Complaint to Crime against Women Cell for dowry harassment, cruelty and statutory rape
Cites the IPC, CrPC or Evidence Act. For matters from 1 July 2024, use the BNS, BNSS or BSA.
0 of 35 blanks filled
ToDt.: Date of complaint
The Assistant Commissioner of Police,
The Crime Against Women Cell,
Police cell address,
New Delhi.
Sub: Complaint against Accused No. 1 Husband's name (Husband), Accused No. 2 Father-in-law's name (father-in-law), Accused No. 3 Mother-in-law's name (mother-in-law), all residing at Husband and in-laws' address, and Accused No. 4 Sister-in-law's name (sister-in-law) (Nand), residing at Sister-in-law's address, for dowry demand, physical abuse, cruelty, mental harassment, statutory rape, and harassment for dowry.
Respected Sir/Madam,
1.That the present complaint has been filed against the atrocities and cruelties committed upon Mrs. Complainant's name Complainant's surname (hereinafter referred to as the "complainant") by her husband, namely Husband's name (Husband), Father-in-law's name (father-in-law), Mother-in-law's name (mother-in-law), and Sister-in-law's name (sister-in-law) (Nand), (hereinafter collectively referred to as the "accused persons").
2.That Accused No. 1 and the complainant began seeing each other in Year in which the complainant and Accused No. 1 started dating, when the complainant was only Complainant's age when they started dating years of age. Accused No. 1 used to come to her school and take her away from there; the accused made her skip school and took her to a park near her school, where he attempted to touch her inappropriately. Subsequently, the accused began taking the complainant to hotels, where he forced her into a physical relationship, and this continued for several years. The accused persistently pressurised the complainant into a physical relationship and threatened her by stating that he would disclose the relationship to her family and abandon her. The accused also compelled the complainant to accompany him to Place the accused forcibly took the complainant to, blackmailing her on the pretext that he would inform her parents about their physical relationship, and thereupon forcibly took the complainant to Place the accused forcibly took the complainant to at the complainant's own expense. At that time the complainant was below Complainant's age at the time of the trip years of age, whereas the accused had attained majority, being Accused No. 1's age at the time of the trip years of age; there also, the accused forced the complainant into a physical relationship. Thereafter, the accused also took the complainant to Other place the accused took the complainant to, again at her expense. It is pertinent to mention that the complainant was a minor at the time Accused No. 1 established a physical relationship with her, while he was Accused No. 1's age at the time of the trip years of age. It is well-settled law that any male who has intercourse with a female below the age of 18 years, with or without her consent, commits statutory rape. This offence exists to protect minors from exploitation by adults. In cases of statutory rape, an adult is liable to punishment for any physical interaction with a woman or girl aged 18 years or below, irrespective of whether she participated voluntarily or not. The consent of the minor is immaterial and constitutes no defence to the accused. Statutory rape often remains concealed, as the voices of victims go unheard or they receive no support from society or from the system. Minors who suffer such acts live a life of horror, and it inflicts grave and lasting damage upon their minds. Persons with such perverted minds who commit these acts must be awarded strict punishment so that a fitting lesson is imparted to the wrongdoers.
3.That the accused persistently pressurised and emotionally tortured the complainant to give him money for his day-to-day expenses, on the ground that his parents never gave him any pocket money. On one occasion, when the complainant refused to give him money and told him, "I don't want to stay with you anymore," Accused No. 1 slapped the complainant in front of her friend, beat her, physically tortured her, and quarrelled with her on this issue. The accused has, on numerous occasions, beaten the complainant in front of her cousin. The accused constantly abused the complainant and repeatedly forced her into physical relations with him. The accused took the complainant to various hotels and blackmailed her into physical relations, saying: "agar nahi karogi, ya paise nahi dogi toh shaadi nahi karunga." Before every physical relationship and before taking money from the complainant, the accused always promised her that he would marry her. The accused repeatedly forced and compelled the complainant to give him money and to enter into physical relations with him, failing which he stated that "he would not marry her and tereko badnaam kar dunga." The accused repeatedly promised marriage and promised to keep the complainant separately from his parents, and constantly brainwashed her into agreeing to marry him. Suddenly, the accused began mentally and emotionally pressurising the complainant to marry him, stating that he had told his father and mother and that they were aware of the relationship. The accused persons coerced the complainant and demanded money in the name of the marriage. The accused persons blackmailed the complainant by saying: "apne bete ki shaadi nahi karenge tujhse agar humko paise nahi diye toh." All the accused persons took money from the complainant; at all times Accused No. 1, under the influence of his parents, blackmailed the complainant and extracted money from her. The accused persons took Amount demanded in the name of the marriage in the name of the marriage, and thereafter the family members of Accused No. 1, i.e., Accused Nos. 2 to 4, accorded their permission for the marriage.
