Complaint to police for registration of FIR for abduction for ransom, extortion and forgery
Cites the IPC, CrPC or Evidence Act. For matters from 1 July 2024, use the BNS, BNSS or BSA.
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affidavit. The complainant already had a stamp paper of Rs. 100/- for the purpose of writing the affidavit. I was compelled to write as dictated, since Accused's name threatened that, in case I did not comply, he would keep me confined in the flat, would not permit me to leave, and would have me severely beaten. It was under such threat, pressure and apprehension that I wrote down the contents in Hindi. I reproduce below, to the best of my recollection, what I was made to write. The same reads as under:
“I, Complainant's name, son of Complainant's father's name, resident of Complainant's address, am taking an amount of Amount taken from the first lender from First lender's name, S/o Shri First lender's father's name, resident of First lender's address, and an amount of Amount taken from the second lender from Second lender's name, S/o Shri Second lender's father's name, resident of Second lender's address, i.e., a total amount of Total amount borrowed, for my business, at the instance of Accused's name. The said amount shall be returned within a period of Repayment period stated in the affidavit, failing which the said lenders may take legal action against me.”
Sd/- (xx)
13.Accused's name also got two photocopies of my Aadhaar card made and obtained my signatures on the said photocopies of the Aadhaar card.
14.While forcing me to write and sign the aforesaid affidavit, Accused's name asked me for the telephone numbers of my near and dear ones and noted down the phone numbers existing in the mobile phone itself of my two brothers and of my mother and father. Thereafter, he started calling on the said numbers from his mobile number Accused's mobile number, and called my mother on her mobile number Mother's mobile number and told her that I was in his custody. He demanded that she should issue cheques amounting to Ransom amount demanded, stating that loss had been caused to him on account of her son and that her son was responsible to return that amount, and further stated that he was sending a person to her home to collect two cheques of Amount of each cheque demanded each. Upon this, my mother, out of fear, requested him to release her son, stating that she was not aware of anything, and requested that he allow her son to speak to her, but Accused's name declined to do so. A number of calls were made by Accused's name to my mother. Incidentally, my brother Brother's name was also with my mother, and Accused's name repeated the same demand to him and informed him that he had confined his brother. A copy of the call records is annexed herewith. Accused's name also threatened Brother's name and told him that, in case he wanted the release of his brother, he should immediately make arrangements to transfer an amount of Ransom amount demanded to the account of one Beneficiary account holder's name. My brother expressed his inability to arrange such a large amount immediately and stated that he could arrange only Total amount brother said he could arrange, out of which he could arrange only First amount transferred at that very moment. Accused's name pressurised my brother to deposit immediately whatever amount he could, failing which his brother would be physically tortured to any extent. Under such immense pressure, my brother agreed to deposit an amount of First amount transferred into any account as per their instructions. Thereafter, they sent the details of the account, namely the account of Beneficiary account holder's name with Beneficiary's bank name, A/c No. Beneficiary account number, Bank branch, IFSC No. IFSC code, on the WhatsApp number Brother's WhatsApp number of my brother from the mobile number Accused's mobile number, and they exerted tremendous pressure through telephone calls on my mother as well as through messages sent on the WhatsApp of my brother. Copies of the exchanged messages are enclosed with the present complaint, which show the extent of pressure created by the said culprits. Somehow, my brother made arrangements and got an amount of First amount transferred transferred into the account of Beneficiary account holder's name through the Advocate's bank name account of Advocate's name, Advocate, who is a friend of my younger brother. Thereafter, they brought me back to the same flat and kept me in confinement throughout the night, having locked the flat so that I could not move out of it.
15.On the next day, i.e., Date of incident, at about Time of the call on the next day, my brother called Accused's name and requested him to release me, as he had done whatever he could at his asking. Upon this, Accused's name again started demanding a further amount of Further amount demanded for release and stated that he would release me only after receiving the said amount. They immensely pressurised my younger brother to deposit the said amount, and my brother further deposited Further amount demanded for release into the same account of Beneficiary account holder's name, on the instructions of Accused's name, from the account of Advocate's name, Advocate. The details of the WhatsApp messages and audio recordings exchanged are enclosed with the present complaint, and they show that Accused's name, during the conversation, clearly stated that he would release me from his custody only after receiving the said amount.
