IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS,
KHADKI AT KHADKI
Criminal Complaint No. /200_
Shri __ B __ B _ K _, )
age 30 years, occupation – service, )
Complainant
resident of 100 Shitolenagar, Sangavi, )
PUNE 411 027. )
Versus
1. Shri _ K __ V _ A __, )
age 56 years, occupation – agriculture, )
2. Smt. __ A ___ B _ K _, )
age 25 years, occupation – household, )
3. Shri _ D __ K _ A __, )
age 30 years, occupation – service, )
4. Shri __ S __ K __ A __, . )
age 25 years, occupation – education, )
all residents of Yeli, Taluka Pathardi, )
District Ahmednagar. )
A COMPLAINT U/SS 323 & 504 R/W SEC. 34 OF THE INDIAN PENAL
CODE
The complainant abovenamed submits this complaint, praying to state
as follows:
1. That the complainant is a resident of the within mentioned address, and
the accused No. 2 is his legally wedded wife, while the accused No. 1 is
her father and the accused Nos. 3 and 4 are her brothers.
2. That the complainant is originally a resident of the village Yeli,
Taluka Pathardi, District Ahmednagar.
3. That on account of his service in the Bajaj Tempo Limited, Chinchwad, Pune,
the complainant has presently been residing at the within mentioned
address for the last five years.
4. That the complainant was married to the accused No. 2 in the year 20,

and they have a son of about three years.
5. That due to some misunderstanding on the part of the accused No. 2
and at the instance of the accused Nos. 1, 3 and 4, the accused No. 2
has not been cohabiting with the complainant for the two years, and
during this period, she has all along been residing with the accused No. 1
only.
6. That despite several requests and a lot of persuasion made by this
complainant, his parents and also reconciliation tried by the relatives- in-
common, the accused No. 2 has never turned up to cohabit with the
complainant and has also wittingly and willingly refused to cohabit for no
fault on the part of the complainant.
7. That in the mean time, instead of responding to the requests and
appeals repeatedly made by this complainant with a view to restoring back the
normalcy of his domesticity with the accused No. 2, the accused No. 2 has
filed a maintenance application in the Pathardi Court, and the same has
since then been pending in that court of law.
8. That even though the said case between the complainant and the
accused No. 2 is already sub judice, all the accused on their own pursued
the complainant upto Pune and thereby committed the following offence.
9. That on Sunday, the….of…200 when the complainant returned from his
duty in the evening, got down from his company-bus near the Khadki
Station, all of a sudden, he happened to confront the accused near the
Excelsior Talkies where the accused accosted him.
10. That the accused asked this complainant that he should be ready and
willing to pay a sump sum of Rs. 1,00,000/- towards the maintenance
of the accused No. 2, to which the complainant did riot agree, and when the
complainant particularly pointed out about the pending court-case, the
accused threatened that ii the complainant were to show his readiness and
willingness before the court of law to cohabit with the accused No. 2, they
shall undo what they please, and, at the same time, the accused Nos. 1, 3
and 4 gave blows on the person of the complainant and kicked him down on
the ground, and while the other accused were beating the complainant, the
accused No. 2 was standing nearby shouting and abusing the
complainant.
11. That the complainant was injured, and, when with the help of the
passers-by, he tried to stand up, all the accused had already been
disappeared.
12. That the complainant was very much ashamed of himself when such a

public scene was created by the accused, and he was, thus, tortured by
the accused physically and mentally to a great extent, and since then, the
complainant apprehends that the accused may cause danger or commit
hurt to the complainant in future also.
13. That the complainant also made a complaint-application to the
Khadki Bazaar Police Chowkey, with a request to give him necessary help and
protection, which the police did.
14. That the accused have, thus, committed an offence u/ss 323 and 504
R/W Sec. 34 of the Indian Penal Code within the local limits of the
jurisdiction of this court, and hence, this Hon'ble Court has right and
jurisdiction to try this complaint and punish the accused.
15. That the cause of action for this complaint first arose on…….., and the
same has since then been every day thereafter, and hence, this complaint
filed today is well within limitation.
16. That the offence has been committed within the local limits of the
jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to try and
decide this complaint.
17. That the necessary court-fee is paid herewith.
18. That the complainant, therefore, prays that the accused be charged
with and tried for the offence punishable u/ss 323 and 504 R/W Sec.
34 of the Indian Penal Code and punished according to law.
Pune, Sd/- BBK
COMPLAINANT
Dated :
Sd/- xXx
ADVOCATE FOR COMPLAINANT

VERIFICATION
I, Shri BBK, the present complainant, do hereby state on solemn
affirmation that the contents of this complaint in paras 1 to 18 are
true and correct to the best of my knowledge and belief, and so I

have signed hereunder.

Sd/- BBK
COMPLAINANT