IN THE COURT OF ILLAQA MAGISTRATE, GURUGRAM

COMPLAINT CASE NO. ____ OF 2023

IN THE MATTER OF:

Smt. Sushma Devi ...Complainant
Versus
Smt. Chandro …Accused

INDEX
S.No. Particulars Page No.

1 Memo of Parties

2 Complaint U/Sec 156(3) & 200 of CR.P.C

alongwith supporting affidavit

3 List of Documents

4 List of witnesses

5 Vakalatnama

Date: __________
Gurugram
Complainant
Sushma Devi

Through Counsel
 IN THE COURT OF ILLAQA MAGISTRATE, GURUGRAM
COMPLAINT CASE NO. ____ OF 2023

IN THE MATTER OF:

Smt. Sushma Devi ...Complainant
Versus
Smt. Chandro …Accused

MEMO OF PARTIES

Smt. Sushma, aged 31 years, W/o Sh. Sher Singh R/o H.No. 486,
Mauji Wali Gali, near Mauji Wala Kuan, Gurugram, Haryana-122001
...Complainant
Versus
Smt. Chandro W/o Sh. Lakhmi, R/o G19, 8 Biswa, Moji Wala Qua,
Sec-5, Gurugram, Haryana
…Accused
Date: __________
Gurugram
Complainant
Sushma Devi

Through Counsel
 IN THE COURT OF ILLAQA MAGISTRATE, GURUGRAM
COMPLAINT CASE NO. ____ OF 2023

IN THE MATTER OF:

Smt. Sushma Devi ...Complainant
Versus
Smt. Chandro …Accused
COMPLAINT UNDER SECTION 156(3) & 200 OF
CRIMINAL PROCEDURE CODE, 1973
Respected Sir,
The complainant most respectfully submits as under:-
1. That the complainant is a law abiding citizen of India and is a
resident of above-mentioned address. The copy of the ID Proof of
complainant is annexed herewith as ANNEXURE-A.
2. That the accused person has alleged registered an FIR bearing No.
404 under Section 323, 506 of IPC on dated 23.09.2020 at Police
Station of Sector-5, Gurugram containing the contents which are
totally false, frivolous, fabricated and concocted. The copy of the
above-said FIR is annexed herewith as ANNEXURE-B.
3. That the complainant has been falsely implicated in the above
noted case though she has committed no offence whatsoever by the
police and there is no role of the complainant as mentioned was
attributed in the said FIR.
4. That the complainant belongs to a very respectable and reputed
family.
5. That in the case of the said FIR despite lapse of considerable
amount of time the investigating agency is not conducting just and
proper investigation, hence the complainant prefer the present
complaint on following amongst other grounds:
GROUNDS:
a. That the date of incident mentioned in the FIR is 21/09/2020.
The complainant also had approached the local police on the
same date regarding the same matter and even before the
accused approached them, but complainant has not been dealt
with satisfactorily by the police officials.
b. That on the said incident, accused namely Chandro, her two
daughter-in-law (Kamla, Bimla) and other neighbours namely
Kuldip, Shashi, Billu, constructed illegal stairs to create a fuss
for the complainant and her family and regarding the same,
complainant also filed complaint to the various authorities
namely Police Commissioner Officer, Gurugram, Haryana dated
23/09/2020 and CM, Haryana dated 23/09/2020, but no
action was taken by either of the authority. The copy of the
above-said complaint made to the respective authorities
annexed herewith as Annexure-C and Annexure-D
respectively.
c. That on the date of registration of FIR i.e., 23/09/2020, the
complainant also filed the complaint regarding the same matter
of voluntarily causing hurt by the accused to the Police
Commissioner, Gurugram Haryana, and also to the ACP, Palam
Vihar, Gurugram, Haryana but neither police nor authorities
took any action against the said-incident.
d. That After the registration of FIR, the complainant got to know
about the said FIR by the accused against her. The complainant
and her family were shocked at this act by the accused and
have undergone mental agony on this account. Despite this,
compromise had also took place with the assistance of
Panchayat but there is no such withdrawal or compromise
 statement ever made in the court by the accused in respect of
said FIR.
e. That further many times, the complainant wants to seek justice
and for the same, she made various complaints dated
18/01/2021, 23/05/2022 against the accused to the various
authorities namely Police Commissioner Officer, Gurugram,
Haryana and CM, Haryana but no action was taken by either of
the authority. The copy of the above-said complaints are
annexed herewith as Annexure-E and Annexure – F
respectively.
f. That the police is duty bound to conduct the fair investigation
in a timely manner, however in the present case the police
didn’t investigate properly. It is pertinent to mention here that
there is No medical reports of Complainant despite there is
several injuries to her. The photograph in respect of above-
said injuries is annexed herewith as Annexure-G and No CCTV
footage of the incident despite the fact that CCTV Camera
was also there at the time of the said incident. The
photograph of CCTV footage situated at the said incident is
annexed herewith as Annexure-H.
g. That nothing which has been recovered or to be recovered that
is likely of broken locket of OM from the possession of the
complainant or from the place of incident as stated in the FIR .
h. That the complainant submits in the given facts and
circumstances, the complainant being a victim is left with no
alternative but to approach this Hon’ble Court for justice as the
police have failed to act in the matter of the case as the accused
are roaming scot free despite serious allegations against her
 despite the fact that the said FIR was registered about three
years ago.

