SAMPLE COMPLAINT DRAFT U/S 323, 324 OF IPC BY KODALI NEEHARIKA@LEXCLIQ

IN THE COURT OF JUDICIAL MAGISTRATE FIRST CLASS, DEHRADUN

   CRIMINAL COMPLAINT CASE NO ——- OF 2021

 

 

Mr. Ashish, age 35

S/o Mr. Rahul

R/o No: 23, Indira vihar , Dehradun.………………………………………. Complainant

Versus

1. Mr. Ravi Prakash, age 38

S/o Mr.Guru Prasath

R/0 No: 53 Rich street, prem Nagar, Dehradun.

 

2. Mrs. Malti Devi,age 35

D/o Guru prasath

R/o No: 53 Rickstreet , Dehradun………………………………………… Accused

 

Police Station: Indira Vihar, Dehradun

 

 

Complaint under Section 323,324,325 and 326 of Indian Penal Code

 

 

The complainant above named most respectfully submits as under:

 

1.The complaint was a reputed person residing at Indira vihar street in Dehradun. He is working in the software company which is situated at the NH road in Dehradun. The accused persons were residing at Rich street in Dehradun. They both areworking in the TATA showroom situated at prem Nagar.

 

2. The complaint on 23.03.2021 while returning from his office,around 6.00 pm when he approached to the FRI (Forest Research Institute) which is near to his home, he was stopped by accused person by the car. The accused persons mentioned above came by the car bearing No. UK 10X 1234 registered in Dehradun. Both the accused carried the weapons with them and assaulted the complainant by saying that they are going to teach the lesson for filing a civil suit in Dehradun court.

 

 

3. The accused ( No 2) gave a Gandasi( sharp edge weapon) blow on the left arm of the Complainant. While the accused ( No 1) gave a lathi blow on his back causing a contusion and also slapped the complainant. As people gathered around, the accused persons ran away by leaving the weapons on the spot.

 

4.The complainant fainted and taken to the hospital around 6.45pm by Mr. Navinsingh who is a passer-by. From the hospital, the Doctor on duty sent the Medical Rukka (intimation) containing all the details of the Complainant and his injured position to the Indira Vihar Police station and then ASI Balwinder Singh from the Police station, Indira Vihar reached the hospital to record the statement of the Complainant.

 

5. After recording the statement ASI Balwinder Singh has not lodged the FIR against the accused persons and he didn’t take any action about the information given by the complainant. After repeated request by the complainant since the police officer had not taken any action.

 

6. It is, therefore, prayed before this Hon’ble court that the accused persons had committed offence under sections 323,324,325 and 326of the Indian Penal Code in accordance with law and hence, please the court to summon and tried the accused persons in the interest of justice.

 

Place: Dehradun

Date: 29/03/21

 

 

 

Complainant

Mr. Ashish

Through

 

Advocate

 

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