IN THE COURT OF THE LD.

ADDITIONAL CHIEF JUDICIAL MAGISTRATE AT

BIDHANNAGAR
Ref : M. P. No. 12 /2022
In the matter of :
Complaint u/s. 156 (3) Cr. P. C.
And
In the matter of :
Smt. Dipali Gon
w/o. Late TusherGon
residing at 185/B, Bangur avenue,
Block – A, Banguravenue, P. S. Lake
Town, Kolkata – 700055.
…………..Complainant
-Vs–
1) NilkamalGon
s/o. Late RadhashyamGon
2) Rita Gon
w/o. Nil Kamal Gon
both are residing at 185/B, Bangur avenue,
Block – A, Bangur avenue, P. S. Lake
Town, Kolkata – 700055.
…………….. Accused persons.
OFFENCE COMMITTED BY THE ACCUSED PERSONS U/s. 498 (A) / 406/307 IPC
The humble petition on behalf of the above
namedcomplainant.

Most Respectfully sheweth :

1. That the complainant is a peace loving and law abiding citizen of India

2. That the complainant is a widow of the younger brother of the Accused No. 1
(Nil Kamal Gon) and the Accused No. 2 (Rita Gon) is the wife of Accused No. 1.
and the marriage of complainant was solemnised between the complainant and
Sri. Tusher Gon (younger brother of Accused No. 1 since deceased) on 07.0 5.
1993 at Village + P.O.Ghoralia, P. S. Santipur, Dist. Nadia as per Hindu rites and
customs.

3. That the husband of the complainant Tusher Gon had passed away on 13. 10.
2006 at 185/B, Bangur Avenue, Block – A, in a room of 3rd floor, P.S. Lake Town.
 Kolkata – 700055. Dist. North 24 Parganas, which is the matrimonial house of the
complainant and she resides there with her children and the accused persons.

4. That after the death of Tusher Gon (complainant’s husband) the accused
persons started physical and mental torture on complainant and on her children.
The accused persons demanded money of Rs. 2,50,000/- from the complainant.
They threatened the complainant that if the complainant and her children would
want to stay in her matrimonial house, she had to give them the said amount
otherwise she will be kicked away from the said premises. Finding no other
alternative the complainant told her father to give the amount of Rs. 2,50,000/-
to the Accused No. 1 and Accused No. 2 and subsequently the father of the
complainant gave Rs. 2,50,000/- to the complainant to give Accused No. 1 and
Accused No. 2.

5. That the physical as well as mental torture upon the complainant and her
children were increased day by day by the accused persons. They started forcing
to the complainant to leave her along with her two children from her
matrimonial house with the intention to grab the whole property. The accused
persons are so dangerous and desperate in nature that the complainant along
with her children are passing their days under the shadow of great fear.

6. That the complainant stays in the ground floor (one flat in the back portion) and
first floor (one flat in the front portion) of her matrimonial house. She has also
two rooms in the third floor. As the complainant stays with her children alone, by
taking the advantage of their loneliness the accused person have locked the
room of the third floor and took away all her belongings of the said rooms of the
third floor and also took away all the jewelleries and valuables from the almirah.
They are also restraining the complainant and her children to go to the third
floor. If the complainant would want to go the third floor, the accused persons
threaten them by saying that they would throw them from the said third floor to
the ground.

7. That on January 2013, in order to oust the complainant and her children, the
accuse No. 1 and accused No. 2 inflicted mental as well as physical torture on
complainant and on her children. They inflicted tremendous physical as well as
mental torture upon the complainant purposefully so that the complainant
would compel to leave the said premises. In fact the accused persons intended to
take possession of the entire property and to grab the whole property for
promoting purpose. The complaint intimated several complain (dairy) regarding
the matter to the Lake town P.S. dated: 11-3-2013, 19-4-2013, GDE NO. 491
dt. 9-7-2013, GDE No. 263 dt. 24-10-2013, 21-11-2013.
8. That the Accused No. 1 and Accused No.2, besides inflicting mental and physical
torture upon complainant also cut all water connection of the complainant from
roof water tank and looted all valuable goods form the two rooms at 3rd floor, of
the complainant and ousted forcefully the complainant from the 3rd floor and
locked the stairs by collapsible gate from the 1st floor stairs, which was intimated
to the Lake Town P. S. vide GDE No. 1181 dt. 19.6.2007.

9. That again from the 24th, November2020 the Accused No. 2 (Rita Gon) with the
intention for taking possession of the entire property with her hooligans gang
started extreme harassment and metal and physical torturing upon the
complainant and on her family members by threatening with dire consequences,
using filthy languages to the complainant and others by saying, that if
complainant with her family don’t leave this said premises soon, they will throw
the complainant and her all members forcefully from the said premises.
Thereafter the Accused No. 2(Rita Gon) and her hooligans also threated to the
complainant by saying that they are very much influential persons, so if the
complainant with her all members would not leave or vacate the said premises
with her son and daughter the accused No. 2 ( Rita Gon) will file false complaint
to the police against them and also those persons who are standing beside the
complainant.

a) That it is pertinent to mention the accused persons are very much

dangerous and desperate in nature and they are involved in so
many crime and criminal activities. Due to such acts of them so
many criminal cases has been pending against the accused no. 1
such as - Case No. N-7/94 In the Court of Ld. AddlDist.& Sessions
Judge, 6th Court, Barasat , North 24 parganas, u/s 20(b)(i) of NDPS
Act 1985 as amended, and sent to jail for more than 2 years.

b) That after the aforesaid offence, Accused No. 1 was also arrested
and sent to Jail by Police and Honourable court for severalRobbery
Case.

c) That again on 2013, Accused No. 1 was arrested for Ganja case
under NDPS Act. And sent to the jail for 12 years by The
Honourable Justice Shupratim Bhattacharya of The Honourable
AlipurCourt., which was published on the leading Bengali
newspaper AnandabazarPatrika on 1-7-2015.

