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Criminal Complaint U Ss 323 & 504 R W Sec. 34 Of The Indian Penal Code Drafting Criminal Template 1094 - Legal Draft

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CRIMINAL COMPLAINT U SS 323 & 504 R W SEC. 34 OF THE INDIAN PENAL CODE
IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS,
KHADKI AT KHADKI
Criminal Complaint No.    /200_
Shri __ B __ B _ K _,     )
age 30 years, occupation - service,      )
Complainant
resident of 100 Shitolenagar, Sangavi,    )
PUNE 411 027.     )
 Versus
1. Shri _ K __ V _ A __,          )
 age 56 years, occupation - agriculture,   )
2. Smt. __ A ___ B _ K _,         )
 age 25 years, occupation - household,     )
3. Shri _ D __ K _ A __,         )
 age 30 years, occupation - service,       )
4. Shri __ S __ K __ A __, .      )
 age 25 years, occupation - education,     )
 all residents of Yeli, Taluka Pathardi,   )
 District Ahmednagar.      )
A COMPLAINT U/SS 323 & 504 R/W SEC. 34 OF THE INDIAN PENAL CODE
The complainant abovenamed submits this complaint, praying to state as follows:
1. That the complainant is a resident of the within mentioned address, and the accused No. 2 is his legally wedded wife, while the accused No. 1 is her father and the accused Nos. 3 and 4 are her brothers.
2. That the complainant is originally a resident of the village Yeli, Taluka Pathardi, District Ahmednagar.
3. That on account of his service in the Bajaj Tempo Limited, Chinchwad, Pune, the complainant has presently been residing at the within mentioned address for the last five years.
4. That the complainant was married to the accused No. 2 in the year 20 , and they have a son of about three years.
5. That due to some misunderstanding on the part of the accused No. 2 and at the instance of the accused Nos. 1, 3 and 4, the accused No. 2 has not been cohabiting with the complainant for the two years, and during this period, she has all along been residing with the accused No. 1 only.
6. That despite several requests and a lot of persuasion made by this complainant, his parents and also reconciliation tried by the relatives- in-common, the accused No. 2 has never turned up to cohabit with the complainant and has also wittingly and willingly refused to cohabit for no fault on the part of the complainant.
7. That in the mean time, instead of responding to the requests and appeals repeatedly made by this complainant with a view to restoring back the normalcy of his domesticity with the accused No. 2, the accused No. 2 has filed a maintenance application in the Pathardi Court, and the same has since then been pending in that court of law.
8. That even though the said case between the complainant and the accused No. 2 is already sub judice, all the accused on their own pursued the complainant upto Pune and thereby committed the following offence.
9. That on Sunday, the .... of

... 200 when the complainant returned from his duty in the evening, got down from his company- bus near the Khadki Station, all of a sudden, he happened to confront the accused near the Excelsior Talkies where the accused accosted him.
10. That the accused asked this complainant that he should be ready and willing to pay a sump sum of Rs. 1,00,000/- towards the maintenance of the accused No. 2, to which the complainant did riot agree, and when the complainant particularly pointed out about the pending court-case, the accused threatened that ii the complainant were to show his readiness and willingness before the court of law to cohabit with the accused No. 2, they shall undo what they please, and, at the same time, the accused Nos. 1, 3 and 4 gave blows on the person of the complainant and kicked him down on the ground, and while the other accused were beating the complainant, the accused No. 2 was standing nearby shouting and abusing the complainant.
11. That the complainant was injured, and, when with the help of the passers-by, he tried to stand up, all the accused had already been disappeared.
12. That the complainant was very much ashamed of himself when such a public scene was created by the accused, and he was, thus, tortured by the accused physically and mentally to a great extent, and since then, the complainant apprehends that the accused may cause danger or commit hurt to the complainant in future also.
13. That the complainant also made a complaint-application to the Khadki Bazaar Police Chowkey, with a request to give him necessary help and protection, which the police did.
14. That the accused have, thus, committed an offence u/ss 323 and 504 R/W Sec. 34 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.
15. That the cause of action for this complaint first arose on ........ , and the same has since then been every day thereafter, and hence, this complaint filed today is well within limitation.
16. 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.
17. That the necessary court-fee is paid herewith.
18. That the complainant, therefore, prays that the accused be charged with and tried for the offence punishable u/ss 323 and 504 R/W Sec. 34 of the Indian Penal Code and punished according to law.
Pune,              Sd/- BBK
COMPLAINANT
Dated :
Sd/- xXx
ADVOCATE FOR COMPLAINANT
VERIFICATION

I, Shri BBK, the present complainant, do hereby state on solemn affirmation that the contents of this complaint in paras 1 to 18 are true and correct to the best of my knowledge and belief, and so I have signed hereunder.
Sd/- BBK COMPLAINANT
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