IN THE COURT OF THE LD.

CHIEF METROPOLITAN
MAGISTRATE KARKARDOOMA COURTS, NEW DELHI
Crl. Complaint Case No. ______/2022
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y
INDEX
S. No. Particulars Pages
1 Memo of Parties
2 Complaint u/s 200 of Cr.P.C. with affidavit
3 List of Witness
4 Application u/s 156 Cr. P.C. with affidavit
5 Vakalatnama

Place:
Date: Signature of Complainant
Through

Adv. Z
Address of Z
 IN THE COURT OF THE LD. CHIEF METROPOLITAN
MAGISTRATE KARKARDOOMA COURTS, NEW DELHI
Crl. Complaint Case No. ______/2022
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y
MEMO OF PARTIES
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y

Place:
Date: Signature of Complainant
Through

Adv. Z
Address of Z
 IN THE COURT OF THE LD. CHIEF METROPOLITAN
MAGISTRATE KARKARDOOMA COURTS, NEW DELHI
Crl. Complaint Case No. ______/2022
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y
P.S.: Shakarpur

CRIMINAL COMPLAINT UNDER SECTION 156 (3) r/w Section 200

Cr.P.C. AGAINST THE ABOVE-MENTIONED ACCUSED PERSONS
COMMITTED COGNIZIBLE OFFENCE UNDER SECTION 498A, 506,
406 IPC
MOST RESPECTFULLY SHOWETH:-
1. That the marriage of the Complainant Wife, Ms. X was solemnized with the
Accused Mr. Y, (address of accused) on 22nd February, 2015 as per Hindu Rites
and ceremonies in Patna, Bihar where the parental home of the accused is
situated and where he presently reside. It is submitted that subsequent to the
solemnization of marriage the Complainant and the Accused stayed in Patna.
2. That one day prior to the engagement ceremony of the Complainant and the
Accused i.e. on 19th January,2015, the Accused called the Complainant and her
parents for a meeting at Soho Hotel, New Delhi because the Accused wanted to
have a discussion related to the engagement and subsequent marriage
ceremony. On the said date, the Accused made a demand for dowry from the
Complainant and her parents wherein specific demand for jewellery, cash, silver
items, clothes and other household items to be given to the Accused and his
other family members was made. The Accused also supported his parents and
stated that the demand of the is justified.
3. That the Accused further stated that since they are from a very renowned family
in Patna and therefore, a grand Tilak Ceremony should be held in Patna and all
the expenses of the said Tilak Ceremony should be borne by the Complainant
 and her family members. Moreover, the Accused also stated that the jewellery,
cash, silver items, clothes and other household items so demanded should be
given to the Accused and his family members in the engagement and subsequent
Tilak Ceremony otherwise the engagement and the marriage would be called
off.
4. That during the abovementioned discussion the Accused, for the first time, told
the Complainant and her parents that 1500 guests would be attending the
marriage at Patna from their side and therefore, the best arrangements should be
made for them by the Complainant’s family. Since the Accused persons had
threatened to call off the engagement and the marriage if their demand was not
met therefore, the Complainant and her parents had no option but to agree with
the unreasonable demand for jewellery, cash, silver items, clothes and other
household items as well as arrangements for accommodating more guests and
when the Complainant’s father told the Accused that his demand would be met
to the extent possible as per the financial capacity of the Complainant’s family,
the engagement ceremony of the Complainant and the Accused took place on
20th January, 2015 at New Delhi. In the said engagement ceremony, expensive
gifts including jewellery and cash were given to the Accused and his their family
members as per the demand made by the Accused.
5. That on 20th February, 2015 the Tilak Ceremony took place in Patna, Bihar
where as per the demand of the Accused jewellery, cash, silver items, clothes
and other household items were given to the Accused and other family
members. At the end of the Tilak Ceremony, the Accused told the father of the
Complainant that more cash and jewellery should be given otherwise the
marriage would be called off which would bring disrepute to the Complainant
as no one would marry her in future.
6. That the marriage of the Complainant and Accused was solemnized on 22 nd
