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IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, DELHI

IN THE MATTER OF:

SH. A …..… COMPLAINANT

VERSUS

SH. X ………. ACCUSED

INDEX

SL.No. PARTICULAR COURT FEE PAGES

1.
MEMO OF PARTIES

2. COMPLAINT UNDER SECTION


324, 326 INDIAN PENAL CODE
ALONGWITH SUPPORTING AFFIDAVIT

3.
LIST OF DOCUMENTS

ALONGWITH DOCUMENTS

4.
VAKALATNAMA

COMPLAINANT

Place: Through

Date: Sd/- ( Advocate)


IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, DELHI

IN THE MATTER OF:

A ……Complainant

Versus

X …….. Accused

MEMO OF PARTIES

In Re:

A, s/o B, r/o Mayur Vihar, Delhi ……Complainant

Versus

X s/o Y, r/o Vasant Vihar, Delhi …….. Accused

COMPLAINANT

Place: Through

Date: Sd/- ( Advocate)

IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, DELHI

A, s/o B, r/o Mayur Vihar, Delhi ……Complainant

Versus

X s/o Y, r/o Vasant Vihar, Delhi …….. Accused

Complaint No. : _______


U/s : 324/326, I.P.C.

P.S.:______________

COMPLAINT UNDER SECTION 324 AND SECTION 326, INDIAN PENAL CODE

Sir,

The complainant above-named most respectfully submits as under:

1. That the complainant is a money-lender by profession. On 21 st April, 2018, the


complainant lent Rs, 5000/- to the accused on a pro-note executed by the accused in
the favour of complainant. Hereto annexed an marked ‘A’ is a copy of the said pro-
note. Since then, the accused is avoiding complainant. The complainant went to
accused’s place on several occasions for complainant’s dues but the accused
quarrelled with the complainant. The complainant then warned the accused that he
would now file a suit against the accused.
2. That on 28th February, 2020, the complainant along with his brother to for the last
time to the accused’s place to demand payment, The accused came out of his house,
and under the pretext of taking out the money from his pocket, the accused took out a
knife and stabbed complainant on his left arm. The brother of the complainant tried to
intervene but he was also injured by the accused in the stomach and other places in
the body. Both the complainant and his bother received fatal injuries.
3. That the complainant then lodged a report in the police but the police did not take any
action against the accused.
4. That the accused has committed the offences under Sections 324 and 326, I.P.C.
within the jurisdiction of this Honourable Court.
5. The case has been filed within the period of limitation and on proper stamps.

PRAYER
It is therefore most respectfully prayed that the accused be tried and punished
according to the law.

LIST OF DOCUMENTS

1…………………

2………………

3………………….
LIST OF WITNESSES

1…………………….

2…………………….

3…………………….

Place: Complainant

Date: Through
Sd/-(Advocate)

IN THE COURT OF THE CHIEF METROPOLITAN MAGISTRATE, DELHI

A, s/o B, r/o Mayur Vihar, Delhi ……Complainant

Versus

X s/o Y, r/o Vasant Vihar, Delhi …….. Accused

AFFIDAVIT

AFFIDAVIT OF Shri. A, S/O B, R/O MAYUR VIHAR, DELHI

The Deponent does hereby solemnly affirm and declare as under:

1. That the accompanying complaint for grievous hurt under Sec. 324, 326, I.P.C has
been drafted by my counsel as per my instructions and all the facts stated therein is
true to my own knowledge and correct.
Deponent

VERIFICATION

Verified at Delhi on 15th March, 2020, that the contents of above affidavit are true to
my own knowledge and nothing material has been concealed therefrom.
Deponent

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