IN THE HON’BLE COURT OF MS.

AKANSHA
GAUTAM, M.M., DISTT. WEST, TIS HAZARI
COURTS, DELHI

D.V. COMPLAINT NO._________/2020

IN THE MATTER OF:

SMT. DHEERAJ …COMPLAINANT

VERSUS

KAPIL RAGHAV & ORS. …RESPONDENTS

D.O.H.:

EVIDENCE BY WAY OF AFFIDAVIT OF

COMPLAINANT AS CW-1

I, Dheeraj, W/o Sh. Kapil Raghav, D/o Sh. Vinod

Chauhan, aged about D-196, Laxmi Park, Nangloi,

Delhi-110041, do hereby solemnly affirm and declare as

under:-

1. I say thatam the deponent is the complainant in

the above noted case and is well conversant with the

facts of the case and isI am competent to swear this

affidavit.
2. I say that the marriage of the deponent was

solemnized on 02.12.2019 with the respondent No.1

according to Hindu Rites and customs at Krishna

Mandir, Najafgarh Road, New Delhi-110041.

3. I say that the marriage of the deponent with the

respondent No.1 had got marriedbeen arranged by the

parents of the deponent. All the demands of the

respondents were fulfilled as per the expectation and

choices and they had met the marriage ceremonies out

of their status and approx. Rs.8,00,000/- was spent by

the parents of the deponent in the said marriage.

4. I say that soon after the marriage, the behavior of

the respondents got changed and they started

harassing and torturing the deponent on petty issues

and started demanding dowry articles and when the

parents of the deponent were not in a position to

fulfilled their demands then the deponent was thrown

out ousted from the matrimonial home.

5. I say that the deponent’s parents given the lot of

gift items i.e. using of all the articles of daily uses just

like sofa-set, Almirah, washing machine, fridge, AC and

steel utensils, copper utensils etc. and the demand of

respondent No.1, my parents given one motor cycle

ofbike Royal Enfield brand and expensive expenses

gifts were given to the his family member of the

relatives of the respondent family.

6. I say that the deponent went the matrimonial

home dated 03.12.2019 about one week spend

withpassed happily and thereafter, slowly changed the

behaviour of the respondent family slowly changed and

they started givingen taunts for dowry demands and

torturinge the physically and mentally by the

respondent No.1.

7. I say that the on 17.12.2019, the respondent No.1

came in home thereafter, the respondent No.5 given

the deponent regarding the dowry articles “mujhe inke

gharwalo ne ek sone ki aunguthi bhi neg main hi diya.”

the deponent replied that my parents haves given

beyond their his capacity but the respondent No.1

being angry hadand beaten to the deponent and told

that gate outto leave my homehouse.

8. I say that the member of the matrimonial home

always taunteding to the deponent and beaten and

usedgiving the filthy language and always given the

threatening to kill them. The respondent No.3 hads

been insulted to the deponent and saidying that “tere

maa- baap ne tuje kuch bhi nahi sikhya hum to tumhare

jaise kangloo k ghar apene larke ka rishta kar ke bure

tarah has gya hai” instead the insulting by the member

of the matrimonial home the deponent is always giving

the respect and honour of the every member of the

matrimonial home but the member of the matrimonial

home always hit and giving the taunting for dowry.

9. I say that one day the deponent suffering from

stomach pain and told the respondent No.3 for check

up and treatment byto the doctor but the respondent

No.3 has been not attentiondidn’t care for the health of

the deponent and saidying to that call her is parents for

treatment thereafter, the deponent hads been called

herhis father on 17.02.2020 and deponent came tois

her matrimonial home and thereafter, her parents

giving the proper treatment and in meantime neither

the respondent No.1 nor family members had inquireds

been told about the health of the deponent. The

deponent tried to contract so many times to the

respondent No.1 has came on dated 14.03.2020 the

parental house and told that your treatment conducted

in Meerut, Uttar Pradesh where is very big hospital of

my mosaji. Thereafter the respondent No. 1 hads been

bring to the brought back the deponent, for treatment

at histhe house of mosaji, but the respondent No. 1

hads been not giving the proper given any treatment

ofto the deponent and instead told to doing all entire

household works to the deponent at the home house of

the mosaji.

10. I say that not proper treatment given by the

respondent No.1 thereafter, the deponent told his her

parents on by telephonic regarding her treatment on

dated 04.04.2020 the father of the deponent came and

on that day bring the deponent and join the treatment

Rajiv Gandhi Cancer Hospital, Rohini, Sector-5, Delhi

where the is some tests and discharged to the

deponent and doctor giving the opinion conducted to

advised for the surgical operation then to save the life

of the deponent. Thereafter, on 21.04.2020 the

deponent again admitted atin the hospital and

operation conducted on dated 11.05.2020 thereafter,

one week the deponent has beenwas discharged from

the hospital. The deponent parents has been had spent

for the treatment approx. the Rs. Six lacs rupees only.

The deponent has been told about the expenses for her

treatment to the member of the matrimonial home on

which they replied that I am they are not responsible

for anything treatment and had not given any

moneypanic regarding the treatment.

11. I say that the deponent had has been told after

herthe surgical operation regarding her treatment to

the respondent No.1 but he didnot even pick up the

phone of the deponent, and when the phone was if by

mistaken picked up the phone ofby the respondent, it

was deponent starting only to given abuse the

deponent with the filthy language and given the

warning don’t give mywas threatened to in anyonenot

call in future and you did at once I have not care you

and threat to I am remarry and liveing the luxuries life.

Thereafter, sometime when the family member of the

deponent feeling that the deponent has been treated

and living very well after the treatment. Continued her

medical treatment which gradually made the deponent

in better health.

