Complaint to ACP, CAW Cell against husband for cruelty and domestic violence
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ToDt.:
The Assistant Commissioner of Police,
CAW Cell,
Sub: Complaint against Accused's name, S/o Sh. Accused's father's name.
Respected Sir,
That the complainant has been constrained to approach your good self on account of the atrocities committed upon her by the accused (husband of the complainant), namely Accused's name.
1.That the accused has neglected, harassed and abused the complainant out of greed for money, and has caused physical and mental cruelty to the complainant and her two children.
2.That Complainant's name ("the complainant") was married to Dr. Accused's name ("the accused") on Date of marriage and is presently residing at Address of shared household ("the property") along with the accused and her two children. The complainant holds a post-graduate degree in commerce and had several job opportunities available to her at the time of the marriage. However, the accused and his family members strongly objected to the very idea of a working woman, and consequently, the complainant was never permitted to take up any employment.
3.That the complainant, having been neglected by the accused, and the accused having refused to maintain her, has suffered physical and mental cruelty at his hands, as a result of which the complainant has been thrown out of the home without her clothes and other articles of istridhan belonging to her, and the accused has not provided any shelter to her.
4.That the accused, despite having sufficient means, has deliberately and intentionally neglected to maintain the complainant and her children. That the accused is a man of means, and yet, owing to the physical and mental cruelty caused to the complainant, the accused has made no arrangements whatsoever for their maintenance. That the complainant is unable to maintain herself and is in a state of distress.
5.That the accused has been working as a doctor with the Name of hospital where accused works hospital in the NFSG (Non-Functional Selection Grade) at Place of accused's posting. That the accused is at present drawing a salary of more than ₹ Accused's monthly salary (₹) per month, along with other benefits, from the hospital. That the accused is also the owner of the property, which comprises the ground floor as well as the first floor. That the accused has let out the ground floor of the property on rent and is earning more than ₹ Monthly rental income amount (₹)/- per month as rental income, apart from his other incomes.
6.It is pertinent to mention that the complainant, despite being the legally wedded wife of the accused, has been deprived by him of all necessities and comforts. That the complainant has been denied all the pleasures of married life. That till date, the accused has never shared with the complainant any details pertaining to his finances, salary and other multiple sources of income. That for the last 3 (three) years, the accused has stopped cohabiting with the complainant and has deprived her of all the marital rights of a wife.
7.That the accused has been an alcoholic throughout his life; however, over the last 2-3 years, his habit of alcoholism has increased to an all-time high. That the accused is a heavy drinker and consumes alcohol on a daily basis as soon as he reaches home every evening. That the accused drinks approximately a bottle of liquor every day. That after consuming liquor, the accused not only hurls abuses at the complainant but also threatens the complainant as well as the children with dire consequences.
8.That the accused has rendered the complainant financially dependent upon him, as despite her meritorious academic background, he never permitted the complainant to work and develop an independent source of earning. That the complainant has been seriously deprived of the necessities of life, and for more than the past 4 (four) months, the accused has not contributed even the basic minimum amount required to meet the household expenses. That it is trite to mention that at present, the accused is the only earning member of the family, as both the children are somehow striving to make ends meet and complete their qualifications. That the accused, in complete disregard of his obligations and responsibilities towards the complainant and the children, is living a life according to his own whims and fancies.
9.That it is pertinent to mention that around 2008, owing to the alcoholism and violent behaviour of the accused, the complainant was compelled to leave the shared household. That as the complainant was not receiving any monetary aid from the accused, she secured a modest job in order to sustain her day-to-day expenses and to support her children. That the complainant was able to secure the said job only after sustained efforts, as no employer was willing to employ her on account of her age. However, upon the timely intervention of relatives, the accused pleaded guilty and sought forgiveness from the complainant, and assured her that he would not consume alcohol and would adequately take care of the expenses and financial needs of the complainant and her children. That the accused gave the aforesaid assurance subject to the condition that the complainant would not join any employment. That the complainant, in order to maintain peace and harmony in the family, accepted the condition put forth by the accused and left her job.
