IN THE COURT OF LD. C.M.M.

, KARKARDOOMA COURTS,

DELHI.

C.C.NO. _________ OF 2015

IN THE MATTER OF :-

MRS. LUCKY RANI …COMPLAINANT

VERSUS

BHARTI @RAVI & ORS. …ACCUSED PERSONS

INDEX

S.NO. PARTICULARS COURT PAGE NO.

FEE

1. Memo of parties

2. COMPLAINT CASE U/S 200

C.r.P.C. along with affidavit.

3. List of documents along with

documents.

4. Vakalatnama

DELHI COMPLAINANT

DATED

SHAKIR HUSSAIN
 ADVOCATE

IN THE COURT OF LD. C.M.M., KARKARDOOMA COURTS,

DELHI.

C.C.NO. _________ OF 2015

IN THE MATTER OF :-

MRS. LUCKY RANI …COMPLAINANT

VERSUS
BHARTI @RAVI & ORS. …ACCUSED PERSONS
PS-GOKULPURI
MEMO OF PARTIES
MRS. LUCKY RANI
W/O LT. SH. PARVEEN KUMAR BHADRA,
R/O:-H.NO.F-15,40 Foota Road,
Ganga Vihar, Delhi-110094 …COMPLAINANT
VERSUS
1. BHARTI @RAVI
R/O D-63, GOKULPURI,
DELHI-110094
2. KUSUM
3. SHAHI
R/O C-237, GALI NO.9,
GANGA VIHAR, GOKULPURI
DELHI-110094
4. VINITA
5. KALYANI
6. SHANTI
7. MANJU …ACCUSED PERSONS
DELHI COMPLAINANT

DATED

SHAKIR HUSSAIN

ADVOCATE

IN THE COURT OF LD. C.M.M., KARKARDOOMA COURTS,

DELHI.

C.C.NO. _________ OF 2015

IN THE MATTER OF :-

MRS. LUCKY RANI

W/O LT. SH. PARVEEN KUMAR BHADRA,

R/O:-H.NO.F-15,40 Foota Road,

Ganga Vihar, Delhi-110094

…COMPLAINANT

VERSUS

1. BHARTI @RAVI
R/O D-63, GOKULPURI,
DELHI-110094
2. SHASHI
3. KUSUM
R/O C-237, GALI NO.9,
GANGA VIHAR, GOKULPURI
DELHI-110094
 4. VINITA
5. KALYANI
6. SHANTI
7. MANJU …ACCUSED PERSONS
PS: GOKULPURI

COMPLAINT U/s 200 Cr.P.C. AGAINST THE ACCUSED

PERSONS ON BEHALF OF COMPLAINANT.

MOST RESPECTFULLY SUBMITTED:

