CHECK-LIST

1. VALUATION OF SUIT JURISDICTION

('I IL.

2. NAME & ADDRESS OF ADVOCATE M ~ -SvP~l 'fA MAI\JArv

(,, UAN 6 E-1'(. ,-:JO. 2 I S, CH!\ '1.i ~"-.JC 8 1..-0vl< - :I
!>~U1I t-t It., H C.OUI( T /11£ ,._, OtL-HJ - JJooo;
3. NATURE OF SUIT
1>1vo(c.e- ~ 111 101\J u.j HMA

4. AGE OF PARTIES Plaintiff

3 J ~ .1.J
Defendant ..30 u .,,.,. ... . ~
IT
5. CAVEAT
(V-ON f:

6. WHETHER ANYT EARMARKED COURT

N£.Sf 1)1~ 1~ I (. 'f

7. COURT FEE AFFIXED SI Relief Valuation Valuation Court fee

No. Sought of Relief of relief paid on
for the for the each relief
purpose of purpose individually
jurisdiction of court
fee
1. J)l~E- djo/- '-IE!
2. VPl<J:at,1.i,J WA .;(/-;-
3.
4.
5.
6.
7.
8. CONNECTED CASES IF ANY & NAME OF THE
NON€; .
COURT WHERE PENDING
.' CASE INFORMATION FORMAT Civil ~
-
' flisTRICT
Crimina1O
s. PLAINTIFF / PETITIONER/ COMPLIANT/ APPELLANT/ DECREE HOLDER ETC.
No. PLEASE FILL UP AU THE RELEVANT FIELD & (*) FIELDS ARE MANDATORY)
1 Name of the Pllantlff / ~~01<_~
Complainant/ Etc.
\\JSkASl..
2 Slo W/o 0/o M\n. {nu)-f, H A, V AR.oRA
3 Address ltJ/1 o S:.Gco\J~ ft,Ut>~, MoT\ UAVJA- 1~ 1

t,.Jf w Ccl.\\ \ - '\bbl 5

4 Aadhar Card No. j Pin Code: I Joo 15 _-
5 Gender INDIAN
Male ~ e m a l Q Other Nationality
Other:
6 Date of Birth II I Age 3)
7 Mobile No ~<3 6 00 ~9 60~ e-mail:
8 Act I Section , ~u ') c., '6 ' y MM~
9
- Court Fee Ascetalned:
• Valuation of Suit
Court Fee paid/ Deposited:.
10 Police Station
l'\0T1 tJAwAR In Criminal Matters only
11 F.I.R. No. & Year Nj f", . In Criminal Matters only
s. DEFENDANT I ACCUSED I RESPONDENT JUDGEMNET DEBATER ETC.
No. · PLEASE FILL UP ALL THE RELEVANT FIELD & (*) FIELDS ARE MANDATORY)
1 Name of The DE.EfA"-'S.H l tv1%4AN
DEFENDANT/ACCUSED
EtC.
2 Sl&W/o Bio .,-v.S.HA R ~ILA

3 Addre~s '3(n-30, Nii- ?> ,

PAR.I DA~ D I 1-f A~l(,A/\J~

4 Aadhar Card ~o-I Pin Code: 12-1 0 0/

-
5 INDIAN
Gender Male ~emal.J7 Other Na.t ionality
~ - Other:
6 Date of Birth . I I I Age 3o
7 Mobile No. '":t8~.8 S 22 a.ob e-mail: Dfet>~"'~l-1, MA DA~ IJ<:£(} €),
s.
No. ADVOCATE FOR PLAINTIFF I COMPLAINANT I PETITIONER I DECRES.S HOLDER ETC.
1 Name of The Advocate • St1P~\'l'1 ~ A-t.J-AU
Enrl. No. t>I lr=f6 2c,o+
2 Office/ Chamber No. ,..,5 , t>e J..H\ M,Cn~ (/D~~T '~~
3 Mobile No. • Ie-mail: q flD5gRP :t-4 l.s.,,i.-,01\//b l\t\a fta n,, law

SUBMITTED BY :- ·····;P I .~
·I ej -· ~ ~
....:.............. ....................................... ~
PLAINTIFF I PETITIONER / OE EN >AN . I ACCUSED/ OTHE<,:ADVOCATE
-
 IN THE COURT OF PRINCIPAL JU DGE FAMILY COURT, \VEST

llJSTRICT, TIS HAZARI COURT NEW DELHI

H.M.A. PETITION NO. : OF 2024

IN THE MATTER OF:

TUSHAR ARORA .. . . .. PETITIONER

VERSUS

DEEPANSHI MADAAN ... .. . RESPONDENT

INDEX

S. NO. PARTICULARS PAGE NO.

I MEMO OF PARTIES 1-2

2
..
COURT FEES 3

PETITION U/S 13(1) (IA) AND 13(1) (IB) OF

HINDU MARRIAGE ACT 1955 ON BEHALF OF

3 THE PETITIONER NAMELY TUSHAR ARORA 4- 12

FOR DISSOLUTION OF MARRIAGE ON THE

GROUNDS OF CRUELTY & DESERTJON.

4 AFFIDAVIT IN SUPPORT 13- 14

EXEMPTION APPLICATION UNDER 151 CPC

5 15-16
FOR NOT FILlNG ORIGINALS IN ANNEXURES

6 AFFIDAVIT IN SUPPORT l 7-18

 6 LIST OF DOCUMENTS 19
7 LIST OF WITNESSES , 20

ANNEXURE P-1
8 • 21
AADHAAR CARD OF THE PETITIONER

ANNEXURE P-2 1(COLLY)

9 WEDDING INVITATION AND PHOTOS OF THE

WEDDING ALONG WITH 65-8 CERTIFICATE

ANNEXURE P-3

COMPLAINT TO P&, MOTi NAGAR BY THE

10
MOTHER AND SISTER OF THE PETITIONER'

DATED 18.11.2023.

ANNEXURE P-4

11 LEGAL NOTICE FOR MEDIATED DIVORCE

DATED 21.12.2023

ANNEXURE P-5

12 MEDIATION NOTICE DATED 16n1 JANUARY

2024

ANNEXURE P-6 (COLLY)

MEDIATION NOTICE DATED 15m MARCH 2024

13 J • ._

ALONG WITH THE REPLY EMAILED BY THE

PETit'IONER 'S COUNSEL

 ANNEXURE P-7 (COLLY)
·- .
COMPLAINT TO THE OFFICE OF DM AND SOM, l-11 ...~..s-
14 '. .
MOTi NAGAR BY THE MOTHER OF THE ~

. ) . I

PETITIONER DAT.ED 24TH FEBRUARY 2024

.
15 VAKALATNAMA I -~

~~
PETITIONER

THROUGH

NEW DELHI
DATED: 16.05.2024
SUPRIYAM A ASSOCIATES
CH. 2 I5, Chamber Block I,
Delhi High Court,
NEW DELHI

I
 PAGE I

IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT, WEST

DISTRJCT, TIS HAZARI COURT NE\V DELHI

H.M.A. PETITION NO. OF 2024

IN THE MATTER OF:

TUSHAR ARORA ... . .. PETITIONER

VERSUS

DEEPANSHI MADAAN... . .. RESPONDENT

J"o~:t.so.:rc. T:tOf'J - Mor 1. N Ay fH~

MEMO OF PARTIES

TUSHAR ARORA
S/O MR GULSHAN ARORA,
16/ 16, SECOND FLOOR,
MOTINAGAR,
NEW DELHI 11001 5
MOBILE NO.8860049608
EMAIL: ATUSHAR985@GMAIL.COM ... .. .PETITIONER

VERSUS

DEEPANSHI MADAAN,
D/O MR. RAJINDER MADAAN, •

ALSO RIO 3G-30, NIT-3,

FARIDABAD, HARYANA-121001
MOBILE NO. 7838522006
EMAIL: DEEPA~SHIMADAAN89@GMAIL.COM... . .. RESPONDENT
CURRENTLY RESIDING AT: 16/16, SECOND FLOOR, MOTI NAGAR,
DELHI-15
 PAG E 2 (''

-!~A~
PETITJONER

THROUGH

NEW DELHI
DATED: 16.05.2024
SUPRlYA MANAN
CH. 215, Chamber Block I,
Delhi High Court,
NEW DELHI
•
 PAGE 3

NCT OF 0£lHI COURT fEE

l'ILC101'25,4~232t10 •
07-NOV.202.1 '

NCT Of' DELHI COVfllT ,u

~CTil743424K23270
07-NOV-2023
 PAGE 4

IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT, WEST

DISTRICT, TIS HAZARI COURT NEW DELHI

H.M.A. PETITION NO. OF 2024

IN THE MATTER OF:

TUSHAR ARORA… …PETITIONER

VERSUS

DEEPANSHI MADAAN… …RESPONDENT

PETITION U/S 13(1) (IA) AND 13(1) (IB) OF HINDU MARRIAGE ACT

1955 ON BEHALF OF THE PETITIONER NAMELY TUSHAR ARORA

FOR DISSOLUTION OF MARRIAGE ON THE GROUNDS OF

CRUELTY & DESERTION.

