IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS,
(COURT NO. 4), PUNE AT PUNE
Criminal Complaint No. /200_
Shri __ B __ A __ R , )
age 45 years, occupation – service, ) Complainant
resident of 777 Sadashiv Peth, )
PUNE 411 030.
Versus
1.Smt. _ R__ A _ B _,
age 35 years, occupation – service,
2.Shri A __ B R , ) Accused
age 40 years, occupation – service, )
both residents of 555 Narayan Peth, )
PUNE 411 030. )
A COMPLAINT U/SS 500 & 506 R/W SEC. 34 OF THE INDIAN PENAL
CODE
The complainant above-named submits this complaint, praying to state as
follows:
1. That the complainant has been in service of the Technical Education
Department since the last twenty-five years, and is, at present, working as
an Assistant Professor of Mechanical Engineering at the Government
Polytechnic, Pune, for the last ten years.
2. That the accused No. 1, who is the first wife of the accused No. 2, is also
in the service of the said Technical Education Department and is now
working as a Lecturer in Physics, while the accused No. 2 is working as an
Administrative Officer at the Sassoon General Hospitals, Pune.
3. That as a colleague of this complainant at the said institute, the accused
No. 1 also used to visit the residence of the complainant and his family
occasionally and thereby developed domestic intimacy with them.
4. That subsequently, when the accused No. 2 contracted a second
marriage with one, Miss Poonam, who is also working at the Sassoon
General Hospitals, Pune, as a Staff Nurse, the accused No. 1 started to
narrate to this complainant and other colleagues in their institute the new
stories and the indifferences then being developed between both the
accused, and also unnecessarily expected the complainant to take interest
in the same and to do something on her behalf and in her favour, but taking
into consideration the very nature of such family affairs, the complainant
refused to interfere with the same and paid no heed to what the accused
No. 1 was then saying to him, which rightly or wrongly offended the

accused No. 1, and this has resulted into difference of opinions for no fault
on the part of the complainant.
5. That as a result of such an indifferent behaviour on the part of the
accused No. 1, she made a false complaint to the Principal of the institute
and also to the police, alleging that the complainant teased her, and when
there was an enquiry made in the matter, it was found that there was no
substance in the said complaint, and similar were the findings of the police
investigation also.
6. That during the period of the last six months or so, the accused No. 1
with common intention of the accused No. 2 wrote five anonymous letters
to the complainant with intimidating and obscene language to the effect that
his ten-year old daughter will be kidnapped, raped and murdered.
7. That the complainant accordingly reported the matter to the police, and
from their preliminary investigations, it was revealed that those anonymous
letters have been written or caused to be written by the accused No. 1 with
common intention and in league with the accused No. 2.
8. That on account of these threatening letters and false, fabricated,
imaginary, baseless and defamatory allegations made by the accused, the
complainant and the whole of his family have been defamed and are also
under constant tensions and tortures, and they apprehend that the accused
may further indulge into such criminal activities and cause danger to the
family of the complainant.
9. That this complainant also submits that all such illegal activities indulged
into by the accused have threatened the security of the family of this
complainant as a whole, and hence, it has become necessary for the
complainant to book the accused and file this complaint against them.
10. That the cause of action for this complaint first arose on……, and has
since then been arising every day thereafter, and hence, this complaint
filed today is well within limitation.
11. 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.
12. That the necessary court-fee is paid herewith.
13. That the complainant, therefore, prays that the accused be kindly
charged with and tried for the offence punishable u/ss 500 & 506 R/W Sec.
34 of the Indian Penal Code and punished according to law.
Pune, Sd/- BAR
COMPLAINANT
Dated:
Sd/- xXx

ADVOCATE FOR COMPLAINANT
VERIFICATION
I, Shri BAR, the present complainant, do hereby state on solemn
affirmation that the contents of this complaint in paras 1 to 13 are true and
correct to the best of my knowledge and belief, and so I have signed
hereunder.
Sd/- BAR COMPLAINANT