IN THE COURT OF LEARNED ILLAQUA/ DUTY MAGISTRATE,
REWARI
Dhramvir ...… Complainant
Versus
Prakash & Others ….Accused
Persons
Police Station: Rampura
CRIMINAL COMPLAINT AS PER THE PROVISIONS OF
SECTION 200 OF THE CODE OF CRIMINAL PROCEDURE,
1973, PERTAINING TO OFFENCES UNDER SECTIONS
307/323/325/506 READ WITH SECTION 34 OF IPC
WITH A PRAYER TO SEND THE SAME FOR
INVESTIGATION TO THE STATION HOUSE OFFICER
CONCERNED, AS PER THE PROVISIONS OF THE
SECTION 156(3) OF Cr.P.C.
INDEX
Sr. No Particulars Page No.
1. Complaint U/s 200 with a prayer
U/s 156 (3) of C.r.P.C.
2. Affidavit in support of Complaint
U/s 200 with a prayer U/s 156 (3)
of C.r.P.C.
3. Annexures
4. Talbana
5. Vakalatnama
Date: 06.01.2024
Place: Rewari Complainant:
Dharamvir, S/o Sh. Ram Singh R/o
Village Pithrawas,, PO- Khori, Tehsil
& Disrict- Rewari, Haryana.
Through:
Vivek Tanwar, Advocate.
IN THE COURT OF LEARNED ILLAQUA/ DUTY MAGISTRATE,
REWARI
Dharamvir,
S/o Sh. Ram Singh,
R/o Village Pitherawas, PO-Khori
Tehsil & District-Rewari, Haryana
...… Complainant
Versus
1. Prakash
S/o Sh Ram Singh
2. Monu
S/o Sh Laxman Singh,
3. Saroj
W/o Laxman Singh,
4. Sandeep
S/o Sh Prakash
5. Mamta
W/o Sh Sandeep
All resident of –
Village Pithrawas. PO- Khori
Tehsil & District- Rewari
,
….Accused Persons
Police Station: Rampura
CRIMINAL COMPLAINT AS PER THE PROVISIONS
OF SECTION 200 OF THE CODE OF CRIMINAL
PROCEDURE, 1973, PERTAINING TO OFFENCES
UNDER SECTIONS 307/323/323/506 WITH
SECTION 34 OF IPC WITH A PRAYER TO SEND THE
SAME FOR INVESTIGATION TO THE STATION
HOUSE OFFICER CONCERNED, AS PER THE
PROVISIONS OF THE SECTION 156(3) OF Cr.P.C.
Respected Sir,
The complainant most humbly submits as under:
1. The complainant is a law abiding citizen of India and
the resident of the above captioned address and is
entitled to invoke the extra ordinary jurisdiction of
this Hon’ble Court by filing the present complaint in
the interests of Justice. Copy of Aadhaar Card of the
complainant is marked and annexed as Annexure C-
1 for the kind perusal of this Hon’ble Court.
2. That the facts of the complaint are that on 24 t h of
December, 2023, accused no. 4 & 5 had threaten the
complainant, warning him that if he dared to gaze
upon the the land near the bus stand, then his entire
family will be killed. The accused no.4 & 5 further
escalated their threats by asserting that they are in
Police and have connection with High Rank Officials
and said “ Agar tumhe hum maar bhi dete h , tab
bhi koi hamar kuch nhi bigad sakta .”
3. That on 26 t h December,2023, the accused 1to 3
initiated construction activities on Bus stand land
which is ancestral land of the complainant, without
any formal partition between the accused persons
and the complainant.
4. That after complainant call on 112 Helpline number
to stop the construction activities and thereafter
Police intervened contentious situation and directed
the accused persons and the complainant to be
present at Police Station on 27, December,2023 at
around 12 pm.
5. That on 27, December,2023 at around 11:30 pm
complainant and his son was going to Police Station,
they saw accused no 1 to 3 were present on the Bus
Stand land and they were getting the illegal
construction activities on the said land.
6. When complainant told the accused persons 1 to 3 to
go to Police Station as they were getting illegal
construction on the Bus stand land, accused no. 1 to
3 started hitting the complainant and his with lathi
and iron rod, that they had already kept with them.
7. That complainant and his son fell down and
thereafter accused no.2 started hitting with kicks and
fists blow to the complaint and his son and accused
no. 3 started hitting complainant and his son with
stone. Accused no. 1 started hitting the
complainant’s son from behind with rod.
8. That thereafter accused no.2 took the rod from
accused no.1 and attacked the complainant’s son
with intention to kill him , but when complainant’s
son tried to protect himself, accused no.2 hit the
complainant’s son directly on his head and hand due
to which complainant’s son suffered grievous injuries.
That thereafter accused persons 1 to 3 starting
hitting the complainant and his son with brick and
stone due to which they sustained grievous injuries.
9. That thereafter, some by passer saved the
complainant and his son from the accused persons 1
to 3 and further accused no. 1 to 3 threaten to kill
them and said” Aaj toh tumhara bachav ho gya,
age muka milne per tumhe jaan se maar dege .”