IT IS RESPECTFULLY SHOWETH:

1. That the Petitioner is a law binding citizen of the country having Aadhaar card

number. A copy of the same is here with attached as ANNEXURE P-1.

2. That the Petitioner entered an arranged marriage with the Respondent on 23rd

April 2022 as per Hindu rites and ceremonies at Palm Greens Hotel and

Resorts, Main GT Karnal Road, 21/30, Bakoli, New Delhi-110036 , and both

the parties continue to be Hindu as on the date of presentation of the present

petition.
 PAGE 5

3. A copy of the wedding invitation and photographs of the wedding ceremony

are here with attached as ANNEXURE P-2 (COLLY).

4. That the status, age, and place of residence of parties to the marriage before
the marriage and at the time of filing the present petition were/are as follows:

HUSBAND

Status Age Place of

Residence
Before Marriage Hindu/Unmarried 29 years 16/16, Second
Floor, Moti
Nagar, New Delhi
110015
At the time of Hindu/Unmarried 31 years 16/16, Second
the Petition Floor, Moti
Nagar, New
Delhi 110015

WIFE

Status Age Place of

Residence
Before Marriage Hindu/Unmarried 28 years 3G-30, NIT-3,
Faridabad,
Haryana-121001

At the time of the Hindu/Married 30 years 16/16, Second

Petition Floor, Moti
Nagar, Delhi-15

5. After the marriage the parties stayed at 16/16, Second Floor, Moti Nagar, New

Delhi 110015, which falls in the instant Court’s jurisdiction till 30.05.23.
 PAGE 6

6. However, soon the parties entered into matrimonial discord and started having

fights. The Respondent left the Petitioner’s Parent’s House on 30th May 2023

after another fight.

7. While the parents of both the parties tried to resolve the issues between the

Petitioner and Respondent, the persisting issues between the parties did not

resolve and the couple have stayed separately ever since.

8. In order to resolve the issues between the parties both the families met outside,

in neutral ground, but the matters were never resolved and the acrimony

between the Petitioner and Respondent remained ever present.

9. On 5th November 2023, the Respondent along with 7 members of her family

barged into the Petitioner’s parents’ home in Moti Nagar during the absence

of Petitioner. It is pertinent to state here that at the Petitioner’s parent’s house,

his grandparents stay with his parents along with his unmarried sister.

10.On the said date, the Respondent’s family members physically assaulted the

Petitioner’s mother, sister, and his grandfather while the Respondent

continuously abused the Petitioner’s family. All this happened while the

Petitioner was absent from home.

11.When the Petitioner arrived at his Parent’s House, he was also manhandled by

the Respondents brother and father.

12.As the Petitioner did not want to increase further discord between the families

and escalate the issue, he thought it to be pertinent to involve the Police and

dialled 100 from his mobile phone. However, the Respondent also dialled 100
 PAGE 7

from her mobile phone and filed a false Complaint of domestic violence

against the Petitioner and his family.

13.It is pertinent to note here that the Respondent was absent from the Petitioner’s

Parent’s House from 30th May 2023 till 5th November 2023 and the same can

be proven easily through the CCTV footage recording at the front gate of the

Petitioner’s Parent’s House. On 5th November 2023, the Respondent came to

the house along with 7 of her family members. In such circumstances it is

inconceivable for the Petitioner or his family members to commit any

domestic violence against the Respondent. The false Complaint to the Police

was done only to ensure that no action is taken against the Respondent’s family

for physically and verbally assaulting the Petitioner’s family in their very

home. The CCTV Footage at the outside gate of the Petitioner’s residence

shows that the Respondent’s Family created a scene and left hurling abuses to

the Petitioner’s family to embarrass them in their peaceful neighbourhood.

14.The Respondent’s family left the Petitioner’s parents’ home before the Police

arrived. As the day was a Sunday and a festival of Karva Chauth was being

celebrated the Police had come late to the residence of the Petitioner’s family.

By that time, the Respondent had already locked herself in her bedroom. The

Respondent refused to answer even the Police upon their arrival. On being

enquired regarding domestic violence allegation against the Petitioner’s

family the Respondent ask the Police to come to the bedroom and take a

statement. The Respondent falsely alleged again regarding domestic violence

 PAGE 8

perpetrated against her by the Petitioner’s family and refused to leave the

house. As it was already 7:00 PM the male Police officer refused to cooperate

with the Petitioner and his family and asked them not to escalate the matter

further and left the family to deal with their dispute on their own.

15. The Respondent henceforth has occupied one bedroom of the Petitioner’s

parents’ home and has placed her own belongings in the said room although

she does not co-habit with the Petitioner in the said bedroom. The Respondent

since 5th November 2023 has never spoken to any of the family members

staying in the same house nor has, she inquired about the well-being of elders

in the house especially the Petitioner’s grandparents, who have been

hospitalised a number of times since 5th November 2023.

16.On 18th November 2023, the mother and sister of the Petitioner filed a

Complaint against the Respondent’s family members who had assaulted them

on 5th November 2023. A copy of the Complaint 2 PS Moti Nagar is here with

attached as ANNEXURE P-3.

17.However, no action was taken by the Police on the said Complaint as they kept

referring to the physical and verbal assault on the mother and sister of the

Petitioner as part of the matrimonial dispute between the Petitioner and

Respondent.

18.The Respondent came to the House of the Petitioners parents only 2-3 times

in a week and upon arrival she used to lock herself in her bedroom. The routine

followed by the Respondent was to leave for the office early in the morning
 PAGE 9

and as and when she chose to come back to the Petitioner’s Parent’s House,

she used to lock herself in her bedroom for the night and leave the next

morning for her office. Since 5th November 2023 till date there has been zero

communication between the Respondent and the members of the family of

Petitioner staying in the house.

19.The Respondent has not made any effort to resolve any dispute with the

Petitioner. The Petitioner had sent a Legal Notice to the Respondent along

with her family to arrive at a mutual resolution of the matrimonial dispute. A

copy of the said legal Notice is here with attached as ANNEXURE P-4.

20.However, the Respondent and her family refused to reply to the said Notice as

well.

21.On 16th January 2024, the Petitioner received a Notice from Delhi Mediation

and Conciliation Centre to appear before it on 3rd February 2024 in order to

mediate the dispute between the Respondent and the Petitioner. A copy of the

said Notice is here with attached as ANNEXURE P-5.

22.It is pertinent to mention here that the Notice did not have a copy of the

Complaint annexed to it and the Petitioner was not given any reason upon

asking about the nature of the Complaint which had to be mediated between

the parties.

23.The Petitioner along with his counsel appeared at Delhi Mediation and

Conciliation Centre on the appointed date of 3rd February 2024 only to be

informed that the Mediator is not available, and they were given another date.
 PAGE 10

This occurred 2 more times at the last appointed hour. The Mediator was never

present and on 2nd March 2024 which was the 3rd date given for the Mediation,

the Petitioner asked the Mediation Centre to drop the proceedings as they were

going nowhere.

24. On 19th March 2024, another Notice from the Delhi Mediation and

Consideration Centre was sent to the Petitioner’s permanent residence asking

him to come on 29th March 2024 for another round of mediation between the

Respondent and the Petitioner. However, this time the Petitioner refused to

attend the mediation proceedings and a reply to the Notice was emailed to the

Mediation Centre. A copy of the said Notice along with the reply email by the

Petitioners counsel is here with attached as ANNEXURE P-6 (COLLY).

25. The Petitioner’s Parent’s House is a 3 BHK in which currently the parents of

the Petitioner, the grandparents and his young sister are staying in 2 bedrooms

while the 3rd bedroom is occupied by the Respondent who uses the bedroom

only 1 to 2 times in a month when she comes to stay for the night.

26. The whereabouts of the Respondent for the rest of the month are unknown to

the Petitioner and his family. The Petitioner is also unaware of any and all

activities of the Respondent as there is no communication between the 2

parties.

27. However, the Respondent has illegally occupied a bedroom in the Petitioner’s

Parent’s House and refuses to clear her belongings from the said room despite

the fact that the Petitioner is not cohabiting with her.

 PAGE 11

28.In February 2024, the mother of the Petitioner had filed a Complaint with the

office of SDM Moti Nagar against the illegal occupation by the Respondent

of one of the rooms in her house. A copy of the said Complaint is here with

attached as ANNEXURE P-7.

29.It is clear from the above mentioned facts and circumstances that the

Respondent has wilfully deserted the Petitioner in the marriage and has also

committed cruelty against the Petitioner and his family by not only refusing

to cohabit with the Petitioner but also illegally occupying a room in the

Petitioner’s Parent’s House while the Petitioner himself is living somewhere

else.

30. The couple are staying currently (albeit seperately) within the jurisdiction
of this Court at 16/16, Second Floor, Moti Nagar, New Delhi-110015.

PRAYER

In the facts and circumstances as mentioned above, this Hon’ble Court may be

pleased to:

(a) Dissolve the marriage between the parties by a decree of divorce on the

grounds of cruelty and desertion and committed by the Respondent on the

Petitioner.

