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Ankita Dey - Mat Suit - Plaint
Ankita Dey - Mat Suit - Plaint
700048
…Plaintiff
-VS-
Kolkata - 700043
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…Defendant
1. That both the parties to the suit Hindu by Religion and presently
Ld. Court.
2. That both the parties to the suit were studying in the same college
while they are pursuing their B. Tech. Degree and while they were
studying in the same college they have affection with each other
into the relationship of husband and wife they have applied for
parties to the suit bearing Certificate no. 146 of 2012 by the said
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3. That as at the time of registration of the marriage the parents of
both the parties were not in support of the marriage, the parents of
daughter in law and to take her to the house of the plaintiff and
they were not even ready to recognize the said marriage between
the parties to the suit in front of the society, but as the parents of
the defendant are very greedy in nature they accepted the plaintiff
and got ready for the social marriage between the parties to the
alternative but to save their prestige before the society they have to
accept the terms of the Defendant’s parents and gave the dowry
without any protest and on the said illegal work the Defendant at
that time has not said a single word as he was unemployed at that
5. That after the said marriage the Boubhaat Ceremony was arranged
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Road, P.O. Nona Chandanpukur, Barrackpore, P.S. Titagarh,
Ld. Court.
6. That after the marriage the plaintiff also requested her husband to
defendant has also turned her ear about the desire of the plaintiff
7. That soon after the marriage the plaintiff had to hear various
much lower dowry they got from her father’s house. And she often
her in laws the plaintiff has got a huge mental agony from the first
with him and started living therein and during these days
throughout the day the plaintiff used live along in the rented house
plaintiff has got pregnant and soon after she got pregnant the
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Defendant has taken the plaintiff straight to her fathers house as
9. That the plaintiff from the month of September, 2013 stayed in her
and his parents have not taken any news from the plaintiff which
was also a reason of mental stress for the plaintiff at that period of
Talpukur, Kolkata – 123, which far from the paternal house of the
plaintiff and despite of not having of the plaintiff and her parents
plaintiff in the said nursing home and the plaintiff was operated in
the said nursing home at the cost of the father of the plaintiff and
the said receipts are lying with the custody of the Defendant as he
10. That on 08.06.2014 a female child was born out of the wedlock of
the parties to the suit, whose name is SHRIYA MANDAL, and all
the expenses of the delivery of the said female child and medical
days of the birth of the said female child the plaintiff had to do all
the household works and for that reason the plaintiff’s health
condition was getting deteriorated day by day and for that reason
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the plaintiff with her baby had to went to her paternal house for
29.10.2014.
January, 15, 2014 and after the plaintiff went back to her
they have bitterness on the plaintiff since from the first she came
stressful work the plaintiff stich in her belly has got swollen and
her father to give her some money for the purpose of medication
and she has done the medication completely out of the expenses
she got from her father and as she was living in her matrimonial
house all the papers and documents is left there due to which the
12. That as the all the expenses of the plaintiff and her daughter was
to arrange for some money every month for their future and by
hearing the same the defendant has got brutal to the plaintiff and
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when the plaintiff have requested her in-laws to make their son
understand about the situation they have also stated the plaintiff
that if they maintain their granddaughter she can not live with her
and they will take the daughter of the plaintiff with them in their
his parents has brought more insecurity to the plaintiff and she
plaintiff due to her demand of financial backup for her and their
child and the said physical tortures were used to be done in front
13. That subsequently the defendant and in laws of the plaintiff have
the plaintiff for her separately wherein the plaintiff used to live
alone with her daughter, and even the defendant refused to live
with her in the said room and by this conduct plaintiff got a deep
mental trauma and/or agony for which she was unable to find any
family, and these days the plaintiff had to live at the mercy of the
14. That continuing with the above mentioned physical and mental
torture from June, 2016 when the plaintiff has started finding a
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job for her which was desperately needed for herself and her child,
mental and physical torture upon the plaintiff and may a times the
plaintiff from her, and when she protest such kind of conduct, she
the defendant and her father in law. And for such conduct the
Government Railway Police all the time she got threat from them
and for the purpose of security of herself and her daughter the
defendant.
