Criminal complaint under Section 200 CrPC for defamation, assault and criminal intimidation by husband's video
Cites the IPC, CrPC or Evidence Act. For matters from 1 July 2024, use the BNS, BNSS or BSA.
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IN THE COURT OF THE LEARNED CHIEF METROPOLITAN MAGISTRATE,
TIS HAZARI COURTS, DELHI
COMPLAINT NO Complaint number/Year
IN RE:
Complainant's name…. COMPLAINANT
VERSUS
Respondent's name…. RESPONDENT
P.S. Police station
I N D E X
| Sr. No. | Particulars | Pages |
|---|---|---|
| 1. | Memo of Parties |
| 2. | Criminal Complaint under Section 200 Cr.P.C. read with Section 190 of Cr.P.C. for the commission of offences under Sections 499, 354, 500, 503 and 509 of the Indian Penal Code, 1860, for making and circulating false and defamatory statements/allegations against the Complainant through mobile and electronic media by the above-named Respondent |
| 3. | List of Witnesses |
| 4. | List of Documents |
| 5. | Certificate under Section 65-B of the Indian Evidence Act |
| 6. | Vakalatnama |
New DelhiComplainant
DateThrough
Counsel
Address: Complainant's addressMOB: Complainant's mobile number
Email: Complainant's email address
IN THE COURT OF THE LEARNED CHIEF METROPOLITAN MAGISTRATE,
TIS HAZARI COURTS, DELHI
COMPLAINT NO Complaint number/Year
IN RE:
Complainant's name…. COMPLAINANT
VERSUS
Respondent's name…. RESPONDENT
MEMO OF PARTIES
Complainant's name (memo of parties)
W/o Father's name of complainant
R/o Complainant's residence
Complainant's name…. COMPLAINANT
VERSUS
Respondent's name
S/o Father's name of respondent
R/o Respondent's residence
Respondent's name…. RESPONDENT
DelhiComplainant
DateThrough
Counsel
Address: Complainant's addressM: Complainant's mobile number
Email: Complainant's email address
IN THE COURT OF THE LEARNED CHIEF METROPOLITAN MAGISTRATE,
TIS HAZARI COURTS, DELHI
COMPLAINT NO Complaint number/Year
IN RE:
Complainant's name…. COMPLAINANT
VERSUS
Respondent's name…. RESPONDENT
P.S.: Police station
CRIMINAL COMPLAINT UNDER SECTION 200 Cr.P.C. READ WITH SECTION 190 OF Cr.P.C. FOR COMMISSION OF OFFENCES UNDER SECTIONS 354, 499, 500, 503 AND 509 OF THE IPC, ALONG WITH SECTIONS 34 AND 35 OF THE IPC, 1860, FOR MAKING AND CIRCULATING FALSE AND DEFAMATORY STATEMENTS/ALLEGATIONS AGAINST THE COMPLAINANT THROUGH MOBILE AND ELECTRONIC MEDIA BY THE ABOVE-NAMED RESPONDENT
MOST RESPECTFULLY SHOWETH:-
1.That the Complainant is the permanent resident of the property bearing Complainant's residence address and is a law-abiding citizen of India. It is further submitted that the Complainant is the wife of the accused. A copy of the Aadhaar Card of the Complainant is annexed hereto as ANNEXURE C-1.
About the Section of the Complaint and Cause of Action:-
2.That this Complaint is filed under the authority of Section 200 read with Section 190 of the Criminal Procedure Code, 1973. Further, this Complaint is filed for the purpose of redressing the commission, by the accused, of "criminal defamation" of the Complainant within the meaning of Section 499 of the Indian Penal Code, 1860, in relation to a video recorded by the accused from his shop bearing No. Number of the accused's shop, Location of accused's shop, Delhi, which was replete with allegations against and character assassination of the Complainant, together with threats to the Complainant that if she did not give him money and a share in the property, the accused would commit suicide and hold the Complainant responsible for the same, which video was distributed and disseminated. This Complaint seeks due and just punishment to the accused in terms of Sections 499, 354, 500, 503 and 509 of the Indian Penal Code, 1860.
Brief Facts:
3.That the father, namely Father's name of accused, and the mother, namely Mother's name of accused, of the accused resided at Place where accused's parents lived for more than Number of years accused's parents lived there years; the father of the accused died at Place of death of accused's father; and the mother of the accused is alive and residing at Place where accused's mother lives with her sons.
4.That it is pertinent to mention that the relations between Father's name of accused, the father of the accused, and the accused have not been good for several years. It is further pertinent to mention that the relations between the Complainant and her son, namely Complainant's son's name, on the one hand, and the accused, on the other, have not been cordial for the last several years, and such a state of affairs arose on account of the atrocities committed by the accused upon the Complainant and her son. It is further submitted that the accused was, and is, a habitual drinker and frequently creates unlawful scenes with the Complainant. The Complainant further submits before this Hon'ble Court that she and her son have been living peacefully and earning their livelihood on their own, and have no relations whatsoever with the accused.
