To

The worthy Senior Superintendent of Police,

Amritsar.

Sub:- Complaint against Kuldeep Kumar S/o Ram Chand R/o

H.no._______,Gali No.1, Himmat pura, near gujjar pura,
Amritsar.

Sir,

It is respectfully submitted as under:-

1. That marriage of the applicant with culprit Kuldeep Kumar was

solemnized on 4-02-2001 at Janj ghar(shivala mandir) chowk
lakshmansar,Amritsar according to Hindu rites and traditions.
Before the solemnization of marriage Shagun ceremony was also
performed on 2-02-2001 at Amritsar. At the time of marriage and
shagan ceremony, parents of the applicant had given huge dowry
articles in the shape of gifts to culprit and his parents and other
relatives. List of the dowry articles is attached herewith. Beside this
parents of the applicant had also given lot of gold ornaments and
other articles to the applicant at the time of marriage and it was
specifically stated by the parents of the applicant to the culprit and
his parents that such articles are the Istridhan of the applicant.
Culprit and his parents assured that they will hand over the said
articles to the applicant for her own use as and when she will
demanded and as and when she will reach the matrimonial home.
The marriage was solemnized with great pomp and show and more
than 300 persons attended the marriage from the side of culprit and
near about 100 persons attended the marriage from the side of
applicant.
2. That after the solemnization of marriage applicant and culprit
cohabited together as husband and wife in the matrimonial house of
the applicant and soon after the marriage of the applicant with
culprit, behaviour and attitude of the culprit was not good towards
the applicant and he used to taunt, maltreat and tease her. Even he
used to beat the applicant and culprit and his family members used
to torture by saying that they expect for much more dowry and the
articles which her parents had given to them is of inferior quality
and as such they demanded dowry from the applicant. The
applicant was not allowed to stay in her matrimonial house and in
the month of may, 2003, applicant was turned out of her
matrimonial house on account of demand of dowry by accused
 Kuldeep Kumar.The culprit demanded Rs.50,000/- in cash from
applicant as he wants to start a new business. When applicant told
to the accused that her parents are not in a position to give the
aforesaid money and on listening these words from the mouth of
the applicant, accused gave severe beatings to applicant and was
turned out of the house. But with the intervention of respectables
matter was compromised and applicant was allowed to keep in her
matrimonial house.
3. That out of wedlock, one daughter namely Neha was born on 5-06-
2002 at civil hospital, Amritsar and one son namely Arun was born
on 11-10-2003 at Aggarwal Nursing Home, lakkad mandi, near
Jallianwala Bagh, Amritsar and at that time all the expenditure was
incurred by the parents of applicant. At the time of birth of both
children lot of gifts as per the demand of culprit was given by the
parents of the applicant.
4. That the culprit is habitual drunkard and drug addict. He used to
drink liquor every day and gave merciless beatings to the applicant
every day. In the month of sept,2005 she was turned out of her
matrimonial house at night in three wearing apparels and accused
told that in case u want to live in her matrimonial house she has to
bring 50,000/- in cash. The applicant came back to house of her
parents and she narrated all the facts to her parents then with the
help and intervention of the respectables, applicant was allowed to
live in her matrimonial house and accused assured to the parents
and the respectable that he will not taunt and harass to the applicant
and will not demand for any kind of things. Whenever parents of
the applicant came to the matrimonial house of applicant to meet
her and when they give gave some money to applicant to spend,
accused snatched the money and articles from applicant. Accused
used to lock the applicant in one room and he did not provide food
to the applicant. Applicant had requested to accused many times
but he did not listen the genuine requests of the applicant.
5. That culprit did not mend his ways and he again started maltreated
the applicant but applicant tolerated all such things for the sake of
her children.
6. That it was on 08.4.2009 when applicant was beaten mercilessly by
the culprit and was turned out the matrimonial house, then
applicant came back to house of her parents and she narrated
incident to her parents and then parents of the applicant along with
respectable had gone to the house of accused to reconcile the
matter but the accused flatly refused to keep the applicant and
children with him and he defame the parents of applicant and
respectables and also declared that he will not return the
dowry/istridhan belonging to applicant and had given threats of
dire consequences if any one came to him with such demands and
 then applicant and her parents had gone to police station ‘C’
division and after conducting the medical examination by the
doctors, police of police station ‘c’ division has lodged a FIR
bearing no.______under section 323/324 IPC against the culprit.

7. That the accused kuldeep kumar have criminally breached the trust
and mis- appropriate the ISTRIDHAN of the applicant which her
parents had given to her for her own use and refused to return the
same and also maltreated her and demanded dowry. As such culprit
has committed criminal offence for which he is liable to be
punished and a case is liable to be registered against him.
It is, therefore, humbly requested that kindly intervene the
matter and a case may be registered against the culprit and he may
be dealt according to law and Istridhan of the applicant may be
recovered and returned to applicant in the interest of justice.

Applicant

Roshini sharma
dated: D/o Kahan chand R/o
H.no.1454/8,chowk
jai singh,gali gujjar
wali,near gilwali gate
Amritsar.
 List of dowry articles

2-02-2001 shagun ceremony:-

1. Videocon color T.V.

2. one kelvinator refrigerator
3. one fan
4. sofa
5. bed
6. one gold chain
7. one gold ring
8. one gold ring to brother uttam chand
9. 11 boxes of sweets
10. 3100/- cash as shagun

4.2.2001 day of marriage

1. three milinis
 father-one blanket and 500/- cash;
 brother- one blanket and 500/- cash;
 mama- one blanket and 500/- cash;
2. Rent of janj ghar(shivala mandir)
3. Food,sweets,coffee,cold drinks,snacks,etc.
for 400 persons Rs.20,000/-

Muklawa

 1 gold set for bride

 One pair silver panjeban for bride
 Utensils-dinner set,12 glasses,12 plates,12 katoris,1 dozen
spoon,1 cooker Hawkins;
 7 bistere.2 gadde,2 rajai;

complainant….Roshini sharma
D/o Kahan chand R/o.1454/8,
chowk jai singh,gali gujjar wali,
near gilwali gate,Amritsar.
The worthy Senior Superintendent of Police,
Amritsar.

