IN THE HON’BLE COURT OF CHIEF JUDICIAL

MAGISTRATE, JAMMU

IN re:

Harmeet Singh,

S/o Tirath Singh,

R/o New Chatha Road, Gadigarh,

Jammu.

.. Applicant

VERSUS

1. Union Territory of Jammu and Kashmir,

Through Incharge Police Station, Crime Branch,
Jammu

.. NON-APPLICANT

2. Tirath Singh, S/o Giani Harnam Singh, R/o

Akali Kour Singh Nagar,Jammu.

.. ACCUSED

AND

IN THE MATTER OF :-

Application under section

155 (2) Cr PC for issuance of
necessary direction to the
Non-Applicant to investigate
the offence under section
182 IPC and thereafter
 proceed under criminal
procedure code.

MAY IT PLEASE YOUR HONOUR,

The complainant, Harmeet Singh, most

respectfully submits as under:

1. That the present application is being preferred

by the above named applicant under Section
155(2) of the Cr PC with a prayer to direct the
Non-Applicant to investigate the offence under
section 182 IPC committed by the accused
Person i.e., Tirath Singh duly mentioned above
named above for filing a false, vexatious and
frivolous complaint before the Non Applicant i.e.,
Crime Branch against the complainant.

2. That the Complainant herein is an Indian citizen

and is a resident of Union Territory of Jammu
and Kashmir and is presently working as an
advocate at Jammu. The Complainant has
earned substantial reputation in the society for
his impeccable professional work.
3. That the applicant completed his academic
qualifications vis-à-vis Matriculation, 10+2 and
B.A from MAM College, Jammu. The applicant did
his LLB Degree from KC Law College, Jammu,
in the year 2020 and started his professional
career in the Courts of law, at Jammu. The
licence number of the applicant is JK-
428/2020. Copies of the qualification
certificates of the complainant are annexed
herewith and are marked as ANNEXURE- ‘A’,
collectively.

4. That the Accused namely Tirath Singh, is the

father of the complainant and is well aware and
in know, of all the facts with respect to the
educational qualifications of the complainant.
Earlier the parties were residing at Nai Basti,
Satwari, but later on shifted to Akali Kour Singh
Nagar, Jammu. The applicant is now living
separately at abovementioned address.

5. That the accused Tirath Singh, is very inimical

with the complainant and filed plenty of criminal
and civil casaes against the complainant. The
accused leaves no stone unturned to cause loss
(monetory/mental and physical) to the
complainant.
6. That the complainant being a decent son of the
accused was having all the respects for his father
i.e. accused. With the passage of time, the
complainant completed his academic
qualifications followed by completion of
professional Degree in Law i.e. (LLB) from the
University of Jammu.

7. That the accused filed complaints one after the

other based on false, misleading and concealed
facts. One such complaint was earlier filed before
the Universtity of Jammu also which was also
with respect to the Educational Qualifications
obtained by the complainant.

8. That the accused person filed another complaint,

alleging fakeness of the academic qualifications
of the applicant. The inquiry / investigation was
carried out by the Crime Branch and the after
detailed inquiry/ investigation, receipt of letters
regarding genuineness of qualification of the
complainant i.e. Matriculation Certifcate and
10+2 diploma issued by the J&K Board of School
Education and the Degree obtained by the
Complainant from the University of Jammu, the
Crime Branch submitted its Status Report before
the Hon'ble Court. Copy of the Status Report is
annexed herewith and is marked as
ANNEXURE- ‘B’.
9. That as per the Status Report, the qualifications
of the complainant have been found to be
genuine and there has been no doubt on the
same as was alleged by the accused before the
respective authorities i.e. J&K Board of School
Education and the University of Jammu. The
accused, this way has committed offence under
Section 182 IPC. Section 182 IPC reads as
under:-

“Section 182 of the Indian Penal Code

states that if someone knowingly gives
false information to a public servant
with the intention of causing them to
do something they shouldn't or use
their power to harm someone, they
may be punished with imprisonment,
fine, or both, for a maximum of six
months”.

10. That the accused has wilfully, intentionally and

deliberately given false information to the non-
applicant, with the intention to cause legal injury
to the complainant and thus, being the father of
the applicant, the accused has knowingly given
false information to the crime branch and is
thus, liable to be punished for the offence
committed under Section 182 IPC and tried for
the same.
11. That the accused though is the father of the
complainant, yet, having bad intentions towards
the complainant and is always in search of an
issue to cause embarrassment, humiliation and
to implicate the applicant in criminal cases.

12. That the complainant being a son, has been

ignoring all the acts of his father i.e. accused
person, however, the accused has been
continuing with his nefarious designs in causing
immense loss to the complainant including
harassment, mental torture, defaming in the
society at large. The complainant has been put
to severe tensions, anxiety for the offences,
which the complainant never committed.

An affidavit in support of accompanying complaint is

annexed herewith.

PRAYER:

It is, therefore, most respectfully prayed that in view

of the submissions made hereinabove and others to
be urged at the time of hearing, the Hon'ble Court
may be pleased to direct investigation under section
155 (2) Cr PC for offence under section 182 IPC and
punish the accused namely Tirath Singh, under law.

COMPLAINANT

Place: Jammu

Dated: 12.04.2024

IN THE COURT OF HON’BLE CHIEF JUDICIAL

MAGISTRATE JAMMU.
HARMEET SINGH VERSUS TIRATH SINGH

IN re: An affidavit in support of complaint.

I, Harmeet Singh, S/O Tirath Singh, R/O Akali Kour Singh Nagar, Jammu

do hereby solemnly affirm and declare on oath as under:-

1. That the contents of accompanying application

have been drawn and drafted by me. Nothing has
been concealed there from.

2. That the contents of accompanying application are

true and correct to the best of my knowledge and
belief.

DEPONENT
VERIFICATION.

Verified at Jammu today the 12th day of April,

2024, that the averments made hereinabove, are true
and correct to the best of my knowledge and belief.
Nothing is concealed or suppressed therefrom.

DEPONENT