COMPLAINT

Dated 27th October 2017

From :-
Mrs. Pooja Pankaj Done
Room No. 101, Ghagari Apartment,
1st Floor, Shankarbuwa Wadi,
Near Saibaba Mandir, Ghansoli,
Navi – Mumbai – 400 701.
Mob No. 9699653457

To,
1) The Commissioner of Police Navi Mumbai
Opposite RBI, Sector – 10 CBD- Belapur,
Navi – Mumbai 400 614.

2) The Deputy Commissioner of Police

Plot No. 180, Sector 19C, APMC Market Vashi
Near Y J Petrol Pump Zone 1
Vashi, Navi Mumbai

3) The Assistant Commissioner of Police (Vashi Div)

Plot No. 180, Sector 19C, APMC Market Vashi
Near Y J Petrol Pump Zone 1
Vashi, Navi Mumbai

4) Senior Inspector Of Police

Rabale Police Station
Sector – 27, Ghansoli
Navi – Mumbai Maharashtra – 400 701.
Sub:- Complaint to lodge F.I.R U/s. 154 Cr.P.C for offences under
section 307, 324, 328, 420, 493 of Indian Penal Code .

Accused – Pankaj Shamrao Dhone

Mobile No - 9326002500
having Address No.1 at:-
Room No. 101, Ghagari Apartment,
1st Floor, Shankarbuwa Wadi,
Near Saibaba Mandir, Ghansoli,
Navi – Mumbai – 400 701.

And

S/o Shamrao Dhone, Hanuman Mandir,

Plot No 23/C Sangam Nagar,
Wanjri Layout, Uppalwadi,
Nagpur Maharashtra – 440 026.

Respected Sir,

I, the undersigned Pooja Dhone having abovementioned address state

the facts of the case as under:-

1) I state that I am citizen of India and a working with a private firm, I

state that in the year Feb- 2013, I shifted from my residence from
Lucknow and started staying in Kamothe as P.G with the owner
named Mr. Mishra and the Accused was staying in Sukhapur near
Panvel.
2) While working with firm namely Digicall I met with the Accused and
came close with him while working with the firm in the year December
2013.

3) We both came close and fell in love with each other, the Accused
told me that he was searching for a room for his family and also told
me to search for a room in Kamothe for him and his family in the year
Apr- 2014. After finding out and finalizing the room for the Accused, I
paid the deposit and brokerage for the said room as the Accused didn’t
had money because he was terminated from Digicall company where
we use to work together as he used foul language with the Customer
in the year March -2014.

4) On 4th May 2014, the Accused family came to my P.G

accomodation and fought with Mr. Mishra the owner of the P.G
accomodation and told me to come and stay with them in the room
which I had searched for them.

5) Thereafter they took me forcefuly along with all my belongings and I

started staying with the Accused before the marriage from 4th May
2014 in Kamothe Goan near Vithal Mandir. We started staying
together as the Accused promised to get married with me in front of
his family. On 21th of May 2014 I and the Accused got married in the
temple Vithal Mandir near Kamothe. Mr. Pratap from the Accused side
and Mr. Mrinal and Mrs. Lalita Dutta, my office collegeus were witness
to the said marriage.

6) The Accused was jobless and I was supporting the Accused

expenses and the expenses of the home out of the earning from my
Job. The Accused got a job in my company itself i.e. one point one
solutions and working as the Team Leader of the company. Mr.
Ranjith Kotian, owner of One Point One Solution Company, knows
that we are husband and wife, as the Accused has introduced me to
him as his wife.

7) Our families were knowing the relation between us and was telling
us to registered the marriage, my mother – in – law use to come and
stay with us often in Kamothe and we even went to my home town in
Kalyanpur Lucknow in the month of November – 2014.

8) I state that the Accused and in laws were never agreering for
registering the marriage and in the month of Aug-2015, Accused left
the house without any reasonable cause and took all his belongings
and also taking my gold chain and all the money.

9) In Sep- 2015, I went to meet the Accused in Nagpur, but the

Accused didn’t even took me to his house and met me at the Nagpur
Station and from there along with my mother-in-law and brother-in-
law took me to Lucknow at my parental home. After reaching
Lucknow, the Accused told my parents that currently he cannot stay
with me and told my parents to tell me to stay with them for sometime
till the Accused calls her and takes her back to his home.

10) Thereafter I returned back to Mumbai on Sep-2015 and started

staying with my friend Pranali in Ghatkopar for sometime. In between
I tried calling the Accused but he neither picked up my calls nor he
inquired about my whereabouts. In betwen I called up my mother – in
– law and she told that the Accused is in Bengaluru and will come
back after 4 years.
11) I came back to place we both last resided i.e. Kamothe and
registered a complaint with Kamothe Police Station that the Acused is
my lawful husband and has left me without any reasonable cause and
PSI Badwodkar from Kamothe Police Station registered the complaint
and call the Accused mother – in – law in the year Nov-2015.