16.My brother repeatedly requested Accused's name that, since he had already parted with cash, he should arrange a railway ticket so that I could safely reach Destination city. Despite promising to leave me at the railway station by the next available train after arranging a railway ticket, he did not do so. My brother went on pleading with him to put me on the evening or even the night train, but he did not do so. It appears that he did not want to take the risk of my getting down from the train and making a complaint against him. In the night, he again created pressure, stating that he would release me only when my family members sent an air ticket, and upon this, my brother got an air ticket booked from Origin city of flight to Destination city of Airline name airlines dated Date of release, which was scheduled to depart at Departure time of the flight.
17.Accused's name returned my mobile phone and Aadhaar card, but did not return my watch and the cash amount of Cash amount taken from the purse, which had been taken by him from my purse.
18.In the morning of Date of release at about Time of being dropped at the airport, he sent me with Accused's name, who dropped me at Airport name Airport, and after dropping me, Accused's name sent a message to my younger brother that his brother had entered the airport and had left for Destination city. At around Time of arrival at the destination airport, I reached Destination city Airport.
19.I request that all the call records of the telephone calls received by my mother and my brother shall be submitted later, as, after returning from City of incident, I was in a state of great shock and fear and was not in a position to describe the incident that had occurred with me.
20.It is submitted that on Date of incident, Accused's name made around Approximate number of calls made to the mother calls on my mother’s mobile and around Approximate number of calls made to the brother calls on my brother’s mobile (No. Brother's mobile number). After reaching Destination city, I started collecting all the call details from my brother and mother.
21.It may be mentioned that Accused's name had been playing a fraud in conspiracy with other persons, namely Mr. Co-accused's name and Mr. Second co-accused's name, to extort money. It was Co-accused's name who had been sending messages for and on behalf of Accused's name, and it is Co-accused's name into whose account the money was transferred at the instance of Accused's name. Moreover, the affidavit mentioned in paragraph No. 12 above was also got made from me in favour of Mr. Co-accused's name and Second co-accused's name.
22.It is clear from the aforesaid conduct that Accused's name, with the help of his associates and goons, committed various criminal offences against me.
23.It may also be stated that Accused's name posed himself as working as ADM in the DC office at City of DC office, State, and it appears that this was their modus operandi to carry out organised loot from innocent persons like me.
24.The undersigned has already filed a police complaint before the SHO, Police Station Police station, on Date of police complaint, vide DD number of police complaint, for registration of an FIR against the said accused persons.
25.As would be clear from the contents of the complaint, cognizable offences under Sections 364A/365/385/468/506 read with Sections 120-B/34 of the IPC are made out. The SHO of P.S. Police station ought to have registered the FIR, but for reasons best known to him, the SHO has not registered the FIR till date.
It is, therefore, most respectfully prayed that this Hon'ble Authority may kindly be pleased to register the FIR, or direct the police station concerned to register the FIR, against the aforesaid accused persons for the offences of abduction for ransom, extortion by putting fear of grievous hurt, forgery, criminal conspiracy, criminal intimidation and such other offences as may be revealed during investigation, punishable under Sections 364A/365/385/468/506 read with Sections 120-B/34 of the IPC; and further to investigate the deep-rooted criminal conspiracy and fraud, prosecute the culprits and ensure that they are punished in accordance with law.
Thanking you,
Yours faithfully,
(Complainant's name)
Complainant's name
Complainant's address,
Complainant's city
Mobile: Complainant's mobile number
CC to:-
1.CC addressee name,
CC addressee's address
CC addressee's city.
2.Second CC addressee name
Second CC addressee's designation,
Second CC addressee's address,
Second CC addressee's city.
Encls.:-
1.Copy of the typed call records from No. Accused's mobile number (Caller's name) to No. Mother's mobile number (Mother).
2.Copy of the typed call records from No. Accused's mobile number (Caller's name) to No. Brother's mobile number (Brother's name).
3.Copy of the call records of one of the accused, Accused's name, Mobile No. Accused's mobile number, to No. Mother's mobile number (Mother).
4.Copy of the call records of one of the accused, Accused's name, Mobile No. Accused's mobile number, to No. Brother's mobile number (Brother's name).
5.Copy of the WhatsApp messages sent by WhatsApp sender's name to my Message recipient's relation.
6.Copy of the WhatsApp messages sent by WhatsApp sender's name to my brother, Brother's name.
7.Copy of the bank transaction of Rs. 20,000/- transferred from the account of Advocate's name to the account of Mr. Beneficiary account holder's name on Date of transfer.
8.Copy of the bank transaction of Rs. 10,000/- transferred from the account of Mr. Advocate's name to the account of Mr. Beneficiary account holder's name on Date of transfer.
9.Copy of the audio CD containing the recorded conversation between Mr. Person in audio recording, Person in audio recording and Person in audio recording.