To,                                                                                     Dt.:

The Asstt. Commissioner of Police,

CAW (Cell),

Sub: Complaint against _____________ S/o Sh_____________.

Respected Sir,

          That the complainant have been forced to approach your goodself due to atrocities committed by the accused (husband of the complainant) namely ___________.

1.       That the accused, who has neglected, harass and abuse the complainant due to greed of money and have caused physical and mental cruelties to the complainant and her two children.

2.       That ___________ (“the complainant”) had been married to Dr. _________ (“the accused”) on __________ and is presently residing at ___________ (“the property) along with the accused and her two children. The complainant had done her post graduation in commerce and had numerous job opportunities with her at the time of marriage. However, the accused and his family members strongly objected to the very idea of working women and therefore, the complainant was never allowed to take up job opportunities.

3.       That the Complainant, who has been neglected by the Accused and further Accused refused to maintain of her and has caused physical and mental cruelties to her, resulting complainant has been thrown out of the home without taking clothes and other articles / istridhan related to her and Accused has not provided shelter to her.

4.       That Accused having sufficient means deliberately / intentionally neglecting the Complainant for maintaining her and her children. That Accused is man of means and due to physical / mental cruelties caused to the Complainant. The Accused has not made any arrangements for their maintenance. That Complainant is unable to maintain herself and is under distress.

5.       The Accused has been working as a Doctor with the _____ hospital in the NFSG (Non-functional selection grade) at __________. The Accused at present is drawing salary of more than Rs.1,50,000 (One Lakh Fifty Thousand) per month  along with other benefits from the hospital. The Accused also is the owner of the property, which comprises of Ground Floor as well as the First Floor.  The Accused has given the ground floor of the property on rent and the Accused is earning more than Rs. _____/- per month as rental income amongst other incomes.

6.       It is pertinent to mention that the Complainant inspite of being a legally wedded wife of the Accused has been devoid of all the necessities and comforts by the Accused. That the Complainant has been devoid of all the pleasures of the married life. That till date the Accused has never shared any details pertaining to the finances, salary and other multiple sources of income of the Accused with the Complainant. That the Accused for the last 3(three) years has stopped cohabiting with the Complainant and has deprived the Complainant of all the marital rights of a wife.

7.       That the Accused had been an alcoholic all his life. However, since last 2-3 years the habits of alcoholism has risen to the all time high. The Accused is a heavy drinker and consumes alcohol on a daily basis as soon as he reaches home every evening.  That every day, the accused drinks about a bottle of liquor. That after drinking the liquor, the Accused not only hurls abuses upon the Complainant but also threatens the Accused as well as the children of dire consequences.

8.       That the Accused has made the Complainant financially dependent upon him as inspite of having a meritorious academic background, the Accused never allowed the Complainant to work and develop her independent source of earning. The Complainant has been seriously deprived of the necessities of life and since past more than 4 (four) months, the Accused is not giving even the basic minimum monetary contribution so as to meet the expenses of the house. It is trite to mention that at present, it is only the Accused who is the earning member of the family as both the children are trying to even meet their ends and complete their qualification somehow. That the Accused in all disregards of his obligations / responsibilities towards the Complainant as well as the children is living a life according to his own whims and fancies.

9.       It is trite to mention that around 2008, the Complainant owing to the habits of alcoholism and violent behavior of the Accused; the Complainant was compelled to leave the shared household. As the Complainant was not receiving any monetary aid from the Accused; the Complainant secured a meager job so as to sustain her day-to-day expenses and to support her children. That the Complainant could secure the job only after sustained efforts as no employer was wiling to give the Complainant a job because of her age.  However, due to timely intervention of the relatives, the Accused pleaded guilty and sought forgiveness from the Complainant and assured the Complainant that the Accused would not drink alcohol and would also adequately take care of their expenses and financial needs of the Complainant and her children. However, the Accused assured the aforesaid subject to the condition that the Complainant would not join any employment; the Complainant in order to maintain peace and comity in the family accepted the condition put forth by the Accused and left her job.

10.     That since last four months, the Complainant many a times went to the Accused for the release of basic minimum monetary contribution so as to meet out the day to day expenses of the house and to maintain herself. The Accused instead of contributing to the concern of the Complainant, every time responds furiously and threatens the Accused with dire consequences in the following words:

“_____________________

.”

11.      The aggressive behavior of the Accused is not only limited to hurling abuses upon the Complainant and her children but also the Complainant gets physically violent upon the Complainant and children.

12.     It is pertinent to mention that the Accused and his family members had always dissuaded the Complainant from taking any work as the Accused prior to her marriage kept on assuring that the Accused would take care of the financial and monetary requisites of the Complainant. However, post marriage of the Complainant with the Accused; the Complainant was kept hand to mouth by the Accused.

13.     That the Complainant is a diabetic and low blood pressure patient and requires medicines on a daily basis. That the Complainant being a legally wedded wife of the Accused is also entitled to the free medicines as the Accused is employed as an ___ doctor. That inspite of the fact that the Accused would not have to incur any financial cost to purchase the medicines of the Complainant; the Accused is still reluctant to provide the requisite medicines to the Complainant.

14.     That the children have suffered hugely due to the ill treatment of the Accused. That the Accused has never acted as a responsible father to both children. That inspite of the fact that the Accused is a man of means and has multiple sources of revenue, the Accused has refused to sponsor future educational initiatives of the children. That the Accused has also refused to provide the children with basic day to day to expenses; all of which has hugely jeopardized the psyche of the children. The Accused after drinking alcohol not only mis-behaves but also hurls abuses upon the children.

15.     That the Complainant for the last six months is surviving on the contribution and help of her brother and her relatives. It is pertinent to mention that the Accused owing to his whims and fancies never allowed the Complainant to maintain relationship with her brother and other relatives. However, inspite of the obnoxious behavior of the Accused towards the Complainant’s family members, the Complainant could only survive the hardships due to the financial and mental support from her brother and her relatives. However, at present even the brother and the relatives of the Complainant have expressed their inability to support further. The Complainant, therefore, is compelled to approach this hon’ble court.

16.     The aforesaid acts of neglect and cruelty have left a deep impact upon the psyche of the Complainant. The constant neglect and regular acts of cruelty has led to development of suicidal tendencies in the Complainant.

17.     That applicant is an aggrieved person who has been in a domestic relationship with the accused and has been subjected to acts of domestic violence committed by the accused.

18.     That the accused has committed acts of domestic violence by harming / injury / endangering the health, safety, life of the applicant and the Accused has deprived the applicant to economic and financial resources for which the applicant is entitled as per legitimate right of being a legally wedded wife of the Accused.

19.     That the cause of action accrued in favor of the applicant and against the accused on different occasions when the applicant received atrocities at the hands of accused and when the accused threatened the applicant to oust from her matrimonial house and the accused refused to keep the applicant in their home and threatened the applicant and her family members with dire consequences. Hence the cause of action is still continuing one.

20.     That from the day of the marriage, accused made it a point to harass and humiliate the complainant on one pretext or the other.

21.     That the life of the complainant became hell in her matrimonial house, which forced the complainant to file present complaint. That it is also important to mention here that accused caused lots of physical, mental torture and harassment to the complainant.

22.     That due to vile and abusive behavior of the accused, complainant has been subjected to mental cruelty / physically and psychologically. That the accused 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 than physical cruelties and this have destroyed the peace of mind and grievously hurt the mental state of mind of the complainant.

It is therefore request to your goodself kindly take appropriate action against the accused person.

Thanking you,

          Your’s faithfully,

 _______________

 __________________,

______________,

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