IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE,
DWARKA COURTS, NEW DELHI
CRIMINAL COMPLAINT NO. _____/2020
IN THE MATTER OF:
Sh. Satish Kumar
S/o Sh. Dharmpal
R/o House No-200,
New Lohar and Dhariyan Mohalla,
Dhansa Village (South-West District)
New Delhi- 11007 ……… Complainant
Versus
1. Pradeep Kumar @ Deepu
S/o Sh. Nafe Singh Panchaal
R/O VPO Shaanpur, District Jind,
Tehsil Safeedon, Haryana- 126112
2. Kiran
W/O Satish Kumar
C/O Pradeep Kumar @ Deepu
R/O VPO Shaanpur, District Jind,
Tehsil Safeedon, Haryana- 126112
… Respondents/Accused
P.S. J.P.KALAN
COMPLAINT UNDER SECTION 200 Cr. P.C. FOR
THE OFFENCE U/S 499/500/120-B IPC
MOST RESPECTFULLY SHOWETH:
1. That the complainant is a law-abiding
citizen and residing at House No-200, New
Lohar & Dhariyan Mohalla, Dhansa Village,
(South-West), New Delhi- 110043 on rented
premises with his mother and children.
2. That the respondent No. 1 is the lawfully
wedded wife of Shri Sarbjit Salaria married on
08.12.2013 in a simple ceremony attended by
some close relatives, friends, acquaintances and
also the respondents No. 2 and 3 who are
respectively maternal uncle (Maama) and
maternal aunt (Mausi) of the respondent No. 1
and have been instrumental in dragging the
name of the complainant with the husband of
the respondent No. 1. Although, the
complainant is neither a blood relative nor
otherwise having any family link with the father
of the husband of the respondent No. 1 namely
Sh. Madan Singh Salaria but is only known to
them through their common social circle
whereas the respondents No. 4 is the SHO of the
concerned police station while the respondent
No. 5 is the I.O. of the case who has filed the
charge sheet and verified the complainant, her
address, relations and other details of the
complainant.
3. That the complainant did not have any part to
play either in the negotiation for the marriage or
its performance but had merely attended the
marriage function owing to her social contacts.
4. That since the complainant is neither a member
of the family of the husband of the respondent
No. 1 nor even a distant relative, the manner of
leveling all sorts of false allegations against the
complainant either orally or in writing
tantamount to the acts of civil and criminal
defamation against the complainant. All the
allegations leveled against the complainant
having no basis, truth or evidence therein nor
can be justified in any manner whatsoever.
5. That all such allegations made by all the
respondents to the police making allegations
against or involving the complainant are
absolutely false to the knowledge of the
respondents but while making registration of the
FIR against the husband of the respondent No. 1
and his family members and for supporting the
case of the respondent No. 1, all the
respondents resorted to make absolutely false,
untrue and defamatory allegations against the
complainant in the hand written complaint filed
with the Crime Against Women Cell, East District
on the basis of which, the FIR No. 2618/14 dated
13.12.2014 under Section 498-A/406/34 IPC had
been registered resulting in avoidable and
unnecessary harassment to the complainant and
also causing criminal and civil defamation
against her.
6. That the respondent No. 1 had stooped so low
that she did not even take into consideration the
fact that the complainant had renounced all
comforts of this worldly life and has been living
in the compound of Mata Vaishno Temple in
Pathankot but in order to give false support to
the complaint against the husband of the
respondent No. 1 and in-laws, the respondent
No. 1 made absolutely false allegations despite
claiming falsely that the complainant is the
maternal aunt (Mausi) of the husband of the
respondent No. 1. In fact, the complainant is not
related to the husband of the respondent No. 1
or his other family members either by blood or
otherwise. The family of the husband of the
respondent No. 1 was simply known to the
complainant in a social manner.
7. That all the respondents without having any
shame or remorse in making all sorts of such
false allegations, have not only used written
word to tarnish the image of Sarbjit and his
other family members but have also made
foolish and false allegations against the
complainant of having sexual relationship with
the husband of the respondent No. 1. The
respondent No. 1 has also alleged that she had
seen the complainant and Sarbjit involved in
such dastardly act and since the police has used
those allegations while preparing the charge
sheet, the complainant has been exposed to
such criminal defamation resulting directly from
the written word of the respondent No. 1 which
is doing the rounds everywhere including the
general public and those known to the
complainant and also all those before whom the
complainant has to take all those papers in
order to safeguard her rights in the matter.
