COMPLAINT

(U/S-154 of Cr. P. C.)

DATED:-…………………………

To,
Station House Officer

Police Station-(Lajpat Nagar)

New Delhi-110024 Commented [Madhav1]: Please confirm the pin code.

Subject:-Complaint against Charanjeet

Sharma (hereinafter referred to as

“Accused no. 1”) and Puneet Sharma

(hereinafter referred to as “Accused no.

2”) (hereinafter collectively referred to

as “Accused Persons”) for the offences of

criminal conspiracy, theft extortion,

cheating and dishonestly inducing delivery

of property, Making a false document,

Forgery for the purpose of cheating,

criminal intimidation, as committed by

them with the present complainant.

Dear Sir;

I, the complainant named as:- Mr. Joginder

Sharma, S/O- Late. Sh. Puran Prakash Sharma

R/O-Ground Floor F/113 Lagpat Nagar, New

Delhi; do hereby lodge the present

complaint with following contents:-

1. That the Accused Persons i. e.

Accused no.1 is brother and Accused

no.2 is the nephew of the complainant.

2. That the complainant is law abiding

senior citizen with the age of around

63 years.

3. That complainant is the absolute

owner of the ground floor F/113 Lagpat

Nagar, New Delhi (hereinafter referred

to as the “said Floor”) by virtue of

will executed in favour of the

complainant by his father Late. Sh.

 Puran Prakash Sharma dated October 22,

1993.

4. That the complainant resides in the

said Floor with his mother i.e.

Leelawati Sharma. The complainant is

unmarried and looks after his widowed

old age mother.

5. That the complainant’s mother has

no source of income for maintaining Commented [Madhav2]: Please confirm the understanding.

herself and she has to depend on

complainant for any monetary help.

6. That the Accused Persons have

already got their share in the said

property, although Accused Persons out

of their greed, malicious and dishonest

intention are trying and have

previously tried to grab the said Floor

bequeathed in favour of the complainant

according to the will.

7. That Accused no. 1 has committed

offences of criminal breach of trust

and theft by stealing the property

papers of the said Floor at the time of

death of complainant’s father. In

furtherance to this act by the Accused

Persons the mother of the complainant

had logged a complaint dated October

18, 2016 at Lajpat Nagar Police

Station.

8. That the Accused no. 2 had also

instituted a false and frivolous suit

having suit no.197/2016 against the

complainant for the possession of the

said Floor based upon a false and

fabricated will. However said suit was

dismissed by Learned Civil Judge Prabh

Deep Kaur considering the case to be

devoid of any merits.

9. That the Accused no. 2 in

conspiracy with Accused no. 1; has

given false information before public

servants and thereby committed the

premeditated fraud by way of the

criminal concealments of the true

facts and circumstances pertaining to

the said Floor of the complainant.

10. That the Accused Persons after

having tried all means and measures to

dispossess the complainant from the

said Floor have started harassing and

torturing the complainant mentally as

well as physically.

11. That the complainant is a senior

citizen and his mother is a widow woman

of almost 98 years of age and she has Commented [Madhav3]: Please confirm the age of mother.

no shelter to live in; other than

property detailed as mentioned above.

12. That Accused Persons taking the

advantage of old age of the complainant

have tried to harass the complainant

and his mother on many occasions, by

physically hurting them, stealing their

valuable assets and by threatening them

of making false and frivolous police

complaints against them.

13. That the Accused Persons have

criminally trespassed into the said

Floor of the complainant forcefully

at various time and occasions, having

made preparations for causing hurt to

the complainant and assaulting them

and wrongfully restrained the

complainant in order to carry on

their criminal extortions under the

garb of the life threats.

14. That Accused Persons have

committed forgery and fabricated

fraudulent documents, will and other

relevant documents and filed all

these forged and fictitious, details

in the court of law in order to cheat

and abuse the such public servants

and their offices for the undue,

criminal and illegal gains to the

Accused Persons.

15. That the Accused Persons,

fraudulently and dishonestly used as

genuine the fictitious, fraudulent

and the forged documents, which they

knew and had reason to believe the

same to be the forged documents.

16. That the Accused Persons; still

have in their possession; the said

fictitious, fraudulent and the forged

documents, knowing the same to be

forged and intending that the same

shall fraudulently and dishonestly be

used by them as genuine.

The abovementioned facts and the

circumstances disclose the commission of

cognizable offences of, criminal

conspiracy, Cheating and dishonestly

inducing delivery of property, Making a

false document, Forgery for the purpose of

cheating, criminal intimidation, as

deliberately committed by the Accused

Persons, and hence; it is most respectfully

prayed that your kind office may be pleased

to register the F. I. R. in the present

complaint and take actions against the

Accused Persons as per Law, and for this

 act of your kindness the complainant shall

ever pray.

With regards!

Dated:-……………………………

Place:-New Delhi Yours truly

Complainant

Mr. Joginder Sharma,

Aged about 63 years,

R/O-Ground Floor F/113,

Lagpat Nagar, New Delhi.