IN THE COURT OF (as per jurisdiction)
Complaint Case No. ____ of 2025

IN THE MATTER OF:
XXX                                                                                       …COMPLAINANT
VERSUS
YYY                                                                                      …RESPONDENTS

                                     MEMO OF PARTIES

COMPLAINANT NAME : ______________________________________
Aged about ______ years
W/O : ______________________________________
R/O : ______________________________________
Mob. : ______________________
Police Station : _____________________________                                          …COMPLAINANT

VERSUS

RESPONDENT NAME : ______________________________________
Aged about ______ years
S/O : ______________________________________
R/O : ______________________________________
Mob. : ______________________
Police Station : _____________________________                                       …RESPONDENT

DATED: ____________            PLACE: ____________
THROUGH COUNSELS: __________________________________________

IN THE COURT OF (as per jurisdiction)
Complaint Case No. ____ of 2025

IN THE MATTER OF:
XXX                                                                                       …COMPLAINANT
VERSUS
YYY                                                                                      …RESPONDENTS

APPLICATION UNDER SECTION 12, 18, 19, 20, 21, 22 AND 23 OF THE PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

MOST RESPECTFULLY SHOWETH:

1. That the Complainant is a Hindu woman by birth who follows Hindu Vedic Dharma and rituals, a law-abiding citizen and a permanent resident of India.

2. That Respondent No.1 is the husband of the Complainant, also Hindu by birth, and a permanent resident at the aforesaid address.

3. That the marriage between the Complainant and Respondent No.1 was solemnized on [DATE OF MARRIAGE] at [PLACE OF MARRIAGE].
   A copy of the marriage photograph is annexed herewith as ANNEXURE P-1.

4. That out of the said wedlock, [number] child/children was/were born.

5. That Respondent No.1 is working as [designation/occupation] and the Complainant is a homemaker.

WRITE CONTENTS OF THE CASE (STORY OF THE COMPLAINANT)
6. That the persistent cruelty, humiliation and ill-treatment have deeply affected the mental and emotional well-being of the Complainant and her minor child/children. The actions of the Respondents amount to domestic violence and mental cruelty under law.

7. That the instances of cruelty are numerous. The Complainant craves leave to refer to and rely upon additional instances as may be required.

8. That due to the aforesaid cruelty and harassment, the future prospects of the Complainant have been adversely affected. She is entitled to adequate compensation for the severe pain and suffering caused.

9. That this Hon’ble Court has jurisdiction to entertain the complaint as the Complainant and the Respondents reside within the jurisdiction of this Hon’ble Court.

LIST OF ANNEXURES (illustrative):
P-1: Marriage photograph/certificate
P-2: Medical records/injury reports
P-3: Complaint/FIR/DD Entries (if any)
P-4: Communication records (messages/emails)
P-5: Expense proofs (rent, education, medical)

It is most respectfully prayed that this Hon’ble Court may be pleased to:

1. Protection Order (Section 18): Prohibit the Respondents from committing any act of domestic violence, aiding or abetting the same, entering the place of the Complainant or any place frequently visited by her, and from communicating with the Complainant in any manner including personal, written, electronic, or telephonic contact.

2. Residence Order (Section 19): Pass appropriate residence orders in favor of the Complainant, including alternate accommodation or restraining the Respondent from dispossessing or disturbing her possession.

3. Monetary Relief (Section 20): Direct the Respondent to pay Rs. [amount in figures/words] towards the trauma, medical expenses, loss of earnings and maintenance of the Complainant and [amount] towards the child/children as applicable.

4. Custody Order (Section 21): Grant interim/permanent custody of the [CHILD/CHILDREN] to the Complainant, with appropriate visitation (if any) in the best interest of the child.

5. Compensation (Section 22): Award compensation/damages for injuries including mental torture and emotional distress suffered by the Complainant.

6. Interim/Ex-parte Orders (Section 23): Considering the chain of events and immediate threat to life, limb, and dignity, grant interim/ex-parte reliefs as prayed above.

Any other reliefs that this Hon’ble Court deems fit and proper in the facts and circumstances of the case may also be granted in the interest of justice.

                                                                                                  …COMPLAINANT
PLACE: ____________     DATED: ____________
THROUGH COUNSELS: __________________________________________

Verified at [PLACE] on this [day] of [month], 2025 that the contents of paragraphs 1 to [__] are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

PLACE: ____________            DATED: ____________
                                                                                                  …COMPLAINANT
THROUGH COUNSELS: __________________________________________

IN THE COURT OF (as per jurisdiction)
Complaint Case No. ____ of 2025

IN THE MATTER OF:
XXX                                                                                       …COMPLAINANT
VERSUS
YYY                                                                                      …RESPONDENTS

                                                   AFFIDAVIT

I, [COMPLAINANT NAME], W/O [RESPONDENT NAME], R/O [full address],
do hereby solemnly affirm and declare as under:

1. That I am the Complainant in the present case and am well conversant with the facts and circumstances of the case; I am competent to swear this affidavit.

2. That the accompanying petition has been drafted by my counsel under my instructions. I have read and understood the same. The petition may be read as part and parcel of this affidavit; its contents are not reproduced herein for brevity.

3. That the contents of the accompanying petition are true and correct to the best of my knowledge and belief.

                                                                                                      DEPONENT

VERIFICATION:
Verified at [PLACE] on this [day] of [month], 2025 that the contents of the above affidavit are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

                                                                                                      DEPONENT