Exercise1

To,

The Station House Officer

Byculla Police Station

Byculla, Mumbai (400001)

15th November 2023

Subject: Criminal Complaint against Tara Lakadwala and Raj Lakadwala u/s

323,354A,356,378,379,380,383,384,442,448 of Indian Penal Code,1860 requesting

immediate registering of an FIR.

Respected Sir/ Ma’am,

1. This is to bring to your kind attention that I am writing this on behalf of my

client-

Mrs. Reena Mathur, aged 70 years is a senior citizen residing at 801, Bombay

Towers, Byculla, Mumbai 400001. Mrs. Reena Mathur married Mr. Raj Mathur in

1995. She was the second wife of Mr. Raj Mathur and his first wife predeceased

him and out of his first marriage he had seven daughters namely -Tara, Zara, Teena,

Riya, Jaya, Taruna and Seema, all of whom are married and currently reside at

their matrimonial houses. Three years after his second marriage with my client Mrs.

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Mathur, Mr. Mathur fell victim to an unfortunate paralysis attack and was hence

bedridden, and soon after the paralysis attack he passed away on xx April 2023. To

secure Mrs. Mathur’s future, Mr. Mathur made savings in various bank accounts

and invested in mutual funds and fixed deposits.

2. After the unfortunate demise of Mr. Mathur, all his seven daughters started

torturing Mrs. Mathur intending to seize over the assets of Mrs. Mathur. On 15th

April 2023, Tara Lakadwala along with her husband, came to resedential house of

Mrs. Mathur and started beating her with a stick. They also stole 4 gold bangles

along with ₹ 5 Lakh in cash which Mrs. Mathur kept her in room. On the very next

day, that is on 16th April 2023, Raj Lakadwala, husband of Tara Lakadwala called

Mrs. Mathur abused her and made sexually coloured remarks against her.

Due to the beating by Mrs. Tara Lakadwala and Mr. Raj Lakadwala , Mrs. Mathur

had sustained very serious injuries and her whole body was marked with clear cuts

and bruises. Mrs. Mathur being aged 70 years, her body is very weak and fragile,

she could easily have died on the spot had she been subjected to more beating on

15th April 2023 by Mr&Mrs. Lakadwala. Mrs. Mathur’s self esteem has also been

shattered after being subjected to abuses and sexually coloured remarks by Mr. Raj

Lakadwala, and since Mrs. Mathur is a heart patient, unable to bear the physical

and mental stress, she has very frequent recurring episodes of very high blood

pressure. Mrs. Mathur lives alone and she has no close relatives and due to

unfortunate circumstances she is left with no money to pay her bills and for her

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treatment. It is clear that the aforementioned events amount to series of offences of

Grievous hurt u/s 323, Theft u/s 379,380, Extortion u/s 383, 384, Sexual Harassment

u/s 354A and Criminal house trespass u/s 442, 448 by Mr &. Mrs. Lakadwala.

On 15th November 2023, Mrs. Mathur along with her distant relative Mr. Harsh

came to my office and described the whole situation.

So I humbly request to you to please take quick legal action in this

matter and it is prayed that an FIR be registered against Mrs. Tara Lakadwala and

Mr. Raj Lakadwala and forthwith commence an investigation. I have annexed a

copy medical reports of Mrs. Mathur done on xx April 2023 as Annexure A with

this application.

Thanking You

Yours Truly

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 Exercise2

IN THE COURT OF JUDICIAL MAGISTRATE FIRST CLASS, MUMBAI

Criminal Complaint No.___/2024

IN THE MATTER OF:

Mrs. Reena Mathur aged about 70 years

R/o 801,Bombay,Byculla,Mumbai 400001 ……Complainant

Versus

Raj Lakadwala & Ors. ……Accused

Criminal Complaint under section 200 r/w section 156(3) of Crpc and for

registration of offences under sections 323,354A,379,380,383,384,442,448 of Indian

Penal Code,1860

MOST RESPECTFULLY SHOWETH:

1. I and writing this complaint on behalf of my client, Mrs. Reena Mathur, the

complainant in this case. Complainant resides at 801, Bombay Towers, Byculla,

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Mumbai.

2. Complainant got married to Mr. Raj Mathur in the year 1995 and was the

second wife of Mr. Raj Mathur, whose first wife predeceased him and out of this

first marriage he had seven daughters. Mr. Raj Mathur unfortunately suffered from

a paralysis attack and passed away but before he passed away, he left various

savings for her wife, the complainant. On 15th April 2023, the Complainant’s eldest

step-daughter named Tara Lakadwala along with her husband named Raj

Lakadwala came to the complainant’s house and beat her with stick. They stole 4

gold bangles along with ₹ 5 lakhs in cash. On the next day, that is on. 16th April

2023, the Complainant received a phone call from Mr. Raj Lakadwala, on which he

used sexually coloured remarks against the Complainant.

3. Soon after the incident Complainant approached the local police station on 17th

April 2023. A copy of complaint along with receipt dated 17th April 2023 has been

annexed herewith as Annexure A. When Station House Officer refused to file FIR

the Complainant approached Superintendent of Police on 22nd April 2023 in

accordance with section 154(3) of CrPC. A copy of the receiving of the complaint

to Superintendent has been annexed herewith as Annexure B.

4. Since there has been no action taken by the Police, the only option left for the

Complainant is to seek remedy under section 156(3) from Hon’ble Court. In light

of facts & circumstances several cognizable cases can be made out against the

accused in accordance with sections 323,354A,379,380,383,384,442,448.

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 PRAYER:

a. To direct the Superintendent of Police incharge of Byculla, Mumbai

jurisdiction to lodge an FIR on the basis of complaint and direct an investigation

against the accused u/s 323,354A,379,380,383,384,442,448.

b. The complainant fears for her safety and believes some harm may come to her

so to issue a Protective Order in favour of the complainant.

c. Pass any such order which the court may deem fit in interests of justice and

equity/ facts and circumstances of the case.

List of witnesses:

1. Mrs. Reena Mathur

2. Mr. Harsh Mathur

Complainant

Advocate

Dated : 20th November 2023