(b) Pass any other order/relief which this Hon’ble Court may deem fir and proper

in the facts and circumstances of the case in favour of the Petitioner and against

the Respondent in the interest of justice.

 PAGE 12

vfwJ,~.--
PETITJONER

THROUGH

NEW DELHI
DATED: 16.05.2024
:& ASSOCIATES
CH. 215, Chamber Block J,
Delhi High Court,
NEW DELHI
•

VERIFICATION

The above-named petitioner states on solemn affirmation that para-No. I to

29-of the Petition are true to the Petitioner's knowledge and believed to be
true by him.
,.....
Verified in New Delhi on this JI, day of
May202l
.J../L
P TITIONER
 PAGE 13

IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT, WEST

DISTRICT, TIS HAZARI COURT NE\iV DELHI

H.M.A. PETITION NO. OF 2024

IN THE MATTEA. OF:

TUSHAR ARORA ... ...PETITIONER

VERSUS

DEEPANSHI MADAAN ... . ..RESPONDENT

AFFIDAVIT

I, Tushar Arora, s/o Mr Gulshan Arora, aged 31 years, r/o 16/ 161 Second Floor,

Moti Nagar, New delhi-110015 do hereby solemnly declare and affirm as under:

1. That I am the Petitioner in the accompanying Petition, and I am acquainted

with the facts and ciral!mstances o_f the case, and I am competent to swear this

Affidavit.

2. That I have perused the accompanying Petition which has been drafted by my

counsel on my instrnctions. The contents thereof are trne and correct to the

best ofmy knowledge and belief and have been read over to me in vernacular.

3. That the Deponent is fully conversant with the facts of the case and is

competent to swear upon in this Affidavit.

 PAGE 14 J

4. That the Deponent submits that the Petitioner has not filed any other simi lar

Petition before any District Cou1t or Hon 'ble High Cou1t or before the Hon 'ble

Supreme Court of India.

Affidavit are true and con·ect to the best of my knowledge and belief and

nothing material has been concealed there from. 1.J. ~ _

DEPONENT

•
,- PAGE 15

IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT, WEST

DISTRICT, TIS HAZARI COURT NEW DELHI

MISC. APPLICATION /2024

IN

H.M.A. PETITION NO. OF 2024

IN THE MATTER OF:

TUSHAR ARORA ... ...PETITIONER

VERSUS

DEEPANSHl MADAAN ... ...RESPONDENT

APPLICATION UNDER SECTION 151 OF THE CIVIL PROCEDURE

CODE SEEKING EXEMPTION FROM FILING ORIGINALS OF THE

ANNEX UR ES

IT IS RESPECTFULLY SHOWETH:

I. That the Petitioner is filing a Di vorce Petition under section 1J of the Hindu

Marriage Act on the basis of cruelty and desertion by the Respondent, his wife.

2. That the Petitioner has filed true copies of all Annexures along with the

Petition.
-
3. That the Petitioner shall submit the original copies of the Annexures as and

when required by the Hon ' ble Court during the proceedings of the <::ase .

•
 PAGE16
,,
I

PRAYER

It is humbly requested that given the above-mentioned facts and

•
circumstances the Petitioner be exempted from filing originals of the
AnneKures. AND/OR pass any other order(s) as this Hon 'ble Court may
deem·fit in the interest of justice.

DATED: 16.05.2024

PLACE: NEW DELHI

Supri anan & Associates
Advocate
Chamber No. 215, Chamber block I,
Delhi High Court, New Delhi-03.
Mobile - 9810588874
Emai l: supriyamanan.law@gmail.com
 PAGE 17

IN THE COURT OF PRINCIPAL JUDGE FAMILY COURT WEST

' ' '
DISTRICT, TIS HAZARI COURT NEW DELHI

MISC. APPLICATION /2024

IN
H.M.A. PETITION NO. OF 2024
IN THE MATTER OF:

TUSHAR ARORA ... . .. PETITIONER

•
VERSUS

DEEPANSHI MADA AN .. . ... RESPONDENT

AFFIDAVIT

I, Tushar Arora, s/o Mr Gulshan Arora, aged 31 years, r/o 16/16, Second Floor,

Moti Nagar, New delhi-l l 0015 do hereby solemnly declare and affirm as under:

L That I am the Petitioner/Applicant in the accompanying Petition/Application,

and I am acquainted with the fact~ and circumstances of the case, and I am
I

competent to swear this Affidavit.

2. That I have perused the instant Application which has been, drafted by my

counsel on my instructions. The contents thereof are true and correct to the

best ofmy knowledge and belief and have been read over to me in vernacular.

3. That the Deponent is fully conversant with the facts of the case and is

competent to swear upon in this Affidavit.

Jf~JI--
DEPONENT
 PAGE 18 ; ✓,
I

VERIFICATION

Verified on solemn affirmation at Delhi on , the contents of the

Affidavit are true and correct to the best of my knowledge and belief and

nothing material has been concealed there from.

~).~
DEPONENT
 PAGE 19

IN THE COURT OF PRINCirAL JUDGE FAMILY COURT, WEST

DISTRICT, TIS HAZARJ COURT NEW DELHI

H.M.A. PETITION NO. OF 2024

TN THE MATTER OF:

TUSHAR ARORA ... . .. PETITIONER

VERSUS

DEEPANSHI MADAAN ... ... RESPONDENT

LIST OF DOCUMENTS

1. AADHAAR CARD of the Petitioner.

2. Wedding Invitation and photographs of the marriage.

3. Complaint filed in PS Moti Nagar by the Mother and Sister of the

Petitioner dated

4. Legal Notice for Divorce Mediation dated

5. Mediation Notice dated .

6. Complaint filed with the Office of SDM by the Mother of the Petitioner

dated ~~A-
PETITIONER
THROUGH

NEW DELHI
DATED: 16.05.2024
~-""! ASSOCIATES
CH. 215 , Chamber Block l ,
Delhi High Court,
NEW DELHI
 I

PAGE 20

IN TflE COURT OF PRINCIPAL JUDGE FAMILY COURT, WEST

DISTRICT, TIS HAZARJ COURT NEW DELHI

H.M.A. PETITION NO. OF 2024

IN THE MATTER OF:

TUSHAR ARORA ... , ... PETITIONER

VERSUS

DEEPANSHI MADAAN ... ...RESPONDENT

LIST OF WITNESSES

1. TUSHAR ARORA, the Petitioner himself.

2. Mr~. SUDHAARORA, the Mother of the Petitioner.

•
3. Ms NITASHAARORA, the Sister of the Petitioner.

PETITIONER

THROUGH

NEW DELHI
DATED: 16.05.2024
l~ ' I . . ! - ' ~ ASSOCIATES
CH. 215, Chamber Block I,
Delhi High Court,
NEW DELHI

, '
 PAGE 21
ANNEXURE P-1

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__
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regutalions, submilled by Aedham number holder.
■ This A..,IIMar !elter should be varir.ed through either onllne
ou1Mnll<:01ion by UI0l\1-appo,nlod eulhantieallon ngency or QR codo
3eannlng uc,ng mA:adn.-~, or Aadhaa, OR Scanner app ivallable in
RJ>P s101es or u•ing secure QR code reader app available on
www.uldal.govJn.
■ Aaelhner Is unique and secure.

■ 0ocumcnts to supoon identity and addro" should be uJ)datod in

A.>dtlaar after every 10 years from dale of enrolment ro, Aadt\ailf.
I ■ A.Jdhnnr helps you ~•ail or various Govemmenl and Non-
Governmenl benefits/services.
~ 3-TTUR" ~ I Your Aadhaar N o. ■ Keep your mobile number and email id updated in Aadha:u.

2782 2391 0667 ■ Download mAadhaar app 10 avail or Aadhaar ser.,ices.

■ Use the feature ol lock/Unlotk Aadhaarlbiomelrics to ensure
- - VID ·: 9160 2038 4871 3656
secunty when not using Aaohaarlbiometrics.
~ .3i'TUR, ~ 4 ~ 'c.i I crt ■ Enlitios seeking IIMM.ir are obfrgaled to seek consent.

- - . - . . - - . - - . - .. - .. - .. - - . - . ' - . . . .. - ..••. - . .• . . · ><- . • •• - • •• • •• •••••••• •• •• - ••. . . • - . - - . . - . - - .. - . . . . . · >-<!- .

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Unique ldelffi!jcatlo('(TAUthonty ot"lndia

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AA.OMA.AN.

Tushar Aro,a :I u;.q 'ill, <"Ill 'lt'R. ~ ·~-.

vl"II fllflvoOB: 12/08/1992 g~·ll0015
~/MALE ' !Address:
s10 GULSHAN ARORA. H N0-16 BLOCK
""'"'""""""""''· ~"'01"!111!1!""""' 1
8N0-16, 2NO FLOOR MOTi NAGAR. Karam
~(f~I Jt..~)lf ft~f1M ( 'M•➔t'fl$"' a.:'f!\,-f.ct,sM, Ill fttl-.3'tl~ ~J/ I Pura. PO: Ramesh Nagar. 01ST: West Oelh1
~ ~ d i ' ! Tlll#lJ hf rr.t1 ~ :J!1',fl ~ I jOelhi • 11001s '
Aadhaa, Is proof of Identity, not of citiztnO1fp \
o, dlle of birth. II ,tiould be u,ed wllh vo~ftc,non (onlloe
•ulhtnn,ai1on, or sunnlns of QR tode / offllne XML).

