of the petition, and save the lives of the Petitioner.

Prayed,

Place Sd/-xxxxxxxx
(Smt. Bharati)
Date
Petitioner No.1 for herself and for her minor children

Verification: I Smt Bharati, W/o Arjun, aged 30 years, Occ House-hold, R/o.
Visakhapatnam do hereby solemnly state and declare that the contents from paras 1 to 4
of this petition are true and Correct my own knowledge I say that I have not concealed or
suppressed anything.

Verified at Visakhapatnam on this the ......th day of......., 2018

Sd/-XXXX

(Smt. BHARATI)
Petitioner No. 1

Interpreted and identified by

Sd/- xxxx
Petitioner’s Advocate