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

of India and residing at the above said address with her family.
2. That the accused No.1 Namely Bharti @Ravi who is known to
the husband of the complainant due to this the complainant
knows him since a long time and he (accused No.1) had come
severely to the house of the complainant and the accused No.2
(Shashi) is the friend of Bharti@ Ravi who was the neighbor at
the previous address of the complainant in the month of
September, 2014. That the Husband of the complainant had
given Rs.7,00,000/- to Shashi (Accused No.2) as a friendly
loan through Bharti @Ravi and against the said amount
accused No.2 Shashi was given a cheque to the Husband of
the complainant and the accused No.2 also handed over her
property documents along with an agreement with her
signature regarding the friendly loan to the husband of the
complainant.
3. That after a month the accused No.1 Namely Bharti @Ravi also
needed some money, so he demanded money from the
husband of the complainant then complainant’s husband
asked the complainant to give Rs.6,50,000/- to the accused
No.1. That on being asked by the husband of the complainant,
the complainant gave that money to the Accused No.1 Namely
Bharti @Ravi, when the money was given to the accused No.1
Namely Bharti @Ravi, he promised to return the money within
 8 months and the accused No.1 has given the complainant a
cheque of Rs.5,00,000/- as a security.
4. That when the complainant asked the accused No.1 namely
Bharti @Ravi to give her money back several times then one
day the accused No.1 called the complainant to come to his
residence alongwith the agreement papers, property paper of
Shashi and both the security cheques and the accused No.1
assured the complainant to give her money back.
5. That thereafter the complainant went to the residence of
Accused No.1 namely Bharti @Ravi with the property papers
but she forgot to take the cheques.
6. That when the complainant reached to the residence of
accused No.1 namely Bharti @Ravi the accused No.2, her
husband and accused No.3 with other unknown people were
present at the residence and Bharti @Ravi’s Wife was also
present in the residence at that time.
7. That when the complainant asked Accused No.1 namely Bharti
@Ravi to give her money back, then the accused No.1 gestures
accused No.2 and her husband and then on the very next
moment accused No.2,3,7,1 and Husband of the accused No.2
forcefully snatched the property papers from the complainant
and they also forcefully taken her thumb print on some papers
and when the complainant asked accused No.1 that you called
me here to do this work, then accused No.1, 2 and husband of
accused No.2 threatened the complainant that if she complaint
about this act to police or tell about this act to anyone then
they will kill her son and husband after then the complainant
went to her home quietly.
8. That after the complainant asked the accused No.1 to give the
money back for which the accused No.1 kept making excuses
thereafter the complainant deposited the security cheque in
the Bank but the cheque got bounce. Then the husband of the
complainant also deposited the security cheque in the bank
which was given to him by the accused no.2 namely Shashi
but the cheque got bounce and then the husband of the
 complainant filed a Recovery suit against the accused No.2
namely Shashi and also send a recovery notice to the accused
No.1 namely Bharti @Ravi. When the accused No.1 & 3 got the
recovery notice they got angry and again they started making a
conspiracy against the complainant and her husband.
9. That on 06/10/2015 the complainant, her husband and
children were not at home and they were at Mandawli, Delhi.
That in the morning on 07/10/2015 when the complainant
came back home, she found her house was locked and when
the complainant asked the neighbors about the lock then they
told her that the accused No.3 namely Kusum put over the
lock and when the complainant asked the accused No.3 about
the lock, she said that she locked the house of the
complainant on the saying of accused person No.1 namely
Bharti and accused no.7 namely Manju and when the
complainant strictly told accused No.3 namely Kusum to open
the lock of the complainant’s house she unlocked it
immediately and then the complainant entered in the house
with her husband and children.
10. That after sometime accused persons No.3,4,5,6&7 namely
Kusum, Vinita, Kalyani, Shanti and Manju respectively barged
into the complainant’s house with the intention to kill the
complainant. The accused No.4 had a stick in her hand,
accused No.7 had dab of Laundry and accused No.5 had a
stick and they attacked complainant and her daughter then
her husband saved them and then the complainant called the
police on 100 Number then police came to the house of the
complainant and took the complainant, her husband and
children and all the accused persons to the police station.
11. That complainant told about the entire incident to the police
officials but the accused person No.4 namely Vinita wrongfully
accused the complainant’s husband about tearing her clothes,
the police ignored the complainant’s statement and took the
complainant’s husband into the room and started false
investigation against the husband of the complainant.
12. That daughter (namely Layli) of the complainant was also
present in the police station who had the complainant’s Mobile
Phone and was wearing a Gold Chain at that time. That the
accused persons again attacked on the complainant’s daughter
and snatched the complainant’s Mobile phone and Gold Chain
then she (complainant) complained about the incident to the
police official namely Raghuban but he and the other police
officials never heared to the complainant and no legal action
was taken and they even filed a false and frivolous complaint
U/S 107/151 against the husband of the complainant and
took him into the custody. That on the next day the Seelampur
court granted bail to the complainant’s husband.
13. That in the house of the accused person No.1 namely Bharti
@Ravi the accused person No.1,2,3 & 7 fraudulently snatched
the papers, started beating, abusing the complainant and
threatened the complainant that they will kidnap and kill her
Son and forcefully had her thumb prints on a paper. That the
accused persons breached the trust of the complainant and all
the accused persons conspired against the complainant and
locked complainant’s house and started mercilessly beating
the complainant with sticks and dab of laundry with the
intention to kill her and still threatening the complainant and
her family members.
14. That the accused persons told the complainant “POLICE
HAMARE SATH HAI TU HUMARA KUCH NAHI BIGAD SAKTI”.
15. That the act of the accused persons are illegal, unjustified,
actionable and un-ignorable and for the same they are liable to
be punished as per law.
16. That after several request and approach to the concern
police they are not listening and not arresting the accused
persons and also filed a false complaint against the husband of
the complainant so, finding no option the complainant
approached before this Hon'ble Court to get justice.
17. That the offense has been committed within the jurisdiction
of this Hon’ble Court and hence this Hon’ble Court has got
jurisdiction to entertain this complaint.

PRAYER

It is, therefore, most respectfully prayed that this Hon’ble

Court may kindly be pleased to take cognizance of above
mentioned offences and accused persons may kindly be
summoned, tried and punished according to the provision of law
in the interest of justice. Prayed Accordingly.

Delhi …Complainant

Date :

Through

(SHAKIR HUSAIN)

Advocate
 IN THE COURT OF LD. C.M.M., KARKARDOOMA COURTS,
DELHI.

C.C.NO. _________ OF 2015

IN THE MATTER OF :-

MRS. LUCKY RANI …COMPLAINANT

VERSUS

BHARTI @RAVI & ORS. …ACCUSED PERSONS

LIST OF WITNESSES

1. Complainant himself.

2. Any other witnesses as per direction of this Hon'ble Court will

be produced.

Delhi …Complainant

Date :

Through

(SHAKIR HUSAIN)

Advocate
 IN THE COURT OF N-E, KARKARDOOMA COURT, DELHI.

C.C.NO. _________ OF 2015

IN THE MATTER OF :-

MRS. LUCKY RANI …COMPLAINANT

VERSUS

BHARTI @RAVI & ORS. …ACCUSED PERSONS

AFFIDAVIT

I, Lucky Rani W/O Late Sh. Parveen Kumar Bhadra R/o

H.NO.F-15, 40 Foota Road, Ganga Vihar, Delhi-110094, do
hereby solemnly affirm and declare as under:-

1. That the deponent is the complainant in the present case and

being fully conversant with the facts and circumstance of the
case, she is competent to swear this affidavit.
2. That the contents of accompanying complaint case under
section 200 Cr.P.C. has been drafted by my counsel under my
instructions and the same is correct to my knowledge and
belief and the contents of the same be understand to me in my
vernacular language and the contents of the same may kindly
be read as part and parcel of this affidavit and same are not
repeated herein for the sake of brevity.

DEPONENT

VERIFICATION:-

Verified at Delhi on ___________________ that the contents of the

above affidavit are true and correct to my knowledge and belief,
no part of it is false and nothing material has been concealed
there from.

DEPONENT