DRAFTING OF CRIMINAL COMPLAINT U/s 498-A OF THE INDIAN PENAL CODE by Mahek Upadhayay@LexCliq

CRIMINAL COMPLAINT U/s 498-A OF THE INDIAN PENAL CODE 

IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS, (COURT NO. 2) GURUGRAM

Criminal Complaint No. 245/2021

Mrs. PINKY (COMPLAINANT)
(House NO. 32, Aarya Residency,
Gurugram)

V/s

1. Mr. RINKU
2. Mr. OMPRAKASH
3. Mrs. KAVITA DEVI
4. Ms. MEENAKSHI

COMPLAIN U/s 498-A OF INDIAN PENAL CODE

The complainant above named submits this complaint, praying to state as follows:

  1.  That the complainant has been married to accused no. 1 on 03rd May, 2005, and is residing with
    him at above mentioned address, along with his family, namely, his father (accused no. 2), his
    mother (accused no. 3) and his sister (accused no. 4).
  2. That the accused no. 2 is a regular drinker and does not anything to earn livelihood. These facts
    were hidden from the complainant and his family at the time of marriage.
  3.  That the family of accused no. 1 was disappointed with the dowry given by complainant’s
    family in her marriage and due to this they often beats her up.
  4. That on 7/11/2006, the accused no.1 and his family members demanded Rs. 2,00,000/- from the
    complainant by stating “hume kuch nahi dia tere gharwalo ne, logo ko kitna kuch milta hai,
    apne maa baap se 2, 00,000/- leke aa, agar yaha rehna hai to (WE’VE GOT NOTHING FROM
    YOUR PARENTS, PEOPLE GIVE A LOT OF DOWRY TO THEIR IN LAWS, GO AND GET
    Rs. 2,00,000/- FROM YOUR PARENTS)” and on complainant’s refusal they brutally beaten
    her and confined her in a cupboard.
  5. That the complainant was bearing, from past 16 years, all these cruelties by accused no. 1 along
    with other coaccused with a hope that one day he and his family will change their behavior
    towards the complainant and will lead a happy married life ahead.
  6.  That on 19/04/2021, the complainant was brutally beaten up by accused no. 1, after a heated
    argument between the two on some household matter.
  7.  That the quarrel was huge so that the complainant, to save herself, come out of the house and
    someone in the neighbourhood called the police.
  8.  That the accused no.1 and other coaccused fled away from their house, before police arrived.
  9. That the police took the complainant to the nearest hospital where medical reports that the
    Patient has been brutally beaten up, left hand has been fractured and has blackness over the left
    eye.
  10.  That the accused along with other named coaccused, thus, committed an offence u/s 498-A &
    325 of the Indian Penal Code within the local limits of the jurisdiction of this court, and hence,
    this Hon’ble Court has right and jurisdiction to try this complaint and punish the accused
  11. That the complainant also made a complaint-application to the Sagar Chawk Station, with a
    request to give her necessary help and protection.
  12. That the cause of action for this complaint has been observed on various occasions, since the
    solemnization of marriage dated 3rd May, 2005 and more recent, on 19/04/2021 and hence, this
    complaint filed today is well within limitation.
  13.  That the offence has been committed within the local limits of the jurisdiction of this Court, and
    hence, this Hon’ble Court has jurisdiction to try and decide this complaint.
  14. That the necessary court-fee is paid herewith.
  15. That the complainant, therefore, prays that the accused be charged with and tried for the offence
    punishable u/s 498-A & 325 of the Indian Penal Code and punished according to law.

Place: Gurugram

Date: 22nd July, 2021

________________
Complainant
(Signature)

________________
Advocate for Complainant
(Signature)

VERIFICATION

I, PINKY, the present complainant, do hereby state on solemn affirmation that the contents of this complaint in are true and Correct to the best of my knowledge and belief, and so I have signed hereunder.

_________________
(COMPLAINANT

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