4.That under the emotional influence of, and in love with, Accused No. 1, the complainant was married to him on Date of marriage at Place of marriage in the presence of Accused Nos. 2 to 4, and the complainant was directed to remain at her parental home and never disclose the marriage to her parents. Subsequently, the parents of the complainant learnt of the marriage between the complainant and Accused No. 1. The complainant being the only daughter of her parents, and out of their love and affection for her, the parents of the complainant beseeched the parents of Accused No. 1 and requested them to accept the complainant as their "Bahu" and as the wife of Accused No. 1. After numerous requests and the intervention of relatives, the accused persons agreed, but demanded: "hum yese nahi lekar jayenge ladki ko, humari bhi ijjat hai samaj mein, aapko uski Vidai ka function karna padega aur dan dahej dena padega, warna hum use accept nahi karenge." The parents of the complainant agreed and arranged the "Vidai" ceremony, which was held on Date of vidai ceremony in the presence of the family members of the accused persons. However, the accused persons pressurised the parents of the complainant to give gifts, clothes, and money to their entire family members, and immediately before the complainant was to move in with her husband, the accused persons told the complainant that "if you want to stay with your husband, then you have to ask your parents for a house, furniture, electronic appliances and other necessary things, and hard cash of Cash demanded at the time of the vidai ceremony"; only upon fulfilment of this demand could the complainant enter her matrimonial home and stay with their son, Accused No. 1. The accused persons emotionally tortured the complainant, and under the emotional influence of Accused No. 1, she narrated all these demands to her parents. The complainant being their only daughter, and out of love and affection, her parents fulfilled the demands and handed over all the demanded items and cash of Cash demanded at the time of the vidai ceremony to the accused persons. Accused No. 1 asked the mother of the complainant to either purchase a property for her daughter or to transfer one floor, namely the Floor of the parents' property demanded to be transferred, of the property of the complainant's parents into the complainant's name; in the meantime, she would be required to pay house rent and security deposit, as Accused No. 1 wished to reside in rented accommodation, having promised the complainant that he would live separately from his parents. The parents of the complainant also fulfilled this illegal demand of Accused No. 1 and paid the rent and security deposit for the rented accommodation, as they wished their daughter to live peacefully. However, owing to the fear of the societal stigma attached thereto in their Hindu society, the parents of the complainant could not report the said illegal dowry demands of the accused persons to the police.
5.That the accused began pressurising the complainant to obtain money from her parents and to have the Floor of the parents' property demanded to be transferred of the complainant's parents' property transferred to her name. Accused No. 1 repeatedly said: "tere parents ka kaunsa kharcha hua hai shaadi mein, ask them for Floor of the parents' property demanded to be transferred and cash." The accused constantly pressurised the complainant for the same and repeatedly said: "agar nahi layegi toh tereko chhod ke chala jaunga apne maa-baap ke paas." He also pressurised the complainant to such an extent that she was compelled to ask her mother to arrange even "ration" for her household. In the second month of the complainant and Accused No. 1 residing in the rented accommodation, the accused refused to pay the rent and pressurised the complainant to seek money from her parents for the payment of rent, but the complainant refused. After a few months, the accused pressurised the complainant and said: "agar tu nahi degi toh I will leave you and go to my parents' place." This continued until Accused Nos. 2 and 3 moved in and began residing with them. Thereafter, Accused Nos. 2 and 3 began pressurising the complainant to pay the rent and to provide money for other household requirements; in connivance with one another, the accused persons would gang up against the complainant and torture her for money. All the accused persons were fully aware that the complainant was studying and not earning, and they also knew that the complainant's parents and her brother gave her pocket money for college transportation and other expenses. Whenever the complainant received her pocket money from her brother, the accused persons would again begin pressurising and forcing her to hand over that money to them for the payment of rent and other expenses. The complainant was under such acute pressure and was so thoroughly brainwashed that she could not think clearly as to what she should or should not do. The accused persons also forced the complainant not to disclose anything to her parents or her brother. Owing to this constant pressure and emotional blackmail, the