February, 2015. The total expenditure incurred amounting to Rs. 44 lakhs in the
marriage ceremony and all other ceremonies was borne by the Complainant and
her parents. The Accused took the entire jewellery and stridhan of the
Complainant, under the pretext of keeping the same in safe custody, after the
Complainant came to live in the house of Accused in Patna subsequent to the
solemnization of marriage. It is submitted that immediately thereafter, the
 Accused started humiliating and taunting the Complainant regarding the
insufficient dowry brought by the Complainant in the marriage and even in the
presence of the relatives and family friends, he and his family used to humiliate
the Complainant. Moreover, the Accused have been constantly pressurizing the
Complainant for bringing Rs. 20 lakhs cash and more jewellery as dowry.
7. That on 4th May, 2015 the Accused continued taunting her for the insufficient
dowry brought by her. The Accused harassed the Complainant by stating that
he had been betrayed by the Complainant and her parents as she had not brought
more cash and jewellery as per his demands and now either she and her parents
have to fulfill his demands otherwise, she would not be allowed to live in the
matrimonial home.
8. That when the Complainant and her family members failed to respond to the
demands made by the Accused, the Accused adopted a very cold and cruel
approach towards her and treated her in the most discriminatory and callous
manner. The height of mental and physical cruelty came to surface when the
Complainant was given very little food to eat and that too in a separate utensil
and at a separate place instead of the dining table where the Accused and the
other family members used to eat. Moreover, the Complainant was not allowed
to use the electric appliances such as iron, washing machine, etc since the
Accused always taunted her about not bringing enough dowry and bringing
disrepute to the family by coming as daughter-in-law with insufficient money.
Such torturous attitude often led to great depression and feeling of dejection in
the Complainant who got very disturbed and even thought in terms of quitting
the world. However, the Complainant constrained herself realizing that any such
step will come as a shock to her parents and would ruin their life completely
and this thought itself has sustained the Complainant till date despite all the
above mentioned torture and cruelty.
9. That the Complainant left Patna and came to Delhi Airport on 7th September,
2015, the Accused asked the Complainant to buy an expensive watch for him.
When the Complainant asked him as to how she would pay for such an
expensive watch he said that it is her problem and told her to ask her father for
money. On the Complainant’s refusal to do so, the Accused got very agitated
and started shouting at the Complainant at Delhi Airport itself. The Accused
 told the Complainant that she has ruined his life as he never thought that he was
marrying into a family of paupers who do not even have Rs. 85,000/- to pay for
a watch. The Accused further threatened the Complainant saying that the
demands of his family should be taken seriously and till the demands with
regard to the cash and jewellery are not met the Accused would neither come
and reside with the Complainant in Delhi nor let her accompany him to Patna.
Due to such hostile attitude of Accused, the Complainant started crying due to
which people present at the Airport started gathering and asking questions.
Seeing the situation the Accused got scared and started telling the gathered
crowd that there was some misunderstanding between them which would be
resolved soon if given a chance to speak alone. Thereafter, once the crowd
dispersed the Accused immediately told the Complainant that he was ready to
forego his desire for watch and she should stop crying forthwith. Subsequently,
the Accused boarded his connecting flight to Patna whereas, much against the
wishes of the Complainant the Accused asked her to stay in Delhi.
10. That in October, 2015 the Accused on insistence of the Complainant, allowed
her to accompany him for a conference organized by his company in Goa.
Thereafter, the Complainant accompanied the Accused to Mangalore to meet
his sister. During the said trip, the Accused told the Complainant that she has
