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To

S.H.O.
Police Station
xxxxx xxxxx,
New Delhi
Sub:- Request for registration of case against Smt. xxxxxx and accomplices
Respected Sir
It is submitted that undersigned got married on xx-xx-xxx with Smt xxxxxxx d/o
xxxxxxx R/o address as per Sikh rituals. Ours was a love marriage after a courtship of 7
yrs. which took place after my mutual consent divorce from my first wife due to
inducement /interference on the part of Smt. xxxxx in our married life. Two children
Master Meet aged 5 yrs and Master Parinit 3 yrs were born from this marriage which
are in the custody of Smt. Xxxxxxxxx. Soon after our marriage Smt. Xxxxxxxxx started
abusing and quarrelling with me on one pretext or the other. To resolve the matter and to
save our marriage I requested in person as well as by way of written submission to the
concerned authorities /officers (Annexure A, Annexure B). But nothing solved our
problems and because of this tension/harassment I got suffered from High Blood Pressure
due to Left Ventricular Hypotrophy (LVH) in my heart and now living on medicines. Smt.
Xxxxxxxxx is of indifferent nature women whose behaviour towards married life was
highly irresponsible as she has no interest in daily household works, cooking, taking care
of children and being social. On 04/10/2007 due to her above mentioned habits she has
mercilessly beaten the minor child Meet, and on enquiring her about the same, she made
quarrel with me and left for her parents home without any reasonable cause and filed a
false complaint in the CAW Cell, Nanak Pura, New Delhi vide no. nnn/2007. Being
employee of Delhi Police, the law and enforcement organisation and remained posted in
CAW Cell, Nanak Pura for more then 5 yrs and by virtue of her experience and
knowledge, she grossly misused the law with the help of Insp. Xxxxxxxxx and Insp.
Xxxxxxxxx, who accomplice her with ulterior motives best known to them. They over
ruled all the laws and regulations despite the instructions in the circular 07/2007 dated
23/03/2007 issued by Commissioner of Police which are evident from the followings:1. List of Stridhan submitted by Smt Xxxxxxxxx (Attached as Annexure C) was not
maintainable as it was not as per Rule 2 of Dowry Prohibition (Maintenance of
List of presents to the bride and bridegroom) Rules of 1985 and is direct
violation of law by Smt. Xxxxxxxxx and hence the same was false and fabricated
which was not even cared by Insp. Xxxxxxxxx, I.O. (the then) of CAW Cell,
Nanak Pura.
2. The undersigned requested in writing (Annexure D) to Joint. C.P., Caw Cell, to
ask Smt. Xxxxxxxxx to submit bills for genuineness of claims of her list of Stridhan
but Insp. Xxxxxxxxx neither cared nor Smt. Xxxxxxxxx submitted any bills to the
satisfaction of the undersigned for her claim and she managed to extort all items

which undersigned has handed over all the items to Smt. Xxxxxxxxx vide list
dated 07/12/2007 (Annexure E).
3. Despite the clear direction /orders of Honble High Court CRL.M.C.7262/2006
dated 23/02/2007 (Annexure 1) and Commissioner of Police Circular no. 07/2007
dated 23/11/2007 (Annexure 2) which states that where there is expenditure of
a huge amount of money without disclosing the source of income , police
should insist upon compliance of Rule 2 of dowry Prohibition (Maintenance of
lists of presents to the Bride and Bridegroom ) rules , 1985 and should not
entertain any complaint if the rules have not been complied with . The source
of income was not verified from the income tax returns of Smt. Xxxxxxxxx, Sh.
Xxxxxxxxx(Father) and Sh. Xxxxxxxxx (Brother) and Smt. Xxxxxxxxx
(Mother). The ruling of the Honble High Court order mentioned above has been
violated and the same was ignored by the I.O. Insp. Xxxxxxxxx and Insp.
Xxxxxxxxx and on their recommendations FIR No. nnn/2008 under section
498A/406/34 of IPC has been registered in Police Station Dabri against
undersigned and his relatives. IPC 406 was intentionally invoked with malafied
intention to frame undersigned even when there is no allegation in FIR regarding
Stridhan not returned. Even the 498A is being registered merely on the statement
of Smt. Xxxxxxxxx where no MLC or other record of any grave injury was
specifically stated by the complainant and hence the FIR is false(Annexure F)
and is an effort to convert failed marriage into a criminal case against undersigned
and his relatives.
4. Smt. Xxxxxxxxx has submitted one complaint dated 25/01/2008 in the office of
Commissioner of Police (Annexure G) in which she admitted that she and her
parents had given dowry to the undersigned. Therefore as per the direction of
Honble High Court CRL.M.C.7262/2006 dated 23/02/2007 and also Circular no.
07/2007 dated 23/11/2007 issued by Ld. Commissioner of Police, Delhi, Smt.
Xxxxxxxxx, her father Sh. Xxxxxxxxx, Mother Smt. Xxxxxxxxx also become
accomplices under section 3 of dowry Prohibition Act, 1961 and appropriate
action should also be taken against them.
5. It is further submitted that WHC Smt. Xxxxxxxxx has already performed gross
misconduct by misusing the Govt. Loan for two wheeler as she had taken a
scooter loan during her posting in CAW Cell, Nanak Pura, New Delhi in the