Sub:- COMPLAINT AGAINST 1.lucky kumar S/O

AMARJEET 2.AMARJEET,3.PARVEEN W/O
AMARJEET,4.SUNNY S/O AMARJEET,5.MALA W/O
SUNNY, ALL RESIDENT OF HOUSE NO. 642,
EKTA NAGAR,CHAMRANG ROAD, AMRITSAR.

Sir,

It is respectfully submitted as under:-

1. That marriage of the applicant with culprit LUCKY

Kumar was solemnized on 12-03-2008 at RAVINDRA
INTERNATIONAL, CHAMRANG ROAD, Amritsar
according to Hindu rites and traditions. Before the
solemnization of marriage RING CEREMONY
ceremony was also performed on 26-07-2007 at
MARRIAGE IN,100 FT ROAD,Amritsar. At the time
of marriage, parents of the applicant had given huge
dowry articles in the shape of gifts to culprit and his
parents and other relatives. List of the dowry articles is
attached herewith. Beside this parents of the applicant
had also given lot of gold ornaments and other articles
to the applicant at the time of marriage and it was
specifically stated by the parents of the applicant to the
culprit and his parents that such articles are the
Istridhan of the applicant. Culprit and his parents
assured that they will hand over the said articles to the
applicant for her own use as and when she will
demanded and as and when she will reach the
 matrimonial home. The marriage was solemnized with
great pomp and show and more than 600 persons
attended the marriage from the side of culprit and near
about 800 persons attended the marriage from the side
of applicant.
2. That accused no.1 is husband of the complainant, accused no.2 is
father-in-law, accused no.3 is mother-in-law, accused no.4 is
BROTHER-in-law of the complainant, accused no.5 is WIFE OF
accused no.4.

3. That after the solemnization of marriage applicant and

culprit cohabited together as husband and wife in the
matrimonial house of the applicant and after the ONE
MONTH OF marriage, behaviour and attitude of the
culprit was not good towards the applicant and after the
period of ONE month the accused no.1 to 5 started taunting to the
complainant and they all told to complainant the her parents had
not given much dowry as per their status and articles which they
had given are not of their status and all the accused no1 to 5 in
connivance with each other had started taunting to complainant and
they all demanded RS.1,00,000/- CASH from the complainant as
accused no. 1 wants to start a new business and when complainant
told to accused no.1 to 5 that her MOTHER AND SISTER had
already given lot of dowry articles to them and now they are not in
a position to give CASH Rs.1,00,000/- to them and on listening
gave
these words from the mouth of the complainant accused
severe beatings to applicant and was turned out of the
house. But with the intervention of respectables matter
was compromised and applicant was allowed to keep in
her matrimonial house.

4. That out of wedlock, one son was born on 10-07-2009

at aggarwal Hospital, Amritsar, which was expired
later on.thereafter, one female child namely sonam was
 born on 02-12-2011 at Amritsar. At the time of birth of
both children lot of gifts as per the demand of culprit
was given by the parents of the applicant.

5. That the culprit is habitual drunkard and drug addict.

He used to drink liquor every day and gave merciless
beatings to the applicant every day. In the month of
sept, 2005 she was turned out of her matrimonial
house at night in three wearing apparels and accused
told that in case u want to live in her matrimonial house
she has to bring 50,000/- in cash. The applicant came
back to house of her parents and she narrated all the
facts to her parents then with the help and intervention
of the respectables, applicant was allowed to live in her
matrimonial house and accused assured to the parents
and the respectable that he will not taunt and harass to
the applicant and will not demand for any kind of
things. Whenever parents of the applicant came to the
matrimonial house of applicant to meet her and when
they give gave some money to applicant to spend,
accused snatched the money and articles from
applicant. Accused used to lock the applicant in one
room and he did not provide food to the applicant.
Applicant had requested to accused many times but he
did not listen the genuine requests of the applicant.

6. That culprit did not mend his ways and he again started
maltreated the applicant but applicant tolerated all such
things for the sake of her children.

7. That it was on 08.4.2009 when applicant was beaten

mercilessly by the culprit and was turned out the
 matrimonial house, then applicant came back to house
of her parents and she narrated incident to her parents
and then parents of the applicant along with respectable
had gone to the house of accused to reconcile the
matter but the accused flatly refused to keep the
applicant and children with him and he defame the
parents of applicant and respectables and also declared
that he will not return the dowry/istridhan belonging to
applicant and had given threats of dire consequences if
any one came to him with such demands and then
applicant and her parents had gone to police station ‘C’
division and after conducting the medical examination
by the doctors, police of police station ‘c’ division has
lodged a FIR bearing no.______under section 323/324
IPC against the culprit.

8. That the accused kuldeep kumar have criminally

breached the trust and mis- appropriate the
ISTRIDHAN of the applicant which her parents had
given to her for her own use and refused to return the
same and also maltreated her and demanded dowry. As
such culprit has committed criminal offence for which
he is liable to be punished and a case is liable to be
registered against him.
It is, therefore, humbly requested that kindly
intervene the matter and a case may be registered
against the culprit and he may be dealt according to law
and Istridhan of the applicant may be recovered and
returned to applicant in the interest of justice.
 Applicant

Roshini sharma
dated: D/o Kahan chand
R/o
H.no.1454/8,chowk jai
singh,gali gujjar
wali,near gilwali gate
Amritsar.