CRIMINAL COMPLAINT U/SS 323, 324, 504 & 506
RW SEC 34 OF THE INDIAN PENAL CODE
IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS,
(COURT NO. 2), PUNE AT PUNE
Criminal Complaint No.
Shri __ D _ M __ K _,
)
age 35 years, occupation - service,
) Complainant
resident of 1000 Kasba Peth,
)
PUNE 411 011.
)
Versus
Shri _ B __ J _ P __,
)
age 56 years, occupation - business,
)
Shri __ S __ B __ P __,
) Accused
age 25 years, occupation - business,
)
both residents of 1050 Kasba Peth,
)
PUNE 411
Oil.
)
A COMPLAINT U/SS 323, 324, 504 & 506
R/W SEC. 34 OF THE INDIAN PENAL CODE
The complainant above-named submits this complaint, praying to
state as follows:
1. That the complainant is a resident of the within mentioned address,
and the said house property is owned by the accused No. 1 and let
out to this complainant as a monthly tenant.
2. That the complainant is a Government servant, peace-lover and law-
abiding citizen.
3. That in the month of
200_, the accused No. 1 called upon this
complainant to vacate the said premises within a week or so.
4.
That since this complainant did not vacate the said premises, the
accused No. 1 then again on
.....
, the son of the accused No. 1, i.e.
the accused No. 2, came to the complainant and threatened him of the dire consequences, if the complainant, if the complainant were
to fail or avoid to vacate the said premises before the end of
....
200
.....
5. That the complainant submits that he did not vacate the said
premises, and he was not legally bound to do so.
6. That then, on
.....
, at 6.30 p.m., when this complainant had been
returning from his office to his residence, while he was entering the
said premises, both the accused accosted the complainant and
started abusing him in a dirty and filthy language, and even though
the complainant tried to convince and tell them that what they were doing was all illegal, both the accused attacked the complainant and
gave him a number of blows with fists and lastly the accused No.
2 gave a severe blow with a cudgel/staff/ stick in his hand on the
forehead of this complainant and thereby caused a serious injury to
the complainant, and the complainant had also become unconscious.
7. That when the people staying in the neighbourhood gathered there,
the accused stopped beating and they both went away, announcing
and pronouncing a threat that if the Complainant were to fail to
vacate the said premises within a couple of days, he would be killed,
and hence, this complaint.
8. 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.
9. 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.
10. That the necessary court-fee is paid herewith.
11. That the complainant, therefore, prays that the accused be kindly
charged with and tried for the offence punishable u/ss 323, 324, 504
and 506 R/W Sec. 34 of the Indian Penal Code and punished
according to law.
Pune,
Sd/- DMK
COMPLAINANT
Dated:
.
Sd/- x X x
ADVOCATE FOR COMPLAINANT
VERIFICATION
I, Shri DMK, the present complainant, do hereby state on solemn
affirmation that the contents of this complaint in paras 1 to 11 are true
and correct to the best of my knowledge and belief, and so I have signed
hereunder.
Sd/- DMK
COMPLAINANT