To,                                                                                 Dt.: xxx

The Asst. Commissioner of Police, 

The Crime against Women Cell,

xxxx,

New Delhi.

Sub:  Complaint against Accused No.1 Xxx(Husband), Accused no.2 Xxx(father in law), Accused no.3 Xxx(mother in law), All R/o Xxxand Accused no.4 Xxx(sister in law) (Nand) R/o Xxx, for dowry demand, physical abuse, cruelties, mental, statutory rape, and harassment for dowry demand.

Respected Sir/Madam,

1.           That the complaint has been filed against the atrocities and cruelties committed upon Mrs. ………. Kapoor (hereinafter called the “complainant”) by her husband namely, Xxx(Husband), Xxx(father in law), Xxx(mother in law), and Xxx(sister in law) (Nand), (hereinafter called the “accused persons”).

2.           That the accused no.1 and complainant started dating each other in 2014, she was just 15 years old at that time. Accused no.1 used to came to her school and take her from there, accused made her bunk her school and used to go to a park near her school and there accused tried touching her inappropriately. Later the accused started taking the complainant to hotels, where he forced me into a physical relationship, same happened for many years. Accused always pressurized me for making physical relationship and scared complainant by saying that accused will tell her family about relationship and leave her. Accused also forcing the complainant to go with him Mumbai and he blackmail the complainant on the pretext that accused will tell everything to her parents about their physical relationship with him and then accused forcibly took the complainant to Mumbai, on the expense of the complainant at that time complainant was under 17 years and accused was attended the majority of age 18 years, there also accused forced and make physical relationship with the complainant. Thereafter, accused also took the complainant to Amritsar from her expenses. It is pertinent to mention here that complainant was minor at that time when the accused no.1 make physical relationship with the complainant and he was 18 years cold. It is view of the settled law that any male, who does an intercourse with any female who is below the age of 18, with or without her consent will be constituting a Statutory Rape. This offence is created to save the exploitation of the minor by the adults. In this kind of rape, the adult will get punished if he had any kind of physical interaction with a woman/girl, in the age of 18 or below, no matter if she has voluntarily participated in the act or not. The consent of the minor is immaterial and will not be considered any defence to the accused. Statutory Rape is always in a shadow as the voice of victims goes unheard or they will not get any support from the society and our system. The minors who gets suffered from these acts, lives a horrifying life and it creates a massive disaster in their mind. The narrow minded people who do these acts, should be given the strict punishment so that it gives the pact lesson to the wrongdoers.

3.           Accused always pressurized the complainant and emotionally tortured her to give him money for his day to day expense, because his parents never give him any pocket money. One day, when the complainant refused to give any money and told him that “I don’t want to stay with you anymore”, Accused slapped the complainant in front of her friend and hit her, physically tortured and fought with complainant on this issue. Accused has many times beaten the complainant in front of her cousin. Accused always abused the complainant and he always forced her for making physical relationship with him. Accused took the complainant to different hotels and blackmailed her to make physical relations with him. Accused always said “agar nahi kregi, ya paise nahi degi toh shaadi nahi karung”. Before making any physical relationship and taking money from the complainant, accused always promised her that he will marry her. Accused always forced her and compelled to give him money and to make physical relationship with him on else accused said “he wouldn’t marry her and tereko badnam kar dunga”. Accused always promised for marriage and to keep the complainant separately from his parents, he always brainwashed her to get married to him. Suddenly, accused started mentally and emotionally pressurizing the complainant to marry with accused as he told his father and mother and they knew about their relationship. Accused persons forced the complainant and demanded money in the name of marriage. Accused persons blackmailed the complainant by saying “apne bete ki shadi nahi krenge tujhse agar humko paise nahi diye toh”. All the accused persons took money from the complainant at that time, accused no.1 in the influence of his parents always blackmailed the complainant and took money. Accused persons took Rs.2 Lakhs on the name of marriage and thereafter his family members i.e. accused persons no.2 to 4 gave the permission to marry with accused.