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 ,
I

PAGE 22

r?/mt. r?!Ula!J'n ~ @) ~ - fl~~~

request you to join them for the •

8tijOlu ~
of

. @Zu:r~ & @~tm,fc

~
On Saturday, 16th April, 2022
at 7:00 p.m.
(Followed by Dinner)
-\)-
Venue:
- ...> • - .. ~.

STARLA.ND BANQUET
~ dJ ·A-98, Mayapuri Industrial Area
,-•• ' }t' Phase-II, Mayapuri, New Delhi-110064
l
 PAGE 23

cordially invites you & requests the pleasure

of your company for an evening of
'
MEHENDI & COCKTAIL
to ·celebrate the forthcoming wedding of

@Ziir~ & @y«Ml:i'

• I
_,_ _ _ _ _ _ _ _ _ _ _ _ _ _,;;;;;a_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

PAGE 24

R.S. V.P.
Gulshan Arora
8860234742
--Q-
Wtth Best Compliments From :
All Relatives & Friends
-Q-
\ Wann Regards:;
\ ," . Arora's, Kalra's, Mehndirata's
,\ & Ma.go's

~
t~>
) · ,..

I
 PAGE 25

IN THE COURT OF PRINCIPAL JUDGE FAM ILY COURT, WEST

DISTRICT, TIS HAZARI COURT NEW DELHI

H.M.A. PETITION NO. OF 2024

IN THE MATTER OF:

TUSHAR ARORA ... . .. PETITIONER

VERSUS

DEEPANSHI MADAAN ... .. .RESPQNDENT

65-B CERTIFICATE

I, Tushar Arora, s/o Mr Gulshan Arora, aged 31 years, r/o 16/ 16, Second Floor,

Moti Nagar, New.delhi- 110015 do hereby solemnly decl~re and affirm as under:

I. The screenshots taken from my mobile number are true and correct.

2. I have carefully examined the screenshots of my Wedding invitations taken

from my WhatsApp and certify that this has been generated from my mobile

phone, the details of which are given below:

Mobile Phone

Manufacturer: APPL£ .If HON€

Model Nutfiber: M l-0- b1 rt N/ A
SERIAL NUMBER: - Kx,~ t,J2. tf FS$-,
IMEi: 3S6D 3g Lt¼ (e o2.L26:
Mobile number: 8g' 6 oc ½_ 9 6 0 f
 PAGE 26

3. They are true and correct copies of the screenshots of my Wedding

invitations taken of my WhatsApp as mentioned above. The said print outs are

true and correct from the said mobile phone.

This is to further certify that the above said information is true and correct to the

best of my knowledge.

Place: Delhi

Date: 16.05.2024 TUSHARARORA

-- - - - - - - -
PAGE 27
 -
ANNEXURE P-3

To,

TheSHO,

MOTINAGAR,

NEWDELID

DATED: 18th NOVEMBER 2023

SUBJECT; COMPLAINT AGAINST RAJINDER MADAAN, MANISH

MADAAN, KAMLESH MADAAN, SHABNAM BATRA MADAAN,
SHANTI SWARUP MAN CHANDA, VIRENDER BATRA, VEENA BATRA
BY MRS SUDHA ARORA AND MS. NITASHA ARORA FOR THE
OFFENCES NAMED,
Respected Sir,

I, Mrs Sudha Arora, aged 53 years, w/o Mr Gulshan Arora, r/o, 16/16, Second
Floor, Moti Nagar, New Delhi-I I 0015 and my daughter, Ms Nitasha Arora, aged
'
28 years, d/o Mr Gulshan Arora, r/o, 16/16, Second Floor, Moti Nagar, New
Delhi-I I 0015 have been criminally intimidaied, and words/acts were done to
outrage our modesty under a Criminal Conspiracy by an unlawful assembly of
the following persons who committed lurking house trespass after preparation to
hurt/assault us.
The persons involved in the unlawful assembly are:

ACCUSED N0.1

Mr. Rajioder Madaan, r/o, 3G-30, NIT-3, Faridabad, Haryan~12100l. Having

Mobile nwnber+91-9999897175. He is my son, Tushar's Father-in-law.

ACCUSED NO. 2

• 11P age
 , .
,·.

Mr$, Kamlesh Ma<Jaan, r/o, 30-30, NIT-3, Faridabad, Haryana- 12100 I. Having
Mobile number +91- 9999819272. She is my son Tushar 's Mother-in-law.

ACCUSED NO. 3
Mr Manish Madaan, r/o, 30-30, NIT-3, Faridabad, Haryana-121001. Having
Mobile number +91-9999819575. He is my son Tushar's Brother-in-law.

ACCUSED NO. 4
Mn. Shabnam Batra Madaan, r/o, 3G-30, NIT-3, Faridabad, Haryana- 121001.
Having Mobile number +91-9034341704. She is my son Tushar's Sister-in-law.

ACCUSED NO. 5
Mr Shanti Swarup Manchanda. Having Mobile number +91-9818510831 . He
is my son Tushar's wife's Maternal uncle (Mama)'.

ACCUSED NO. 6

Mr Virender Batra, resident of Sonipat, Haryana. Having Mobile nwnber +91-

9416427907. He is my son Tushar's Sister-in-law's Father.

ACCUSED NO. 7
Mn Veena Batra, resident of Sonipat, Haryana. Having Mobile number +91-
9034197588. She is my son Tushar's Sister-in-law's Mother.

The brief facts of the case are as follows:

My son Tushar married Deepanshi Madan on 23rd April 2022. It was-an arranged
marriage. However, since the very inception of the marriage the couple were
having marital problems. My son Tushar and his wife Deepanshi lived with us at
our above mentioned residence since the beginning of their marriage.

Deepanshi, my daughter.in. Jaw left her matrimonial home ·after having a fight
with her husband Tushar on 30th May 2023. •

.
21 Page

•
 PAGE . ·30 })

On 31 May 2023 I along with my husband, Mr Gulshan Arora and my son,

st

Tushar went to Dipanshi's parents' shop to resolve the matter at hand and met ·
them in their shop. However, things escalated out of hand and ·Accused No. 3,
Deepanshi's Brother verbally abused me and my husband and physically
assaulted us and shoved us out of the premises of their shop.

My daughter-in-law Deepanshi has been staying at her parental dbme ever since.
We had been trying to sort out the matter and in the spirit of resolving the marital
problems between my son Tushar and his wife Deepanshi both the families met
on 23rd September 2023 in a neutral place. All the above mentioned Accused
persons were present on the said date. Nonetheless, things did not go in a positive
-
direction rather all the Accused persons mentioned above threatened us
individually and collectively. My son Tushar was even threatened that he wilJ be
fired from his job due to the connections of the said Accused persons.

The said meeting did not go as planned and hence alJ the partie.5 concerned
returned to their homes. Deepanshi went with her parents and Tushar returned
with us to our. home.

On 5th November 2023 which was a Sunday all the Accused persons named above
entered our home along with Deepanshi. We were not given any information
rather the above mentioned Accused persons entered our home forcefully when
only me, my daughter and my aged father were present at home alone.

First, Accused No. 5, Deepanshi 's mama used very vile abusive language for me
and physically overpowered me at the front door of our house, so that the rest of
the persons could enter the house. When my daughter tried to stop the Accused
persons .from entering our house she was also physically assaulted and pushed
•
back by Accused No. I, Deepanshi's Father, and Accused No. 3, Deepanshi's
Brother.

~ 1 3IP age
I :~
 PAGE ·_ 3/

Then my daughter N'ltasha was physically

• assaulted by the 2 men older than her
(Accused no. 1 and 3) and verbally abused by the 2 ladies (Accused No. 2 and 7)
accompanying them .
.
Upon entering the house, we were threatened with fake dowry allegations against
my son Tushar and told that false Police Complaints against Tushar will be filed
if we do not comply with the whims and wishes of Deepanshi and her family.

Accused No. 2, Deepanshi's Mother then threatened my entire family of being

embroiled in a false police case if we do not keep Deepanshi at her matti,noniaJ
home.

During this time, my son Tushar had gone to the hospital to take care ofmy ailing
hospitalised mother and he had returned in the meanwhile. Upon seeing' him, the
Accused Nos. 6 and 7 threatened all ofus with legal cases as they allegedly belong
•
to the legal profession. It is pertinent to mention here that Accused Nos. 6 and 7
. are the parents of Dipanshi 's sister in law. They did not have any cause or right
to enter my home and threaten us in any manner and yet they criminally
intimidated us ~ behest of the other Accused persons.

