Criminal Complaint (Section 498A IPC) (India)
This document is a formal criminal complaint template used in India for filing charges of domestic cruelty under Section 498A of the Indian Penal Code. It outlines the specific allegations of physical and mental harassment, the history of the marriage, and the legal grounds for the court's jurisdiction.
CRIMINAL COMPLAINT U/S 498A R/W SEC. 34 OF THE INDIAN
PENAL CODE
IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS,
(COURT NO. 9), PUNE AT PUNE
Criminal Complaint No./200_
Smt. __ S __ A _ D__,)
age 25 years, occupation - service,) Complainant
resident of C/o Shri DAD, 75 Kasba Peth,)
PUNE 411 011.)
Versus
1. Shri __ M __ A __ D _,)
age 30 years, occupation - business,)
2. Smt.BAD,) Accused
age 55 years, occupation - household,)
both residents of 150 Aundhgaon,)
PUNE 411 007. )
A COMPLAINT U/S 498-A R/W SEC. 34 OF THE INDIAN PENAL CODE
The complainant above-named submits this complaint, praying to state as follows:
1. That the complainant is the legally wedded wife of the accused No. 1, and the accused No. 2 is the mother of the latter.
2. That the complainant was married to the accused No. 1 at Pune on according to the Hindu religion, vaidic rites and ceremonies.
3. That before the marriage, the complainant was known by her maiden name as Kumari Komal..
4. That in the celebration of the said marriage, the parents of this complainant did everything without requiring the accused to spend anything on any account, and even though the father of this complainant is from mediocrity, all the customary gifts and presents were given to the accused and their near relations.
5. That since the complainant had been in Government service, she had her own savings, and after the marriage, she had kept the same for herself at her matrimonial home.
6. That on the second day immediately after the marriage, when the complainant and the accused No. 1 had been Mahableshwar for honeymoon, this complainant was shocked to know and accept it as a truth that the accused No. 1 is alcoholic, and he is a man of many vices.
7. That when, after return from Mahableshwar, this complainant complained to the accused No. 2 about the misbehaviour on the part of the accused No. 1, she paid no heed to the same, and it took no time for this complainant to realise that the accused No. 1 being the only son and scion of her in-laws, the accused No. 2 cosseted him like anything and further that the accused No. 2 would not allow this complainant to say anything against him or both of them.
8. That whenever the complainant tried to open her month about the indifferent attitude and misbehaviour on the part of the accused No. 1, both the accused to ill-treat the complainant and the accused No. 1 with common intention of the accused No. 2 had been creating heavy mental tensions and subjecting this complainant to suffer excruciating mental and physical tortures and misery for no fault of hers.
9. That the accused did not allow this complainant to go to her parents', and on many occasions, this complainant was starved by them, and she was also not allowed to talk to neighbours.
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