4.           In the emotional influenced and in love with accused no.1, complainant was married to him on ………….. at …………….. in the present of accused no.2 to 4 and told the complainant to remained in her parental home and never tell anything about the marriage to her parents. Later on the parents of the complainant got to know about the marriage of the complainant and accused no.1, being a only daughter of her parents and due to the love and affection the parents of the complainant, bag to the parents of the accused no.1 and requested to accept the complainant as their “Bahu” and wife of accused no.1, after so many requests and intervention of relatives, accused persons agreed and demanded that “hum yese nahi lekar jayenge ladki ko, humari bhi ijjat hai samaj mai, appko uski Vidai ka function karna padega aur dan dahej dena padega, warna hum use accept nahi karenge”, parents of the complainant agreed and managing the “Vidai” ceremony function which was held on ………. in the presence of family members of the accused persons, but accused persons pressurized the parents of the complainant to give the gifts, cloths and money to their entire family members and just before moving in together, accused persons said to the complainant that “if you want to stay with your husband then you have to ask your parents for house, furniture, electronics appliances and other necessary things and hard cash of Rs.2 Lakhs”, after fulfilling this demand then only complainant can enter her matrimonial home and stay with their son accused no.1. Accused persons emotionally tortured the complainant and in the emotional influence of the accused no.1, she narrated all this demand of the accused persons to her parents and being their only daughter and in the love and affection parents of the complainant fulfill their demand and handed over all the demanded items and cash of Rs.2 Lakhs to the accused persons. Accused no.1 asked the mother of the complainant to buy the property for her daughter or give the name the one floor in the property of the complainant’s parents in her name and in the meantime she will pay house rent and security money as accused no.1 want to live in the rental accommodation because he promised with the complainant to live separately from his parents. Parents of the complainant also fulfill this illegal demand of the accused no.1 and paid the rent and security money for rented accommodation, as they wanted to live her daughter peacefully, right after complainant and accused no.1 moved in the rented accommodation and due to the fear of societal stigma attached to it in their Hindu society, the parents of the complainant could not reported the police of the said demand of illegal dowry demand of the accused persons.

5.           Accused started pressuring the complainant to asked the money from her parents and get named the 2^nd floor of property of the complainant’s property. Accused no.1 always said “tere parents ka kaunsa kharcha hua hai shadi main, ask them for 2^nd floor and cash”. Accused always forced the complainant for the same and always said “agar nahi layegi to tereko chor ke chala jaunga apne maa-baap ke pass” he also compelled the complainant to a level where she had to ask her mother to put “ration” in her house. During the 2^nd month started of us living in rented accommodation, accused denied to pay the rent and pressurized the complainant to ask money from her parents for pay the rent, but the complainant refused to the same, after few months accused pressurized the complainant and said “agar tu nhi degi toh I will leave you and go to my parents place”, the same was continued till the accused no.2 and 3 moved in and residing with us, thereafter accused no.2 and 3 started putting pressure on the complainant for pay the rent and give money for other household things, in connivance with each other accused persons used to gang-up on the complainant and tortured me for money. All the accused persons knew that the fact that the complainant is studying and not earning, accused persons also knew that complainant’s parents and her brother give her pocket money for college transportation and other expenses, whenever complainant used to get her pocket money from her brother accused persons again started pressurizing and force her and given that money to them paying the for rent and other things. Complainant was under acute pressure and brainwashed that she could not think about what she should do and what not. Accused persons also forced complainant to do tell anything to her parents and her brother. Due to this instinct pressure and emotional blackmail complainant had to give all her pocket money to accused persons. Later on, accused no.2 and 3 started putting differences between the accused no.1 and complainant and instigate the accused for every small thing and accused persons no.2 to 4 used to provoked the accused against the complainant. Accused persons always instigated to the accused no.1 against the complainant, always said “tum room lock karke nahi soege, tum ek dusre se baat nahi karoge, tumhari awaz nahi ani chahiye, hum tumhare room mein tumhare sath soyenge”. Accused persons never let accused and complainant leave alone and they always interfere in the privacy of the husband and wife. Accused persons also never let them go out alone, always said “hum bhi saath challenge, tum akele bahut ja liye shadi se pehle ab jaha jaoge humare saath jaoge”, accused persons started creating differences between the accused and complainant, accused parents were torturing the complainant to a level where they didn’t let her sleep with her husband alone on even talk on eat alone. Accused persons always said “ki ye college nahi jayegi”, they always provoked the accused husband and said that “we don’t know where she goes on the name of college, who she meets, maybe she goes with other man”. Accused parents always provoked and questioning on the character of the complainant and influenced the accused husband against the complainant in a very wrong way.