complainant was constrained to hand over all her pocket money to the accused persons. Subsequently, Accused Nos. 2 and 3 began creating differences between Accused No. 1 and the complainant, instigating Accused No. 1 over every trivial matter, and Accused Nos. 2 to 4 habitually provoked Accused No. 1 against the complainant. The accused persons constantly instigated Accused No. 1 against the complainant, saying: "tum room lock karke nahi soge, tum ek doosre se baat nahi karoge, tumhari awaaz nahi aani chahiye, hum tumhare room mein tumhare saath soyenge." The accused persons never permitted Accused No. 1 and the complainant to be left alone and constantly interfered in the privacy of the husband and wife. The accused persons also never allowed them to go out alone, always saying: "hum bhi saath chalenge, tum akele bahut ghoom liye shaadi se pehle, ab jahan jaoge humare saath jaoge." The accused persons began creating differences between Accused No. 1 and the complainant. The parents of the accused tortured the complainant to such an extent that they would not allow her to sleep with her husband alone, or even to talk or eat alone. The accused persons repeatedly said: "ki ye college nahi jayegi," and always provoked the accused husband by saying: "we don't know where she goes in the name of college, whom she meets, maybe she goes with other men." The parents of the accused constantly provoked Accused No. 1 and cast aspersions upon the character of the complainant, thereby influencing the accused husband against the complainant in the most improper manner.
6.That Accused Nos. 2 and 3 went to the extent of stating that they did not like the Complainant, made ill and degrading remarks about her, and told her that they had married her only on the pretext of extracting dowry from her parents and grabbing their property. Upon hearing these humiliating words and embarrassing remarks from her husband, the Complainant was heartbroken and shattered, feeling that her life had been ruined and that nobody loved her in the matrimonial home. The Complainant suppressed all the humiliation she was subjected to and hoped that matters would settle down in her matrimonial home and that one day the Accused persons would begin to love her. However, the Accused persons kept brainwashing the husband of the Complainant by telling him that "she is not loyal to him". The husband of the Complainant also left his job after the marriage, as he had become dependent upon the Complainant and her parents. After leaving his job, the Accused pressurised the Complainant to bring money from her parents, stating that he wished to invest in some business, and he forced her mentally and physically to ask her parents for money. Under this pressure, the Complainant was constrained to ask her mother for money, and her mother pledged her gold and gave the money to the Accused to fulfil his demand. The Accused persons also pressured the Complainant to the extent of saying, "paise nhi layegi toh apne ghar ja". After some time, the Accused persons again began pressurising the Complainant, subjecting her to severe mental pressure and playing with her emotions, and forced her to once again ask her parents for money. The Complainant was under such pressure that she could not think straight and had to ask her parents for money again, whereupon the mother of the Complainant again gave gold to the Accused persons to sell and appropriate the proceeds. Apart from this, wherever the parents of the Complainant sent anything to her, the Accused persons always demanded money from her, knowing full well that whatever she possessed had been given to her by her brother for her college expenses and personal use. On many occasions, the Accused persons forced the Complainant to take money from her brother to pay the rent and to hand over the balance to them. On every occasion, whatever the parents of the Complainant gave to her was taken away by the Accused persons. Every day, the Accused persons tormented the Complainant to perform household work despite knowing that she had to study for her examinations. The Accused persons repeatedly said, "ya toh apne ghar se kisi ko bula le kaam karne ke liye varna khud kaam karna padega". The Accused persons always wanted the help of the parents of the Complainant for their work. Whenever the Accused persons had any work pending — even for trivial reasons such as the cooler not working, the exhaust not working, or the maid being on leave — they always asked the Complainant to call someone from her mother's place to do their work. Even for ordinary household requirements, the Accused persons made themselves dependent upon the parents of the Complainant, and forced the Complainant to call for house help from her mother's place for every small matter. That Accused No. 2 used to instigate Accused No. 1 against the Complainant by making false allegations and accusing the Complainant of not performing the household chores. As a result of such instigation, Accused No. 1 used to abuse the Complainant, hurl derogatory words at her, and warn her to perform all the household chores in accordance with the directions of Accused No. 2.
