Application under Section 156 (3) Cr.P.C.
In the Court of Chief Judicial Magistrate at ……………..
Complainant Accused ‘X’
(1) “Y” W/o S/o ……… D/o
(2) “Z” At present residing at her father’s place, S/o ……….
At ……………………………… all of ………..
Distt. ….P.S. …… District ….
Witnesses: (1)…….
(2) …………..
Under section 498 – A/40 of the Indian Penal Code
The complainant above-named begs to state as follows:
1. The complainant was married to the accused no. 1 ……(Name) according toHindu rites and customs at her father’s place at ……(Place) P.S. ……….
2. That at the time of the marriage the father of the complainant apart from arranging for a large gathering gave in stridhan gold ornaments worth Rs. ………, a Swift car worth Rs. ………. and ………(mention all other items)
3. That after marriage the complainant was first taken to her matrimonial home where the in-laws were residing and after spending a month complainant and accused (1) and (2) were shifted to …………..
4. That after six months of the marriage, the complainant was subjected to mal treatment, both physically and mental at the hands of accused (1) and encouragement of the accused (2) for demand of dowry of Rs. 20 lacs. Having failed to meet such demand she was tortured continuously and torture by accused (1) and (2) were unabated.
5. That the offence under section 498 –A, Indian Penal Code is a continuing offence and on some occasions both accused (1) and (2) had taken part in inflicting tortures on the complainant and on other occasion accused (1), husband had taken part of the said offence and as such ……….. (P.S.) has jurisdiction to investigate into the matter under Clause (C) of Section 178 of the Cr.P.C. and this Court has jurisdiction to try this case.
6. That there is primafacie case under sections, 498 – A/406 of the Indian Penal Code against all the accused persons.
7. That the incident was reported to the ………..(P.S.), they did not take any action against the accused and refused to report a FIR against them, hence the Complaint is filed in the Court.
Prayer:
It is therefore, prayed that the complaint be forwarded to the Officer-in-charge,………… (P.S.) to investigate the matter and to lodge an FIR in the above case and report may be called from the SHO …… (P.S.)
under Section 156 (3 of Cr.P.C.) in the interest of Justice.
Sd. Complainant Through Council
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