8. That the respondent No. 1 did not stop at that
also and had named Bittu Deva also being
involved in such sexual relationship with the
complainant while making reference to the
alleged “Tantrik Powers” being derived from the
alleged acts of such sexual relationship between
the complainant and various other people.
9. That the respondent No. 1 has not only
committed the offence of criminal defamation of
the complainant through spoken and written
word without having any basis or evidence in
that behalf and with the sole motive of seeking
revenge from the husband of the respondent No.
1 and other family members and/or teaching
them lesson by lodging the FIR mentioned above
but while doing so, all the respondents have
dragged the name of the complainant without
any just and sufficient cause even though, the
complainant is not even a distant relative much
less any blood relative of the husband of the
respondent No. 1 or in-laws and thus forcing the
complainant to face serious trouble while trying
to satisfy all those known to the complainant in
her social circle and acquaintances.
10. That unwarranted and illegal help is being
provided to the respondent No. 1 by the
respondents No. 2 and 3 who appear to be a
part of such scheme to achieve the nefarious
ends while exposing the complainant to such
serious shame in the eyes of everyone known to
her and also the general public whom the
complainant has to face during putting up of
defence to all those allegations.
11. That in this manner, all the respondents have
been jointly and severally responsible for the
offence of civil and criminal defamation by
causing grave mental agony, harassment,
torture and depression apart from the ignominy
caused to the complainant from the registration
of FIR naming the name of the complainant
without there being any responsibility on her for
either of the actions attributed to her which has
resulted in defamation to the complainant by the
spoken words and written complaints and other
deeds in the presence of large number of
persons before whom, such written documents
have been rotated and the complainant would
be exposed to serious humiliation and
harassment.
12. That by acting in such manner, the respondents
have lowered the social and financial dignity of
the complainant before her social circle,
religious acquaintances, family friends,
colleagues and their respective parents, society
and general public at large before whom the
position of the complainant has been lowered
and she has suffered in the manner explained
above.
13. That the complainant being a responsible citizen
and not wishing to precipitate matters, had
instructed the counsel to send a legal notice to
all the respondents while calling all the
respondents to tender an unconditional and
unqualified written apology to the complainant
for the aforesaid acts and as such, a legal notice
dated 04.05.2016 was sent to the respondents
on 13.05.2016 through Speed Post but neither
any reply to the legal notice nor any apology has
been tendered on behalf of the respondents.
Copy of the complaint dated 08.08.2014 to the
CAW Cell, East District upon which, an FIR
bearing No. 2618/14, P.S. Shakarpur under
Section 406/498A/34 IPC are being enclosed
herewith as Annexure A& B respectively. Copy
of the Legal Notice dated 04.05.2016 is annexed
as Annexure C and a copy of the Postal Receipt
is annexed as Annexure D sent to the
respondents No. 1 to 3.
14. That the respondents No. 1 to 3 have not
complied with the instructions of the legal notice
within the stipulated period, therefore, the
complainant is constrained to file the criminal
complaint under Section 200 Cr. P.C. for the
offence mentioned above.
15. That the respondents No. 4 is the overall
incharge of the police station being SHO under
whose supervision, the charge sheet has been
signed and filed on 16.12.2015 whereas, the
respondent No. 5 is the Investigating Officer of
the case who has submitted the charge sheet
and verified the particulars i.e. names, relations,
address and other details of the accused
persons charge-sheeted. The Investigating
Officer is responsible to collect the documents,
evidence about the defamatory allegations
leveled against the complainant herein. More or
so, the complainant was never summoned or
called by the Investigating Officer, moreover,
the I.O. of the case, has mentioned the address
of the complainant i.e. H.No. H-84, H-Block, DDA
Flats, Naraina Vihar, Delhi and the same has
been shown to be verified by the I.O. but in fact,
the complainant never resided at the given
above address. The respondent No. 5 has failed
to collect a single evidence against the
complainant herein against the allegations
leveled by the respondent No. 1, therefore, the
respondents No. 4 and 5 are collectively, jointly
and severally responsible for the offence of
defamation.
16. That the offence relates to the defamation of the
complainant and being non-cognizable, the
complainant sent a notice to the respondentsNo.
1 to 3 but they did not reply to the said notice.