6. That the Hon’ble Court of your lordship is the Court of Illaqa

Magistrate for Police Station Sector-5, Gurugram and as per the
provisions of Section 156(3) of the Cr.P.C., the Hon’ble Court in
view of the ratio of judgment laid down by the Hon’ble Apex Court
of India in case titled Sakiri Vasu Vs. State of U.P. and others
reported in 2008(1) RCR (Criminal),192 is empowered to ensure
proper investigation and monitoring the same, so as to ensure that
it is being done in a fair manner as per the provisions of law of
land. The ratio of law as laid down in Sakiri Vasu’s case is squarely
applicable to the present case. The copy of the said-judgment
annexed herewith as Annexure-I.

PRAYER

In the view of the aforesaid submission made here in and in the interest
of the justice, it is therefore most respectfully prayed that the Hon’ble
Court may graciously be pleased:
a) To take an adequate action against accused and punished for the
said offence in the interest of justice,
b) To seek a report from the Police Station Sector-5, Gurugram,
regarding the action taken on the said FIR till date,
c) To re-open the investigation so as to ensure that the guilty are
brought to book and are not spared simply because of their social
and political status.
d) To issue appropriate directions to the investigating officer to file
weekly action taken report regarding the status of investigation so
as to ensure proper investigations.
e) To pass such other or further orders as this Hon’ble Court may
deem fit and proper in the facts and circumstances of the case.

Date: __________
Gurugram
Complainant
Sushma Devi

Through Counsel

IN THE COURT OF ILLAQA MAGISTRATE, GURUGRAM

 COMPLAINT CASE NO. ____ OF 2023

IN THE MATTER OF:

Smt. Sushma Devi ...Complainant
Versus
Smt. Chandro …Accused
COMPLAINT UNDER SECTION 156(3) & 200 OF
CRIMINAL PROCEDURE CODE, 1973
AFFIDAVIT
I, Smt. Sushma, aged 31 years, W/o Sh. Sher Singh R/o H.No. 486,
Mauji Wali Gali, near Mauji Wala Kuan, Gurugram, Haryana-122001,
do hereby solemnly affirm and declare as under:
1. That I am the complainant in the said complaint and am well
conversant with the facts and circumstances of the case and am
competent to swear this affidavit.
2. That accompanying complaint U/Sec 156(3) & 200, Cr.P.C has
been drafted by my counsel under my instructions and contents
of the same have been explained to me in vernacular and
understood by me and the same are not being repeated herein for
the sake of brevity and may be read as part and parcel of this
affidavit.
3. That this is my true and correct statement.

DEPONENT

VERIFICATION:

Verified at Gurugram on this 10th day of October, 2023, that the

contents of my above affidavit are true and correct to the best of my
knowledge and belief. No part of it is false and nothing material has
been concealed therefrom.

DEPONENT
IN THE COURT OF ILLAQA MAGISTRATE, GURUGRAM
 COMPLAINT CASE NO. ____ OF 2023
IN THE MATTER OF:
Smt. Sushma Devi ...Complainant
Versus
Smt. Chandro …Accused
LIST OF DOCUMENTS
S.No. Particulars Page No.
1 Annexure A- Copy of ID Proof
2 Annexure B- Copy of the FIR against
complainant bearing No. 404 under Section
323, 506 of IPC on dated 23.09.2020 at Police
Station of Sector-5, Gurugram
3 Annexure C- Copy of the Complaint to the
Police Commissioner Officer, Gurugram,
Haryana dated 23/09/2020
4 Annexure D – Copy of the Complaint to the
CM, Haryana dated 23/09/2020
5 Annexure E- Copy of the complaints to the
Police Commissioner Officer, Gurugram,
Haryana and CM, Haryana dated
18/01/2021
23/05/2022
6 Annexure F- Copy of the complaints to the
Police Commissioner Officer, Gurugram,
Haryana and CM, Haryana dated
23/05/2022
7 Annexure G- The photograph of the injuries
made to the complainant
8 Annexure H- The photograph of CCTV
footage situated at the said incident
9 Annexure I- The copy of the judgment titled
as Sakiri Vasu Vs. State of U.P. and others
reported in 2008(1) RCR (Criminal),192
Date: __________
Gurugram
Complainant
Sushma Devi

Through Counsel
IN THE COURT OF ILLAQA MAGISTRATE, GURUGRAM
 COMPLAINT CASE NO. ____ OF 2023
IN THE MATTER OF:
Smt. Sushma Devi ...Complainant
Versus
Smt. Chandro …Accused
LIST OF WITNESSES
S.No. Particulars Page No.
1 Complainant herself
2 Sher Singh, complainant’s husband
3 Neighbours namely:

4 Any other witnesses if later on required shall

be produced before this Hon’ble Court

Date: __________
Gurugram
Complainant
Sushma Devi

Through Counsel