Criminal Complaint (Sections 323 & 504 read with Section 34 IPC) (India) by OLL

Open Legal LibraryUpdated 19 Oct 2026

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CRIMINAL COMPLAINT Sec 323 & 504 R W SEC. 34 OF THE INDIAN PENAL CODE

IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS,

KHADKI AT KHADKI

Criminal Complaint No./200_

Shri __ B __ B _ K _,)

age 30 years, occupation - service, )

Complainant

resident of 100 Shitolenagar, Sangavi,)

PUNE 411 027.)
Versus

1. Shri _ K __ V _ A __,)
age 56 years, occupation - agriculture,)

2. Smt. __ A ___ B _ K _,)
age 25 years, occupation - household,)

3. Shri _ D __ K _ A __, )
age 30 years, occupation - service,)

4. Shri __ S __ K __ A __, .)
age 25 years, occupation - education,)
all residents of Yeli, Taluka Pathardi,)
District Ahmednagar.)

A COMPLAINT U/SS 323 & 504 R/W SEC. 34 OF THE INDIAN PENAL CODE

The complainant abovenamed submits this complaint, praying to state as follows:

1. That the complainant is a resident of the within mentioned address, and the accused No. 2 is his legally wedded wife, while the accused No. 1 is her father and the accused Nos. 3 and 4 are her brothers.

2. That the complainant is originally a resident of the village Yeli, Taluka Pathardi, District Ahmednagar.

3. That on account of his service in the Bajaj Tempo Limited, Chinchwad, Pune, the complainant has presently been residing at the within mentioned address for the last five years.

4. That the complainant was married to the accused No. 2 in the year 20, and they have a son of about three years.

5. That due to some misunderstanding on the part of the accused No. 2 and at the instance of the accused Nos. 1, 3 and 4, the accused No. 2 has not been cohabiting with the complainant for the two years, and during this period, she has all along been residing with the accused No. 1 only.

6. That despite several requests and a lot of persuasion made by this complainant, his parents and also reconciliation tried by the relatives- in-common, the accused No. 2 has never turned up to cohabit with the complainant and has also wittingly and willingly refused to cohabit for no fault on the part of the complainant.

7. That in the mean time, instead of responding to the requests and appeals repeatedly made by this complainant with a view to restoring back the normalcy of his domesticity with the accused No. 2, the accused No. 2 has filed a maintenance application in the Pathardi Court, and the same has since then been pending in that court of law.

8. That even though the said case between the complainant and the accused No. 2 is already sub judice, all the accused on their own pursued the complainant upto Pune and thereby committed the following offence.

This is a preview. The full template is free on GitLaw.

This document is a formal template for filing a criminal complaint in an Indian court under Sections 323 and 504 of the Indian Penal Code. It is designed for cases involving voluntary hurt and intentional insult with common intention, typically arising from domestic or personal disputes.

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About this template

What is this template?

This is a private criminal complaint addressed to a Judicial Magistrate First Class in India. It is not a First Information Report (FIR) filed with the police; it is a direct petition to the court to take cognizance of offences involving multiple accused acting with common intention. The document specifically includes a verification section where the complainant must state the facts are true on solemn affirmation.

When should you use it?

Use this filing when the police have not acted on a report of physical hurt or when you wish to pursue a private prosecution for offences under Sections 323 and 504 IPC. If the grievance is purely civil or involves a property dispute without physical assault, use a Civil Suit Plaint instead.

Who it's for

  • a resident of Pune seeking to initiate criminal proceedings against relatives
  • an individual reporting an assault that occurred near Khadki Station
  • a complainant alleging physical torture and mental harassment by multiple accused persons

How long it runs and how it's signed

How long
Used once
Signed by
Complainant, Advocate for Complainant
Witness
Not required
Notarisation
Not required
Also needed
verification on solemn affirmation; payment of court-fee

Law it's drafted under

Governed by
Section 323 IPC
Governed by
Section 504 IPC
Governed by
Section 34 IPC
Governed by
Indian Penal Code
Jurisdiction
India
Document info
MS Word. Document created on Fri Jul 24th, 2026. Last updated on Mon Oct 19th, 2026.
This document is public
Licensed under CC BY 4.0 (Attribution).
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