To,

The Incharge,

Crime Against Women Cell,

Dwarka, Dabri

New Delhi.

SUB: COMPLAINT FOR HARASSMENT/CRUELTY AND MENTAL

TORTURE ON ACCOUNT OF THREATS AGAINST

Regarding to the torture, harassment, threat to life of the complainant,

apprehension of danger to life and property and other criminal activities, seeking

proper legal action against above mentioned accused persons and restrain them

from committing heinous crime against an innocent lady.

1. That the complainant was married with the respondent on

21.08.2020 according to Hindu rights and ceremonies and
customs at Amritsar. The marriage was solemnized with great
pomp and shows. The huge amount was spent by the
complainant’s family on her marriage and on demand of
respondent, in laws, complainant’s family members and
relatives also gave handsome stridhan, and during course of
matrimonial alliance, silver and gold ornaments and gifts were
presented by them at the time of her marriage, complainant’s
family has spent around Rs.25 lac in her marriage.
2. That just after reaching at the matrimonial home the
respondent and his mother and sister they saw the dowry
articles and gifts etc. given by the complainant’s family in the
marriage and started taunting for insufficient dowry articles.

3. That from the inceptions of complainant’s marriage with the

respondent, the behavior of respondent, his mother and sister
was not good towards the complainant. Complainant was
treated very cruelly by all the these members of the
respondent’s family during her stay at matrimonial home, they
all passed sarcastic remarks upon her daily routine on false
pretext while saying that complainant’s family members have
not given them good in marriage. They always claimed that
their family have high standard and status and they also
claimed that they will perform the second marriage of the
respondent, they were ready to spent more than the
complainant’s family and sometimes on account of bringing
less dowry articles, while on the other times, or demanding
cash and kind on the one pretext or the others from
complainant’s family members on different occasions and as
such was remained to mental and physical violence and
assault of this account in the hand of respondent and his
other above mentioned family members.
4. That all matrimonial dreams of the complainant were
converted into nightmare due to nefarious acts and conduct of
respondent and his other above mentioned family members.
They jointly as well as severally inflicted inhuman cruelties
upon the complainant and just after very next day of the
marriage abusing, cursing the complainant, had become a
routine of the day. It is pertinent to mention here that
immediately after reaching at the matrimonial home
respondent directed the complainant to handover her entire
jewellery to his mother, respondent and his other family
members pressurized the complainant to keep all jewellery,
cash, important documents like passport, bank papers, voter
ID card, PAN card & Driving License in their bank locker and
respondent also insisted for doing the same and the entire
jewellery (except Mangalsutra and Engagement ring) and other
above mentioned documents were forcibly taken by the in laws
from the complainant and same has been kept with mother –
in-law as the same shall be safe in their custody.

5. That right from the day one of the married life the behavior of
the respondent and his other family members was filled with
animosity towards the complainant and the complainant was
treated with contempt and cruelty. During the stay of the
complainant at her matrimonial home the respondent and his
other family members subjected the complainant with taunts
and sarcastic remarks.
6. That just after reaching at the matrimonial home the behavior
of the respondent towards the complainant was very cruel
even the respondent used to pick up fights on trivial issues
and used to beaten the complainant on without any fault. The
respondent never gave any love and affection to the
complainant during her stay at matrimonial home.

7. That from the very beginning of the marriage the behavior of

husband and in-laws of the complainant towards the

complainant was very rude, abnormal, harsh and arrogant

and they used to harass the complainant in pity issues and

pressurized the complainant to bring lots of dowry articles and

started harassing and torturing the complainant mentally by

taunting, teasing and using abusive language and were giving

merciless beatings to the complainant.

8. That the husband, mother-in-law, brother-in-law are never

wanted to talk and did not like the things of the complainant.

As it is a arrange marriage he never take interest in talking the

likes and dislikes of the complainant. He always used to his

phone where he talked many of girls on Instagram, Snapchat

and Whats app and some Dating apps.

9. That when complainant and her husband were in Amritsar he

never makes efforts to do something special for the

complainant. He always wanted to visit his maternal aunt’s

house.

10. That complainant’s husband always having issues

regarding physical intimacy, touch, hugs and kisses as well.

Whenever she used to do the same, he denies all the time or

he makes faces that he is not interested in making physical

relation with the complainant.

11. That whenever complainant asked him for a hug only,

but he denies. After sometime we make some physical relation

but in that case as well he did not perform well, he just did his

part like it is a job for him only he did not even thought about

me on the bed. He is emotionless person during the physical

relations as well.

12. That after marriage husband of the complainant never

wanted to go for a honeymoon, when complainant insist him

for that as well, complainant spent all the money in

honeymoon whether it is hotel booking or travel expenses or

food items etc. after that mother –in-law taunt the

 complainant that she unnecessary spend money which she

have to give to the mother-in-law and also used fifty language

toward the complainant

13. That he never used to take me out for any date, party or

not even for a walk. Complainant always do the efforts and

planed some trips like – Kashmir, Mussoorie, Thailand,

Dalhousie, Ladakh she spent almost the money in this so that

their marriage relationship become stable and happy but her

all efforts and investments become zero.