month of March 2003 but neither purchased any scooter nor intimated the same to
the department (Annexure H :- Salary Slip showing deduction of scooter advance
and Annexure I: RTI reply from PIO, CAW Cell, Nanak Pura, New Delhi) and
hence she is also liable for action under CCS conduct Rules.
6.

Enquiry officer Sub Inspector Xxxxxxxxx under the influence of Smt.


Xxxxxxxxx with malafied/ulterior motive best known to him visited the residence
of my Senior Citizen parents Sh. Xxxxxxx r/o address on 19/06/2008 at about
2300 hrs and harassed the senior citizen and also forced to receive fake summon
of Honble Court even knowing the fact that the Ld. A.S.J. Sh. Xxxxxxxxx has
already issued the orders that father and mother are not wanted in this case and
need not appear in court in this bail application as stated by I.O. and complainant
on 07/06/2008 (Annexure J) just before the final hearing of the bail application.
The same was strongly condemned by the Honble A.S.J. and warned the I.O. for
future.

7. Smt. Xxxxxxxxx purchased one scooter no. xxxxx xx xx in the month of mm m


yyyyfrom M/s xxxxxxxxxx, which is from the unaccounted money, earned by
way of illegal means from her Traffic posting, to which undersigned has given
application (Annexure K) but no action was taken by the concerned authorities
against her till date. The payment of the same was given by a City Bank Credit
Card which was issued to her brother Sh. Xxxxxxxxx which can be verified from
the bill of scooter and the credit card details of her brother.
8.

Therefore you are requested to kindly register the case for being congnizable
offence ouccrred as per the direction of Honble High and take necessary action
against Smt. Xxxxxxxxx, her father Sh. Xxxxxxxxx, her mother Smt.
Xxxxxxxxx , Insp. Xxxxxxxxx and Insp. Xxxxxxxxx of CAW Cell, Nanak Pura
and Sub Inspector Xxxxxxxxx of P.S. Dabri for Contempt of Court Order and
Gross negligence in performing Govt. Duties and under section 3 of Dowry
Prohibtion Act along with sections 120B, 177, 182, 191, 192, 193, 194, 195, 196,
199, 200, 209, 211, 383, 388, 406, 464 506 and 34 of IPC.

9. It is necessary to mention here as per the guidelines of various Honble Courts


and Commissioner of Police circular that the police is duty bound to register FIR

immediately in the case any cognizable offence is reported without starting any
enquiry on the information received as per following orders:-

a. HOBBLE SUPREME COURT OF INDIA in Criminal Appeal No. 1229


of 2002 in title RAMESH KUMARI VS STATE(NCT OF DELHI) &
ORS. Dated 21/02/2007 held in 2006(1) JCC 468 (Annexure O):4. That the Police Officer mandatorily register a case on a complaint
of a cognizable offence by the citizen under Section 154 of the Code
are no more res-integra. The point of law been set at rest by this
Court in the case of State of Haryana and others vs Bhajan Lal and
others, 1992 Supp(1) SCC 335. This Court after examining the
whole gamut and intricacies of the mandatory nature of Seciton 154
of the code has arrived at the finding in paras 31 & 32 of the
judgment as under :

