IN THE COURT OF FAMILY JUDGE AT CHENNAI

M.C.NO. 186/2012

1.N.Devi
D/o.Nagalingam
2. Pavithra /12 yrs
3. Ranjith /8yrs
Petitioner 1 &2 rep.by
Natural guardian N.Devi
All are residing at :
27,B-Block ,West Cementry Road ,
Old Washermanpet ,
Chennai -600 021.
Petitioners

-VSK.Sankar ,
S/o.Kuppusamy Naicker ,
251,I Block ,
Old Washermanpet ,
Chennai -600 021.
Respondent
PETITION FOR MAINTAINENCE FILED U/S 125 OF CR.P.C
The petitioner above named most respectfully states as follows :

1.The first petitioner is N.Devi D/o Nagalingam ,Hindu , aged 33 years

(2)the second petitioner is pavithra ,D/o Sankar ,Hindu ,aged about
12years and (3) Ranjith S/o sankar ,Hindu,aged 8 years ;all are
residing at 27,B-Block West Cementry Road ,Old Washermanpet

,Chennai -600 021.The address for the service of all notices and
process on the petitioner is the same as stated above .

2.The Respondent is K.Sankar ,S/o.Kuppusamy Naicker ,Hindu, aged

about 41 years residimg at 251,I Block ,Old Washermanpet ,Chennai
-600 021. The address for the service of all notices and process on the
petitioner is the same as stated above .
3.The first petitioner submits that she married the respondent on
21.2.99 according to Hindu rites and customs at Baleswari
Thirumana Mandapam ,No.29 ,Cementry Road ,Chennai -21 .The
petitioner submits that the marriage solemnized with the consent of
the elders of both the family members and 15 soverign of gold was
gifted to the petitioner and two sovereign s of gold was gifted to the
respondent as demanded by the respondent and his family members .

4.The first petitioner submits that after the marriage the marital life
went smoothly and out of thje wedlock two children were born
namely(1) Pavithra , aged 12yrs and Rahjith aged 8 yrs .

5. The first petitioner submits that the respondent had love affair with
one Motcha prior to this marriage and concealing the truth due to the
instigationand compulsion of his parents , the respondent had
married the petitioner who is none other than his aunts daughter
.The petitioner submits that initially the resopondent was very caring
and affectionate and he did not reveal his true colour and the
petitioner believed the respondent that he had true love and affection
on the petitioner but in vain.

6.The first petitioner submits that the respondent had illicit affair with
the said Motcha who arried an other person and was residing besides
them .The respondent was caught red handed when he was having

illicit affair with the said Motcha and the same was witnessed by his
own sisters husband one Mani .The petitioner submits that she
immediately questioned the respondent as to why he had ruined her
future by concealing the truth and marrying her without any affection
and leading a machinery life to satisfy the society .

7.The first petitioner submits that the respondenmt most of the time
reached home in intoxicating state and used to beat the petitioner and
further stated that he only loved and cared for the said Motcha and
the petitioner had no right to question the respondent and further
stated that if she creates any confusion regarding this issue she would
lose her life .The petitioner further submits that due to intrusion of
the family members of the respondent her life became more
miserable .
8.The first petitioner further submits that the respondent hardly gives
money to the petitioner to run the family and further every time
insisted the petitioner to get financial assistance from her family
members .The petitioner further submits that her parents had advised
the respondent to change their residence so that the attitude of the
respondent would mend.Believing the words of the elders the
petitioner and the respondent shifted their residence to Sanjeevirayan
Koil Street , Old Washermanpet.

9.The first petitioner submits that in the year of 2005 she lost her
father and during the procession of her father the respondent instead
of being a dutiful son-in-law created a big chaos and confusion and
when the nuptial knot of the petitioners mother was removed the
respondent insisted the petitioner also to remove her nuptial knot and
the same was resisted by the petitioner and her family members .

10. the first petitioner submits that believing that the attitude of the
respondent would change she had again changed her residence by
giving a huge advance and all the financial assistance for shifting
including the advance was given by the petitioner s parents .The
respondent failed to be a dutiful husband and would never give the
rent and financial assistance to the petitioner and every time she had
to stand and the doorsteps of her parents.