14. That whenever I used to go with my friend for any small

outing that time he also made faces and behave rude. One day
my friend with her husband came to my home, that time he
intentionally and deliberately insulted me infront of them. This
is not the first time he insulted me in front of anyone. He used
to do the same multiple times.
15. That he uses some Dating apps for hatting to different

different girls and some pictures and nudes of that girls and

he used to masturbate seeing their body parts images.

16. That when I told this to my mother in law, she take side

of honey and said why you raise this topic again and again.

After that he did not talk with me around 10-15 days most of
 the times. He never takes initiatives, if I take even though he

did not respond

17. That he was squeezed my neck unable to breath and tear

hair out and beaten me 3 times the respondent given beatings
to the complainant without any rhyme and reason. The
respondent and his other family members insulted the
complainant on account of bringing less dowry, they all passed
sarcastic remarks upon the complainant. They refused to keep
the complainant at the matrimonial home if the parent’ of the
complainant do not fulfill their demands, and respondent even
said that he is unwilling to continue with the marriage. The
respondent and his mother told the complainant that we fulfill
their demands otherwise they are having another suitable
match who can give more money. My mother in and sister in-
law and respondent used so many times that “kangle ki aulad
se palla pad gaya, hum to lut gaye khuch nahi mila dahej me”.

18. That since the marriage of the parties to till date the
complainant have borne all the cruelties of respondent and his
mother & sister with the hope that better sense will prevail one
day and everything will be all right but everything is in vain.
They always used to taunt, harass and humiliate the
complainant for bringing less dowry.
19. That the parents of the complainant gave 5 lakh ash to
the respondent to purchase a flat at Delhi as both were
working at Delhi and in –law of the complainant parents to
give the money but parents of the complainant show their
incapability but after they took a loan from their relative to
save the matrimonial life of her daughter they gave 5 lakh ash
to the husband of the complainant and it is also agreed that
the installment were given by the complainant every month
then the complainant agreed the same and she paid half of the
amount of installment from her salary and rest of the salary
was taken by the husband of the complainant he is not
allowed to her to spend even a single penny to the
complainant as all the password are in the custody of her
husband .

20. That the respondent and his family members used to

harass the complainant for bringing insufficient dowry and in
a pre-planned manner and criminal conspiracy hatched
against the complainant. The complainant tolerated all the
cruelties just that one day better sense shall prevail and
everything will be all right but all in vain.

21. That during the stay of the complainant at their

matrimonial home, the respondent and his family members
committed utmost cruelties for their lust of more and more
dowry and in the month of May after brutal beatings and
 abuses given to the complainant she has been thrown out
from her matrimonial house.

22. That the complainant is never got to pregnant in the

course of marriage, as husband of the complainant is not
interested to make relation with the complainant as he wants
her money which she earn after that the respondent started
more harassing and beating to the complainant, now the
mother in law saying that complainant is looking “Manhoos”
because of the non-pregnancy of complainant.

23. That in the first week of December 2021, complainant

asked her husband to go out on this thing husband of the
complainant misbehave with her and also doing physical
assault with her after that she told her mother-in-law then she
told that if she want to live with her husband she don’t say
anything mans are some and it is normal when husband doing
physical assault with his wife so shut your mouth and don’t
complaint of her son with her again

24. After that complainant told the sister in law (Dewrani) of

the complainant, mother of the complainant and brother
went to her matrimonial home to request and asked any
fault /mistake of complainant and excused to her own her
behalf and also requested to take the complainant back to her
matrimonial house but the husband of the complainant
 straight way refused to keep her along with him and then after
again after the event of Lohri, the complainant’s parents
alongwith some relatives went her matrimonial home and tried
to settle the matter with their best efforts but the husband,
mother in law, mausi straight way refused to keep the
complainant alongwith them in the matrimonial home.

25. That on 10/03/2024 parents of the complainant

alongwith some relatives went to matrimonial house of the
complainant and requested again to keep the complainant in
matrimonial home but mother in law and brother in law
alongwith honey/husband were in same sound that they will
not bring complainant back and that they will do the other
marriage of honey/their son and threatened with loudly to the
complainant’s parents and relatives also “whatever you want
you can do against them”.

26. That the respondent has done all the acts of cruelty with
the complainant/petitioner and is continuously harassing,
humiliating, torturing, abusing in a very filthy language and
beating the complainant/petitioner mercilessly. They are
continuously demanding more money and are threatening the
complainant that if their demand is not fulfilled they will going
to marry their son to some other woman and further threatens
the petitioner to kill her and now there is no possibility that
 the petitioner may live with the respondents under the same
roof furthermore and had filed the present petition.

27. That all the Istridhan items including jewelries and other
valuable are still in the custody of the respondents/in-laws
and they are not returning the same to the complainant on
repeated demands and misappropriating those articles for
their illegal use for which they are liable under the law.