12) After registering of the Police complaint the Accused with my in

laws came to the Kamothe Police station on 13th November 2015 and
Accused in his own handwritted letter in front of the PSI Badwodkar of
Kamothe Police Station in writing stated that the Acused stayed with
me for 1-1/2 years and told to registered the marriage after 2 years
but still has not registered, therafter he promised in the letter that he
will registered the marriage after 20th April 2016. The said copy of the
letter along with the witness signature is annexed herewith and
marked as Exhibit – “A”.

13) I Dec- 15, the Accused came to meet me at my P.G residence and
on April – 2016 as per the written complaint, the Accused came with
his brother Saurab and Pankaj stayed with me, where all the expenses
of ticket and staying in Mumbai was beared by me. Thereafter the
Accused didn’t even bother to fulfil the commitment given to me in
front of the Police and went back to Nagpur after 3 days.

14) In Jun-2016 the Accused told me to get a flat on rent in Mumbai

and I after meeting the brokers and agents searched for a Flat in
Ghansoli and paid all the expenses of deposit and brokerage, took the
Flat on rent in order that me and the Accused will stay together for the
same as the Owner of the Flat had called my Father – in – law to check
whether we both are married and after confirmation received from my
father – in – law decided to give the said flat on rent on both our name.
The Leave and License Agreement of the said flat was made on both of
our name. The said copy of then Leave and License Agreement is
annexed herewith and marked as Exhibit - “B”.

15) The Accused and I was residing together in the said aparment,
during our stay the Accused was frequently quarreling and assaulting
me but I never complaint about the same to anyone. Even my in laws
use to come and stay with us and frequently harrased me and in Feb-
2017 my in laws came to visit Mumbai and stayed with us for about 6
days the expenses for all their stay was born by me.

16) The Accused started working with Digicall again and then was
usually busy on phone over call or what’s app and started avoiding
me. On 18th October 2017, the Accused entered into the house,
started quarelling and assaulted and cause grevious hurt on my left
eye due to which my left eye was completely blackened, after which
the Accused force me to drink phenyl forcefuly, thereafter the Accused
fled the place leaving me in that condition, that it would have cost my
life. I some how mange to get hold of myself, texted as well as called
up friends to come and help me. My friend Ms. Sonali Gaikwad quikly
came and helped me to vomit the phenyl which I had drunk and
somehow got in conciousness. We went to the doctor and after taking
medicines I took rest for two days as guided by the Doctor. I also
waited for the Acussed to come back home day after i.e. on 19th
October 2017. The Acussed neither came back home nor responded to
my calls. All this while I belived in Accused that he loves me and will
marry me but he assaulted, harrased, defrauded and attempted to
murder me. The intenstion of the Acussed made me to belive that he is
no longer interested in me and wanted to remove me from his life.
17) I state that on 20th October 2017, I decided to file a case against
the Accused for the harrasment and trouble which I went through and
I went to Rabale police station to file a complaint agaisnt the Accused
in the morning and registered the complaint against the Accused. The
Rabale Police Station registered the complaint as NC No. 2427/17
dated 20th October 2017.

18) I say that the Accused has commited the offense U/S 307 of IPC of
Attempt to Murder by forcing me to drink the Phenyl, U/S 319 of IPC
of Assaulting me and causing bodily pain to me by hiting me on my
left eye, U/S 321 of IPC of Voluntarily causing hurt and hitting me on
my left eye, U/S 328 of IPC of Causing hurt by means of poison, etc.,
with intent to commit and offence. U/S 420 of IPC of Committing an
offense of Fraud as fooled me all the time and looted me of my money
and jeweller and U/S 493 of IPC of cohabiting with me and having
sexual intercourse to believe that I am lawfully married to him of
Indian Penal Code. The Copy of the messages send is annexed
herewith and marked as Exhibit - “C”, The Copy of the NC 2427/17
dated 20 th October 2017 filed with Rabale Police Station is annexed
herewith and marked as Exhibit - “D”.

Under above circumstances, I hereby call upon you to lodge F.I.R U/s.
307, 324, 328, 420, 493 of I.P.C against above mentioned Accused
for offences mentioned herein above within period of 7 days from
receipt of this complaint.

Yours Truly

Mrs Pooja Dhone

Encl.:
1) Copy of the letter along with the witness signature is annexed
herewith and marked as Exhibit – “A”
2) Copy of then Leave and License Agreement is annexed herewith and
marked as Exhibit - “B”.
3) Copy of the messages send is annexed herewith and marked as
Exhibit - “C”,
4) Copy of the NC 2427/17 dated 20 th October 2017 filed with Rabale
Police Station is annexed herewith and marked as Exhibit - “D”.