IN THE COURT OF ____________,LD.
JUDICIAL
MAGISTRATE FIRST CLASS
DISTRICT COURT, NEW
DELHI
IN THE MATTER OF: -
X VERSUS Y
COMPLAINT TO THE MAGISTRATE
MOST RESPECTFULLY SUBMITTED:
1.
That the complainant was married to
accused no. 1, Y, in accordance with Hindu rites and customs at her father’s
residence in ___________ (place), P.S. ___________.
2.
That at the time of the marriage, the
complainant’s father, apart from hosting a large gathering, gave stridhan,
which included gold ornaments worth Rs. ___________, a SUV car worth Rs.
___________, and other valuable items such as ___________ (mention all other
items).
3.
That after the marriage, the complainant
was taken to her matrimonial home, where her in-laws resided. After spending
about a month there, the complainant, along with accused no. 1 and 2, moved to
___________ (place).
4.
That six months after the marriage, the
complainant began to face both physical and mental abuse at the hands of
accused no. 1, with the support and encouragement of accused no. 2. The abuse
was due to the demand for an additional dowry of Rs. 20 lacs. As the complainant
was unable to meet this demand, the torture, both verbal and physical,
continued unabated.
5.
That the offence under Section ______ of
the Bhartiya Nyay Sanhita is a continuing offence. On several occasions, both
accused no. 1 and 2 actively participated in the abuse and torture inflicted
upon the complainant. There were instances where only accused no. 1, the
husband, was involved. The ___________ (P.S.) has jurisdiction over this matter
and this Hon’ble Court is competent to try the case.
6.
That there is a prima facie
case under Sections ____and ___of the Indian Penal Code against the accused.
7.
That although the complainant reported
the incidents to the ___________ (P.S.), no action was taken against the
accused, and the police refused to register an FIR against them. Thus, this
complaint is being submitted before this Hon’ble Court.
8.
That the present application is made
bonafide and the same be allowed in the interest of justice.
PRAYER
It is, therefore, most respectfully
prayed that this Hon’ble Court may kindly be pleased to:
A)
Pass an order directing
the SHO to investigate the matter and lodge an FIR; and/or
B)
Pass any other or further order(s) as
this Hon'ble court deems fit and proper in the interest of justice.
New Delhi
Applicant
Date Through
Advocate
IN THE
COURT OF ____________,LD. JUDICIAL MAGISTRATE FIRST CLASS
DISTRICT COURT, NEW
DELHI
IN THE MATTER OF: -
X VERSUS Y
AFFIDAVIT
I,
______ S/o ________ R/o ___________________________aged about ________ years,
do hereby solemnly affirm and declare as under: -
1.
That
I am the applicant in the above noted application and am well conversant with
the facts of the present case and as such competent to depose this affidavit.
2.
That
the accompanying application has been drafted by my counsels on my instruction,
and its contents have been read over to me in vernacular and the same are true
and correct to the best of my knowledge and are not being repeated herein for
the sake of brevity.
3.
That
the contents of the accompanying application may kindly be read as part and
parcel of this affidavit.
DEPONENT
VERIFICATION
Verified at Delhi on this ____ day of
______ that the contents of the above affidavit are true and correct to the
best of my knowledge and nothing material has been concealed therefrom.
DEPONENT