15. That subsequently the defendant has to went for the training
purpose in many states, and during those days the plaintiff has to
enter into the room of the plaintiff when she used to feed her
request him to go out of the room he did not hear the same and
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detreatment upon her the plaintiff had to suffer from ulcer on
those days.
16. That in the first quarter of 2017 the defendant got the first posting
the plaintiff to take them with him, has not turned his ear to the
daughter and the defendant also refused to send a single penny for
his family.
17. That in the Month of May, 2017, plaintiff despite several atrocities
to her husband and in laws, started doing a job for the survival of
18. That on first day of July, 2017, the in laws of the plaintiff refused
to let her enter into her matrimonial house and on several request
the father in law of the plaintiff forcefully taken her to her paternal
house and clearly said to the father of the plaintiff that we will
never take back your daughter to our house unless and until she
leave the job and after some days as the daughter of the plaintiff
was not able to live without her mother after some days the
and said to the plaintiff and the father of the plaintiff that, unless
and until and plaintiff leave her job he will not let the plaintiff in
their house and by saying that the defendant and his parents has
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19. That the plaintiff has also admitted her daughter in the month of
Calcutta Public School along with the money receipts are filed
20. That on such threat of the defendant and his parents and mother
of the plaintiff several times requested her to leave the job for the
the request of her mother, she has shown her inability to permit
their prestige in the society and the father of the plaintiff has to
21. That from April, 2018 the plaintiff has managed to take an
apartment on rent for herself and her daughter at C/O Milan Roy,
Kol – 700048, and she has to maintain herself and her daughter
Xerox copy of the House rent and internet bill is filed herewith as
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22. That during this period the daughter of the plaintiff has undergone
with an accident due to which her leg has got burnt and for that
the plaintiff have called the defendant to come and visit her
daughter but the defendant has never taken care of the plaintiff
and her daughter and for all the medication for herself and her
and her daughter Shriya Mandal are filed herewith as Annexure ‘F’
23. That in the month of August, 2019, as the plaintiff has become
due to her need. But the defendant has stuck to his point to take
the custody of her daughter and at that time due to better future of
her child she gave her daughter in the custody of the defendant.
24. That thereafter they mutually decided to file a petition for divorce
and as per the conversation the defendant have sent a draft copy
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25. That thereafter during the lockdown period the plaintiff has lost
her job and doing some part time job still now and somehow
Reach, Kolkata – 700043 and his grade pay is ₹4600 per month
Government Railway Police and thus the defendant does not have
to maintain their parents also. And on the other hand the plaintiff
that your hounor may pleased to direct the defendant to secure the
petition praying for mutual divorce and also denied to accept the
27. Thus having no other alternative the plaintiff have filed the instant
28. That the cause of action arose on 14.08.2012 when the marriage
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defendant has completely deserted the plaintiff from her
refused to sign on the petition praying for mutual divorce and also
the suit was solemnized at the paternal house of the plaintiff i.e.,
suit.
30. That for the determination of pecuniary jurisdiction and court the
suit is valued at ₹100 and for that proper court has been filed
herewith.
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(b) A Decree of permanent alimony and
(d) Cost;
Verification
Affidavit
I, ANKITA DEY D/O Balaram Dey aged about 31 years, by faith Hindu,
by Occupation part time job, presently residing at C/O Milan Roy, 505,
Swamiji Sarani, P.S. Laketown, District North 24 Parganas, Kol –
700048, do hereby solemnly affirm as follows:-
1. That I am the sole plaintiff of the instant suit and well conversant of
the facts of this case. …this is true to best of my Knowledge.
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2. That the statements made in the above paras are true to best of my
Knowledge and belief and sign this affirdavit in the Barasat Court
premises on
Deponent,
Identified by me
Advocate
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