COMPLAINT DRAFT BY NAVNEE GULATI @LEXCLIQ

ADVOCATE ANUPAM KUMARM MISHRA

JANAKPURI, NEW DELHI

Mob- *********

             email id: lexcliq@gmail.com

REFERENCE NO. 121212                                                                                                                        Date- 15/05/2021

REGISTERED A.D.

To,

SHO

P.S Hauz Khas

New Delhi

 

SUBJECT- COMPLAINT AGAINST KIRANPREET KAUR, W/O TANVIR SINGH R/O H-NO.- L-1/11, SOUTH EXTENSION PART- II, ANDREWSGANJ, SOUTH DELHI–110049, PRESENTLY RESIDING AT D-603, SUPERTECH CITY, SEC-137, NOIDA, Uttar Pradesh-201305, FOR ABUSING, HARASSING, TORTURING, MENTALLY, PHYSICALLY AND EMOTIONALLY WITH THE ULTERIOR MOTIVE TO KICK OUT MY PARENTS OUT OF THEIR OWN HOUSE.

Sir,

With due respect, I on behalf of Tanvir Singh, S/o Indervir Singh, residing at H-NO.-L-1/11, South Extension Part- II, Andrewsganj, South Delhi- 110049, and presently residing at D-603,   City, Sec-137, Noida, Uttar Pradesh-201305  wants to lodge a complaint against the aforesaid person for physical, mental, emotional harassment and torture with the ulterior motive to kick out my parents out of their own house. My clients’s parents are senior citizens and are suffering from several old age diseases and presently residing at the address mentioned above.

The brief facts of my complaint are that on 31/05/2020, my client and Kiranpreet Kaur got married at Gurudwara Singh Sabha, Geeta Colony, in a very simple manner. The marriage was affixed through a matrimonial website namely, Shaadi.com. My client and Kiranpreet Kaur got married during the lockdown and as per the Delhi Government guidelines on marriages during lockdown, there was a restriction of only 25 persons from each side to attend the ceremony. Due to the government restrictions only 25 persons including me and Kiranpreet Kaur attended the marriage ceremony. The expenses incurred in our marriage was even less than Rs. 20,000/- as there was a lockdown. As the jewelry shops were not opened during the lockdown, my mother had given her own jewelry and stridhan out of love and affection as she is the only daughter-in-law.

After few days of our marriage Kiranpreet Kaur started fighting on petty issues on one pretext or the other. Kiranpreet Kaur used to abuse my client’s father, mother and my relatives now and then in front of friends and families which have become highly embarrassing for my client being husband of Kiranpreet Kaur. My client’s wife Kiranpreet Kaur used to argue with him in respect of my father’s property on the instigation of her mother. Her mother used to taunt and abuse me in front of friends and families to such an extent that it has become difficult for me to live with her. Kiranpreet Kaur asks my client and my father to transfer the properties of my father in her name otherwise, she will implicate me and my family members in the false case.

The environment of my client’s father’s house is disturbed to such an extent that he was unable to sleep at nights due to the pain, tension and trauma given by Kiranpreet Kaur. She has a habit of consuming alcohol on a regular basis in early evening and creates scene by abusing my client and his members. Whenever someone tries to stop her she reacts by abusing, shouting, breaking glass, throwing bottles on the floor, banging of doors despite knowing this fact very well that drinking is not permitted in our house.

On 04.03.2021 Kiranpreet Kaur at about 11.00 P.M started creating a scene in my client’s parent’s house by breaking glass, screaming, abusing, and even slapped me. She even threatened to take her own life and leaving a note behind with the ulterior motive to implicate my client and his family. My client’s parents called the PCR several times but to no effect.

Earlier my client was residing in the house of his parents but in order to save his matrimonial life he shifted to a rented accommodation at Noida U.P along with his wife, then also she used to visit his parents house and used to abuse, threaten them and create a scene on day to day basis.

My client’s parents and relatives have asked him and his wife not to come to their house but to no effect.

My Client’s family members are spending every moment of their life under stress and utter humiliation due to the nuisance created by Kiranpreet Kaur and her mother. The education of my client’s sister is being adversely affected and the social image of my client family is being tarnished due to acts of Kiranpreet Kaur. Kiranpreet Kaur in active connivance with her mother may harm herself or my  client’s family members and will be solely responsible. my client have an apprehension that Kiranpreet Kaur and her mother may go up to any extent in order to harass me and my family members.

My Client is having every apprehension that Kiranpreet Kaur and her mother may implicate him and his family members in a false and frivolous criminal case by using their influence because they are very influential person.

I, on behalf of my client therefore, earnest and sincerely request you to kindly register my complaint and take strict legal actions under appropriate provisions of law.

Thanking You.

Yours Sincerely,

 

Advocate Anupam Kumar Mishra

  1. No- **********

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