IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE AT PATIALA

HOUSE COURT, NEW DELHI

COMPLAINT CASE NO. __________ OF 2021

(Affix Court Fee stamp of Rs. ___)

IN THE MATTER OF:

Mr. Vijay Das
S/O SH. Prem Das
R/O F-43/A, Khanpur Extension
Near R.K. Public School, New Delhi
………. Complainant
VERSUS
1. Mrs. Shreya Das
2. Mr. Ajay Das
3. Mrs. Priyanka Das
………… Accused Persons

Police Station- Tilak Marg

COMPLAINT UNDER SECTION 200 READ WITH SECTION 156(3) OF THE CODE
OF CRIMINAL PROCEDURE FOR REGISTRATION OF FIR UNDER SECTION
325 OF INDIAN PENAL CODE
Most respectfully showeth:

1. That herein reffered to as the “accused persons”, the complainant’s wife and her relatives
have physically abused the complainant on 03.12.2021 causing him grievous hurt.
2. That the complainant was beaten with lathi and stones.
3. That the complainant then went to his parental home in Meerut to save his life and finally
went to Meerut Hospital to get his MLC done.
4. That the complainant returned back to Delhi on 12.10.2020 and went to the police station
to file a complaint against the accused persons.
5. That the investigating officer of the Neb Sarai police station, Sainik Farm, New Delhi-
110062, Avdesh Dixit refused to take the complaint against the accused persons.
6. That after a lot of requests, the officer stamped a complaint without a necessary Diary
number and stated rudely, “bina dairy number k iski koi value nahi hai or nahi koi action
hoga ispar.”
7. That the complainant often went to the police station to know the reason behind not filing a
proper complaint or not taking any action against the accused persons after which he was
threatened by the investigation officer to not enter the police station.
8. that the investigating officer demanded for one lakh rupees to take any action on the
complaint.
9. That the accused 1, the wife of the complainant has bribed the investigating officer with
substantial amount of money so that no action is taken on the said complaint and therefore the
complainant was being harassed and threatened by the Investing officer of the Neb Sarai
police station.

PRAYER
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 a proper complaint without any bias
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 offence under section 325
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.

AFFIDAVIT
I, Mr. Vijay Das S/O SH. Prem Das R/O F-43/A, Khanpur Extension Near R.K. Public
School, New Delhi hereby affirm and declare as under:-
1. That I am the complainant in the said case and I am well versed with the facts of the
complaint and I am competent to swear the affidavit.
2. That accompanying complaint U/S 156(3) & 200, CrPc. R/W 325 of IPC has been drafted
by my counsel under my instructions and contents of the same have been explained to me and
understood by me and may be read as part and parcel of this affidavit.
3. That the statements made by me are true and correct.
DEPONENT
VERIFICATION
Verified at New Delhi on this day of December 2021, that the contents of my above affidavit
are true and correct to the best of my knowledge and belief and nothing material has been
concealed therefrom

DEPONENT

Complainant
Through
(Ashmita Banerjee)
Advocate
Chamber No. 432, Patiala House Courts,
New Delhi- 1100001
Date: 30/12/2020
Place: New Delhi