BEFORE THE COURT OF LEARNED CHIEF JUDICIAL MAGISTRATE,
SAMBA
Darmo Devi Wd/o Lt Baggar Ram R/o Near Kabir Dass
Mandir Rakh Amb Talli (Lower Karandi) Tehsil and distt
samba.
..Applicant/Complainant
Versus
1. SurajLK
2. Balwant Raj
Both S/o Late Sh Baggar Ram
3. Gara Ram S/o Lt Mangal
4. Rampal S/o Suraj
5. Asha W/o Rampal All R/o Near Kabir Dass Mandir Rakh
Amb Talli (Lower Karandi) Tehsil and distt samba.
Non Applicants /Accused Persons..
In the matter of: -
Complaint under Section 156 (3) Cr.P.C.
seeking direction for the P/P Rakh Amb Talli
to investigate and register the FIR against
the accused persons.
.
May it please your Honour;
The complainant/ applicant most respectfully submits as
under:
1. That the complainant/applicant is an ailing and old aged
lady and out of wedlock four sons and two daughters
were born out and all the sons and daughters are married
and settled at their respective houses.
2. That the accused no 1 and 2 are sons whereas the
accused no 2 and 3 are grand sons and accused no 5 is
grand daughter in law.
3. That the complainant in this old age living with her son
namely Balbir Chand and he look after the complainant
and fulfill all her needs and necessities.
4. That the husband of the complainant was owner in
possession of the land measuring 6 kanal falling under
Khasra No 23 situated at village Lower Karandi rakh Amb
Talli and after his death the complainant was step into his
shoes and become owner of the land, thereafter the
Complaint partitioned the above said land to her sons and
all are in possession of 30 marlas of land and have
constructed their houses.
5. That the accused persons are the strong headed persons.
They never bother to look after the complainant. The
accused persons want to grab the entire property of the
Balbir chand as the complainant is residing with him and
they have not maintaining to the applicant except balbir
chand.
6. That on 25/7/ 2019 when the son of the complainant
namely Balbir Chand when try to construct the wall over
his share all the accused persons caught hold the
complainant and starting beating her mercilessly at this
old age.
7. That the accused persons in the past had been beating,
harassing and torturing the complainant without any just
cause and reason.
8. That on 25.07.2019 the complainants approached I/C Police
Post Rakh Amb Talli and gave him an application in writing
requesting to register an FIR against the accused persons or
take necessary actions as warranted under law but the
concerned I/c Police Post has fail to take any action against
the accused persons rather refused to register FIR
.
In the premises: -
It is, therefore, most respectfully prayed that the
concerned I/c Police Post Rakh Amb Talli Police may kindly
be directed to investigate and register the FIR against the
abovementioned accused persons under relevant sections
and to dealt / prosecute them under law in the interest of
justice.
Complainant
Through Counsel
Dated: 30.08.2019
(Munish Choudhary)
Advocate
BEFORE THE COURT OF LEARNED CHIEF JUDICIAL MAGISTRATE,
SAMBA
Chaman Lal S/o Lt.Sh. Kherati Lal R/o Village Barota Camp
Tehsil Ramgarh and Distt samba.
..Applicant/Complainant
Versus
1. Prem Pal S/o Lt Mohan Lal
2. Varinder Singh S/o Prem Pal All R/o Village Barota
Camp Tehsil Ramgarh Distt Samba
3. Surinder Kumar S/o Bachan Lal All R/o Near
Gurudwara Ramgarh Tehsil Ramgarh Distt Samba
Non Applicants /Accused Persons..
In the matter of: -
Complaint under Section 156 (3) Cr.P.C.
seeking direction to the SHO Ramgarh to
investigate and register the FIR against the
accused persons.
.
May it please your Honour;
The complainant/ applicant most respectfully submits as
under:
1. That the complainant/applicant is permanent
Residence of Union Territory of J&K state and
resident of vill Barota Camp Tehsil Ramgarh Distt
Samba.
2. That the accused No 1 is Ex- Sarpanch of Vill Barota
Camp Tehsil Ramgarh Distt Samba whereas the
accused no 2 is son of the accused No 1 and accused
no is 3 real nephew of the accused no 1.
3. That the accused no 1 is a land grabber and illegally
and forcibly occupied a Evacuee land measuring 178
Kanal which is situated at village Kajyal Khurd Tehsil
Ramgarh Distt Samba and to this extent the Auction
Notice of the said Evacuee property was also issued
and the applicant will also be one of the bidder of the
said auction and the accused no 1 threatened to the
applicant,that if the applicant participate in the said
auction he will kill the applicant as well as his son
and moreover prior to this incidence no of times the
non applicant and his son always used to threatened
to the applicant and others . The photocopies of the
same are attached herewith.
4. That on the instigation of accused no 1 , the
accused no 2 and 3 along with three unknown
persons attacked upon the applicant.
