Complaint to SHO for registration of FIR for snatching of car and criminal intimidation
Cites the IPC, CrPC or Evidence Act. For matters from 1 July 2024, use the BNS, BNSS or BSA.
0 of 43 blanks filled
ToDated: Date of complaint
The Station House Officer,
Police Station: Police station,
District/city of police station.
SUBJECT: Complaint against Name of accused for snatching the complainant's car, namely a Make of first car car bearing Model Number – Model number of first car, Chassis Number – Chassis number of first car, Engine Number – Engine number of first car, Colour – Colour of first car, and for threatening to misuse the said car.
1.That the Complainant is a law-abiding citizen of India. The Complainant and the accused are husband and wife, and were married on Date of marriage (day).Date of marriage (month).Date of marriage (year).
2.That the Complainant purchased a Make of purchased car car bearing Model Number – Model number of purchased car, Chassis Number – Chassis number of purchased car, Engine Number – Engine number of purchased car, Colour – Colour of purchased car, in the year 2015.
3.That the Complainant is working with Name of complainant's employer, and the said company, Name of employer company, has a tie-up arrangement with a leasing company for the purchase of cars by its employees under lease. The Complainant entered into a contract with Name of leasing company and purchased the car under the said arrangement. The Complainant paid the entire installments from her salary to Name of leasing company (installments paid to). Upon completion of the installments, the car was transferred into the name of the Complainant after issuance of the No Objection Certificate by Name of leasing company (NOC issuer), and a fresh Registration Certificate was issued in the name of the Complainant. The relevant documents are annexed herewith.
4.That on Date of assault incident (day).Date of assault incident (month).Date of assault incident (year), at around 8:00 PM, while the Complainant was on an office call, the accused called out to the Complainant from inside the bathroom. As the Complainant did not hear him, the accused came out screaming at the Complainant, held her by the neck, and abused her, saying that she was worthless and did not deserve to live. The Complainant's mother, who had returned from Place complainant's mother returned from on Date mother returned (day).Date mother returned (month).Date mother returned (year), heard the Complainant screaming and tried to stop the accused. Thereupon, the Complainant gathered courage and began screaming to call the neighbours, upon which the accused ran out of the house and went to his brother's house at Place of accused's brother's house, and did not return thereafter. Subsequently, on Date of car snatching (day) Date of car snatching (month), at about 7:00 PM, when the Complainant was attempting to leave the house, the accused, along with his friend, Mr. Name of accused's friend who came drunk, who had come to the house in a drunken state, snatched the aforesaid car from the Complainant by threatening her. The accused slapped the Complainant and beat her mother with a danda in order to evict them from the house. When the Complainant and her mother refused to leave, the accused brought a knife from the kitchen, placed it on the Complainant's neck, and threatened to eliminate her daughter in front of her. The accused then threw the Complainant, her daughter, and her mother out of the house, although the Complainant has been paying the monthly installments of the house from her own funds. This incident occurred at around Time of eviction incident (hour) PM on Date of eviction incident. The Complainant's mother literally begged the accused not to do so, but he showed no kindness, as he was heavily drunk and behaved in a cruel manner. When the Complainant asked to be allowed to take her belongings, the accused did not permit her to do so. When the accused took the Make of snatched car car, he snatched it from her, paying no heed to the fact that two ladies and a minor child were being put out of the house late in the evening.
5.That it is pertinent to mention that Section 2(19) of the Motor Vehicles Act, 1988 defines the word "owner" to mean, inter alia, a person in whom proprietary title in the vehicle vests; the person in whose name the certificate of registration stands is deemed to be the owner of the vehicle.
6.That under the Motor Vehicles Act, 1988, no person has the right to use another person's vehicle without the consent of the owner, and where the owner objects to such use and denies permission, such use would amount to trespass to the vehicle.
7.That the ownership of the vehicle stands in the name of the Complainant, and the accused has no right to use the vehicle without the consent of the Complainant. If the accused uses the vehicle without such consent, his act would amount to trespass to the vehicle.
8.That it is pertinent to mention that the vehicle, i.e., a Make of vehicle in accused's custody car bearing registration no. Vehicle registration number, is in the custody of the accused without the consent of the Complainant. It is further submitted that the accused has forcefully taken possession of the said vehicle and has threatened the Complainant that he will falsely implicate her in various litigations, including civil, criminal and tortious proceedings.
9.That the accused threatened the Complainant that he would vandalise the aforesaid car or deliberately run over someone with it in order to frame the Complainant in a false criminal case. The accused further stated: "MEIN TERI CAR SE KISI KO MAAR KE BHAG JAUNGA AUR TERE CAR KO WAHI CHOD DUNGA AUR JAB CASE HOGA TO TU FASEGI AUR AGAR BACHNA CHAHTI HAI TOH VAAPAS AA JAA, DIVORCE TO NAHI DUNGA."
10.That the accused is in wrongful possession of the aforesaid car, and he has a tendency to drive under the influence of alcohol, which is likely to cause severe harm to innocent persons as well as to the Complainant. The Complainant requested the accused several times to hand over the car to her, but the accused refused to do so and further stated: "MEIN TUJHE TERI CAR NAHI DUNGA AUR MEIN TOH AISAYE HI GAADI CHALUNGA AUR AGAR TU ROK SAKTI HAI TOH ROK LE OR YAHI NAHI AUR AGAR JYADA HOSHIYAR BANEGI TOH TUJHE AISE CASE MEIN FASA DUNGA KI PURI ZINDAGI GAADI KA NAAM NAHI LEGI."
11.That the accused habitually disregards traffic rules and frequently drives over the speed limit, more particularly under the influence of alcohol. He also gets agitated easily and becomes involved in road rage, which not only endangers his own life but places everyone around him at lethal risk. The accused further threatened the Complainant that he would implicate the said vehicle in some legal case.
12.That the accused is a negligent driver likely to cause harm to the lives of others, and since the vehicle stands in the name of the Complainant, the liability would fall upon the Complainant alone. It is also pertinent to mention that the accused threatened the Complainant that he would violate traffic norms and that the challan cost would be double the price of the car. The accused further stated: "MUJHE JYADA GYAN DENE KI JARURAT NAHI HAI MEIN AISE HI CHALUNGA TU JO KAR SAKTI HAI KAR LE AUR WAISE BHI MUJHE TO TUJHSE KAISE BHI PARESHAAN KARNA HAI TAAKI TU KAHIN AUR JAA NAA SAKE, RAHEGI TO TU MERE SAATH HI."
13.That over the last several years, the Complainant's life has been disturbed owing to the accused's unlawful and improper conduct. It is further submitted that the accused, being habituated to drinking and driving under the influence of alcohol, has fought with the Complainant on several occasions while driving the car.
14.That the Complainant has also filed a complaint against the accused at the Crime against Women Cell, Location of Crime against Women Cell.
15.It is, therefore, most respectfully requested that the needful be done and an FIR be registered against the accused under the appropriate sections of the Indian Penal Code, and that the accused be arrested in accordance with law.
Applicant
Complainant's name
W/o Sh. Name of complainant's husband
R/o Complainant's residential address
M – Complainant's mobile number
Copy to:
1.The Deputy Commissioner of Police,
2.The Commissioner of Police,