IN THE COURT OF PRINCIPAL JUDGE, FAMILY COURT, [JURISDICTION]
CRIMINAL COMPLAINT NO. ________ OF _______

IN THE MATTER OF:

1. Smt. [Name], W/o [Respondent’s Name], R/o [Address]
2. Master [Name], S/o [Respondent’s Name], R/o [Address]
   Through his mother and natural guardian, Smt. [Name]

…COMPLAINANTS

VERSUS

[Respondent’s Name], S/o [Respondent’s Father’s Name], R/o [Address]

…RESPONDENT/ACCUSED

APPLICATION UNDER SECTION 125 OF THE CODE OF CRIMINAL PROCEDURE, 1973

The Complainants above named respectfully submit as under:

1. Relationship of the Parties
   That Complainant No. 1 is the legally wedded wife of the Respondent, while Complainant No. 2 is the legitimate son of the Respondent. Both Complainants reside within the jurisdiction of this Hon’ble Court.

2. Marriage and Progeny
   That Complainant No. 1 was married to the Respondent according to Hindu rites and ceremonies on [Date] at [Place]. Complainant No. 2 was born out of their lawful wedlock on [Date] and is presently residing with Complainant No. 1.

3. Cohabitation and Matrimonial Residence
   That after their marriage, Complainant No. 1 and the Respondent cohabited at [Location] for [Duration] years. For the last two years preceding this application, they were residing at [Address], within the jurisdiction of this Hon’ble Court.

4. Disruption of Matrimonial Life
   That during the period [Month-Year], the Respondent indulged in an extramarital affair with [Name/Details]. Despite Complainant No. 1’s efforts to reconcile and dissuade the Respondent from such behavior, he continued the illicit relationship. This led to cruel treatment and mental agony for Complainant No. 1. On [Date], the Respondent compelled Complainant No. 1 to leave the matrimonial home with Complainant No. 2. Since then, both are residing at the home of Complainant No. 1’s parents.

5. Desertion and Refusal to Maintain
   That despite several attempts by Complainant No. 1 to rejoin the Respondent in the matrimonial home, he has refused and continues to refuse to accept the Complainants. The Respondent has also indicated his intention to marry another woman, which is contrary to law.

6. Neglect in Maintenance
   That the Respondent has willfully neglected and refused to maintain the Complainants despite their lawful entitlement. The Respondent has also refused to return the articles belonging to Complainant No. 1, including her Stridhan and dowry items, which remain in his possession.

7. Respondent’s Means and Financial Capacity
   That the Respondent is employed as a [Designation] with [Employer/Organization] and earns a monthly salary of approximately ₹[Amount]. He has no significant financial liabilities apart from his legal obligation to maintain the Complainants.

8. Complainant’s Lack of Income
   That Complainant No. 1 has no independent source of income and is entirely dependent on her father for financial support.

9. Expenditure for Minor Child
   That Complainant No. 2, a minor child, is studying at [School Name], and his monthly expenses for education, clothing, and other essentials amount to approximately ₹[Amount]. Additionally, a maidservant has been employed to care for him, incurring an expense of ₹[Amount] per month.

10. Jurisdiction
    That the Complainants are residing within the jurisdiction of this Hon’ble Court, making it competent to entertain and adjudicate this application under Section 125 Cr.P.C.

PRAYER

In view of the facts and circumstances mentioned above, it is most respectfully prayed that this Hon’ble Court be pleased to:

a) Direct the Respondent to pay a monthly allowance of ₹[Amount] for the maintenance of Complainant No. 1 and ₹[Amount] for the maintenance of Complainant No. 2;
b) Award the costs of these proceedings to the Complainants; and
c) Pass such other orders as this Hon’ble Court may deem fit and proper in the interest of justice.

COMPLAINANTS THROUGH
[Advocate’s Name]
[Address of Advocate]

Place: [City]
Date: [Date]

Verification
I, Smt. [Name], the Complainant No. 1 above-named, do hereby solemnly affirm and verify that the contents of paragraphs [1-10] of the above application are true to my knowledge and belief, and no part of it is false, and nothing material has been concealed therefrom.

Verified at [City] on this [Day] day of [Month, Year].

COMPLAINANT NO. 1
[Signature]

List of Witnesses
[List names and details of witnesses, if any, to be relied upon in the case.]

ANNEXURES
[List of documents attached, including affidavits, evidence, and other supporting materials.]