IN THE COURT OF SESSION, ……

Criminal complaint no…of ….2007.

Shri…….
(Name, description and full address of the complainant) Complainant

Versus
Shri…..
(Name, description and full address of the accused)
Mrs…………………………………………..
(Name, description and full address of the accused) Accused

COMPLAINT UNDER SECTION 500 AND 501 R/W SEC. 34

INDIAN PENAL CODE, 1980.

It is most respectfully submitted as under:

1. That the complainant has been working as a active member of the political
party…, since…

2. That the Mr. XYZ (herein called accused no. 1) who is the member of the rival
political part….and Mrs. (herein called accused no. 2 ) is the wife of the accused
no. is also an active member of the …..(Name of the political party.)
3. That the accused no. 1 had published the pamphlets and distributed in the public
at large with the defamatory substance against complainant’s political party and
substance abusing complainant. A copy of the pamphlet is enclosed as Annexure-
A.

4. That the wife of the accused was also actively involved in the printing and
distribution of pamphlet.

5. That the complainant is having photos of the accused no 1 and accused no 2 while
distribution the pamphlets. A copy of the Photo is enclosed as Annexure B.

6. That the pamphlet enclosed in the annexure A is false, fabricated, imaginary,

baseless and defamatory allegations made by the accused no 1, 2 and 3. the
complainant is under constant tension and tortures.

7. That the case of action for this complainant first arose on…, on the day of
distribution of the pamphlet. And the complaint filed is well within limitation.

8. 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.
 9. that the complainant , therefore, prays that the accused be kindly charged with and
tried for the offence punishable u/s 500 and 501 r/w sec. 34 of the Indian Penal
code and punished according to law.

Pune,
Dated:-------------

Sd/-
Complainant
Sd/-
Advocate for the Complainant.
List of the documents:

VERIFICATION