6.           The accused no.2 and 3 went on to the extent of saying that he did not like the complainant and gave ill and degrading comments about her and also told her that he married the complainant only on the pretext of extorting dowry from her parents and grabbing their property. Hearing all these humiliating words and embarrassing remarks from her husband, her heart broke and the complainant was shattered in dismay that her life has been ruined with the feelings that nobody loves her in the matrimonial home. The Complainant suppressed all such humiliation, which she was subjected to tolerate and hoped that things would settle down in her matrimonial and that one day the Accused persons would start loving her. But the accused persons were brain washing accused husband of the complainant that by saying that “she is not loyal for him”, accused husband also left his job after the marriage because he was getting dependent on the complainant and her parents. After leaving the job accused pressurized the complainant to bring money from her parents because he wanted to invest in some business, he forced her mentally and physically to ask for money from her parents. Under his pressure complainant had to ask her mother for money, her mother then kept her gold on loan and gave him money for fulfill his demand. Accused persons also forced the complainant to a level where they said “paise nhi layegi toh apen ghar ja”. After sometime accused persons were again forcing the complainant, accused persons were mentally putting a lot of pressure on the complainant, accused persons were playing with the complainant emotionally and forced to ask money again from her parents. Complainant was under pressure that she could not think straight and had to ask money from her parents again, but again mother of the complainant gave accused persons gold to sell and take the money. Apart from this wherever, parents of the complainant used to go, accused always asked complainant to pay money knowing that whatever she had was given to her by her brother for college expenses and personal use. Many time accused persons forced the complainant to take money from her brother to pay the rent and rest amount to give them. On every occasion whatever her parents gave to the complainant, accused persons used to take it from her. Everyday accused persons tortured the complainant to do household work inspite of knowing that she has to study for her exam. Accused persons always said “ya toh apne ghar se kisi ko bula le kam krne ke liye varna khud kam karna padega”. Accused persons always wanted her parent help to work for them. Whenever accused persons had any work even like for not working, exhaust not working, maid on leave accused persons always asked complainant to call someone from her mother’s place to do their work. Even for household things accused persons were getting dependent on her parents. Accused persons always forced complainant to call for house help from her mother’s place for every small thing. That accused no.2 used to instigate Accused no.1 against the complainant, by making false allegations and allege the complainant for not doing all the house hold chores. As a result of the instigation, Accused no.1 used to abuse and say derogatory words to the complainant and warned her to do all the household chores in accordance with the directions of the accused no.2.

7.           It is submitted that accused husband concealing the fact that he has work somewhere else and never given any single penny to the complainant for her day to day expense, he used to give it to his parents, spent his money on himself but he never gave complainant any money for her expenses. Whenever complainant asked accused for money he always said “mere pas nhi hai agar chahiye toh apni maa se mangle”.

8.           On her birthday complainant and accused husband went out for a night stay, there also she borne the expenses. Next day morning accused no.2 and 3 called the complainant and accused husband asked to come back home, complainant said that complainant and her husband will be staying for 1 more day. As soon as accused persons got to know that complainant and her husband are staying alone for one more day, accused persons again started provoking accused husband, they abused the complainant and fought with the complainant over a call order to return back to home. When complainant and her accused husband reached home accused no.2 to 4 started abusing and beaten the complainant on the pretext that she wanted to stay alone for one move night with her husband when all this was happening accused husband did not stop them, instead he involved in all cruelty and said “tune mujhe kyu nahi bataya ki mummy-papa bula rahe hai wapis, tere pas jyada paise aa rahe hai udane ke liye”.

9.           On the occasions of Karvachauth parents of the complainant gave the complainant gold bangles and a gold chain to the accused husband as her first Karvachauth gift. After few days accused persons abused me and took the chain of accused husband in their possession and thereafter complainant came to know that they sold the said gold chain. Accused persons always had eyes on remaining jewellery of the complainant and whatever she took from her parents, on every occasion they asked her parents for cloths, money and gifts for everyone in their family.

