CONTINUOUS ASSESSMENT TASK-III

DRAFTING PLEADING AND CONVEYANCING

ASSIGNMENT-III
COURSE CODE: LAW 540

“Criminal Complaint under

the pertinent provisions of
Law.”

Submitted To: Submitted By:

Ms. Ankit Paul Kaur Saloni Jain
Assistant Professor of Law BBA. LLB. (Hons).
School of Law L1704
Lovely Professional University 11713684
 IN THE COURT OF THE HON’BLE JUDICIAL MAGISTRATE FIRST CLASS,

HYDERABAD

CRIMINAL COMPLAINT NO. 321 of 2012

MEMO OF PARTIES

Mrs Monal Jagtani, aged 27 years, D/o Mr. Sudhir Jagtani, W/o Mr. Pranay
Manchanda , R/o House No. B-11/111, Patel Chowk, Near Main Post Office,
Hyderabad

… COMPLAINANT

Versus

Mr. Pranay Manchanda , aged 29 years, S/o Mr. Janardhan Manchanda , R/o
H.No. 168, Adarsh Nagar, Arya Samaj Road, Hyderabad

… RESPONDENT

Elaborated Criminal Complaint under Section 156(3) r/w

Section 190 (a) of the Code of Criminal Procedure, 1973 for
disclosure of offences under Section 498A, 506, 325, 495 of
the Indian Penal Code r/w Section 3 of The Protection of
Women From Domestic Violence Act, 2005 & pertinent
provisions thereof.

__________________
District & Sessions Court, Saloni Jain
Hyderabad
Advocate
Date: 21.12.2012
Counsel for Complainant
If It May Please Your Lordship

Most Respectfully Showeth as follows:

1. That the complainant & the respondent are the legally wedded husband &
wife of each other and their marriage was solemnized on 02.12.2004 at
Hyderabad as pert the Hindu rites, rituals and customs. A copy of the Aadhar
card of the complainant is appended with the complaint. (Mark A)
2. That on 25.12.2004, the respondent took the complainant to United
Kingdom and the marriage was duly consummated on 29.12.2004 by both
the parties.
3. That on 29.12.2004, on the very same day of consummation, the respondent
started hurling abuses at the complainant and inflicted such actions on her
body which eventually resulted in physical illness to the complainant
thereby causing grave injury to her life, limb & health.
4. That the respondent made bitter verbal diatribes and started questioning the
respondent’s fidelity accompanied by driving abuses on the futile
assumption of incapability of conception of children. This caused severe
verbal & emotional abuse to the complainant.
5. That the couple visited & consulted the qualified gynecologist by the name
of Dr. Rush Spencer. The diagnosis prognosticated the respondent to be
suffering with prostrate, due to which the wife was not able to conceive.
Therefore, it was the respondent who was not able to entitle conception to
the complainant.
6. That on 10.12.2005, both the parties returned to India on the account of the
death of the father of the respondent; where the complainant was treated
with ill will, hate & hostility by the respondent & his family members. As a
consequence thereof, this undignified behavior caused a huge mental trauma
 to the complainant. The couple went back to United Kingdom after
performing the last rites of the respondent’s father.
7. That on 03.011.2006, both the parties returned to India on the account of
death of the complainant’s mother. The behavior of the respondent was not
obliging as he blatantly refused to stay with his wife’s family & stood back
with his own family.
8. That the respondent started raising additional monetary demands from the
complainant; thereby causing& inflicting severe economic abuse on the
complainant’s shoulders.
9. That the complainant was subjected to merciless beating accompanied by
consecutive threatening on the part of the respondent for signing the papers
which sanctioned the husband for undergoing a third marriage. It is pertinent
to mention here that the respondent was already married to a girl named
Kamakshi Mehta, and the same fact was concealed and suppressed from the
complainant.
10. That the complainant was in a habit of recording all these events in a diary
whenever she was burdened with suicidal thoughts & this diary was
destroyed by the respondent.
11.That on 20.03.2008, the complainant & the respondent returned to India &
the complainant was sent to her parent’s house at Khammam by the
respondent which tends to be a behavior of sidelining and avoidance.
12.That the father of the complainant decided to conciliate the situation
between the both. It is pertinent to mention here, that during this phase the
complainant & his brother Srinivasa Rao, caused grievous hurt to the
complainant by inflicting kick-blows on her stomach.
13.That the complainant was held by her tuft & was forced to inscribe her
signatures on the divorce papers, thereby subjecting the complainant with
great pain & agony.
14. That the respondent is a wife beater & has caused immense cruelty,
physical, emotional and verbal abuse by threatening the complainant &
suppressing the material facts of his prior marriage & has also caused
painstaking grievous hurt to the complainant by inflicting kick-blows on her
sensitive body areas.
15. That the Hon’ble Court is having complete jurisdiction to entertain and try
the present complaint because the offences are committed within the
jurisdiction of this Hon’ble Court.