Upon arrival Tushar had immediately called the PCR. On arrival of the Police,
we found out that there were 2 calls logged out of our premises. Deep~hi had
made a call to the PCR stating that we had done domestic violence with her and
tried to kill her. We have a CCTV camera at the very entrance ofour house on the
ground floor and we will provide the footage showing that before '5 th November
2023, pee~hi was not residing at her matrimonial home. And that she entered
our house accompanied by 7 adult family members on the said day she made the
domestic violence calJ to the PCR. The said call was made only to pressure us
and there is no truth whatsoever in the said complaint as was evident when the
Police arrived at our home and did not see any need to take our daughter-in-law
Deepanshi for any medical check-up on account of Domestic violence.

41 Page
Now we are .very scareddue to th.e threats given
. to us by all the Accused persons
collectively and in
• d"lvt'dually. We have been assaulted in our own home, verbally
abused, and compelled to not react against the provocations made to us by the
said Accused persons.

In view of the aforesaid facts and circumstances, your good self is humbly
requested to kindly take appropriate legal action against the above named the
Accused No. l to 7 to register a FIR against them as we were criminally
intimidated, and words/acts were done to outrage our modesty under a Criminal
Conspiracy by an unlawful assembly of the Accused persons who committed
lurking house ~espass after preparation to hurt/assault us amongst other relevant
provisions of law and any other offence deemed appropriate under the law of
the land.

.
Yours faithfully,

~
Mrs Sudha.Arora

w/o Mr Gulshan Arora,

r/o, 16/16, Second Floor,

Moti Nagar,
New Delhi-110015

Mobile: +91-7838925542
•

SI Page
 PAGE . ' °3_3
~ D/o _Mr Gulsban Arora,
r/o, 16/16, Second Floor,

Moti Nagar,
New Delhi-110015

Mobile: +91-9953533141

·6 Ir j

•
 I

ANNEXURE P-4
PAGE . J½ ),

di"P'"'/4'
• ~ .
C-7!J, NITI RACH
NH\/ DELH I -11 00'1!!

To,

DEEPANSID MADAAN ARORA DATED: 21.12.2023.

30-30, NIT-3,

F aridabad, Haryana-12100 l

My Client:

tvfR. TUSHAR ARORA

16/16, Second Floor,

Moti Nagar, NewDelhi-110015

I as an advocate act as per the instructions of my client and under the instructions
of the above named client I serve upon you the following Notice.

My client Tusbar Arora married Deepanshi Madaan, the above named Addressee
on 23 rd April 2022. It was an arranged marriage. The couple stayed at the above
mentioned address ofTushar Arora since the beginning ofthe ~arriage. However,
since the very inception of the marriage, the couple have had marital problems,
and you Jeff the matrimonial home after a tight on 30th May 2023.

While, over the next few months, a lot of effort was placed by the families ofboth
parties to arrive at a solution, no positive outcome could be achieved.

On 5th November 2023, you, along with your family members, entered the home
of my client without any information and forcefully stayed there. Even the Police

-v~
was called to intervene at that time.

' 981~874
sup riymnanan.law@gmail.co111

- ---- -- - -- -
I

I
r PAGE. · '3.-1 -

SUfMi'J'l'~
C-7!1, ~ IT! BM;I I
NE\\' DELHI -1IO(M!I

Since 5th November 2023, you have been living, coming, and going, as you
please, without any interaction, with Tushar and his family members.
•
The CUJTCnt situation is neither congenial for a family nor is it a positive
environment for a couple to stay together.

Hence, my client T1,1shar Arora has decided to take a divorce as he does not want
to stay in the marriage under any circumstances.
•
By this Legal Notice, you have 7 days, upon receipt, to respond via email, phone
call, WhatsApp or via post, through counsel or yourself.

My client Tushar Arora would like to meet along with his counseJ at a neutral
place to discuss the terms of a mutual divorce settlement with you.

Non-compliance ofthis Notice shall result in initiation oflegal proceedings both

civil and criminal and shall be undertaken by my client entirely at your costs and
risks which you may please note, f PY kept.

SUP IYA MANAN

• Enr1. No. 0/417512007 Advocate
Chamber No. 215, Block-1
Delhi High Court. New Deihl
Mob.: 9810588874
Email: supriyamanan.law@gmall.com

-h-'-
9810588874
su p1·iy;i Illa 11,111 .law@gmaiI.cm 11
 ANNEXURE P-5
Delhi Govt. Mediation Ot ConcWation Centre
P.W Dlqum Btl9J2tlon 1Pci•t7 (Ro&d,J
Paruam1m Stctcl Ntar Police stat100,New Pelbl·UOOOl
Email:• D.1medlattonce nterjlllt1m1U.com
Jel, No,:, 011-233&8QS§tsz -----
·DELHI GOVERNMENT

l;iir,:cus

r ·- . . ..PARTYN0.2
1\..,/ ,.·· ,' •Y.
•• • 1

NOTICE OF AJ'rl!:ARANCE ID/ MEDIATION

I • ••,,: ,

Whereas the above mcntio~ed case has been referred by:-

1. State ConsumerDisputes Redressal Commission _ _ _ _ _ _ _.,....._ _ _ _ _ _ _ _ _ _ _____;,
2. c.D.R.F.-~_ _ _ __ _ __ _ __ _ _ __ _ _ _ _ _ _...;...._ _ _ _ _ _ __
3. CAWCELL,_ _ _ __ _~_ _ _ _ __ _ __ _ __ _ _ __:....__--,-_ __
~ POLICESTATION - {fi~~ NC~ ~
S. R.W.A. _ _ _ __ _ _ _ _ _ __ _IJ.~
-~ -- - - - -- - -- - --=-- ~ -
6. OTHERS Like DepttsJBauks/Fioancilal Listitution etc.._ __ ___,_ _ _ _ __ _ _ for seulcment of
dispute through Mediation. - • ••

The m,nmballbe tabnup to,...icable settlem,nt lhroughMomation I

~~ O'.!, w.,/Mf _" / 2 l 3 ~_,,,..M.

.You are hereby required to appear -~ person,.~d/or~auth_~~ representative with ~evant reca/4s ~d yam
1dena£,_.00.Pmofbefo,etbeM-..~~ ~p ~~ S1r~ N,a,Po~ S!"'.t ion,r- v' llelld-~0001.

,~f .
.. ,_ .
.IN~CHARGE·/ADDL. DIRECTOR
Dispatch No. le &
Encl~
1. Copy of Applicatioo/ComplAlnt
2. Pamphlet of Delhi Dllpute Resoludori Society

Head Office· Qelbi Dispute Bewalutjon Sos:is:IY ffic¥dl

Qlcgd No S/6758WOQ9· &stahlishc(tby Qpyt AC NCT or Polbl • ~
Pean or J.aw)Ullka & Lcll,1lo11vc Alfala •
• B:Wio1, Yik.os Bh&1WJU1•II Civil Lines Polhi-110054 \ _ \~)
Cgptact N91,; ;zumss. 23813271 Toll Fn;pNg aaoom;za:2 A.,//'
 ANNEXURE P-6 (COLLY) PAGE ' 3r
. Delh,j Govt. Mediation & Concm,et:ion Centre
DtlhJ Df1put11 R,-olytJog Sod1ty (Rtcd.l
Parnament Street. Near Pollet s1at1on.New Detbt-110001 DELHI GOVERNMENT
Email;• psmediattgnc,nterfsrn,n,com RMOIUl-7--IW'Pllf
Iti, No,;-Q11-23368QS6/$7

... PAR1Y No.1 •

Vi:rsu.~

... PARTYN0.2

NOTICE 0 [Afp~:ARANCE JN MEDIATION

Whereas the above mentioned case has been referred by:-

1. State ConsumerDisputes RedressalCommlssloa _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _~ - -
2. C.D.R.R.-_ _ _ _ _ _ _ _ _ _ _ _ __ _ __ _ __ _ _ _ __ ---:-- -- --
3~ CAWCELL
~ POUCEST_A
_T
_I_O_N _ ___ ----:Q)::---()-h
-:-1:~C>
...,.)-~--- ::---- - - - ----:--- -- -
S. R.W.A. _ _ _ _ __ _ _ _ _ ____-1J---'<-+--- - - - - -- -- - -- -- - --
6. OTHERS Like DepttsJBaoks/Financlal InsdtutiGn etc.
dispute through Mediation. -----...---------
for settlement of

2.~ al ~ J P.M. •
Themotter sballli• taken up fo, ,m;oable settlement lluoueh Media1;on oo ?, )3) I)

You are hereby required to appear in person and/or through authorized represen1ative with relevant records and your
Jdenti1ication Proofbefore the Mediation Centre locatcdatParlliunent Street, Near Police on,New DeJhi-110001.