10.       After sometime there was a wedding of brother in law of the complainant. In the wedding accused persons all bought new clothes for themselves, spent money on themselves but they did not buy a single dress to the complainant, rather accused persons forced complainant to ask for clothes and other things from her parents. After wedding of his brother accused, all relatives came to the house of her in laws for a night stay. There also accused husband asked the complainant to pay all the bills and complainant borne the expenses of them for saving the image of her husband. Whenever complainant and accused go anywhere he always forced me to pay the bill. On the instigation of accused no.2 to 4, the accused husband beaten the complainant mercilessly, his parents also came in between and provoke him to beaten the complainant more give her lesson to ignore the demand of property. Accused persons instigate the accused husband to abuse, torture mentally and emotionally to the complainant on the pretext of get the property in his name. Whenever there is a get together of the family at complainant’s parental home, accused husband wants to take complainant with him, in laws always denied and said “usko akele jane de wo kya kregi ja kar”. Accused persons always stopped complainant for going to her parental home and they also never allowed the complainant to talk to her parents and their ears always on complainant. Whatever the complainant used to do, what she wears, what she eats, what she talks to her husband, what she does in her room accused persons always have kept on eye on everything. Accused persons were always involved in between the complainant and her husband. Accused persons always kept us away from each other and they always did things which were creating distance and difference between the complainant and accused husband. After that on birthday of accused husband, complainant planned to go out together for dinner, and when the complainant asked her in laws to go out for his birthday, but they denied and created a scene, and started fighting with the complainant, accused persons were abusing the complainant on filthy language. Later accused persons also provoked the accused husband and he turned their side and started abusing and beating the complainant. After few days accused persons came to complainant and again asking for money and gold bangles which were given to the complainant by her parents on Karvachauth when she refused to given the same, accused persons tortured and blackmailed the complainant by saying “ghar se nikal denge tujhe, aur shadi kara denge apne bete ki kahi aur”, after continuous torture and harassment, accused persons took the bangles from the complainant, the said gold Bangles were of worth Rs.4 Lakhs, they also threaten the complainant for not telling anything to her family, accused no.2 gave the artificial pair of bangles, just in case her parents ask for them.

11.       Accused husband never told complainant about his work and his source of income whenever complainant asked the same, he said “terko batana zaruri nhi samjhta”. Accused never gave complainant any money for her basic expenses, even her toiletries were buy by the parents of the complainant. Later on, her 1^st wedding anniversary complainant and accused were plan to goa and went there, even for that accused forced me to ask money from her parents for the same, parents of the complainant gave him Rs.50,000/-. After that accused kept the gold chain of the complainant on loan which was given to her by her parents. Accused persons also provoked the complainant against her parents, they always eavesdrop when she used to talk to her parents, they used to record her calls. Accused persons tortured to a level where they put a call recorder in complainant’s phone and used to listen to what she talks to ger parents. One day accused persons along with complainant came for dinner at her parent’s place, there accused no.2 created a scene, he got drunk he started abusing the complainant, snatched her phone and asked her to get out of her parent’s house. Accused persons also abusing complainant in front of everyone called her “Randi” again while all this was happening accused husband was standing there but he did not said a single word to stop them of abusing the complainant. Accused no.2 created this whole scene because complainant was talking to her mother alone in another room and he didn’t wanted her to talk to her, accused persons never let her go to her mother house alone. From the accused persons, one of them always come with the complainant to her mother’s place whenever she used to talk to her parents on come to their place and her to talk about the floor and force her parents to get the floor in their name and on the get together day of the family accused persons left the complainant at her parental home because they wanted her to talk to them about floor to be get their name. After two days when complainant went back house accused persons asked her about the floor, when she denied for talk of the same they pushed her out of the house, smashed the door on her face. Thereafter, brother of the complainant called accused persons to talk, she asked accused if he wants to stay with me separately away from his parents. But accused denied and started fighting and abusing the complainant and her parents and her brother then complainant reminded him that accused promised that “we will stay together alone after marriage” then he said “if you wanna stay alone, apne ma-bap ko bol floor tere name karde aur merko 5 lakhs cash de”. Due to the fear of societal stigma in the society, the complainant could not report to the police or higher authorities regarding the said atrocities and cruelty committed by the accused persons.

12.       That the physical as well as the mental health of the Complainant was severely affected, the complainant was made to work whole day without any rest and at night the complainant and her family members were cursed and abused by Accused persons. That Accused no.1 did not leave any chance to abuse and beaten the complainant. That with time, the physical cruelties and atrocities committed upon the complainant by Accused persons further increased and now accused no.3 was also aggressive in physical beatings and when complainant told him that she is his Bhabhi then accused no.3 used to say that “Teri Jaisi Aurat ki hamare ghar me koi ijjat nahi nahi hai, bhai batata hai tumne kya kya kiya shadi se pehle life mein”  and when complainant scolded the Accused no.3 in front of all the family members, on the same night, the accused no.3 abused her in filthiest language and warned her that he would go upto any extent created unnecessary scenes and complainant tried to make 100 number to police then accused no.3 snatched the phone from her beaten her badly with slaps.

13.       That thereafter Accused no.3 again committed all kinds of physical cruelties upon the complainant, accused no.3 pushed, punched in face and beaten mercilessly complainant. That the said physical atrocities become a routine affair and the complainant was regularly beaten by the Accused no.2 & 3 in connivance and support of rest of the accused persons. Those accused no.1,2,3 warned the complainant that if the complainant did not bring the dowry of Rs.5 lakhs in cash and named the floor of the parents of the complainant, she would be subjected to the said atrocities on a regular basis and accused persons would make her condition worsen.

