IN THE COURT OF ILLAQA MAGISTRATE, AMBALA.

******
Banta Ram aged about 80 years son of Sh. Munshi Ram resident of Village
Ladana, Tehsil and District Ambala.
-------- Complainant.

VERSUS

1.

Kuldeep son of Sh. Hari Ram

2.

Jagdish son of Sh. Hari Ram

3.

Nachattar son of Sh. Jagir Singh

4.

Karambir Singh son of Sh. Dayal Chand

5.

Balbir Singh son of Sh. Dayal Chand

6.

Jasbir Singh son of Sh. Dayal Chand

7.

Sunita wife of Balbir

All resident of Village Ladana, Tehsil and District Ambala.
------------ Accused.

COMPLAINT U/S :- 323 / 324 / 452 / 506 / 148 / 149 IPC.

POLICE STATION :- SADAR AMBALA.

Sir,
It is submitted as under:1. That the complainant is permanent resident of village Ladana and is an old
man of about 80 years and all the accused are also resident of resident of
Village Ladana, Tehsil and District Ambala.

2. That there is a street in between the house of the complainant, Vidya Devi,
and Nathu Ram on one hand and accused on the other hand. The accused want
to encroach upon the street and as such the complainant party had filed a suit
for permanent injunction against the accused persons, in which the ld. Court
of Sh. J.S Kundu ADJ, has been pleased to pass an order of restraining the
accused from encroaching upon the street 11 feet in width bearing Khasra no
136.
3. That a litigation is pending qua the street on which the accused had
encroached upon had also raised walls in order to encroach upon the said
street, and as such Vidya Devi made an application for amending the suit to
Mandatory Injunction for bringing down the walls and to bring the site to its
original position, and the accused party was nourishing the grudge against the
complainant party as the complainant was openly supporting Vidya Devi,
Sudarshan etc.
4. That on 20-4-2005 at about 8:30 P.M, the complainant was present in his
house when all the accused namely Kuldeep, Jagdish both sons of Sh. Hari
Ram, Nachattar son of Sh. Jagir Singh, Karambir Singh, Balbir Singh, Jasbir
Singh all sons of Sh. Dayal Chand came in the courtyard of the complainant
armed with Gandasis, Lathis, iron rods etc., while forming un-lawful
assembly and started raising lalkars to come out, as they had won the election
of Panchayat and now the Sarpanch of the village is of their party. The
complainant when came out of the house all the accused raising lalkara
opened the attack on the complainant. Kuldeep accused who was wielding an
iron pipe gave a blow on the person of the complainant which landed on the
right temple near the eye, upon which the complainant fell down and raised
hue and cry and hearing the cries the wife of the complainant namely
Gurbakshi, Somi Devi wife of Jee Ram, Dinesh Kumar son of Sh. Sudarshan
Kumar came to the spot in order to rescue the complainant. The accused again

raised lalkara and opened attack on the complainant and above named persons
who came to rescue the complainant. Jagdish @ Bittu accused gave a gandasi
blow to the wife of the complainant which landed on her head and the
remaining accused gave merciless beating to Somi Devi, Dinesh Kumar with
their respective weapons. The complainant raised hue and cries which
attaracted Hari Singh son of Sh. Arjun Singh, who was also beaten by the
accused persons when he tried to intervene. In the mean time Sunita wife of
Sh. Balbir Singh also came to spot armed with brick and threw towards to the
wife of the complainant. In the meantime many co-villagers namely Nathu
Ram son of Sewa Ram, Sudershan son of Sh. Ramji Lal etc. came to the spot,
and rescued the complainant party from the accused party, otherwise the
accused party would have caused more injuries to the complainant party. The
accused while going threatened that this time they would have been saved but
next time they would be done to death. There after the complainant party was
removed to Civil Hospital Ambala City, where the doctors of Civil Hospital
Ambala City medico-legally examined them.
5. That the complainant remained under the treatment of the doctors of Civil
Hospital, and the police of P.S Sadar Ambala enquired about the incident and
got the signatures of the complainant on a paper.
6. That the police instead of taking action against the accused persons also
arrested the complainant party whereas there is neither fault of the
complainant nor that of the witnesses, and the complainant and the witnesses
were also framed in a false case, in order to put pressure upon them to
compromise the matter.
7. That the police has not arrested some of the accused and they were challaned
under section 323/324/506 IPC, where as the accused has committed heinous
offences under section 323 / 324 / 452 / 506 / 148 / 149 IPC.

8. That the accused deserves to be summoned, tried and convicted under section
323 / 324 / 452 / 506 / 148 / 149 IPC.
Hence prayed, that the accused persons may kindly be summoned,
tried and convicted under section 323 / 324 / 452 / 506 / 148 / 149 IPC, as per
law, in the interest of law, justice and equity.

Banta Ram son of Sh. Munshi Ram

r/o Vill Ladana, Tehsil and District
Ambala.
-------- Complainant.

THROUGH:D.S.CHHILLAR,
Adv.

LIST OF WITNESSES
1.
2.
3.
4.
5.
6.
7.

Complainant.
Gurbakshi wife of Banta Ram
Somi Devi wife of Jee Ram,
Dinesh Kumar son of Sh. Sudarshan
Hari Singh son of Sh. Arjun Singh
Dr. V.K Sharma, M.O Civil Hospital Ambala City
MHC, P.S Sadar, Ambala.

Note:- Supplementary list of witnesses will be supplied later on if found

necessary.