7.It is submitted that the husband of the Complainant concealed the fact that he was working elsewhere, and never gave a single penny to the Complainant for her day-to-day expenses; he used to hand over his earnings to his parents and spend his money upon himself, but never gave the Complainant any money for her expenses. Whenever the Complainant asked the Accused for money, he would always say, "mere paas nhi hai, agar chahiye toh apni maa se mang lo".
8.That on the birthday of the Complainant, the Complainant and her husband went out for a night's stay, and there also she bore the expenses. The next morning, Accused Nos. 2 and 3 telephoned the Complainant and her husband and asked them to return home. The Complainant replied that she and her husband would be staying for one more day. As soon as the Accused persons learnt that the Complainant and her husband were staying alone for one more day, they began again to provoke the husband of the Complainant, abused the Complainant, and quarrelled with her over the telephone, demanding that they return home at once. When the Complainant and her husband reached home, Accused Nos. 2 to 4 started abusing and beating the Complainant on the pretext that she had wanted to stay alone for one more night with her husband. While all this was happening, the husband of the Complainant did not stop them; on the contrary, he joined in the cruelty and said, "tune mujhe kyu nahi bataya ki mummy-papa bula rahe hai wapis, tere paas jyada paise aa rahe hai udane ke liye".
9.That on the occasion of Karvachauth, the parents of the Complainant gave gold bangles to the Complainant and a gold chain to her husband as her first Karvachauth gift. A few days later, the Accused persons abused the Complainant and took the gold chain of her husband into their possession, and the Complainant thereafter learnt that they had sold the said gold chain. The Accused persons always had their eyes upon the remaining jewellery of the Complainant and upon whatever she received from her parents, and on every occasion they asked her parents for clothes, money and gifts for every member of their family.
10.That after some time, the wedding of the brother-in-law of the Complainant took place. For the wedding, the Accused persons all purchased new clothes for themselves and spent money upon themselves, but did not buy a single dress for the Complainant; rather, the Accused persons forced the Complainant to ask her parents for clothes and other articles. After the wedding of his brother, all the relatives of the Accused came to the house of the in-laws for a night's stay. There also, the husband of the Complainant asked her to pay all the bills, and the Complainant bore their expenses in order to save the image of her husband. Whenever the Complainant and the Accused went anywhere, he always forced her to pay the bill. At the instigation of Accused Nos. 2 to 4, the husband of the Complainant beat her mercilessly, and his parents also intervened and provoked him to beat her further and to teach her a lesson for ignoring their demand for the property. The Accused persons instigated the husband of the Complainant to abuse her and to torture her mentally and emotionally, on the pretext of obtaining the property in his name. Whenever there was a family get-together at the parental home of the Complainant, her husband wanted to take her along, but the in-laws always refused and said, "usko akele jaane de, wo kya karegi jaakar". The Accused persons always prevented the Complainant from going to her parental home, never allowed her to speak to her parents, and kept a constant watch over her. Whatever the Complainant did — what she wore, what she ate, what she spoke to her husband about, and what she did in her room — the Accused persons kept an eye upon everything. The Accused persons were always interfering between the Complainant and her husband; they always kept them apart from each other and continually did things which created distance and differences between the Complainant and her husband. Thereafter, on the birthday of her husband, the Complainant planned to go out together for dinner, and when the Complainant asked her in-laws for permission to go out on his birthday, they refused, created a scene, picked a quarrel with the Complainant, and abused her in filthy language. Later, the Accused persons provoked the husband of the Complainant as well, and he turned to their side and started abusing and beating her. A few days later, the Accused persons approached the Complainant and again demanded money and the gold bangles which had been given to the Complainant by her parents on Karvachauth. When she refused to hand them over, the Accused persons tortured and blackmailed the Complainant, saying, "ghar se nikal denge tujhe, aur shaadi kara denge apne bete ki kahin aur". After continuous torture and harassment, the Accused persons took the bangles from the Complainant; the said gold bangles were worth The said gold bangles were worth. They also threatened the Complainant not to tell anything to her family, and Accused No. 2 gave her a pair of artificial bangles, in case her parents were to ask for them.