11.The first petitioner submits that in the year of 2006 she was beaten
up badly by the respondent in front of her brother and mother-in-law
and in order to curatl the harassment and cruelty meted to the
petitioner by the respondent a complaint was lodged before W-13 ,All
Women Police Station ,Washermenpet ,Chennai-600 021 and during
investigation the respondent assured that he would change his
attitude and further all the belongings and articles of the petitioner
were returned to her.
12.The first petitioner submits that attitude of the respondentnever
changed and most of the time he would be in intoxicate state and
always failed to be a dutiful father and would reach the home at odd
hrs and if food was prepared immediately for him he would beat the
petitioner in front of the children .The petitioner submits that the
children hated the respondent for his attitude but the respondent did
not take any effort to change himself whereas continued his illicit
affair with the aforesaid Motcha .The petitioner submits that they had
again shifted their premises to Avadi and the respondent was not
happy for the same as he was not able to saa and continue his illicit
affair with the said Motcha and therefore he left the petitioner and the
children and fled to his house at old washermanpet .

13. The first petitioner submits that the respondent was hospitalized
and when she had rushed to the hospital to carry out the duties as a

dutiful wife the respondent s mother did not allow her to step into the
hospital and she was restrained from even visiting her husband .The
petitioner further submits that she was denied access to the
respondent and all her efforts for reunion turned futile.

14. The first petitioner submits that meanwhile in the year December
2010 she lost her mother and with no one to support her ahe went to
the respondents office to meet him praying to come back and to
support her and their children but the respondent turned deaf ears to
her plea and stated that she would face dire consequences if she again
comes to his office . The petitioner further submits that all her efforts
compromise and reunion turned futile and their marriage has been
irretrievably broken and she cannot condone the cruelty meted to her.

15. The first petitioner further submits thatshe is battling in her life
and further she is working as a teacher and out of the meager income
of Rs.5000/- she has to take care of herself and the 2 nd and 3rd
petitioner .The first petitioner submits that the respondent is working
as Mazdoor in Port Trust and earning a salary of Rs. 30000/- and till
date has not given anymaintanence to the petitioner .The first
petitioner further submits that she is taking various hand loans and
their life has become miserable as the respondent as a dutiful
husband and father is refusing to maintain the petitioners .The first
petitioner has to take care of the children, satisfy their basic needs
,their educational expenses and hence prays to direct the respondent
to pay maintainence to the petitioners.

Under such circumstance it is humbly prayed that this

Honble court may be pleased to direct the respondent to pay
maintainence of Rs.20000/- to the petitioner for their basic needs ,

educational expenses of the 2nd and 3rd petitioners and thus render
justice.
Dated at Chennai on this 4th day of April 2012
First petitioner

VERIFICATION
I,N.Devi ,the first petitioner herein do hereby verify that whatever
stated in above paragraphs are true to my own knowledge and belief .

First petitioner

List of Documents
1.Marriage Invitation original
2. Marriage photo original
3.Petition for Divorce filed in HMOP.No :661/12 on the file of 1 ST
addl.Family Court at Chennai
4.Birth Certificate - Xerox
5. Birth Certificate - Xerox
Dated at Chennai on this 4th day of April 2012

First petitioner
STATEMENT OF ADDRESS :
PETITIONER:

1.N.Devi
D/o.Nagalingam
27,B-Block ,
West Cementry Road ,

Old Washermanpet ,
Chennai -600 021.
2.Pavithra /12 yrs
D/o.K.Sankar
27,B-Block ,
West Cementry Road ,
Old Washermanpet ,
Chennai -600 021.
3.Ranjith /8yrs
S/o.K.Sankar
27,B-Block ,
West Cementry Road ,
Old Washermanpet ,
Chennai -600 021

RESPONDENT:

:K.Sankar ,
S/o.Kuppusamy Naicker ,
251,I Block ,
Old Washermanpet ,
Chennai -600 021.

Dated at Chennai on this 4th day of April 2012

First petitioner

VERIFICATION
I,N.Devi ,the first petitioner herein do hereby verify that whatever
stated in statement of address are true to my own knowledge and
belief .

Verified at Chennai on this 4th day of April 2012

First petitioner