To,                                                               Dated- XX.0X.20XX

The Station House Officer,

Police Station: - __________,

_____________________.

SUBJECT: Regarding complaint against XXXX for snatching My Car ________CAR vide Model number- ____________, Chassis Number- ______________, Engine Number: - ____________, Car Colour- _____________ and threatening for misusing the CAR.

1.     That Complainant is a law-abiding citizen of India and the Complainant and accused are husband and wife and both married on XX.XX XXX.

2.     That the Complainant purchased the _________CAR vide Model Number- ____________, Chassis Number- ___________, Engine Number: -__________, Car Colour-__________ in the year 2015.

3.     That the Complainant is working with _____________________and the company ________________ has tie up with the company CALLED Lease plan India Pvt Ltd to purchase car for its employees under lease and the Complainant signed a contract with _______________, and the Complainant purchased the car vide the same arrangement and after that the Complainant paid the entire installments from her salary to ____________and when the installments completed then the CAR was transferred in the name of Complainant after the NOC from __________and new Registration Certificate issued in the name of Complainant and the documents are attached here with this complaint.

4.     That on XX.XX.XXX around 8:00 PM, the Complainant was on an office call, when the accused asked the Complainant something from inside the bathroom, which Complainant did not hear and the accused came out screaming at Complainant, held her by the neck and told Complainant a useless piece of shit and such people don’t deserve to live and the Complainant’s mother had come back from XXX on XX.XX.XXX, and she heard Complainant’s screaming. She tried to stop accused and Complainant got the courage and started screaming to call her neighbors and then accused ran out from the house and went to his brother’s house in XXXX and did not return till X^t of 20XX and suddenly on XX XX 20XX at about 7 PM, accused along with his friend and when the complainant was trying to leave the house snatched the aforesaid car by threatening the complainant.  Mr. XXX came to the house in a drunken state. Accused slapped Complainant and beaten her mother with a danda to leave the house. When Complainant & her mother refused, he got a knife from the kitchen, put it on Complainant’s neck and threatened her to eliminate her daughter in front of her and threw Complainant, her daughter, her mother from house, for which Complainant paying the monthly installments of her house from her own funds and this incident happened around XX PM on XX X 20XX. The complainant’s mother literally begged to accused for not doing so but he did not show any kindness, since he was heavily drunk and behaved like a devil and when Complainant asked to take her belongings, he did not allow and when the accused took her XXXXX Car, accused snatched the car from her hand and he did not care about 2 ladies & one miner child moving out of the house at late evening.

5.     That it is pertinent to mention that under section 2(19) of Motor Vehicles Act 1988, defines the word “owner” means, namely, a person in whom the proprietary title vested and whose name the certificate, road permit and RC was standing shall be deemed to be the owner of the vehicle.

6.     According to Motor Vehicles Act 1988, no person has right to use anyone’s vehicle without the consent of the owner and if the owner has any objection for the same and denies as person to use his/her vehicle would be treated as trespass to the vehicle.

7.     That the ownership of the vehicle is under name of Complainant and the accused has no right to use the vehicle without the consent of the Complainant, if he does so without the consent of the Complainant then the accused be treated as trespass to the vehicle.

8.     That it is pertinent to mention that vehicle i.e. ______ Car bearing registration no.XXXXXXXXX is in custody of accused without the consent of Complainant, it is further submitted that the accused forcefully lay hold of above said vehicle, the accused threatened the Complainant that he will falsely implicate Complainant in different litigations including civil, criminal and tort etc.

9.     That the accused threatened the Complainant that he would vandalize the above mention car or will deliberately accident someone with the car in order to frame the Complainant in a false criminal case, the accused further stated that “MEIN TERI CAR SE KISI KO MAAR KE BHAG JAUNGA AUR TERE CAR KO WAHI CHOD DUNGA AUR JAB CASE HOGA TO TU FASEGI AUR AGAR BACHNA CHAHTI HAI TOH VAAPAS AA JAA, DIVORCE TO NAHI DUNGA”

10. That the accused forcefully possess the above mention car and he has a tendency to drive a car under the influence of alcohol and this will cause severe damage to any other innocent person as well as Complainant, the Complainant requested so many times for handing over the car to her but the accused not ready to hand over the car to Complainant and he further stated that “MEIN TUJHE TERI CAR NAHI DUNGA AUR MEIN TOH AISAYE HI GAADI CHALUNGA AUR AGAR TU ROK SAKTI HAI TOH ROK LE OR YAHI NAHI AUR AGAR JYADA HOSHIYAR BANEGI TOH TUJHE AISE CASE MEIN FASA DUNGA KI PURI ZINDAGI GAADI KA NAAM NAHI LEGI”

11. That the accused habitually overlooks traffic rules and frequently drives over the speed limit and more so under the influence of alcohol.  Moreover, he also gets agitated easily and gets involved in road rage which not only puts his life in danger but puts everyone around him at lethal risk and the accused threatened the Complainant that he would implicate this vehicle in a case of some legal case.

12. That the accused is a negligent driver to cause harm to the life of others and since the vehicle is in the name of Complainant then the onus would be upon the Complainant only. It is also important to mention here that accused also threatened the Complainant for breaking the traffic norms and the challan cost would be double of the Car price and the accused further stated that “MUJHE JYADA GYAN DENE KI JARURAT NAHI HAI MEIN AISE HI CHALUNGA TU JO KAR SAKTI HAI KAR LE AUR WAISE BHI MUJHE TO TUJHSE KAISE BHI PARESHAAN KARNA HAI TAAKI TU KAHIN AUR JAA NAA SAKE, RAHEGI TO TU MERE SAATH HI”

13. In the last several years, the Complainant's life has been disturbed due to the defendant's bad and unlawful behavior. That it is further submitted that accused having a bad habit of drinking and drive under the influence of alcohol accused fought with Complainant several times while driving the car.

I have also a complaint against him in the Crime against Women Cell, _______________________________________.

It is requested that you do the needful and register the FIR against the accused under appropriate sections of IPC and arrest the accused person.

Applicant

          XXX

W/o Sh. XXX

R/o XXXX

M- XXXXXXXX

Copy to:

1.       The Deputy Commissioner of Police,

2.      The Commissioner of Police,