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Memorandum for payment of maintenance and arrears amount




.. Petitioner
1) ,
2) ,

.. Respondents

Memorandum for payment of maintenance and arrears amount.


That the petitioner have filed this case DVC No. ___ against respondent 1 & 2 that is pending for hearing today.

2. That the Hon’ble court has ordered an interim maintenance amount of RS ___ to be paid towards minor son Master Neeraj vide order dated 18th January 2018 on or before 5th of every month.

3. That the respondent has repeatedly requested petitioner to provide account details so that maintenance amount can be paid. Respondent has requested petitioner on various dates 09-09-217, 14-10-2017, 11-11-2017, 09-12-2017, 19-01-2018, 10- 02-2018, 10-03-2018, 14-04-2018, 15-04-2018, 30-04-2018, 18-05-2018, 09-06- 2018. However petitioner was adamant in not sharing the same.

4. Finally respondent has sent a mail communication to the petitioner on her email ID at ____ dated 11-16-2018 seeking the account details so that maintenance amount can be paid. However petitioner did not give any value to the mail communication as well.

5. However finally left with no choice respondent approached the Hon’ble court vide memo dated 27-06-2018 seeking for account details so that maintenance amount can be paid. The petitioner however filed a memo regarding noncompliance of the interim maintenance order dated 18th January 2018.

6. The Hon’ble court directed the petitioner to open and share account details of Master Neetant to respondent on next date of hearing and she acted on the same and provided the details on 27-07-2018.

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7. After receiving the account details the respondent is regularly transferring the amount and well as part of arrears to the account as per respondents capability. To date petitioner has transferred amount as mentioned below.

Total amount paid till date:
Amount paid in August 2018:
Amount paid in September 2018:
Amount paid in October 2018:
Extra amount paid apart from maintenance in the said period:

8. Though the petitioner is well qualified well maintained earning lady with a huge bank balance and while respondent is transferring amount more than his assigned maintenance in order to clear the arrears the petitioner is praying before this Hon’ble court for clearance of arrears. The petitioner is praying before the Hon’ble court for the presence of respondent and is not also proceeding further with case and creating unnecessary delay to add to business value to the case and trying to create a financial crisis on the respondent and also harass the already distressed and exhausted respondents by her heritable cruel nature to fulfill her ulterior motives of adding harassment towards respondent where respondent has already filed HINDU MARRIAGE PETITION NO. ___ of 2016 for divorce U/s. Section 13(1) (ia) (ib) & (iii) of the Hindu Marriage Act, 1955 against the petitioner and sought a decree of divorce on the ground of cruelty by the wife against the husband.

9. The respondent while appearing to court on every date of no or less business value expels about 4000 Rs that he could manage towards payment of arears.

Date: Counsel for Respondents

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I. A. No. ____ of 2018
D.V.C. No. ___

.. Petitioner
1) ,
2) .. Respondents

Memorandum for payment of maintenance and arrears amount

Filed on: ___.11.2018
Filed by:


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