14.       Since then complainant has seen that there is a complete change in the behavior of the Accused no.1. Further, on smallest things accused no.1 had been giving the complainant threats of throwing her out of the house and also beating mercilessly and in the month of first week of May, 2022, the accused no.1,2,3,4 beaten very badly and due to severe beatings by accused no.1,2,3,4, the complainant was not able to move from the bed for whole night and they thrown the complainant from the house with only wearing clothes and the complainant went to her parental home, however, after reaching her parental home, neither Accused no.1, nor accused no.2 and 3, 4 chose to talk to the Complainant. Accused persons behaved in the cruellest manner with the complainant and when the Complainant returned to her house and on the same day, husband/accused no.1 once again beaten her very badly and asked to leave the house and when complainant denied to do so then accused no.1 thrashed the complainant that now he would remarry & live with new wife in front of complainant and blamed the complainant as characterless and, the accused no.1 did not care and collected all the costly items i.e. all diamond articles, gold jewellery items of Complainants, cash money etc. and left the company of complainant and said he would not come again in the life of complainant and complainant would face the worst phase of life.

15.       That resulting out of the time constraint the Complainant has not been able to bring the complete facts and documents on record, and seeks liberty to allow the Complainant to accordingly bring additional facts and documents on record as and when possible for the Complainant.

16.       That the life of the complainant became miserable in her matrimonial house. That it is also important to mention here that the Accused persons caused lots of physical, mental torture and harassment to the complainant. Also accused persons used to threaten the complainant that they would not leave the complainant alive.

17.       That the Accused persons used to taunt and humiliate complainant on every occasions and whenever, complainant goes outside the house, Accused persons levelled false allegation and complainant most humbly submits that, no one from the family of them has ever tried to pacify and advise him about the right way to lead the family.

18.       That due to vile and abusive behavior of the Accused persons, complainant had been subjected to mental cruelty / physically and psychologically. That Accused no.1 refused to support the complainant and blamed her and apart from physical cruelties, complainant has been subjected to different types of cruelties which is more harmful then of physical cruelties and this have destroyed the peace of mind and grievously hurt her mental feeling.

19.       That the comprehensive appraisal of the entire matrimonial life span of the complainant and the Accused No.1 clearly shows that the Accused No.1,2,3,4 are guilty of treating the complainant with violence that is physically, mentally, economically as well and that is to without any just and reasonable cause, which has been unpardonable and unforgiveable and their willful and unjustifiable acts have inflicted severe harassment and agony to the complainant and has forced the complainant to take the step of filing this complaint against the Accused persons for their unbearable violence.

20.       That the Complainant was so mentally disturbed and encumbered by all the Accused persons that many times she thought to commit suicide, but finding hope, the Complainant used to pacify herself that these times of hardships will end soon but to her bad fortune the Accused persons never showed their care and concern for the Complainant and at all times inflicted atrocity and cruelty upon her.

21.       That due to the atrocities and cruelty committed upon Complainant and trying to come out of the trauma suffered by her. The entire persona of the complainant has been destroyed, who was very confident, smart and hardworking person. She cannot depose confidence in anybody nor can trust anyone due to the ill behavior constant demand of dowry and taunts for the same of the Accused persons meted out on to the complainant and her family members.

22.       That the accused no.1 is still in the possession of the entire jewellery and all other stuff of the complainant. It is pertinent to mention herein that the Accused no.1 forcefully took the jewellery of the Complainant and has kept them in his possession or might be possible they sell out the same. That the complainant has been made to suffer various above stated acts of cruelty and demand of dowry.

23.       That due to the constant threats by all the accused persons the complainant got scared and felt alarmed as the Accused persons are persons of means and are capable of executing their threats and the complainant is left with no other option but to approach your goodself.

I have not left with other remedy except to approach before your goodself to kindly take appropriate actions against the accused persons and help me for getting back my Istridhan articles, and other valuables back which is in their unlawful possession. I reserve my right to make additional statement about their conducts and details of other atrocities committed by them as and when directed by your goodself. I have been forced to file this complaint. It is therefore request that you may take appropriate action against the aforesaid persons.

It is, therefore, requested to your good self to kindly take the appropriate action against the aforesaid accused persons as per law and register FIR under provisions of 375/498A/406/506/34 of IPC.

          Your’s faithfully,

(……… xxxxx)

W/o xxxxxx,

R/o xxxxxx.