UNIVERSITY OF PETROLEUM & ENERGY STUDIES

SCHOOL OF LAW

SEMESTER IV
ACADEMIC YEAR: 2021-22
SESSION: JANUARY- MAY 2021
ASSIGNMENT FOR
DRAFTING IN CRIMINAL MATTERS
Under the Supervision of:
MS. ANJALI BHATT
TOPIC –
“Complaint to JM”

NAME: NIDHI JAIN

SAP NO: 500076798
ROLL NO: R760219051
 IN THE COURT OF JUDICIAL MAGISTRATE, FIRST CLASS,
DEHRADUN

CRIMINAL COMPLAINT NO. ________ OF 2021

IN THE MATTER OF:

Mrs. A
W/O Mr. B
R/O B-5, GROUND FLOOR,
BHIDOLI, DEHRADUN- 248007
….COMPLAINANT
Versus

Mr. Y
S/O Sh. Z
R/O B-10, GROUND FLOOR,
BIDHOLI, DEHRADUN- 248007
.…ACCUSED 1
AND

Mr. X
S/O Sh. Y
R/O B-10, GROUND FLOOR,
BIDHOLI, DEHRADUN- 248007
.…ACCUSED 2
Subject: COMPLAINT UNDER SECTION 504 and 509 OF INDIAN PENAL
CODE, 1860.
THE COMPLAINANT ABOVE NAMED MOST RESPECTFULLY SHOWETH :-
1. That the complainant is a peace-loving citizen of India and is a
resident of B-5, Ground Floor, Bidholi, Dehradun- 248007.

2. The Accused named above are the neighbours of the Complainant.

Both houses are situated opposite to each other.

3. That on 27.12.2013, the accused 1, stored the bricks on the passage

leading towards the complainant’s house which caused trouble in
moving her car inside and outside.

4. That the Complainant make humble request to the accused 1 to

remove the bricks as it is causing inconvenience to the Complainant
and in case of emergency, she has to take out the car outside at night
time also.

5. That the accused 1 instead of removing the bricks rather threatened

the complainant with dire consequences.

6. That on 28.12.2013, the complainant lodge the complaint to the police

but did not proceed with that complaint, as the accused 1 assured
complainant that they will not disturb the peaceful living and will not
block her passage.

7. That the accused 2 started steering the complainant with bad eyes
and used to pass filthy and burglar remarks and language against
her.

8. That on 29.12.2013, the complainant was standing in front of her

house’s gate, when the accused 2 started steering at her with the
intention to intimidate her and the accused 2 shouted at her.

9. That the complainant was very ashamed when such a public scene
was created by the accused 1 and 2, and she 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.

10. That on 06.01.2014, the complainant made a complaint

submitted to the Commissioner of Police, Dehradun, with a request to
give her necessary help and protection, even then, no action has so far
been taken against the accused rather she has been harassed at the
instance of accused 1 and 2.
 Copy of Complaint sent to the Commissioner of Police at Dehradun on
06.01.2014 is attached herewith as Annexure A.

11. That the cause of action for this complaint first arose on
27.12.2013, and the same has since then been every day thereafter,
and hence, this complaint filed today is well within limitation.
12. Under this Circumstances, the Complainant Prays for legal
action against the Accused.

 
In view of the aforesaid submission made here in and in the interest of the
justice, it is therefore most respectfully prayed that this Hon'ble Court may
graciously be pleased to:

1) Register the present complaint.

2) Take cognizance of the offence, as the contents per-se amount to

commission of offences, as indicated above, without anything more.

3) Summon try and punish the accused person for committing the offences
under section 504 and 509 of the IPC.
 
4) Pass such other or further orders as this Hon'ble Court may deem fit and
proper in the facts and circumstances of the case.
AND FOR THIS ACT OF KINDNESS, THE HUMBLE APPLICANT AS IN
DUTY BOUND, SHALL EVER PRAY.
A
COMPLAINANT
THROUGH
ADVOCATE
Place : Dehradun
Date : 08.01.2014
 
 
It is therefore prayed that the accused may kindly be summoned, tried and
punished for the offence under section 138 of the Negotiable Instrument Act
read with Section 420 Indian Penal Code.
Such other or further order(s) which this Hon’ble Court may deem fit
and proper be also passed in favour of the complainant and against
the accused person.

Place: New Delhi

Dated: 20.03.2021
Complainant
Through

Counsel
List of Witnesses:-
1. Complainant
2. Clerk/officials concerned, SBI Bank Ground Floor, Green Park
Extension, New Delhi
3. Clerk/Officials concerned ICICI Bank Ltd., Ground Floor, Yusuf
Sarai, New Delhi
Complainant