10.That since the last four months, the complainant has, on several occasions, approached the accused for the release of the basic minimum monetary contribution required to meet the day-to-day expenses of the house and to maintain herself. That instead of responding to the complainant's concern, the accused, on every such occasion, reacts furiously and threatens the complainant with dire consequences in the following words:
*"Words of threat used by accused"*
11.That the aggressive behaviour of the accused is not confined to hurling abuses at the complainant and her children; rather, the accused also turns physically violent against the complainant and the children.
12.That it is pertinent to mention that the accused and his family members had always dissuaded the complainant from taking up any work, as prior to the marriage, the accused kept assuring the complainant that he would take care of her financial and monetary requirements. However, after the marriage of the complainant with the accused, the complainant was kept hand to mouth by the accused.
13.That the complainant is a patient of diabetes and low blood pressure and requires medicines on a daily basis. That the complainant, being the legally wedded wife of the accused, is also entitled to free medicines, as the accused is employed as an Accused's designation as doctor doctor. That despite the fact that the accused would not have to incur any financial cost in procuring the complainant's medicines, the accused remains reluctant to provide the requisite medicines to the complainant.
14.That the children have suffered immensely on account of the ill-treatment meted out by the accused. That the accused has never acted as a responsible father towards either child. That despite being a man of means with multiple sources of revenue, the accused has refused to sponsor the future educational endeavours of the children. That the accused has also refused to provide the children with basic day-to-day expenses, all of which has gravely affected the psyche of the children. That the accused, after consuming alcohol, not only misbehaves with the children but also hurls abuses at them.
15.That for the last six months, the complainant has been surviving on the contribution and help of her brother and her relatives. That it is pertinent to mention that the accused, owing to his whims and fancies, never allowed the complainant to maintain a relationship with her brother and other relatives. That despite the objectionable behaviour of the accused towards the complainant's family members, the complainant was able to endure her hardships only due to the financial and emotional support of her brother and relatives. That at present, however, even the brother and relatives of the complainant have expressed their inability to support her any further. The complainant is, therefore, compelled to approach this Hon'ble Court.
16.The aforesaid acts of neglect and cruelty have left a deep impact upon the psyche of the Complainant. The constant neglect and repeated acts of cruelty have led to the development of suicidal tendencies in the Complainant.
17.That the Complainant is an aggrieved person who has been in a domestic relationship with the accused and has been subjected to acts of domestic violence committed by the accused.
18.That the accused has committed acts of domestic violence by harming, injuring and endangering the health, safety and life of the Complainant, and has deprived the Complainant of the economic and financial resources to which she is entitled as a matter of legitimate right as the legally wedded wife of the accused.
19.That the cause of action accrued in favour of the Complainant and against the accused on different occasions when the Complainant suffered atrocities at the hands of the accused, when the accused threatened to oust the Complainant from her matrimonial home, when the accused refused to keep the Complainant in the matrimonial home, and when the accused threatened the Complainant and her family members with dire consequences. The cause of action is thus a continuing one.
20.That from the day of the marriage, the accused made it a point to harass and humiliate the Complainant on one pretext or the other.
21.That the life of the Complainant became miserable in her matrimonial home, which compelled her to file the present complaint. It is also pertinent to mention here that the accused caused considerable physical and mental torture and harassment to the Complainant.
22.That owing to the vile and abusive behaviour of the accused, the Complainant has been subjected to mental, physical and psychological cruelty. The accused refused to support the Complainant and blamed her, and apart from the physical cruelty, the Complainant has been subjected to different forms of cruelty which are more harmful than physical cruelty and which have destroyed her peace of mind and gravely injured her mental state.
It is, therefore, most respectfully requested that your good self may kindly take appropriate action against the accused person.
Thanking you,
Complainant's name
Complainant's address
Date of complaint
Ph: Phone number