APPLICATION UNDER SECTION 156(3) CR.P.C. FOR LODGING CASE/FIR UNDER SECTION 379/408/420/120-B I.P.C. | HOW TO REGISTER FIR U/S 156(3) OF CRPC.

 

 IN THE COURT OF HON’BLE DUTY MAGISTRATE,______

Alauddin son of ________

                                                                       …Complainant.

                           VERSUS

1-   Kamaluddin _________

                                                      …..Accused.

APPLICATION UNDER SECTION 156(3) CR.P.C. FOR LODGING CASE/FIR UNDER SECTION 379/408/420/120-B I.P.C.

      Police Station-

Sir,

         The complainant most respectfully submits as under:-

1-         That the complainant is a respectable person, law-abiding citizen of India and he is the permanent resident of __________. 

2-             That on 05-09-2008 the complainant had purchased a JCB Machine bearing its Engine No. _____, Chassis No.________, Model 2008 yellow coloured from the dealer i.e. M/s __________ and the total billing amount paid by the complainant as per the sale invoice bearing No. KNPL 08:09:567 dated 06-09-2008 was Rs. 20,56,333/-(Rupees Twenty Lacs Fifty Six thousand three hundred & Thirty three).   

3-         That the complainant was running the said JCB Machine in the ________. The accused persons were employed by the complainant as operators and cleaner on the said JCB Machine.

4-          That the mining work was stopped by the Government in the _____ Mines and as such the JCB Machine alongwith the accused persons were standing without any work and in view of this in order to find new job work for the Machine on 05-02-2009 the complainant went to the _____ Mines then he did not find neither the JCB Machine nor the accused persons there at the site.

5-         That the complainant has enquired here and there about the machine and the accused persons but could not found the same.

6-         That thereafter the complainant had visited the village of the accused persons and met their father who told that the accused persons are absconding and they have sold the Machinery for a sale consideration of Rs. 8,00,000/- to some one in Kashmir by preparing forged papers and now they are running /operating the same in Jammu & Kashmir.

7-         That the complainant has made a number of visits in the state of Jammu & Kashmir and in the area of ______ to find out the accused persons and to locate the JCB Machine but the accused persons are absconding and are beyond the power and resources of the complainant.

8-         That the complainant has filed a complaint on dated 26-06-2009 before the S.S.P, _______ but police has not taken any action in this regard and it seems that even the police is hand in gloves with the accused persons.

9-         That the accused persons with the common intention hatched a conspiracy and thereby they dishonestly stolen the JCB Machine of the complainant without the complainant’s consent and further they moved the property out of the reach of the complainant and they further fraudulently sold the JCB Machine to some one else without having any right to do and the accused have committed this offence while under the employment of the complainant and these illegal acts of the accused persons amounts to offences under section 379, 408,420,120-B IPC, hence they are liable to be prosecuted and punished by this Hon’ble court. 

10-      That the complainant resides at village _______, Police Station _______ and the accused had committed the offences  within the territorial jurisdiction of P.S. ______ under the territorial jurisdiction of this Hon’ble court and therefore the this Hon’ble court has got the jurisdiction to entertain and try the present complaint.

11-      That there is a involvement of some other unknown accused as well who helped and conspired with the accused persons to sell the JCB Machine in Jammu & Kashmir and the JCB Machine is presently in the State of Jammu & Kashmir hence the complaint of the complainant needs to be thoroughly investigated by the police as well as JCB machinery is to be recovered from the State of Jammu & Kashmir which can only be done by police.

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.

It is also prayed that the present complaint may kindly be sent to the SHO, Police Station _________ Under section 156(3) Cr. P.C. for lodging the FIR and investigating the case as there is a involvement of some other unknown accused as well who helped and conspired with the accused persons to sell the JCB Machine in Jammu & Kashmir and the JCB Machine is presently in the State of Jammu & Kashmir hence the complaint of the complainant needs to be thoroughly investigated by the police as well as JCB machinery is to be recovered from the State of Jammu & Kashmir which can only be done by police in the interest of justice.

Dated ________                                                 Complainant.

Through counsel:

 

 

 (List of witnesses) 

IN THE COURT OF HON’BLE DUTY MAGISTRATE,FARIDABAD.

Alauddin                      VERSUS                      Fakhruddin etc.

COMPLAINT UNDER SECTION 379/408/420/120-B I.P.C.

                        LIST OF WITNESSES

1-         Complainant himself

2-         Sirajuddin _______

3-         The Director /Manager of M/s K________along with the record of invoice bearing No. KNPL 08:09:567 dated 06-09-2008 amounting to Rs. 20,56,333/-(Rupees Twenty Lacs Fifty Six thousand three hundred & Thirty three).  In respect of the JCB Machine bearing its Engine No. 

4-       Manager of National Insurance Company Limited, 

5-        The concerned clerk of SSP Office 

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

Dated ________                                                 Complainant.

Through counsel: