XXXXX                             VERSUS                             XXXXX






1.  That on XXXX, FIR no.260/2021 has been registered U/s 25 Arms Act & 364 IPC in the Police Station XXXX on the complaint of XXXX (Nephew/Bhanja of diseased) S/o XXXX  R/o XXXX Thana- XXXX Distt- XXXX, and later on 302IPC and other sections added in the present FIR.


2.  That the brief of the case is as below:-

     “My Mama XXXX S/o XXXX R/o XXXX, running his Hardware shop, I was also working with him. My mama sat on the opposite shop and I brought his Car number- XXXX white colour and handed over to him and at XX p.m, he left for his home and approx XX p.m, I received a call from my maternal grandmother that Mama did not reach at home and after receiving the call, I came to my maternal grandmother at XXXX and after reaching there, I came to know that near the house of XXXX, one Eco Car stopped Breeza and parked in front of Breeza and pressurized abducted person driving the car and one person drove Breeza car. It is also heard that there was one fire from fire arm there. I doubt that Car Breeza belongs to my mama and they had kidnapped my mama XXXX, I am making my request to recover my mama and take action against the persons who were there in Ecko Car”.


3. That initially, the FIR was registered under sections 25 Arms Act & 364 of IPC in the police station and then got the information that my Mama XXXX was murdered by the abductors and later 302 IPC was added to the FIR.  


4.  That from last more than a month, the police have been investigating the matter and it is said to us that a total of three accused persons namely XXXX were arrested in the matter, and the rest other persons are fleeing from the police and me along with other family members asked several times about the arrest of other accused persons but investigation officers not giving satisfactory answers about the investigation.


6. That since in the above noted FIR, approximately 30 Days have passed but the Investigation Officer has not made all the arrests.


7.  If accused persons were not arrested immediately, they would definitely temper the evidence and threaten the witnesses, which is definitely against the law and injustice to the victim.


8. That there are certain points on which the day-to-day status report of the FIR is to be submitted before this Hon’ble Court and the same points are mentioned below:


(i).      Till date, how many accused persons have been arrested in the present FIR?

(ii).     Whether the pistol, knife, or other weapon used in the crime recovered or not?

(iii).    Whether mobile of all the accused persons seized by the account or not?

(iv).    Whether the location of all the mobile phones of accused persons were obtained by the Investigating officer or not?

(v).     Whether the location of all the mobile phones of diseased were obtained by the Investigating officer or not?

(vi).    Whether the mobile phone of diseased recovered or not?

(vii).   Whether the CCTV Footage of accused persons procured from the different location or not?

9.  That there are few points on which the case is to be seen like it is said that that there were five persons involved in the Crime and sixth person supplied the Katta/Revolver to them, which was used for fire.

It is said that officials have not recovered the weapon used in the crime but to family members, someone conveyed that it has been recovered.

It is said that the two mobile phones of diseased have not been recovered but to family members someone has conveyed that one mobile phone recovered but sim card has been destroyed by the accused persons and other phone, which was not having internet is not yet recovered.

There were certain persons at petrol pump, says the other story of total number of accused persons and CCTV footage of the petrol pump be handed over to the higher official of the police and also to the court concern.

10.That the direction to be given to the investigating officer to file the day to day status report with the Commissioner of Police or the superior officer with the rank of DCP in the interest of justice.

It is therefore prayed that the Commissioner of Police direct the IO of the case to file the detailed day to day status report along with copy of case diary from police station XXXX to the deputy commissioner of police in the interest of justice.

It is prayed accordingly,

Delhi                                                                             Complainant





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