Litigation exp - contd.

Guest (Querist) 16 March 2012 This query is : Resolved
Thanku fr ur eesponses from http://www.lawyersclubindia.com/experts/Litigation-exp-287721.asp.
My lawyers is my cousin only. :). He is a fresher. He has given me this modified draft and we would request to you to let us know if this draft isfine.
Because cousin says none of his lawyer friends applied for litigation but only maintennce. So myself and cousin sit toegether yesterday and prepared this with no guidance from anyone. :(

Petition under section 24 of the Hindu Marriage Act, 1955
1. The petitioner states that she is the petitioner herein and she is the respondent in HMOP No. --- of 2011 and she is the petitioner in OP No. --- of 2011

2. The petitioner states that her husband filed a petition for divorce under section 12(i)(c) of Hindu Marriage Act, 1955 before the court of Hon’ble Sub-Judge at Poonthamalli and the HMOP No. is --- of 2011

3. The petitioner submits that since the respondent had filed for divorce even before one year of completion of marriage she had to content the case to her matrimonial life and to recover her lost family status she applied for restitution of conjugal rights under section 9 of Hindu Marriage Act, 1955 before the Hon’ble Judge at I-Additional Family Court, Chennai and the OP No. is ---

4. The petitioner further submits that she had paid Rs.60000/- as lawyer fees for case proceedings, consulting fees and for Transfer OP for the HMOP No. --- to represent on my behalf and to put forth my contestations.

5. The petitioner further submits that she had paid Rs.60000/- as lawyer fees for case proceedings, consulting fees OP No. is --- to represent on my behalf and to put forth my contestations.

6. The petitioner further submits that she had spent the following amount for travel expenses incurred during the Court Hearings for both the cases

Date Court Taxi Travel Expense (Rs.)
23/12/2011 Poonthamalli Rs. 1500
7/01/2012 I-Additional Family Court Rs.1000
18/01/2012 I-Additional Family Court Rs.1000

7. The petitioner further submits that she had spent the following amount for travel expenses incurred during the Court Hearings for both the cases

8. The petitioner further states that the respondent was earning Rs.35000 during 2011 and he is earning around Rs.50000 as he is employed as ----

9. The petitioner further states that the respondent is earning a rental income for the from his following ancestral properties

Ancestral Home Address Type Rental Income/per month
Address 2 BHK Flat 15000
-------- 2 BHK Flat 15000
------- 2 BHK Flat 15000
--------- 2 BHK Flat 15000

10. The petitioner further states that the respondent is owning a house at ------

11. The petitioner submits that direct the respondent to pay the following litigation expenses which is cost effective to spend to get back her matrimonial life and to proceed a peaceful family life and a good social condition.

Litigation Expenses Amount (Rs.)
Total Travel Expenses till 18/1/2012 Rs.4500
Lawyer Fees for case proceedings, Consulting Fees, Transfer OP --- Rs.60000
Lawyer Fees for case proceedings, Consulting Fees OP No. is --- Rs.60000
Total Litigation Expenses till 18/1/2012 Rs.124500

12. The petitioner therefore prays that this Hon’ble Court may be please to pass a decree and judgement to the respondent to pay the litigation expenses of Rs.1,24,500/- spent so far for the court proceedings expenses and further on monthly during the proceedings and thus render justice

List of Documents filed under Order VII Tule 14(2) of C.P.C
S.No Date Description of Documents
1 23/12/2011 Taxi Travel Xerox
2 7/01/2012 Taxi Travel Xerox
3 18/01/2012 Taxi Travel Xerox
4 Respondent’s Salary Slip for the month of --- of 2011 Xerox
5 Poonthamalli Lawyer Fees Xerox
6 I-Additional Family Court Lawyer Fees Xerox

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