Call Detail Record (CDR) Application

IN THE HON’BLE COURT OF JUDGE MR. __________________, SIRSA

IN THE MATTER OF

STATE OF HARYANA ……COMPLAINANT

VERSUS

Respondent

Subject: Request for Preservation of the CDR (Call Detail Record) and Location Records dated from
22/02/2021 to 22/06/2021 - for my mobile numbers _______ with regard to FIR No. _________
dated 19/02/2021 under ____________ Police Station, Sirsa U/S CR.P.C 91 on behalf of Respondent
No .1

Respected Sir,

1. I, ________________, aged 32 years old, residing at _______________________________,

is hereby submitting my written application for preservation of the CDR (Call Detail Record)
and Location Records dated from 22/02/2021 to 22/06/2021 for my mobile numbers
_____________________ with regard to FIR No. _______ dated 19/02/2021 under Civil
Lines, Police Station, Sirsa.
2. The FIR has lodged a false case numbered _______ with IPC U/S 498A, 406, 506 and 323
under _________, Police Station, Sirsa on 19/02/2021 which has been investigated by IO
_________, Khairpur Chowki, Sirsa.
3. In order to trap and falsely prosecuted the Applicant ________ with IPC U/S 498A, 406, 506
and 323, Investigating Officer _________has not only illegally arrested applicant
_____________________ dated 21/06/2021 when I came to join investigation upon IPC 41A
notice, but also informed my mother in Delhi almost after 8 hours of my arrest whereas my
phone was forcefully switched off around 10:30AM on 21/06/2021.
4. I, reached, Khairpur Chowki at 9:59AM and informed IO _____________________ through
text message via my mobile number __________ that I have reached the Khairpur chowki
police. Once I reached inside the Chowki, IO _____________________ forcefully with two
other constables taken my phone in his custody and switched it off without providing me a
chance to inform my mother or any family member. He did not even inform me that he is
going to arrest me that day. After keeping me there for more than 8 hours, in evening he
made a call to my mother and informed that he has arrested me. Given the fact my mother
is a senior citizen and will not be able to do much, IO _____________________ made sure
that I will be taken into custody for the whole night. He not only disobeyed Supreme Court
COVID guidelines but also did not give any proofs which made my arrest necessary.
5. He even slapped me in the morning when I asked him to make a call to my mother before
the he switched my mobile off. During afternoon he forced me to sign few papers, when I
 asked to read them before signing, he did not show and beaten me with two other
constables.
6. This Complaint has been filed on false allegations against me and my family members
including married sister and her husband by my wife _____________________ with the sole
intention to harass, to extort money and to destroy my life purposely by misusing the dowry
Laws.
7. Hence, I hereby request the Hon’ble Court to kindly direct the Police Department for kindly
preserving the CDR (Call Detail Record) and Location Records of my mobile numbers
____________ from 22/02/2021 to 23/06/2021 and also to take them On-Record and attach
it with the Investigation Files for further proceedings in this case.
8. The above number is registered in my name and residential address. I am currently in
possession of this mobile number.
9. Please consider the preserved CDR (Call Detail Record) and Location Records as part of the
Investigation and court proceeding, since they are of utmost importance which shows that
Applicant always joined the Investigation but without proofs, this arrest was made only on
the pretext of complaint given by _____________________ _____________________.
10. This will help in equitable Implementation of Law and Justice, and also to bring out the real
conduct of IO _____________________ who not only illegally arrested me but put
unnecessary financial burden of legal expenses, bail bonds and lawyer fee, also mentally
harassed me and my family which includes my daughter _________ years old now.
11. I request you to kindly issue the appropriate orders to the IO _____________________ or
Relevant Officer(s) with regard to my application and also to provide me with a reply at the
earliest.

Dated Respondent No. 1

Sirsa Through Advocate

CC: Ministry of Home Affairs, New Delhi

Director General of Police (DGP), Haryana
Commissioner of Police (CP), Sirsa
National Human Rights Commission of India, New Delhi
Supreme Court of India, New Delhi
Punjab & Haryana High court, Chandigarh
President of India, New Delhi
Chief Minister of Haryana