an ordinary physical appearance and he only agreed to marry her on the
expectation that all the demands put forward by him and his parents shall be
fulfilled. The Accused categorically told me that till the time his own and his
parents’ demands for Rs. 20 lakhs cash and more jewellery are not met he would
neither come and reside with the Complainant in Delhi nor let her accompany
him to Patna. Accused again went back to Patna on 11th October, 2015 and the
Complainant was forced to come back to Delhi.
11. That the Accused persons particularly Accused left no stone unturned to
humiliate the Complainant and her parents for non- fulfillment of their
unreasonable demands to the extent that whenever the father of the Complainant
tried to contact or communicate to the Accused in order to resolve the dispute
they always rebuked him by saying that they made a huge mistake by marrying
their son into such a family which has betrayed them and not met their
expectations. Moreover, the father of the Complainant was told that his daughter
 would not be allowed inside the house of the Accused in Patna if she did not
bring with her Rs. 20 lakhs cash and jewellery as demanded.
12. That despite the continued humiliation and harassment, the Complainant in
order to save her marriage went to Patna on 5th December, 2015 to participate
in the birthday celebrations of a family member of Accused, however, on seeing
the Complainant the Accused expressed their displeasure and said that she had
no right to enter the house in view of the fact that their demand for cash and
jewellery has not been fulfilled and consequently humiliated the Complainant.
During the aforesaid stay the Complainant was ill-treated and not allowed to
access her own clothes and other essential items which have also been taken by
the Accused in his custody along with the Stridhan which she had taken after
marriage on the pretext of keeping the same under safe custody. The Accused
also used to support his mother and other family members to torture the
Complainant.
13. That when the Complainant came back to Delhi from Patna after one week, it
was communicated to her by the Accused that till the time the demands made
by him and his parents he would neither take the Complainant back. That on
28th May,2016 when the Accused came to Delhi Airport from Patna, the
Complainant went to the Airport to meet the Accused on his insistence.
However, on meeting the Accused told the Complainant that his parents have
looked for a prospective bride for him and the bride’s parents are willing to pay
dowry amounting to Rs 5-6 Crores and that the Complainant has ruined his life
and therefore, he wants to get rid of her and marry into a rich family. The
Complainant, on hearing this, was completely devastated and started crying as
she was hoping that the Accused would take her to Patna and she would be able
to reside in her matrimonial home. Thereafter, the Accused went to Patna
leaving the Complainant in Delhi.
14. That the Complainant narrated the abovementioned incident to her parents who
were very agitated and called the Accused to try and resolve the dispute.
However, the Accused clearly told the father of the Complainant that even for
talks some money as per their demand should be paid first. The Complainant
was informed by her distant relatives that the maternal grandfather of the
Accused had passed away in August, 2016. On hearing such news, the
 Complainant called the Accused to say that she would like to visit them ,
however, the Accused very rudely told the Complainant that there is no question
of her being allowed in their house till the demand made by him are not met.
15. That in September, 2016 the Accused through his family friend, namely, Mr.
Singh approached the paternal uncle of the Complainant, who resides in Patna,
and the father of the Complainant to settle the matrimonial dispute. Thereafter,
the Accused along with the said Mr. Singh have been continuously pressurizing
the Complainant and her parents to settle the matter without returning the
stridhan, jewellery and other valuable items of the Complainant.
16. That all the costly articles including jewellery and stridhan of the total value of
Rs. 31,50,000/- which belong to the Complainant are in possession of the
Accused and they have not been handed over to the Complainant despite several
requests.