'' tIN . E/M>BL.DIREet:QR

Di9>11Jch No,
~ ~
i Govt. ·M~.J,J\;-;),, o.. ..m ciliatiOI\ C-,tn
Oelhl Dispute ResolulJon ~ t y ~ l. •
"11pll of Law, 'iiustk» S. ~ -.ffa.'ti, GNCT <'' ••--l'!
Encl: 1Par11ament t-Qrest, N t>~r •Police Stal¥,!<
1. Copy ofAppUcadoD/Complaint Na\.. r- ' C1
. ,,
2. Pamphlet of DelhJ l)flpute Rttoludon Society

l:f" d Office: Delhi Dispute Rcso1u1ioo Society /Recd)

!&ad No. S/67S87/2009, Es1ablish.d by (jov1. Of NCJ of Delhi
PCJ1a. of Gaw Jufljcc &. Lc1Jislo1iyc MQ.Uli
Q-Wiog YikA• Bhawgn-ll Civill.ina..O:dhkJ.JJl!U:l .
C..11<t..,81'1JJll 2lill718Toll Fm No lflOOUllJ ~ ch-_,

•
 TO,

DELHI GOVT. MEDIATION AND CONCILIATION CENTRE,

DELHI DISPUTE RESOLUTION SOCIETY,

PARLIAMENT STREET,

NEAR POLICE STATION,

NEW DELHl-110001.

DATED: 29TH MARCH 2024

SUBJECT: REPLY TO NOTICE OF APPEARANCE DATED 15.03.2024 IN

REF. 983/PS/PS-MN/23, DEEPANSHI VERSUS TUSHAR ARORA.

RESPECTED SIR,
•
This is in reference to a notice of appearance in mediation dated 15.03.2024
received by my client Mr Tushar Arora to appear before your Centre on
30.03.2024 at 12:30 PM. A copy of the said Notice is attached here with as

-
ANNEXURE l.

It is brought to the attention of the Mediation Centre that this is the second notice
of appearance given to my client Mr Tushar Arora. The first notice for appearance
was sent on 16.01.2024 to appear before the mediation centre on 03.02.2024. A
copy of the said notice is here with attached as ANNEXURE 2.

It is pertinent to mention here that my client and me had gon<J to the Mediation
• '
Centre on 03:02.2024 at the appointed time only to be informed about the
unavai_lability of the mediator at the last minute. We were given the date of 17.02.
2024 as the next appointment. However, on the next date, again, we were
infonned about th~ unavailability of the mediator and given a new date of
02.03.2024. On the new date, we were again informed at the very last hour about
the mediation not happening. It was at that point of time that l had advised my
·•, l

client Mr Tushar Arora to cancel the mediation. The same was informed to the
Mediation Centre by me over the telephone.

It is also pertinent to mention here that in both the notices' received by Mr Tushar
Arora, the mandato1y copy of Complaint is missing and the same was not
provided by the Mediation Centre after repeated requests. The Mediation Centre
infom1ed us that the complaint can be received only through police station Moti
Nagar.

Whereas Police Station Moti Nagar upon inquiry refused to share the copy of the
complaint and directed us towards the Mediation Centre.

In light of the above facts and circumstances my client Mr Tushar Arora will not
be participating in any mediation proceedings at Delhi Government Mediation
and Conciliation ,entre.

On behalf of Mr Tushar Arora, I hereby inform you to stop sending notice of

appearance for mediation as Mr Tushar Arora is not interested in any mediation
or conciliation with Miss Deepanshi.

As mediation is voluntary Mr Tushar Arora has decided not to pursue the same.

Kindly treat this as the final reply in Deepanshi vs Tushar Arora on be~alf of Mr
Tushar Arora.

SUPRIYA MANAN (Advocate)

Supriya Manan & Associates

Chamber No. 215, Chamber Block I,
Delhi High Court, New Delhi - 03.
 PAGE f:.Jo / I

Mobile - 9810588874 '

Email: supriyamanan.law@gmail.com

•
r PAGE , yI
ANNEXURE P-7 (COLLY)
To,

Ms. Kriti Garg,

District Magistrate (West),

Room no. 302, DM Office,

Raja Gard~, Delhi - 110027

DATED: ~ ', 1 FEBRUARY 2024

SUBJECT: COMPLAINT REGARD~G ILLEGAL OCCUPATION OF

BEDROOM IN MY SELF-OWNED HOUSE BY MY DAUGHTER-IN-LAW

ILLEGALLY

Respected Madam,

I, Mrs. Sudha Arora, aged 53 years, w/o Mr. Gu]shan Arora, r/o, 16/16, Second

Floor, Moti Nagar, New Delhi-110015 have bought the above mentioned house
# • : •

from my own self.:~~7 d i\come. It is my primary residence. The sale deed for

the said res~deqeeis in my name and I have already paid in full through my hard
l\ /
earned htcome for the title of the house.

My son Tushar entered into an arranged marriage with Deepanshi Madaan on 23ro

April 2022. After their marriage, the couple stayed with us, at my above

mentioned residence. However, soon the couple started having matrimonial

discord and owing to the said discord my Daughter-in-law, Deepanshi Maadan

1,,._,Jr .}--Page 1 of 3

·1~i-
r.
left her matrimonial home on 30th May 2023. While the families of both sides

tried to resolve this dispute mutually, the couple could not reach any neutral

ground for settlement.

While the _talks were going on between the families, Deepanshi, my Daughter-in-
.
law along with 8 family members came to my residence unannounced on 5th

November 2023 which happened to be a Sunday. Deepanshi and her relatives not

only entered my home unannounced and forcibly, they also physically assaulted

me and my unmarried daughter, who was present at home at the time. 1 have

lodged a Criminal Complaint against·Deepanshi's relatives for the said assault

with Police _Station Moti Nagar. A copy of the set criminal complaint is here with

attached as ANNEXURE I.

My paughter-in-law planned to stay at her matrimonial home with my son Tushar

henceforth. However, after the assault, in order to ensure the safety ofmyself, my

aged parents, my husband and my unmanied daughter, I asked my son to shift

. out of my house along with his wife.

.
Thereafter, my son has shifted to a rented accommodation in South Delhi and he

had asked his wife Deepanshi to also shift along with him. However, my

Daughter-in-law has refused to vacate the bedroom allotted to the couple and she

is still occupying the -~~~ bedroom, while her husband stays in a rented

accommodation in South Delhi. A copy of the Rent Agreement executed by my

,2of3

tJ
 I PAGE . Lf s
son, Tushar for the residential premises in South Delhi is here with attached as

ANNEXURE2.

I have repeatedly asked my son and his wife to vacate the said bedroom as there

are only 3 bed.rooms in our house and currently there are 2 couples nan,e)y my

aged parents and me and my husband along with my young daughter who are

forced to stay and share 2 bedrooms.

• Through this com~laint, I request you to act against my Daughter-in-·Jaw for not

vacating the bedroom while even her husband has left the residence and is staying

separately and away from his parents.

It 1s also to be noted that my Daughter-in-law does not come daily to my house

but has kept the room locked and is using the same for her own purposes. She

visits only once or twice in a wfek, and I have no infonnation where my

Daughter-in-law. stays for the rest of the days. However, I cannot make use of the

-bedroom in my own house due to the illegal occupation of my ·Daughter-in-law.

I request you to kindly help me in getting the room vacated from my Daughter-

in-law as the said occupation is illegal and is causing me great suffering and
·.,
.. inconvenience.

YOURS SINCERELY,

MRS. SUDHAARORA

Page3 of 3
 PAGE Ly\,j ~

To, '
. The SHO,

MOTINAGAR,

NEW DELHI

DATED: 18th NOVEMBER 2023

..
SUBJECT: COMPLAINT AGMNST ··RAJINDER MADAAN, MANISH
MADAAN, KAMLESR MADAAN; SHABNAM BATRA MADAAN,
SHANTI SWARUP MANCHANDA, ymENDER BATRA, 'VEENABATRA
BY MRS SUDHA ARORA AND -MS. NITASHA ARORA FOR THE
OFFENCES NAMED.
Respected Sir,

I, Mrs SudhaArora, aged53 years, ·w/o·~ ~Gulshan Arora, r/o, 16/16, Second
Floor, Moti Nagar, New Delhi-I l00-11~!& 1llly daughter, Ms Nitasha Arora, aged
28 years, d/o Mr Gulshan Arora, r/o~· J:6/16; Second Floor, Motl Nagar, New
Delhi-110015· have been criminally intimidated, and vvords/acts were done to
outrage our modesty under a Crimin~ Oonspiracy by an unlawful assembly of
the following persons who committed lurking house trespass after preparation to
hurt/assault us.

The persons involved in the unlawful assembly are:

ACCUSED N0.1

Mr. Rajinder Madaan, r/o, 3G-30, NIT~~, Faridabad, Haryana-121001. Having

Mobile number +9·1-9999897175. He is my son, Tushar's Father..in-law.
ACCUSED NO. 2
,-

\ .
PAGE '. Lf ~
Mrs, Kamle$h Madaan, r/o, 30-30, NIT-3, Faridabad, Haryana-121001. Having
Mobi]e number +91- 9999819272. She is my son Tushar's Mother-in:-law.

ACCUSED NO. 3

Mr Manish Madaan, r/o, 3G-30, NIT-3, Faridabad, Haryana'-121001 . Having

Mobile number +91-9999819575. He is my son Tushar's Brother-in-law.

ACCUSED NO. 4

Mrs. Sbabnam Batra Madaan, r/o, 30-30, NIT-3, Faridabad, Haryana-1_21()01.