12. I say that on 01.11.2020 the deponent has been

had joined the matrimonial home when enter her room

the deponent has been seen and found her almirah lock

broken and not foundall her costly clothes and jewellery

items stridhan were misplaced and when the deponent

hads been inquired regarding jewellery, clothes the

respondent No.1 saidsaying that you are insulting my

family members with concocted allegations.

13. That one week spent in matrimonial home of the

deponent and thereafter, one phone came of the grand

maternal aunt (nani) of the respondent No.1 and

thereafter, the changed the behaviour of the member

of the matrimonial home of the deponent and doing

cruelty and torture day by day of the deponent and

thereafter, respondent No.1 has beenhad in anger told

to that you liveing keep quietly or search findthe

another place.

14. I say that when the deponent told her matrimonial

family member that the doctor advised to not doing

heavy work, but the matrimonial family member of the

deponent has beendid not paygiven to the attention

and told her to doing the entire work of the home and

given the threateneding to kill herthem.

15. I say that on 29.11.2020 the deponent told the

respondent No.1 I am feeling very difficulties when

doing the entire work of the home, but the respondent

No.1 hads been beaten to the deponent and given the

threateneding to call herhis parents and live with

them.s there when the deponent told her parents about

all the incident thereafter, deponent’s father has

beenhad came to the matrimonial of the deponent and

brought bring his her back to her parental home.

16. I say that on 30.11.2020 the deponent hads been

reached her parental home when the deponent

contracted by telephonic to the respondent No. 1 that

the respondent No.1 has been sayingsaid that when

your parents has been not fulfilled my demand of one

lakh rupee cash and one car you will be not came

cannot come to the matrimonial home.

17. I say that the parents of the deponent has been

spent about Rs.six lakh for the treatment and the

respondent No.1 has been not given in any one penny

to the deponent for treatment and always insulting for

treatment and always insulting, beating and mental

torture for dowry demand to the deponent.

18. I say that the deponent has been not able to

maintain herself and she has been totally dependent

upon her parents.

19. I say that the respondent No.1 threatened the

deponent and told her that she will continue to be

surrounded be dragged before the police station and

the court and the deponent cannot take any action

against him because the respondent No.1 is in hand in

glove with the police officials and he also told that the

deponent should know that there are several cases

against him in the Meerut, but no harm could take

place to the respondent No.1.

20. I say that when the aggrieved person was at her

matrimonial home, she was kept hungry by the

respondents and respondent No.1 did not care to give

even a single penny to the deponent. However, when

the mother made the respondent understood that they

will try to met their demands then the behaviour of the

respondent remained some what cool, but after some

time again they started harassing, torturing, beating

and humiliating the deponent. The respondent No.1

started demanding and pressurizing the deponent for

bringing cash, when the deponent showed her inability

to give the same she was beaten, tortureding,

humiliateding and harassed by the respondent No.1.

Even the behaviour of the respondents became cruel

towards the deponent and respondents used to taunt

the deponent and keep evil eyes on the deponent.

21. I say that afterwards despitie all this the deponent

in the hope that good sense will prevail upon all the

respondents, continued to stay in the matrimonial

home. The father of the deponent and other family

members, relatives and society person tried number of

times to persuade all the respondents for not harassing,

humiliating, torturing, taunting and beating the

deponent, but again to no avail. The deponent/

aggrieved person was taunted, harassed, humiliated

tortured and beaten by all the respondents on petty

issues on several occasions. The aggrieved person /

deponent was kicked out from her matrimonial home.

22. I say that as the deponent was harassed and

tortured by the respondents on daily basis since the

day one and his family members had shattered the life

of he deponent and caused a great trauma as well as

cruelty both mental and physical to complainant and

her children .

23. I say that the deponent and her children have also

been subjected to other grave cruelties by the

respondents and thus the deponent reserves her right

and craves leave of this Hon’ble Court to initiate further

required proceedings against the respondent No.1 and

his family members as per law.

24. I say that the above said act of the respondent

No.1 and the facts started above showed that the

deponent has been subjected to the serious and grave

mental agony, which has not been condoned in any

manner and the respondent No.1 has got married to

deponent by intentionally concealing the true facts and

thus have committed a calculated fraud and spoiled the

life of the deponent and her future prospects.

25. I say that the following documents are exhibited

as under:-

(i) The original marriage card of the deponent is

exhibited as Exh.CW-1/1.

(ii) The photographs of the marriage of the deponent

is exhibited as Exh.CW-1/2.

(iii) The complaint dated 08.12.2020 is exhibited as

Exh.CW-1/3.
(iv) The complaint dated 09.12.2020 to C.A.W. Cell is

exhibited as Exh.CW-1/4.

(v) The Aadhar card of the deponent is exhibited as

Exh.CW-1/5 (OSR).

26. I say that the statement of the deponent is true

and correct to my knowledge

DEPONENT
VERIFICATION:
Verified at Delhi on this ____ day of May, 2024
that the contents of the above affidavit are true and
correct to my knowledge and nothing material has been
concealed therefrom.

DEPONENT
 IN THE HON’BLE COURT OF MS. AKANSHA
GAUTAM, M.M., DISTT. WEST, TIS HAZARI
COURTS, DELHI

D.V. COMPLAINT NO._________/2020

IN THE MATTER OF:

SMT. DHEERAJ …COMPLAINANT

VERSUS

KAPIL RAGHAV & ORS. …RESPONDENTS

D.O.H.:

INDEX

S.NO. PARTICULARS C. FEES PAGES

01. EVIDENCE BY WAY OF
AFFIDAVIT WITH EXHIBITS
DOCUMENTS
02. VAKALATNAMA IS ALREADY ON
RECORD

DELHI: COMPLAINANT
DATED: 05.2024

THROUGH

A&S LEGAL ALLIANCES

ADVOCATES