5. That on 24th day of July 2020 at about 8:30 P:M , the
applicant along with one surinder Pal went to
withdraw the money from ATM at Ramgarh and
when they reached near ATM at Ramgarh suddenly a
white colour car stopped near to the applicant and
from the car 5 persons i.e accused no 2 and 3 and
three unknown persons suddenly came out and
attacked upon the applicant with iron rods, lathies
started beating to the applicant with iron rods and in
the meantime one Shiv Choudhary who is also
resident of Village barota camp coming from Jammu
saw the accused persons beating to the applicant he
tried to stop them and asked them that why they are
beating to the applicant, the accused persons
suddenly attacked to the shiv Choudhary and
shattered the mirrors of car of Shiv Choudhary and
also beating him and being afraid the said shiv
choudhary fled away from the spot and save his life
and on the applicant hue and cry the public atlarge
gathered on spot and save the applicant from the
clutches of the accused persons and all accused
persons run away from the spot and threatened to
the applicant that on one day they will kill the
applicant, therafter the applicant went to the Police
of Police station Ramgarh, the applicant shocked on
seeing that the accused no 1 is already sitting along
with the S.H.O police Station Ramgarh and having a
cup of Tea with the S.H.O. The applicant filed a
written complaint to the S.H.O and also forward the
copy to the S.S.P Samba. The photocopy of the
complaint/application along with photographs which
clearly shows severely beating by the accused
persons to the applicant is attached herewith for kind
reference of the Honble court.
6. That the applicant no of times approached to the
SHO Ramgarh and requested him to register an FIR
against the accused persons but no FIR has been
register by the SHO Ramgarh and thereafter the
applicant approached to the SSP samba and also filed
a complaint/application through mail but till date no
FIR has been register and now the applicant
approached to the honble court.
9. That the accused persons are the strong headed persons.
And always threatened to the applicant to kill him and his
sons.
10. That on 24.07.2020 the complainant approached to the
SHO Ramgarh and gave him an application in writing
requesting to register an FIR against the accused persons or
take necessary actions as warranted under law but the
concerned SHO Ramgarh has fail to take any action against
the accused persons .
In the premises: -
It is, therefore, most respectfully prayed that the SHO
police of Police Station Ramgarh may kindly be directed to
investigate and register the FIR against the above
mentioned accused persons under relevant sections and to
dealt / prosecute them under law in the interest of justice.
Complainant
Through Counsel
Dated: 17.08.2020
(Munish Choudhary)
Advocate
BEFORE THE COURT OF LEARNED CHIEF JUDICIAL MAGISTRATE,
JAMMU
Chaman Lal V/s Prem Pal & Ors.
In the matter of: -
Affidavit in support of the complaint.
I, Chaman Lal S/o Lt.Sh. Kherati Lal R/o Village Barota Camp
Tehsil Ramgarh and distt samba, do hereby solemnly affirm
and declare as under:-
1 That the contents of the accompanying complaint have
been drafted by my counsel on my instructions and
information given by me.
2 That the contents of accompanying complaint have been
read over and explained to me in language which I
understand fully and the same are agreed to be true and
correct to the best of my knowledge.
Deponent
Verification: -
Verified by me at Samba on 17 th day of August, 2020
and I further declare that the contents made hereinabove
are true and correct to the best of my knowledge and
belief and nothing has been concealed therefrom.
Deponent
To,
The S.S.P,
Samba
Respected Sir,
In the matter of: -
Complaint against the accused person’s namely no 1. Suraj 2.
Balwant Raj Both S/o Lt. Sh. Baggar Ram 3. Gara Ram S/o Lt. Sh.
Mangal 4. Rampal S/o Sh. Suraj 5. Asha W/o Rampal All R/o Near
Kabir Dass Mandir Rakh Amb Talli (Lower Karandi) Tehsil &
District Samba seeking direction for the P/P Rakh Amb Talli to
investigate and register the FIR against the accused persons.
The complainant/ applicant most respectfully submits as
under:
1. That the complainant/applicant is an ailing and old
aged lady and out of wedlock four sons and two
daughters were born out and all the sons and
daughters are married and settled at their respective
houses.
2. That the accused no 1 and 2 are sons whereas the
accused no 2 and 3 are grand sons and accused no 5
is grand daughter in law.
3. That the complainant in this old age living with her
son namely Balbir Chand and he look after the
complainant and fulfill all her needs and necessities.
4. That the husband of the complainant was owner in
possession of the land measuring 6 kanal falling
under Khasra No 23 situated at village Lower Karandi
rakh Amb Talli and after his death the complainant
was step into his shoes and become owner of the
land, thereafter the Complaint partitioned the above
said land to her sons and all are in possession of 30
marlas of land and have constructed their houses.
5. That the accused persons are the strong headed
persons. They never bother to look after the
complainant. The accused persons want to grab the
entire property of the Balbir chand as the
complainant is residing with him and they have not
maintaining to the applicant except balbir chand.
