In the Court of

S.D.J.M. at Patna
Complaint-cum-Protest Petition No. of 2021

Munni Kumarii
Complainant
Versuas
Md. Murtaza Mo
Niyazuddin @Nanhen Accused
Sub.- Complaint Petition.
IN DEX
Sl.No.
Partiçulars Page No.
1.
Complaint Petition with Affidavit. 1 - 100
2. Enclosures.

eby
 In the Court
of
s.D.J.M. at Patna
Complaint-cum-Protest Petition No. of 2021
Name of the
complainant : Munni Kumari, Wife
of
Purushottam Kumar
resident of Jagat Kranti
Apartment, Flat No.12 Mitra
Mandal
Compound, P.S.
Buddha Colony, District-
Patna.
Name of the Accused (1) Md. Murtaza e
Niyazuddin @ Nanhen, Son of
not
known, resident of
Mohalla- Digha, District-
Patna.
Name of other accused who are
employees off
Breakfast shop-

Date and Time of

occurrence: 13.07.21.
Place of occurrence:
Near River Ganges Digha
Ghat.
 2

Offence committed
u/s:-.
of
302, 201, 120
(B) /34
I.P.C.
Name of Witnesses
(1) Munni Kumari, Wife
of Purushottam Kumar.

(2)
Priyanka Kumari, D/o-
Purushottam Kumar.
Both
resident
of-Jagat
Kranti
Apartnent Flat
No.12 Mitra Mandal1
Compound, P.S.- Budha
Colony District- Patna.
The humble Protest-cum-

Complaint Petition on

behalf of above named

Complainant.
Most Respectfully Sheweth:-

L. T'hat the
Complainant's Son
Deepak
Purushottam as usual used to visit and
 3

Walk, Digha Ghat

near river Ganges for the
.ast one
week and return
home.
2
T'hat on the date of
occurrence i.e. on

3.07. 2021 at 8 P.M. had

gone to Digha Ghat
by his
SCOoty at 9 P.M. the complainant
received a
telephonic message on her mobile
no.
bearing-9973473927 by an
unknown personn
that he has
got a mobile set,
cloth, shoes
which was in
lying condition but the
boy is
not being seen.

3. That thereafter
the complainant
requested
the said unknown
person to stay there the
Complainant informed her husband who is

doing job in Saharsa. Thereafter the

Complainant's husband told her Wife to

inform Officer Incharge of P.S.

Digha and

accompany him. The complainant

alongwith
 4

her
daughter Priyanka and Neeraj who is

dnillar to her went to Digha P.S. Id

d
of
them went to the place of occurrence

wuere
they found that very unknown person.
nat
person disclosed that the boy always

used to visit Digha Ghat near river Ganges

put on the unfortunate day, he wa not seen

the unknown person disclose his name Anil

before Officer-in-Charge and also disclose

that Deepak use to listen song by earphone

and return to his horme the Complaint

states that the local person also

further

like this, that the boy used to visit

told

regularly, 1isten song and

Digha Ghat

return back home.

team started
thereafter
S.D.R. F.

A. I'hat

recovered dead
and
river Ganges
in
sQdrch
 5

body and informed

the Complainant husband
to see the dead
body is. which The
person.
Compiainant and others
claimed dead body as

ier son and several

other persons
gathered.
Prima-facie a since df Mar-Pit
Case appeas
after
seeing the dead body. The blood was

O0zing from the Mouth

and Nose. The
accused
namely Murtuza e Nanhe
always harasses who
is an
employee of Hotel insists
harassing
and Deepak to eat Jaleboi agaisnt his will
and
requested not to
harassing him.
5. That the
complainant claims that her son
Deepak Purushottam has been killed by
Murtuza Nanhe, resident of
Digha and
other employees of Hotel by drowning in
water and threw the dead bÍdy
which a

purpose to
dispose of the dead
body.
 6

. That thereafter
on
the basis. of writteen
application of the
Complainant Digha P.S.
Case No.390/2021
registered on 17.07.2021
under sections 17.07.2021
302, 201, 120 (B)/34 I.P.C.
against Murtuza and
1
others.
That
thereafter Manoj
KumarC
OF Sub-Inspector
police of
Digha Poli.ce Station
investigation but there:
is no
the same
progress of
The I.0. has
yet not
statement taken
of the
witness under
of Cr.P.C. section 161
He has
not
examine orally any
person suppose
to bee

act and
acquainted with the
Circumstances of the case.
8. ''hat the I.0. of the
case is
Over
sitting tight
the matter had
also gone into the
Collusion with the
accused person who arce
moving frequentlY.
 7

9. I'hat the complainant's Son namely Deepak

Purushottam (now deceased) succumbed to

death by drowning in water by the accused

persons.

10. That the conduct of the police shows that

the complainants case regarding death of

her son will be spoiled by the police and

there may be serious apprehensin that a

Einal report may be submitted by the police

untrue against the accused

showing assuring

persons. Hence necessity caused to file

Protest-cum-Complaint Petition in this

Iearned court.

It is therefore, prayed

that your Honour may

graciously be pleased to

this petition on
keep
 record and in case the

police submits final reportt

your Honour may be pleased

to hear the petitioner and

take cognizance of the

offence u/s 302 201,

120 (B)/34 of I.P.C. and

Summon the accused person

for trial.

And for this, the complainant shall ever pray.

Date
Place Signature of the complainant
 9

AFFIDAVIT

Munni Kumari, years, Wife of

aged about
Kranti
Purushottam Kumar, resident of Jagat

Apartment, Flat No.12 Mitra Mandal1 Compound,

P.S.- Buddha Colony, District- Patna, do hereby

OLemnLy affirm and state as folloWS

1. That I am Complainant in t h i s case and as such

am well with the facts and

acquainted

Circumstances of the case.

2 That the contents of this complaint petition

to me in Hindi
have read over and explained

I have understood the same and found

which

true and correct to the best of my knowledge

and belief.
 10

VERIFICATION
Munni Kumari,
aged about years, Wife of
'urushottam Kumar resident
Of Kranti
Jagat
Apartment, Flat No.12 Mitra Mandal1
Compound,
P.S. Buddha Colony,
District- Patna, do hereby
Solemnly affirm and
declare that statements
made in
paragraphS -no.. ***ssesdin are true to my
knowledge and the
statement made in paragraph
T1O..
************ ****° derived from the
relevant recordS,
which I believe to be true.
Verifiication this ..day.. ......2
.2021

Deponent