PRAYER
It is, therefore, most humbly prayed that this Hon’ble Court may graciously be pleased:-
1. to direct the officer in-charge of the concerned Police Station, Shakarpur to register an
F.I.R. against the Accused persons U/s. 498A, 506 and 406 IPC and subsequently
conduct investigation;
2. to summon the Accused persons U/s. 200 Cr.P.C. to be tried and prosecuted for offence
committed U/s. 498A, 506 and 406 IPC;
3. to pass any other order in the interest of justice.

Place:
Date:
Signature of Complainant
Through

Adv. Z
Address of Z
 IN THE COURT OF THE LD. CHIEF METROPOLITAN
MAGISTRATE KARKARDOOMA COURTS, NEW DELHI
Crl. Complaint Case No. ______/2022
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y
AFFIDAVIT
I, X, D/O ____ Address ____ do hereby affirm and declare as follows:
1. That I am the Complainant in the present case and I am fully acquainted with the facts and
circumstances of the present case and as such I am competent to swear this affidavit.
2. That I have gone through the contents of this complaint u/s 200 of Cr.P.C. and I say that the
contents are true to the best of my knowledge and belief.
3. The annexures are true typed copies of the originals.

Deponent
Verification
I say that the contents of the above affidavit are true and correct as per my knowledge and
belief. I say that no part of the above affidavit is false and nothing material has been concealed
therefrom.
Verified at ______ on this ______ day of _____ , 2022.
Deponent
 IN THE COURT OF THE LD. CHIEF METROPOLITAN
MAGISTRATE KARKARDOOMA COURTS, NEW DELHI
Crl. Complaint Case No. ______/2022
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y
LIST OF WITNESSES
1. Complainant herself
2. Mr. A
Address of Mr. A
3. Mr. B
Address of Mr. B

Place:
Date:

Signature of Complainant
Through

Adv. Z
Address of Z
 IN THE COURT OF THE LD. CHIEF METROPOLITAN
MAGISTRATE KARKARDOOMA COURTS, NEW DELHI
Crl. Complaint Case No. ______/2022
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y
Application u/156(3) of The Code of Criminal Procedure, 1973
Most respectfully showeth:
1. That the above-cited criminal complaint case has been filed on behalf of the complainant
and the same has been pending before this Hon’ble Court and the contents of the same may be
read as part and parcel to this application and the same is not repeated herein for the sake of
brevity.
2. That the Complainant submitted a representation for registration of F.I.R. against he Accused
persons to the SHO, P.S. Shakarpur, New Delhi on 08.11.2016 but till date no action has been
taken by the Police in the said complaint.
3. That in such circumstances the complainant is left with no other remedy except to file the
present complaint case which is correct and the contents of the same may be read as part and
parcel of this application and those are not repeated herein for the sake of brevity.
4. That the complainant has good prima facie case in her favour and against the accused.
5. That it has become necessary and imperative that the matter must be investigated and
inquired by the police.
It is therefore most respectfully prayed that this Hon’ble Court may be pleased to direct the
police of police station Shakarpur, delhi to register an FIR against the above-mentioned
accused and to investigate the offences mentioned in the complaint in the appropriate manner
and in accordance with law and interest of justice.
To pass any other order in the interest of justice in the facts and circumstances of the above
case.
Place:
Date:
Signature of Complainant
Through

Adv. Z
Address of Z
 IN THE COURT OF THE LD. CHIEF METROPOLITAN
MAGISTRATE KARKARDOOMA COURTS, NEW DELHI
Crl. Complaint Case No. ______/2022
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y
AFFIDAVIT
I, X, D/O ____ Address ____ do hereby affirm and declare as follows:
1. That I am the Complainant in the present case and I am fully acquainted with the facts and
circumstances of the present case and as such I am competent to swear this affidavit.
2. That I have gone through the contents of this application u/s 156(3) of Cr.P.C. and I say that
the contents are true to the best of my knowledge and belief.
3. The annexures are true typed copies of the originals.

Deponent
Verification
I say that the contents of the above affidavit are true and correct as per my knowledge and
belief. I say that no part of the above affidavit is false and nothing material has been concealed
therefrom.
Verified at ______ on this ______ day of _____ , 2022.
Deponent
 IN THE COURT OF THE LD. CHIEF METROPOLITAN
MAGISTRATE KARKARDOOMA COURTS, NEW DELHI
Crl. Complaint Case No. ______/2022
IN THE MATTER OF:
X …Complainant
Address of X
v.
Y …Accused
Address of Y
LIST OF DOCUMENTS
1. Adhaar Card of Complainant
2. Bank Account details of Complainant
3. Bank Account details of the father of Complainant
4. Screen shot of Whats App messages shared between Complainant and Accused