6. That on 25/7/ 2019 when the son of the complainant
namely Balbir Chand when try to construct the wall
over his share all the accused persons caught hold
the complainant and starting beating her mercilessly
at this old age.
7. That the accused persons in the past had been
beating, harassing and torturing the complainant
without any just cause and reason.
8. That on 25.07.2019 the complainants approached I/C
Police Post Rakh Amb Talli and gave him an
application in writing requesting to register an FIR
against the accused persons or take necessary actions
as warranted under law but the concerned I/c Police
Post has fail to take any action against the accused
persons rather refused to register FIR.
In the premises: -
It is, therefore, most respectfully prayed that the
concerned I/c Police Post Rakh Amb Talli Police may kindly
be directed to investigate and register the FIR against the
abovementioned accused persons under relevant sections
and to dealt / prosecute them under law in the interest of
justice.
Complainant
Darmo Devi Wd/o Lt. Baggar
Ram R/o Near Kabir Dass Mandir
Rakh Amb Tali Samba
Dated: 30.08.2019
To,
The SHO Police Station,
Vijaypur.
Subject: Application for lodging the FIR against Mohd Rashid S/o
Yousaf 2. Nageena W/o Mohd Rashid Both R/o Village Amwal
Tehsil Vijaypur Distt Samba 3. Altaf 4.Mirza 5. Juvaid All S/o Gul
Hassan All R/o Village Baguna Tehsil Vijaypur Distt Samba 6.
Imran S/o Alf Din R/o Ghagwal Tehsil Ghagwal Distt Samba 7.
Liquat S/o Hussain R/o Cherni Pahadi Tehsil Majalta Distt
Udhampur
Respected Sir,
I, Parveen Akhter W/o Mohd Latif R/o Sangwal Tehsil Vijaypur Distt
Samba most respectfully submit as under;-
1. That I had solemnized marriage with my husband namely on
. 24-3-2008 against the wishes of my parents .
2. That at the time of marriage my parents are aginst the
marriage
State of J&K through
Incharge Police Station Gharota, Jammu.
…Non-applicant
In the matter of: -
An application under Section 156 (3) RPC
seeking direction to the Incharge Police
Station Gharota, Jammu to lodge FIR against
the accused namely Rashid Ali S/o Ghulam
Nabi R/o Dhar Drochan, Tehsil Bhalwal
District Jammu under relevant provisions of
law.
And
In the matter of: -
Complaint under Section 376 RPC.
May it please your Honour:
The applicant most respectfully submits as under: -
1. That the applicant is the permanent resident of State of J&K
and at present is residing at the above mentioned address.
2. That the applicant is the legally wedded wife of Younus Ali
and living with him at matrimonial home at above
mentioned address.
3. That on 27.07.2016 at about 8:00 A.M. in the morning, when
the complainant had gone for grazing her cattle in the filed,
the complainant was all alone at that time and all of sudden
the accused namely Rashid Ali who was hiding therein
having sharp edged weapon in his hand, caught hold the
complainant from backside and put the sharp edged weapon
on the neck of the complainant and starting abusing her
with unparliamentarily language and tore the clothes of
complainant and forcibly raped her in the open filed. The
complainant made hue and cry but unfortunately there was
no one else to intervene and help her.
4. That after committing the rape, the accused fled away from
the spot and the complainant who was in unstable state of
mind after the incident remained there for few minutes and
when she gained her conscious mind ran toward her house
and narrated the incident to her husband.
5. That thereafter, the complainant along with her relatives
approached the SHO Police Station Gharota on many
occasions but the SHO concern refuses to lodged any FIR
under the relevant sections against the accused person.
6. That on 05.08.2016 the complainant along with her husband
and relatives again approached the SHO Police Station
Gharota and moved a written complaint against the accused
person. The complaint was received by the SHO Police
Station Gharota but he said that he will not take any action
against the accused person nor will he lodge any FIR,
therefore, the complainant seeks kind indulgence of this
Hon’ble Court to direct the concerned SHO to lodge an FIR
against the accused person and investigate the matter.
Copy of written complaint is enclosed herewith and marked
as Annexure-A for the kind perusal of the Hon’ble Court.
7. That the crime committed by accused person is not against
the complainant but also against the society and such kind
of people should be dealt with law and should be kept
behind the bars, so that they cannot harm the dignity of the
innocent persons.
8. That the offence has been committed within the jurisdiction
of the Hon’ble Court and Hon’ble Court ahs jurisdiction to
take action against the accused person.
An affidavit in support of the application is enclosed
herewith.
In the premises: -
It is, therefore, most respectfully prayed that in view of
the submissions made hereinabove, the direction under
Section 156 (3) RPC may please be issued to the Incharge
Police Station Gharota for loding of FIR against the accused
namely Rashid Ali S/o Ghulam Nabi R/o Dhar Drochan Tehsil
Bhalwal District Jammu under relevant provision of law.
Complainant
Through Counsel
Dated:
(Z.A Chauhan)
Advocate