11.That the Accused Husband never disclosed to the Complainant the details of his work or his source of income; whenever the Complainant asked him about the same, he responded dismissively, stating "Accused's dismissive reply when asked about his income". The Accused never gave the Complainant any money even for her basic expenses; even her toiletries were purchased by her parents. On the occasion of the Complainant's first wedding anniversary, the Complainant and the Accused planned a trip to Destination of the first wedding anniversary trip, and even for that trip the Accused forced the Complainant to ask her parents for money; the Complainant's parents gave him Amount given by the complainant's parents for the trip. Thereafter, the Accused kept the Complainant's gold chain, which had been given to her by her parents, on loan. The Accused persons also sought to turn the Complainant against her parents; they would eavesdrop whenever she spoke to her parents and would record her calls. The cruelty reached such an extent that the Accused persons installed a call recorder in the Complainant's phone and listened to her conversations with her parents. On one occasion, the Accused persons accompanied the Complainant to dinner at her parents' house, where Accused No. 2 created a scene; having consumed alcohol, he started abusing the Complainant, snatched her phone and demanded that she leave her parents' house. The Accused persons abused the Complainant in front of everyone by calling her "Abusive epithet used by the accused persons", and while all this was happening, the Accused Husband stood by silently and did not utter a single word to stop them from abusing the Complainant. Accused No. 2 created this entire scene because the Complainant had been talking to her mother alone in another room, and he did not wish her to speak to her. The Accused persons never permitted the Complainant to visit her mother's house alone; one of the Accused persons would always accompany the Complainant to her mother's place whenever she spoke to her parents or visited them, and would press her to speak about the Property of the complainant's parents demanded by the accused and force her parents to transfer the Property of the complainant's parents demanded by the accused in their name. On the day of a family get-together, the Accused persons left the Complainant at her parental home because they wanted her to persuade her parents to transfer the Property of the complainant's parents demanded by the accused in their name. Two days later, when the Complainant returned to her matrimonial home, the Accused persons questioned her about the Property of the complainant's parents demanded by the accused, and when she declined to discuss the same, they pushed her out of the house and slammed the door on her face. Thereafter, the brother of the Complainant called the Accused persons to talk, and the Complainant asked the Accused Husband whether he wished to live separately, away from his parents. The Accused refused, and instead started fighting with and abusing the Complainant, her parents and her brother. When the Complainant reminded him that the Accused had promised that "Accused's promise made at the time of marriage", he replied "Accused's demand for property and cash in his own words". Owing to the fear of societal stigma, the Complainant could not report the atrocities and cruelty committed by the Accused persons to the police or to the higher authorities.
12.That the physical as well as mental health of the Complainant was severely affected. The Complainant was made to work the whole day without any rest, and at night the Complainant and her family members were cursed and abused by the Accused persons. That Accused No. 1 did not let go of any opportunity to abuse and beat the Complainant. That with the passage of time, the physical cruelty and atrocities committed upon the Complainant by the Accused persons further increased, and Accused No. 3 also became aggressive in physically beating her. When the Complainant told him that she was his sister-in-law (Bhabhi), Accused No. 3 used to say, "Insulting remark made by Accused No. 3". When the Complainant reprimanded Accused No. 3 in front of all the family members, on the same night Accused No. 3 abused her in the filthiest language, warned her that he would go to any extent, and created unnecessary scenes. When the Complainant attempted to dial 100 and call the police, Accused No. 3 snatched the phone from her and beat her badly with slaps.
13.That thereafter Accused No. 3 again committed all kinds of physical cruelty upon the Complainant; Accused No. 3 pushed her, punched her in the face and beat her mercilessly. That the said physical atrocities became a routine affair, and the Complainant was regularly beaten by Accused Nos. 2 and 3 in connivance with, and with the support of, the rest of the Accused persons. That Accused Nos. 1, 2 and 3 warned the Complainant that if she did not bring the dowry of Amount of cash demanded as dowry in cash and have the Property of the complainant's parents demanded by the accused of her parents transferred in their name, she would be subjected to the said atrocities on a regular basis, and that the Accused persons would make her condition worse.