10. That complainant and his got admitted to Hospital by
some by passer and where they got treated.
Complainant’s son got fracture his right hand and
complainant also suffered grievous injuries .Copy of
the Medical documents of the complainant’s son is
marked and annexed as ANNERXURE C-2 for the
kind perusal of this Hon’ble court.
11. That the complainant submit the complaint to SHO,
PS- Rampura , against the accused no 1 to 5 and
sought legal action against the accused persons and
same was received by PS Rampura, Rewari. However
till date even after joining the investigation, no FIR
has been registered by the Investigation Agency, for
reasons best known to them. At the very outset, it is
submitted that these are serious offences against
which the Investigation Agency should had registered
an FIR. Copy of the complaint filed by the
complainant is marked and annexed as Annexure C-
3 for the kind perusal of the Hon’ble Court.
12. That the accused persons acting in conspiracy with
each other sharing a common intention have to kill
the complainant and his family member and attacked
the complainant and his son caused grievous injuries
to them his family members and further engaged in
the wrongful appropriation of the ancestral land of
the complainant without any proper
13. That given the seriousness of the offences along with
the grievous injuries suffered by the complainant
and his son at the hands of the accused persons, it is
clear that the accused persons have committed
offences punishable under Sections 307/323/325/506
READ WITH SECTION 34 OF IPC of IPC and any other
section that the Hon’ble Court may deem necessary
in the interest of justice.
14. That it is pertinent to mention over here that the said
incident was occurred within the jurisdiction of the
Hon’ble Court. Therefore, the Hon’ble Court have the
powers to try and adjudicate the above captioned
offences committed by the accused persons.
15. That a proper investigation would reveal the
conspiracy to kill the complainant and his family
members therefore, the complainant most humbly
requests for a proper and fair investigation.
16. That for the safety and security of the complainant,
immediate action is required.
17. That appropriate Court fee has been affixed on the
present complaint.
18. That no other complaint arising out of the same
cause of action is pending before any other Court of
Union of India.
That in the light of the aforementioned facts and
in the attending circumstances of the case, it is most
humbly and respectfully prayed that the concerned
SHO may kindly be directed to lodge an FIR against
the accused persons and investigation of the same as
per the provisions as laid down by Section 156(3) of
The Code of Criminal Procedure, 1973 and/ or;
Alternatively, it is further prayed that the
Hon’ble Court may take the cognizance of the said
offence and may kindly summon and punish the
accused persons under Sections 307/323/325/506
READ WITH SECTION 34 of IPC to meet the ends of
justice.
Date: 06.01.2024
Place: Rewari Complainant:
Dharamvir S/o Sh. Ram Singh R/o-
Village Pitherawas, PO-Khori, Tehsil
& District-Rewari, Haryana.
Through :
Vivek Tanwar, Advocate.
IN THE COURT OF LEARNED ILLAQUA/ DUTY MAGISTRATE,
REWARI
Dhramvir ...… Complainant
Versus
Prakash And Others
….Accused Persons
Police Station: Rampura
CRIMINAL COMPLAINT AS PER THE PROVISIONS OF
SECTION 200 OF THE CODE OF CRIMINAL PROCEDURE,
1973, PERTAINING TO OFFENCES UNDER SECTIONS
307/323/325/506 READ WITH SECTION 34 OF IPC
WITH A PRAYER TO SEND THE SAME FOR
INVESTIGATION TO THE STATION HOUSE OFFICER
CONCERNED, AS PER THE PROVISIONS OF THE
SECTION 156(3) OF Cr.P.C.
AFFIDAVIT IN SUPPORT OF COMPLAINT.
I, Dhramvir, S/o Sh. Rampura ,R/o Village Pitherawas,
PO- Khori, Tehsil & District- Rewari, Haryana, do hereby
solemnly affirm and declare as under:
1. That the deponent is the complainant in the above-
noted matter and is well conversant with the matter
and is well conversant with the facts and circumstances
of the case and as such as competent to swear this
affidavit.
2. That the accompanying application U/s 156(3) R/w
Section 200 CrPC has been drafted by my counsel under
my instructions. The contents of the same have been
read over to me in vernacular, which are true and
correct.
Deponent
Verification:
It is verified on this 06 t h day of January, 2024 at
Gurugram that the contents of the above affidavit are
true and correct to the best of my knowledge and belief
and nothing material has been concealed there from.
Deponent
IN THE COURT OF LEARNED ILLAQUA/ DUTY MAGISTRATE,
REWARI
Dhramvir,
...… Complainant
Versus
Prakash & Others
….Accused Persons
Police Station: Rampura
LIST OF WITNESSES
Respected Sir,
The complainant shall rely upon the following
witnesses to establish his case with the kind permission
of the Hon’ble Court of your Lordship.
1. The complainant himself
2. Ani Kumar, Son of Complainant
3. Any other witnesses with the kind permission of the
Hon’ble Court.
Date: 06.01.2024
Place: Rewari Complainant:
Dharamvir S/o Sh. Ram Singh R/o-
Village Pitherawas, PO-Khori, Tehsil
& District-Rewari, Haryana.
Through:
Vivek Tanwar, Advocate.
