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