Complaint Sec 498A RW SEC. 34 OF THE INDIAN PENAL CODE

Sec 498A RW 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. B A D , ) 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.
10. That it is respectfully submitted for the kind information of this Hon'ble
Court that this complainant and her parents tried their best to improve upon
the misbehaviour of the accused No. 1 by requesting the accused No. 2 to
do something with a view to bringing about, at least, some improvement,
but unfortunately, nothing of this sort could happen, and both the accused,
instead of responding positively, started to behave still differently and
ultimately reached a loose end of their future.
11. That this complainant also submits that she being educated, cultured
and of a respectable clan, she has made all sincere, devout and fervent
efforts in this respect, but she is so unfortunate that she has come to the
final conclusion that now nothing could be done in the matter.
12. That on …. and _.. 200_, this complainant was confined to a dark cell in
the house, and she Was given no food and even no water, and the
accused had not only beaten the complainant up but also subjected her to
mental as well as physical cruelty in an inhuman manner.
13. That since it has become totally and practically difficult for this
complainant to stay on further with the accused, she was compelled to go
to her parents' and stay there against her and also their wish.
14. That the cause of action for this complaint first arose on…… and the
same has since then been every day thereafter, and hence, this complaint
filed today is well within limitation.
15. That the offence has been committed within the local limits of the
jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to
try and decide this complaint.
16. That the necessary court-fee is paid herewith.
17. That the complainant, therefore, prays that the accused be kindly
charged with and tried for the offence punishable u/s 498-A R/W Sec. 34 of
the Indian Penal Code and punished according to law.
Pune, Sd/- SAD
COMPLAINANT
Dated : .
Sd/- x Xx ADVOCATE FOR COMPLAINANT
VERIFICATION
I, Smt. SAD, the present complainant, do hereby state on solemn
affirmation that the contents of this complaint in paras 1 to 17 are true and
correct to the best of my knowledge and belief, and so I have signed
hereunder.
Sd/- SAD COMPLAINANT

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34 OF THE INDIAN PENAL CODE

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