Having Mobile number +91-9034341704. She is my son Tushar's Sister-in-law,

ACCUSED NO. 5

Mr Shanti Swarup Manchanda. Having Mobile number +91-9818510831. He

is my son Tushar's wife's Maternal wicle (Mama).

ACCUSED NO. 6

Mr·Virender Batra, resident of Sonipat, Haryana. Having Mobile number +91-

9416427907. He·is my son Tushar's Sister-in-law's Father.

ACCUSED NO. 7

Mrs Veena Batra, re~ident of Sonipat, Haryal}a, Having Mobile number +91-
9034197588. She is my son Tushar's Sister-in-law's Mother.

The brief facts of the case are as follows:

My son Tushar married Deepanshi Madan on 23rd April 2022. It was an arranged
. .
marriage. However, since the very inception of the marriage the couple were
having marital problems. My son Tushar and his wife Deepanshi lived with us at
our above mentioned residence since the beginning of their marriage. •

Deepanshi, my daughter-in-law left her matrimonial home after having a fight

I

th
with her husband Tushar on 30 May 2023.
 I

On 31 ·q May 2023 I along with my husband, Mr Gulshan Arora and my son,

Tushar went to Dipanshi 's parents' shop to resolve the maper at hand and· met
them in 'their shop. However, things escalated out of hand· and Accused No. 3,
Deepanshi 's Brother verbally abused me and my husband and physically
assaulted us and shoved us out of the premises of their shop.

My daughter-in-law Deepanshi has been staying at her pareAtal home ever since.
We ha~ been trying to sort out the matter and in the spirit'ofresolving the marital
problerns between my son Tushar and his wife Deepanshi both the families met
on 23"' September 2023 in a neutral place~ All the above mentioned Accused
pers"ns were present on the said date. Nonetheless, things did not go ma positive
direction rather all the Accused persons mentio~ed above ' threatened us
individually and collectively. My son Tushar was even threatened that he wiH be
• fired froin his job due to the connections of the said Accused persons.

The said meeting did not go as planned and hence all the parties concerned
returned to their homes. Deepanshi went with her parents and Tushar returned
with us to o~r home.'

On 5.1h November 2023 which was a Sunday all the Accused persons named above
entered our home along with Deepanshi. We were not given any information
rather the above f!lentioned Accused persons entered our home forcefully when
only me,' my daughter and my aged father were present at home alone.

First, Accused No. 5, Deepanshi's mama used very vile abusive language for me
and physically overpowered me at the front door of our house, so that the rest of
the persons could enter the hquse. When my daughter tried to stop the Accused t
persons from entering our house she was also physically assaulted and pushed
back by Accused No. I, Deepanshi 's Father, and Accused No. 3, Deepansh.i 's
Brother.

3/P a ge

I
 '
Then my daughter Nitasha was physically assaulted by the 2 me~ older than her
(Accused no. 1 ~d 3) and verbally abused by the 2 ladies (Accus~d No. 2 and 7)
accomp8:11ying them.

Upon entering the house, we were threatened with fake dowry allegations against
my son Tushar an<;i told that false Police Complaints against Tushar will be filed
_·ifwe do not comply with the whims and wishes ofD~epanshi and her family.
"
Accused No. 2, Deepanshi s Mother then threatened my entire family of being
1

embroiled in a false police case if we do not keep Deepanshi at her matrimonial

home.

During this tim~ my son Tushar had gone to the hospital to take care of my ailing
hospitalised mother and he had returned in the meanwhile. Upon seeing him, the
· Accused-Nos. 6 and 7 threatened all of us with legal cases as they allegedly belong
to the legal prof~ssion. It is pertinent to mention here that Accused. Nos. 6 and 7
~ the parents of Dipanshi's sister in law. They did not have any cause or right
to enter my home and threaten us in any manner and yet they criminally
intimidated us at behest of the other Accused persons.

Upon arrival Tushar had immedi~tely called the PCR. On arrival of the Police,
we fowid out that there were 2 calls logged out of our premises. Deepanshi had
made a call to the PCR stating that we had done domestic violence with her and
tried to kill ht:r, We have a CCTV camera at the very entrance of our house on the
ground floor and we will provide the footage showing that before 5th November
2023, Deepanshi was not residing at her matrimonial home. And that she entered
our house accompanied by 7 adult family members on the said day she made the
domestic violence call to the PCR The said call was made only to pressure us
and there is no truth whatsoever in the said complaint as was evident when the
Police arrived at our home and did not see any need to take our da~ohtP.r-in-lAw
Deepanshl for any medical check-up on accowit of Domestic violeni

II l
F

Now we ·are very scared due to the threats given to us by all the Accused pjlPSOns
• ~ollectively and individually, We have been assaulted in our own home, verbally
abused. and compelled to not react against the provocations made to us by the
said Accused persons.

ln view of the aforesaid facts and circumstances, your good self is humbly
requested to kindly take appropriate legal action against the above named the
Accused No.1 to 7 to register a FIR against them as we were criminally
intimidated, and words/acts were done.to outrage our modesty under a Criminal
Conspiracy by an unlawful assembly of the Accused persons who committed
lurking house trespass after preparation to hurt/assault us amon~t other relevant
provisions of law and any other offence deemed appropriate under the law of
the land.

Yours faithfully,

Ld-
Mrs Sudha Arora
w/o Mr Gulshan Arora,

rlo, 16116, Second Floor,

Moti Nagar,

New Delhi-11001 S

Mobile: +91-7838925542

AND

s I P ag e:

- -------- - - -- - '
rw--
1
' \ PAGE• . • Y9
D/o Mr Gulshan Arora,

r/o, 16/ 16, Second Floor,

Moti Nagar,

New Delhi-110015

Mobile : +91-9953533141

GI Page
,--

INDIA NON JUDICIAL

Government of Na,tional C~pital Te!_!'~tory ~!Del~i_

"
,, ••Stamp

~- Certificate No. IN-DL330819764&1430W

Certillcata Issued Date 26-Jan-2024 01:12 PM
Accounl Reference IMPACC (IV)/ dl1087803/ DELHI/ 0L·0LH
., Unique D0<:, Reference SUBIN•0LDL108780328565737919186W
Purchased by
·, Descrlpllon of DOC\lment
BHARAT SINGH
. • ·•
Article 35(1) Lease• Rant dead upto 1 yea,
~ Property Description 2ND FLOOR, 1616, KOTLA MUBARAKPUR, NEW 0ELHl-110003
~

Consideration Price (Rs.) 0

(Zero)
First Party •
BHARAT SINGH
Second Party
TUSHAR ARORA

•·'
'
-
e Stamp Duly P.aid By
Stamp Duty Amount(Rs.)
BHARAT SINGH
50
(Fifty only)

Pitas, write or type below this llne

! I
 I

RENT AGREEMENT

This Rent Agreement is made at Delhi on 25.01.2024, between:

BHARAT SINGH S/0 RAN. SINGH R/0 1615, KOTLA
MUBARAKPUR, NEW DELHt-11I~03, hereinafter called the Landlord
as a Fir.sl Party, •

AND

TtJSHAR ARORA S/O GtJLS

BLOCK NO, 16, SECOND .FLO
r . ARORA R/O HOUSE . NO. 16,
l\lOTI NAGAR, KARAMPURA, PO,
RAMESH NAGAR, WES:z' DEV , t J:>.E LHl-110015, the'-tenant of the
first party and here in after called as second party. •

Whereas the first party is the oW,Qer of the built up property, 21fD
FLOOR, 1615, KOTLA MUBARi\HPVR, NEW DELHI-110003, and has
agreed lo lel out the said property.,to the second party on the following
terms and conditions as under:-

I. That the Rent Amount will be:Rs. 7000/· per month payable in
every seventh day of eac,h month as rent to the Le~sor always in
advance on 1 Month or before the 101h day of each English
calendar month.

2. That this lease is srant~d·fpr a period of 11 Months commencin~

from 15.12.2023. :•

3. That after eleven months the' rent will be increase by Rs. 10% of
its previous rent.

4. That the s~cond party shall not have any objection for vacating
the said premises after 11 months.

5. That the second part)(';&hait pay ~lectricity, ma:intenance charges,

Water charges, any d~~~~ pf the property bear to tenant etc., in
addition to the rent. Howev~ house tax amount whatsoever shall
be pay.a ble by the first.party.'

6. 'f.hat the second party sbaJl use the said premises only for
accommodation all purposes and•the use should be in such a way
that there is no disturQanc;e·to the first party and other occupants
during the period of tenatrcy. In addition to this second party
shall not use the said premises for any activity which is illegal in
the eyes of law. •

:-:
' .
1
 - ----------- • - ---

'

8.• That the second party shall not sublet, assign' or part with the
possession of the said premises to anybody during the tenure of
the agreement.
9. That the second party has satisfied himself about the premises
which is being rented out is in good condition and shall keep the
• premises intact condition and shall deliver back in the same
condition.

·10. That in case of litigation over the tenanted premises the amount
to be spent in litigation ·J!>'roceeds by the first party shall be
adjusted from the security .amount. Further the first party can
also adjust the amount of any unpaid bills towards electricity
.. charges consumed by the second party from the security amount.