The respondentsNo. 1 to 3 have injured the
reputation of the complainant and still they are
threatening the complainant and they continue
to defame the complainant and injure her
reputation in the society and to the known
persons, hence the present complaint before
this Hon’ble Court to take legal action against
the respondents as far as respondents No. 4 and
5 are concerned, they are responsible for filing
of the charge sheet without having any
verification of the facts and without investigating
the allegations leveled against the complainant
in the FIR.
PRAYER
Under the circumstances stated above, it is
therefore, most respectfully prayed in the interest of
justice that a cognizance may kindly be taken against
the respondents and initiate the legal proceedings
against them as per law in the interest of justice.
COMPLAINANT
DELHI THROUGH
DATED: .2016
(R.S. MALHAN &ASSOCIATES)
ADVOCATES
IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE, KARKARDOOMA COURTS, DELHI
CRIMINAL COMPLAINT NO. _____/2016
IN THE MATTER OF:
Ms. Bimla Devi … Complainant
Versus
Ms. Priyanka Nargotra
& Ors. … Respondents/Accused
AFFIDAVIT
I, Ms. Bimla DeviD/o Sh. Mohan LalR/o Mata
Vaishno Mandir, Dev Nagar, Pathankot,
Punjabpresently at Delhi do hereby solemnly affirm
and declare as under:
1. That the deponent is the complainant in the
above noted case and well conversant with the
facts thereof as such competent to swear this
Affidavit.
2. That the accompanying Complaint under Section
200 Cr. P.C. has been drafted by my counsel
under my instructions and the contents of the
same are true and correct which have been read
over and understood by me in my vernacular
and the same are not being repeated herein for
the sake of brevity which may be read as part of
this Affidavit.
DEPONENT
VERIFICATION:
Verified at Delhi on this day of _____, 2016 that
the contents of the above affidavit are true and
correct. No part of it is false and nothing material has
been concealed therefrom.
DEPONENT
IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE, KARKARDOOMA COURTS, DELHI
CRIMINAL COMPLAINT NO. _____/2016
IN THE MATTER OF:
Ms. Bimla Devi … Complainant
Versus
Ms. Priyanka Nargotra
& Ors. … Respondents/Accused
MEMO OF PARTIES
Ms. Bimla Devi
D/o Sh. Mohan Lal
R/o Mata Vaishno Mandir
Dev Nagar, Pathankot
Punjab … Complainant
Versus
1. Ms. Priyanka Nargotra
D/o Sh. Satpal Nargotra
2. Sh. Ashok Kumar Salhotra
S/o Sh. Dhyan Chand
3. Mrs. Ranjana Rani
D/o Sh. Dhyan Chand
All C/o Sh. Satpal Nargotra
R/o House No. M-165, M-Block
Church Road, Laxmi Nagar
Delhi-110092
4. The S.H.O.
P.S. Shakarpur
East District
5. SI Sanjay Kumar
Investigating Officer
in Case FIR No. 2618/14
U/S 498A/406/34 IPC
P.S. Shakarpur, Delhi
… Respondents/Accused
COMPLAINANT
DELHI THROUGH
DATED: .2016
(R.S. MALHAN &ASSOCIATES)
ADVOCATES
IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE, KARKARDOOMA COURTS, DELHI
CRIMINAL COMPLAINT NO. _____/2016
IN THE MATTER OF:
Ms. Bimla Devi … Complainant
Versus
Ms. Priyanka Nargotra
& Ors. … Respondents/Accused
P.S. SHAKARPUR
INDEX
Sl.No. Particulars Pages C. Fee
1. Memo of Parties A
2. Complaint under Section
200 Cr. P.C.
3. Affidavit in support
4. List of Witnesses
5. List of Documents
6. Vakalatnama
DELHI
DATED: .2016
(R.S. MALHAN &ASSOCIATES)
ADVOCATES
Chamber No. 440
Patiala House Courts
New Delhi
Mob. 9899380772
IN THE COURT OF CHIEF METROPOLITAN
MAGISTRATE, KARKARDOOMA COURTS, DELHI
CRIMINAL COMPLAINT NO. _____/2016
IN THE MATTER OF:
Ms. Bimla Devi … Complainant
Versus
Ms. Priyanka Nargotra
& Ors. … Respondents/Accused
LIST OF WITNESSES
1. The complainant herself.
COMPLAINANT
DELHI THROUGH
DATED: .2016
(R.S. MALHAN & ASSOCIATES)
ADVOCATES
