DRAFTING, PLEADING AND

CONVEYANCING

NISHI PARIN DESAI

ROLL NO. 69
DIV – B

JITERNDRA CHAUHAN COLLEGE OF LAW

 IN THE COURT OF JUDICIAL MAGISTRATE OF FIRST CLASS ESPLANADE
COURT, MAHAPALIKA MARG, MUMBAI, MAHARASHTRA 400001

criminal compliant no. 2345 of 2020

Anjali Kapoor,
D/789, Chitrakala,
Orchid Lane Malad West,
Mumbai- 400060.
Age – 32. ……complainant

VERSUS

Rahul Kapoor
C/345 Heritage Heights,
Nariman Point,
Mumbai – 400020.
Age – 34. ..……Accused

COMPLAINT OF OFFENCE UNDER SECTION 494 OF THE I.P.C.

The aforementioned complainant begs to state on solemn affirmation as under: -

1. the complainant, MRS. Anjali Kapoor, aged 32 is a resident of d/789, chitrakala,

orchid lane Malad west, Mumbai- 400060.

2. The accused, Mr. Rahul Kapoor, aged 34 is a resident of c/345 heritage heights,
Nariman point, Mumbai – 400020.

3. Mr. Rahul married, Mrs Anjali on the 01/01/2018 at Shaadi Mahal, Malad West,
Mumbai 400060. The marriage was solemnized as per the Hindu rites. Thereafter they
both have been residing in the address mentioned, c/345 heritage heights, Nariman
point, Mumbai - 400020. The accused travelled frequently for work, for long period
of time. On 31/12/2019, the complainant was informed by her brother-in-law
(husband’s brother), Mr. Ajay Kapoor that the accused was married to another
woman, Ms. Tine since the year 2017. To prove the same Mr. Ajay showed the
complainant, pictures from the wedding of the accused with Ms. Tina, where he
 himself was present to. It was also brought to the notice of the complainant that the
accused and Ms. Tina lived together in a house located in Thane. The complainant has
been struggling with the fact, from the time she was made aware of her husband’s
bigamy, which has in turned made her leave her house where she and her husband
resided together, and go to her parents’ house located in Malad.

4. After finding out that the accused had been married to another women, before
marrying her, which had resulted in a crime of bigamy committed by the accused.
therefore, the complainant would like to put charges on the accused for the same.

5. In the circumstances as aforesaid the complainant charges the accused as above and
prays for appropriate action against him.

Sd/-A
Complainant

Before Me,

XYZ

-------------- (magistrate)

6th June,2020.