11. That the second party shal1 not make any changes alterations in
the said premises without written permission or the first party.
.. -
12. That second;. ,party shell· keep the said premises clean and
inhabitaple· an"d tena,,t able condition and no such work will be
done which may injure damage or prejudicially affect any part of
.the said premises. In case of·any damage the seoond party shaJJ
have to get it repaired at his own cost and exp~ses.
13. ·That the second p~ . shall be comply with all the
terms/regulations as.decided :~Y µte Soci_ety from time to time as.
per the laws applioab}~ lo: .the said society and its members.

14. That the first party shd-~'V'e the right to get the said property
vacated by the second p~t\f~ the second party's breach of any
of the above terms and c;:oticHtions without prejudice to his right
to realize all arrears of rent due. All outstanding payments
towards, electricity etc. shall ·'be recovered from the second party
due from him on the date of-such vacation.

In witnesesswhereof both the. ;J;>arties have signed this Agreement on

the day month and year first abev~ written.

WITNESESS:-

FIRST PARTY/LANDLORD
1. - - - - - - - - -

2. SECOND PARTY/TEN::iJ-

----- "',' ~)u

·, ATTESTED
~-- ~
~-" Notary Public

/,:
/ 25 JAN 2024
"/
 PAGE :_; -!_3
TO.

SHRI JITENDER,

SUB-DIVISIONAL MAGISTRATE,

ROOM NO. 202, OM OFFICE,

RAJA GARDEN, DELHI-I I0027

DATED:~¾ FEBRUARY 2024

SUBJECT: COMPLAINT REGARDING ILLEGAL OCCUPATION OF

BEDROOM IN MY SELF-OWNED HOUSE BY MY DAUGIITER-IN-LAW

ILLEGALLY

Respected Madam,

I, Mrs. Sudha Arora, aged 53 years, w/o Mr. Gulshan Arora, r/o, 16/1'6, Second

Floor, Moti Nagar, New Delhi-110015 have bought the above mentioned house

from my own self earned income. It is my primary residence. The sale deed for

the said residence is in my name and I have already paid in full through my hard

t:amed income for the title of the hoLI;Se.

My son Tushar entered into an arranged marriage with Deepanshi Madaan on 23n1

April 2022. After their marriage, the couple stayed with us, at my above
{ t

mentioned residence. However, soon the couple started having matrimonial

discord and owing to the said discord my Daughter-in-la , Deepanshi Maadan

ft[{ ,
!);i.·: ' . ·:n:h '1,amp
PIOI lr'II\'~ F1&ee.,
Page 1 of 3
Ftw '· .. ., "lr:w Deltll-27
;2.~ Io?, 'I ?-A-J

r
 ,.
PAGE:_:SL)

left her matrimonial home on 30th May 2023. While the families of both sides t
•
tried to resolve this dispute mutually, the couple could not reach any neutral

ground for settlement.

While the talks were going on between the families, Deepanshi, my Daughter-in-

law along with 8 family members came to my residence unannounced on 5th

November 2023 which happened to be a Sunday. Deepanshi and her relatives not

only entered my home unannounced and forcibly, they also physically assaulted

me and my unmarried daughter, who was present at home at the time. I have

lodged a Criminal Complaint against Deepanshi 's relatives for -the said assauJt

with Police Station Moti Nagar. A copy of the set criminal complaint is here with

attached as ANNEXURE 1.

My Daughter-in'-Iaw planned to stay at her matrimonial home with my son Tushar

.
henceforth. However, after the assault, in order to ensure the safety of myself, my

aged parents, my husband and my unmarried daughter, I aske_d my son to shift

out of my house along with his wife.

Thereafter, my son has shifted to a rented accommodation in South Delhi and he

had asked his wife Deepanshi to also shift along with him. However, my

Daughter-in-law has refused to vacate the bedroom allotted to th'e couple and she

is still occupying the said bedroom, while her husband stays in a rented

accommodation in South Delhi. A copy of the Rent Agreement executed by my

..
 -
I

son, Tushar for the residential premises in South Delhi is here with attached as

ANNEXURE2.

1 have repeatedly asked my son and his wife to vacate the said bedroom as there

are only 3 bedrooms in our house and currently there are 2 couples namely my

aged parents and me and my husband along with my young daughter who are

forced to stay and share 2 bedrooms.

Through this complaint, I request you to act against my Daughter-in-Jaw for not

vacating the bedroom while even her husband has left the residence and is staying

separately and away from his parents.

L
It is also to be noted that my Daughter-in-law does not come daily to my house

but has kept the room locked and is using the same for her own purposes. She

visits only once or twice in a week, and I have no infonnation where my

Daughter-in-law stays f?r the rest of the days. However, I cannot m~e use of the

bedroom in my own house due to the iHegal occupation of my Daughter-in-law.

I request you to kindly help me in getting the room vacated from my Daughter-

in-law as the said occupation is illegal and is causing me great suffering and

t inconvenience.

YOURS SrNCERELY,

MRS. SUDHAARORA

Page 3 of 3
p

IN THE COURT OF PS.!.IY.(!.P.P...'7:....I.l!..~.~f.,...E.~~!.'=~ ....0?..l!..~.::...~HA

.~~'!...??..~~J.~!~~ 11"Sl.5
'2..Alll CA.I U"-
Sult / Appeal No. ......H:J:·:1:..S................................................................................... JURISDICTION OF 201...~
In re:-
......T.Y.:~.l:t.~.~....l~.&Q.M....................................................................... ¥1ffH<pptt./Petltloner/Geffll'lalAaAl
VERSUS
....... ~.~f::~.~.':!.!.....t.1.~.~.~~~.....................................................'.........................9efdt./RespUAcc:uaec;I
KNOW ALL to whom these present shall come that 1/W&:........~ :~.lj_~/L...~.~BA ......................................
••··················································.......·······························....................····································........................
the above-named........ f..(;..1!.T.!.f?.~.S~ ...........................................................................do hereby appoint

J'Ait N ~, N C,11 SUPRIYA MANAN & ASSOCIATES ~AHvt-J~ttOr>-f

D/J=t&4/:J-otg E. No.: D/475/2007 Advocates D,, 0 J1 °/ )Nl,f
Chamber No. 215, Block-I, Delhi High Court, New Delhi-110003
Chamber No. 242-243, Patiala House Courts, New Delhi-110001
Mob. : 9810588874, E-mail: supriyamanan.law@9111ail.com
,---- - - - - - - - - - - ,
(Herein after celled the edvocate/s)to be my/our Advocate In the above-
To .act, appear end pleaded in the above noted case In this Court or , ;
the same may be tried or heard and also in the appellate court Including High , )icy Of' DEi.H i COURT FEE
IX.CT2 I "5e7C24'9l
separately for each court by me/us. 21-MAR-202A
To sign, file, verify end present pleadings, appeals cross-objection
review, revision, withdrawal, compromise or other pe\ltlons or affidavits or 11 11111111111
deemed necessary or proper for the prosecuUon of the said case In all Its
111111111
of fees for each stage.
To file end take back documents, to admit and /or deny the document
To withdraw or compromise the said case or submit to arbitration an) - ,, • ~~
may arise During Proceedings or in any manner relating to the said case. b ~ !!! • ":·
To take execution proceedings. .
The deposit, draw end receive money, cheques, cash and grant rece
acts and things which may be necessary to be done for the progress end in ti !hi ! 13 -
...,.
.. ,,. -

s
t
.._- v
Ii i _
;
; (
5,
of the said case. , ... r l - r; ~
To appoint and instruct any other Legal Practitioner authorizing him to # U ; ~;; - , ~ ~ ?• :•
authority hereby conferred upon the Advocate whenever he may think fit to do i - >- ~ ; ~ ti
attorney on our behalf. ~ ,.. ':> C"'4
AND I/WE the undersigned do hereby agree to ratify and confirm all a, •0 _;;; :: • ;. ~
his substitute In the In the matter as my/our own acts, as If done by me /us to e O s ~
AND I/WE undertake that !Nie or my/our duly authorized agent W< _ _ ,.,. 111 '"'our .:r ~
hearings and will Inform the Advocate for appearance when the case is celled. ~ / /
AND I /WE undersigned do hereby agree not to hold the advocate of his substitute responsib1~ 1or
the result of the said case. The adjoumment costs whenever ordered by the court shall be of the Advocate
which he shall receive and retain for himself.
AND I/WE the undersigned do hereby agree that In the event of the whole or part of the fee agreed
by me/us to be paid to the advocate remaining unpaid he shall be entitled to withdraw from the prosecution
of the said case unUI the same is paid up. The fee settled is only for the above case end above Court.
I/We hereby agree that once the fees Is paid, I/Ille wlll not be entitled for the refund of the same In any case
whatsoever and If the case prolongs for more that 3 years the original fee shall be paid again by me/us.
IN WITNESS WHERE OF I/We do here unto my/our hand to these presents the contents of which
have been understood by me/us this ~
6f M~Y 20 2-1.f - - ~ - - - - - - - - - - - - - --=- ~ !---
bJect to the terms of the fees.
:fo.-\1"

I ,~ p~ CLIENTS
OJ,\ ATE