Here we will discuss about the modal draft format a criminal complaint filed under section 323, 325, 506, 34 of IPC along with an Application Under Section 156(3) Cr.P.C. for Investigation and Registration of the FIR against the accused persons.

IN THE COURT OF ILLAQUA MAGISTRATE ________.

Aijaj son of Sh. _________

                                .…COMPLAINANT.
VERSUS

1- Amrin D/o _________

2- Salauddin son of

3- Nasir son of Salauddin

4- Smt. Khurshid wife of Salauddin

All residents of________.

                                   …..Accused

CRIMINAL COMPLAINT UNDER SECTION 323/ 325/506/34 OF IPC.
                                                                                   Police Station:
R/Sir,
The complainant most humbly submits as under :-

1- That on dated ________ at about 10.00 AM when the complainant was going to work and approached near Mathura Road from his house and the said accused persons were standing in a lonely corner of the bye-lane and made the complainant to stop there. And all the said accused persons were armed with iron rods and hockey sticks. That upon his so stopping the said accused persons forcibly asked the complainant to sign a TALAKNAMA to divorce his wife Amrin i.e. the accused NO.1.

2- That when the complainant refused to sign the said TALAKNAMA forcibly all the said accused persons then started beating the complainant by iron rods and hockey sticks and thereafter all of them forcibly put him inside a Maruti Van and tried to take him away but after some distance seeing the traffic police on duty they threw him outside the Van and due to so throwing of the complainant out of the Van and injuries inflicted by the said accused persons by iron rods and hockey sticks the complainant suffered serious injuries and fall unconscious.

3-That the traffic police on duty tried to bring him into his senses and when he regained consciousness he gave address and Telephone No. of his father to the said traffic police Staff who in turn called his father who had got him admitted in Hospital.

4- That in the said Hospital the complainant was got medico legally examined. The MLR No_______ dated _____ was prepared by Dr. ______, M.O on duty at Hospital which is Annexure –A. And as per the injury No. 1 he was advised X-Rays and was to be kept under observation (KUO). Accordingly his X-Rays conducted vide MLX No. _____ dated ____ according to which the complainant suffered fracture of clavicle bone , injury on left shoulder and skull due to which the complainant remained admitted in B.K. Hospital, for one week under intensive treatment. The MLX is Annexure –B.

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5- That even though the Doctor on duty at Hospital sent a Rukka to the concerned Police Station _______ but police did not turn up to record the statement of complainant and after discharge of complainant the complainant and his father filed a complaint to the Illaka Police post but no action so far has been taken by the Police which means that the accused persons are hand in gloves with the accused party.

6-That the accused persons with common intention and in collusion with each other inflicted serious injuries upon the complainant, and the complainant was mercilessly beaten up by the accused persons and due the said beatings of the accused persons the complainant had suffered multiple injuries including fracture of clavicle bone and remained admitted in _____ Hospital, for about one week and suffered a lot of mental and physical pain. The accused persons also threatened to kill the complainant and pressurized him to sign the Divorce Deed hence the accused persons have committed offences under section 323/325/506/34 IPC for which they are liable to be prosecuted and punished as per the provisions of the law.

7- That the accused persons committed the offence at ________, which falls under police post ______ within the territorial jurisdiction of this Hon’ble court therefore this Hon’ble Court has got the jurisdiction to entertain and try the present complaint.

PRAYER:-

It is, therefore, most respectfully prayed that the accused may kindly be summoned through non-bailable warrants and punished, prosecuted, convicted and sentenced in accordance with the law.

Dated ________ Complainant

Through counsel:

IN THE COURT OF ILLAQUA MAGISTRATE ________.

Aijaj …COMPLAINANT.

VERSUS

Amrin & Others …..Accused

CRIMINAL COMPLAINT UNDER SECTION 323 / 325 / 506/ 34 OF IPC.

List of Witness

1- Complainant

2- Shri Jamaluddin

3- Dr. _______, M.O., ______Hospital alongwith the record of MLR & MLX.

4- ________

5- ____________

6- Any other witnesses if later on required shall be produced before this Hon’ble court.

Dated ________ Complainant

Through counsel:

IN THE COURT OF ILLAQUA MAGISTRATE ________.

Aijaj Vs Amrin and others

CRIMINAL COMPLAINT UNDER SECTION 323/325/506/34 OF IPC.

Application Under Section 156(3) Cr.P.C. for Investigation and Registration of the FIR against the accused persons.

Respectfully Showeth

1- That the complainant/applicant has filed the above noted complaint today before this hon’ble court, the contents of which may be read as part and parcel of this application as the same are not being reproduced here for the sake of brevity and avoidance of repetition.

2- That it is very necessary to investigate the matter through the SHO, Police Station _________ and to get registered the FIR/case against the accused persons as a thorough investigation is necessary to be conducted and recovery of dowry articles are to be recovered and which can only be done by the investigation of the case by police.

It is therefore, prayed that present complaint may kindly be sent to the Police Station ______ for investigation and lodging the FIR against all the accused persons under Section 156(3) Cr.P.C. in the interest of justice, equity and fair play.

Dated _______