10. That on October 2021, the accused No.1 came out from jail and after coming
from jail, the accused no. 1 along with the accused no. 2 started inflicting mental
as well as physical torture upon the complainant and on her children mercilessly
and threatened them by saying that the accused no. 1 is acquainted with so
many dangerous criminals with whom he has good relationship and the
 relationship had grown up with the accused no. 1 during his stay at the jail.
Thereafter on 19. 1. 2022 at about 10:15 p.m. the Accused no.1(Nil kamal gon)
and Accused No. 2 (Rita gon) along with 2 hooligans came to the complainant flat
at ground floor and started threatening the dire consequences and abused the
complainant with filthy languages and said, they are giving only 15 days more
time to the complainant to vacate the said premises with all family members
otherwise they will take strong action against the complainant and also on her all
family members and at that time, one hooligan by showing one pistol to the
complainant said to obey all the instruction given by the Accused No.1 and
Accused No. 2. and he also said, if the complainant make any complain about
that matter to the Police, he will kill her on the street outside.

11. That on 16. 02. 2022 at about 7:10 a.m. the Accused No.1(Nil kamalgon) and
Accused No. 2 (Rita gon) with others 4 hooligan came to the complainant’s flat
on ground floor (at 185/B, Bangur Avenue, Ground floor, Back portion, kol-55,
Dist. North 24 Parganas, P. S. Lake Town) and started threatening the dire
consequences and abused the complainant with filthy languages and the
Accused No.1(Nil kamalgon)started assaulting physically by slapping on the
complainant’s face and also started kicking on the complainant’s stomach and on
leg(poof at M. C. report), after than accused No. 1 grabbed complainant’s throat
with both hand and tried to suffocate her and kill(proof at M. C. report), whereas
Accused No. 2(Rita gon) on that time tried to put some liquid poison in the
complainant’s mouth but the complainant pushed Rita gon’s (Accused No. 2)
hands back and all those liquid fall on the complainant’s face, neck, chest and on
kamij(dress)after than Acussed No.2 attacked with one “Katari” on the
complainant, and by the grace of god, complainant’s son avail to safe his mother
(the complainant) by pulling back complainant, and that punch of “Katari” was
hit on the one side of the open door after than Rita Gon(Accued No.2). Started
hitting by one stick on the complainant’s head(Poof at M. C. report), shoulder
and on leg (Proof at M. C. report). That when complainant and her son Subhadip
Gon and others member of the complainant family protested against this and
started shouting, the Accused No. 1 and his 4 hooligan started assaulting to the
complaint’s son Subhadip Gon by fist and blow and also by one stick and after
that,the accused No.1 and accused No. 2 and their hooligan left the place by
threatening and abusing the complainant with filthy language and also said, they
are giving only 7 days time to vacate this premises, otherwise they will come
again after 7days and will forcefully oust the complainant with all her members,
and at the time of leaving they also said, if the complainant make any complain
to Police or anywhere, they will shoot her and her family member on the street
outside. Due to inhumane torture of the accused persons while one of the
persons who stays in the first floor of the said premises as tenant came to the
spot and protested against such ill activities of the accused persons, the accused
 persons threatened that tenant that if he would come to say anything in favour
of the complainant they would kill him.

12. That the complainant after aforesaid incident for treatment went to R. G. Kar
Medical College & Hospital, Kolkata,there Doctors made one C. T. Scan of
Brain/Head and 2 X-Ray of KNEE AP & LAT (Xerox copy of proof annexed
herewith) and prescribe treatment thereof. Thereafter the complainant
intimated the matter to the Lake Town P. S. with M. C. report (GDE No. 1029
dt. 16.02.2022).

13. That under such circumstances the complainant intimated the matter to the Lake
Town P. S. several time and lodged several GDS vide..

a) GDE No. 620 dt. 9. 5. 2007 (Xerox copy of the GDE annexed here with)
b) GDE No. 827 dt. 12. 5.2007 (Xerox copy of the GDE annexed here with)
c) GDE No. 1181 dt. 19. 6. 2007(Xerox copy of the GDE annexed here with)
d) GDE No. 1673 dt. 25. 6. 2007(Xerox copy of the GDE annexed here with)
e) GDE No. 151 dt. 10.3. 2008(Xerox copy of the GDE annexed here with)
and the complainant also intimated to the several higher authorities.

14. That the Accused No. 1 and Accused No. 2 committed the offence punishable
U/s. 498(A)/406/307 IPC. But till date the concerned police authority did not
take any step against the accused persons.

In the above facts and circumstances it is the

complainant humbly prayed that your Honour
would graciously be pleased to send this
complaint to the I/C. Lake Town P. S. u/s. 156(3)
of Cr. P. C. to treat the complaint as FIR U/s.
498 (A)/ 307 IPC and /or to pass any other
order/orders as your Honour may deem fit and
proper for the ends of justice.
And for this act of kindness, your complainant as in duty bound shall ever pray.