14.Since then, the Complainant has observed a complete change in the behaviour of Accused No. 1. Further, on the smallest of matters, Accused No. 1 repeatedly threatened the Complainant with throwing her out of the house and with beating her mercilessly. In the first week of Month and year of the severe beating incident, Accused Nos. 1, 2, 3 and 4 beat the Complainant very badly; on account of the severe beating, the Complainant was unable to move from her bed for the entire night, and the Accused persons threw the Complainant out of the house with only the clothes she was wearing. The Complainant went to her parental home; however, upon her reaching there, neither Accused No. 1 nor Accused Nos. 2, 3 and 4 chose to speak to the Complainant. The Accused persons behaved with the Complainant in the cruelest manner, and when the Complainant returned to her matrimonial home, on the very same day her husband, Accused No. 1, once again beat her very badly and asked her to leave the house. When the Complainant refused to do so, Accused No. 1 thrashed her and declared in her presence that he would remarry and live with his new wife, and branded the Complainant as characterless. Accused No. 1, without any concern, collected all the costly items, i.e., all the diamond articles, gold jewellery and cash of the Complainant, left her company, and declared that he would never return to her life and that she would face the worst phase of her life.
15.That owing to constraints of time, the Complainant has not been able to place the complete facts and documents on record, and seeks liberty to be allowed to bring additional facts and documents on record as and when possible for the Complainant.
16.That the life of the Complainant became miserable in her matrimonial home. That it is also pertinent to mention here that the Accused persons subjected the Complainant to extensive physical and mental torture and harassment. The Accused persons also threatened the Complainant that they would not leave her alive.
17.That the Accused persons used to taunt and humiliate the Complainant on every occasion, and whenever the Complainant went outside the house, the Accused persons levelled false allegations against her. The Complainant most humbly submits that no one from their family has ever tried to pacify or advise them about the right way of leading a family life.
18.That on account of the vile and abusive behaviour of the Accused persons, the Complainant has been subjected to mental, physical and psychological cruelty. That Accused No. 1 refused to support the Complainant and blamed her. Apart from the physical cruelty, the Complainant has been subjected to different forms of cruelty which are more harmful than physical cruelty, and these have destroyed her peace of mind and grievously hurt her mental feelings.
19.That a comprehensive appraisal of the entire matrimonial life of the Complainant and Accused No. 1 clearly shows that Accused Nos. 1, 2, 3 and 4 are guilty of treating the Complainant with physical, mental and economic violence, without any just and reasonable cause. Their conduct has been unpardonable and unforgivable, and their wilful and unjustifiable acts have inflicted severe harassment and agony upon the Complainant and have forced her to take the step of filing this complaint against the Accused persons on account of their unbearable violence.
20.That the Complainant was so mentally disturbed and beleaguered by all the Accused persons that on many occasions she thought of committing suicide; however, finding hope, the Complainant would pacify herself with the thought that these times of hardship would soon end. But to her misfortune, the Accused persons never showed any care or concern for the Complainant and at all times inflicted atrocities and cruelty upon her.
21.That as a consequence of the atrocities and cruelty committed upon the Complainant, and in her endeavour to come out of the trauma suffered by her, the entire persona of the Complainant, who was earlier a confident, smart and hardworking person, has been destroyed. She is unable to repose confidence in anybody, nor can she trust anyone, due to the ill-treatment, constant demands for dowry and taunts on that account inflicted upon the Complainant and her family members by the Accused persons.
22.That Accused No. 1 is still in possession of the entire jewellery and all other articles of the Complainant. It is pertinent to mention herein that Accused No. 1 forcibly took possession of the jewellery of the Complainant and continues to retain the same, or it is possible that the same may be sold off by him. The Complainant has thereby been made to suffer the various acts of cruelty and demands for dowry stated above.
23.That owing to the constant threats held out by all the Accused persons, the Complainant got scared and felt alarmed, as the Accused persons are persons of means and are fully capable of executing their threats. The Complainant is left with no other option but to approach your goodself.
I have no other remedy left except to approach your goodself and request that appropriate action be taken against the Accused persons, and that I be assisted in recovering my Istridhan articles and other valuables which are in their unlawful possession. I reserve my right to make additional statements regarding their conduct and the details of other atrocities committed by them, as and when directed by your goodself. I have been compelled to file this complaint. It is therefore requested that appropriate action may be taken against the aforesaid persons.
It is, therefore, most respectfully requested that your goodself may kindly take appropriate action against the aforesaid Accused persons in accordance with law and register an FIR under the provisions of Sections 375/498A/406/506/34 of the IPC.
Yours faithfully,
(Complainant's first name Complainant's surname)
W/o Husband's name,
R/o Complainant's address.