31. at the stage of registration of a crime or a case on the basis of the information
disclosing a cognizable offence in compliance with the mandate of section 154(1) of the
Code, the concerned police officer cannot embark upon an enquiry as to whether the
information, laid by the informant is reliable and genuine or otherwise and refuse to
register a case on the ground that the information is not reliable or credible. On the other
hand the officer in charge of a police station is statutorily obliged to register a case and
then to proceed with the investigation if he has reason to suspect the commission of an
offence which he is empowered under Section 156 of the Code
to investigate..

33. it is, therefore, manifestly clear that if any information


disclosing a cognizable offence is laid before an officer in
charge of a police station satisfying the requirements of Section
154(1) of the Code, the said police officer has no other option
except to enter the substances thereof in the prescribed form,
that is to say, to register a case on the basis of such
information.

5. The views expressed by this Court in paragraphs 31, 32, and 33


as quoted above leave no manners of doubt that the provision of
Section 154 of the Code is mandatory and the concerned officer is
duty bound to register the case on the basis of such an information
disclosing cognizable offence.

b. HONBLE HIGH COURT OF DELHI in W.P.(Crl.)No. 1266 of 2007


dated 10/10/2007 held in para 7(Annexure P):In all those cases where there is a refusal of registration of FIR,
even where cognizable offence is reported, disciplinary action should
be taken against such police officers. The Courts are unnecessary
being burdened with complaints of writ petitions, where direction are
sought for registration of FIRs.

c.

Ld. Commissioner of Police, Delhi vide circular no. 35/2007 dated


19/11/2007 issued instructions as under(Annexure M):Keeping in view the above directions of Honble High court and
also as per procedure laid down u/s 154 Cr.P.C., First Information
Report (FIR) should be recorded immediately on receipt of
information of cognizable offence.

d. HOBBLE SUPREME COURT OF INDIA in Writ Petitioner (CRL.) No.


68 of 2008 in title LALITA KUMARI VS GOVT OF U.P. 7 ORS. Dated
14/07/2007 held in page 3 (Annexure Q):In view of the above, we feel that it is high time to give directions
to Governments of all the States and Union Territories besides their

Director Generals of Police/Commissioners of Police as the case be


to the effect that if steps are not taken for registration of F.I.Rs
immediately and copies thereof are not made over to the complaints,
they may move the concerned Magistrate by filing complaint
petitions to give direction to the police to register case immediately
upon receipt/production of copy of the orders and make over copy of
F.I.Rs

to

the

complaints,

within

twenty

four

hours

of

receipt/production of copy of such orders. It may further give


direction to take immediate steps for apprehending the accused
persons and recovery of kidnapped/abducted persons and properties
which were subject matter of theft or dacoity. In case F.I.Rs not
registered within the aforementioned time, and/or aforementioned
steps are not taken by the police, the concerned Magistrate would be
justified in initiating contempt proceeding against such delinquent
officers and punish them for violation of its orders if no sufficient
cause is shown and awarding stringent punishment like sentence of
imprisonment against them inasmuch as the Disciplinary Authority
would be quite justified in initiating departmental proceeding and
suspending them in contemplation of the same.
It is pertinent to state that although the matter has already been escalated at
various levels in writing (Annexure L collectively) but despite this no action has been
taken against Smt. Xxxxxxxxx till date due to undue favour by the department and
concerned authorities who are shielding her and encouraging her to misuse the law
and the undersigned is being harassed unnecessarily.
I have full faith on the Ld. Deputy Commissioner of Police that I will be given
justice by initiating a strict action against all the law misusers named above by
registering a case and saving the precious time and burden of judiciary for preventing
undersigned to request the court to initiate action in case of failure.

Attachments :
xxxxx

xxxxx xxxxx

Annexure: 1, 2 and A to L
Copy to :1. Secretory, M.H.A., North Block, New Delhi.
2. DCP, South West Distt.
2. S.H.O. Police Station Dabri

Address