****
 PRAYER CLAUSE
1. It is therefore, most respectfully prayed that this Hon’ble Court be pleased to
summon the accused under the relevant provisions of law & the accused by
tried and punished in accordance with the law for the aforesaid offences
committed by him.
2. That a protection order be passed by the Ld. Court in its wisdom prohibiting
the respondent from committing any act of domestic violence under the
relevant provisions of The Protection of Woman From Domestic Violence
Act, 2005.
3. Any other relief, as the Court in exercise of its judicial wisdom, deems fit.

Dated: 21.12.2012
COMPLAINANT
THROUGH
ADVOCATE

_____________
Saloni Jain
VERIFICATION:

I, Monal Jagtani , the concerned complainant in this case, do hereby certify that the
contents of the Para 1 to 15 are true and best to my knowledge and as derived
from the records of the case, no part of it is false or malafide and nothing has been
concealed there from.

Verified at District & Sessions Court, Hyderabad, Delhi on 21.12.2012.

_______________

Monal Jagtani

Deponent
 PW-1/A

IN THE COURT OF THE HON’BLE JUDICIAL MAGISTRATE FIRST CLASS,

HYDERABAD

CRIMINAL COMPLAINT NO. 321 of 2012

MEMO OF PARTIES

Mrs Monal Jagtani, aged 27 years, D/o Mr. Sudhir Jagtani, W/o Mr. Pranay
Manchanda , R/o House No. B-11/111, Patel Chowk, Near Main Post Office,
Hyderabad

… COMPLAINANT

Versus

Mr. Pranay Manchanda , aged 29 years, S/o Mr. Janardhan Manchanda , R/o
H.No. 168, Adarsh Nagar, Arya Samaj Road, Hyderabad

… RESPONDENT

AFFIDAVIT

I, Monal Jagtani, aged 27 years, D/o Mr. Sudhir Jagtani, W/o Mr. Pranay
Manchanda , R/o House No. B-11/111, Patel Chowk, Near Main Post Office,
Hyderabad do hereby solemnly affirm and declare as under:

1. That I am the complainant in the accompanying case and I am well

conversant with the facts and circumstances of the case & application to
depose the present affidavit.
2. That I have read & understood the contents of the accompanying complaint
& state that the same are true and correct to the best of my knowledge.
 3. That no part of the petition is false and nothing has been concealed there
from.
4. That no other petition concerning the same issue has been filed in any other
coordinate court, superior court or any foreign court.

____________

Deponent

VERIFICATION:
Verified at District & Sessions Court, Hyderabad, on 21.12.2012 that the contents
of the above affidavit are true and correct to my knowledge and as derived from
the records of the case, no part of it is false and nothing material has been
concealed there from.

_____________ ________________

Monal Jagtani THROUGH

Deponent Saloni Jain

ADVOCATE
 LIST OF WITNESSES (ENCLOSED COPY)

1. Ms. Monal Jagtani, the Complainant

2. Sudhir Jagtani, Father of the Complainant

3. Dr. Rush Spencer, Gynecologist, Spencer Clinic, Baker Street, United Kingdom,
London.

4. Mr. Ramesh Kumar Garg, relative of the Complainant