5.That the accused and the Complainant reside under the same roof; however, the accused and the Complainant are not on speaking terms, and the kitchens of the Complainant and the accused are separate and not at all joint. The conduct of the accused is against basic ethics, as he habitually uses abusive language and, in the past, has also raised his hand upon the Complainant and her son. It is pertinent to note that the conduct of the accused towards his parents, siblings and all other family members was similarly poor. It is further submitted that the accused has one son and three daughters, and no member of the family is on speaking terms with him. The conduct of the accused towards his daughters was such that he attempted to create a ruckus at the marriage of his youngest daughter, and the accused was sent to a rehabilitation centre on the day of his daughter's marriage.
6.That the Complainant submits that in and around Date/period when accused threatened his father, the accused threatened his father, Father's name of accused, with dire consequences in the event that the father did not give the accused his share in the property. Consequent thereto, the father of the accused, in grief and hurt, openly announced in the family:
"ME TUJHE EK PAISA NAHI DEKAR JAUNGA, TERE HISSE KA SARA KA SARA ME APNI BAHU AUR POTE KO DE JAUNGA AUR APNI BAHU AUR POTE KO BOL KAR JAUNGA KI TUJHE KUCH BHI NA DE NAHIN TO SAB KUCH SHARAB ME UDHA DEGA". Despite the fact that the treatment meted out to the Complainant by the accused is absurd and unethical, and the lives of the Complainant and her son stand disturbed on account of the various atrocities of the accused, the accused, under the influence of alcohol, has otherwise also quarrelled with the Complainant and her son and used abusive language in front of everyone.
7.That it is noteworthy that the siblings of the accused have been living separately from him for more than Number of years accused's siblings live separately years, and it was the accused who quarrelled with his parents and siblings and demanded a share in the properties. Upon his father's refusal, the accused migrated from Place accused migrated from, Delhi, and, after some time, opened a shop at Location of accused's shop, Delhi, and since then the accused has been residing in Delhi with the Complainant, one son and three daughters. The relations between the accused and the Complainant have been strained for a couple of years owing to the accused's excessive consumption of alcohol, as a result of which the accused has also been sent to a rehabilitation centre a couple of times in the last four to five years.
8.That the father of the accused, namely Father's name of accused (now deceased), made repeated efforts to make the accused understand that drinking alcohol was not a good habit, and that if the accused did not stop drinking, the father would disown him from all movable and immovable properties. However, the accused failed to mend his ways and continued his misbehaviour towards the family members and his father.
9.That on account of the continuous bad and unlawful conduct of the accused, the deceased father of the accused called him and conveyed that he intended to distribute all his movable and immovable properties in equal shares between his two sons, namely Name of accused's brother and Name of accused's brother, and the son of the accused, namely Name of accused's son. It is further submitted that the accused raised no query or objection, and in fact gave his consent to the said distribution. The father of the accused accordingly distributed all his movable and immovable properties equally in favour of Beneficiary name under the will, Beneficiary name under the will (son) and Beneficiary name under the will, equally, by way of a Will. A copy of the Will is annexed as ANNEXURE C-2. A notice dated Date of newspaper notice was also published in the daily newspaper Name of newspaper by the Sub-Registrar, Sub-registrar office, inviting objections, if any, to the Will. A copy of the notice dated Date of newspaper notice, published in Name of newspaper by the Sub-Registrar, Sub-registrar office, is annexed as ANNEXURE C-3. It is pertinent to note that the said Will was within the knowledge of the accused, and the accused never refuted the said fact.
10.That it is significant to state that in the year Year, the accused consumed a mixture of Name of tablet consumed by accused tablets, as conveyed by him, and was hospitalised at Name of hospital. However, owing to legal disputes between the accused and the hospital, the accused did not disclose the said hospitalisation to the Government authorities and conveyed the same only to his family members. After a few days, he was discharged from the hospital, and since then, every member of the family has been afraid of speaking to the accused, as he was highly aggressive. Since his discharge from the hospital, a drastic change came over the accused's behaviour: he increased the frequency of his consumption of alcohol, and on account of his excessive drinking, he had to be sent to rehabilitation centres. Indeed, the father of the accused, who was distressed by the accused's ill-behaviour, died due to the acts of the accused on Date of death of accused's father.
11.That it has now been learnt that the accused indulges in the excessive use of alcohol throughout the day, and his abusive conduct towards the complainant has increased. He recorded a video from his shop bearing no. 10-3596, Location of accused's shop, Delhi, full of allegations against the complainant and assassination of her character, levelling the gravest allegations of extra-marital and illicit relations with other persons, and threatened the complainant that if she did not give him money and a share in the property, he would commit suicide and hold the complainant and all other family members responsible. The accused sent this video to his brother, Name of accused's brother, from his mobile number Accused's mobile number to the latter's mobile number Recipient brother's mobile number on Date video was sent to brother by Medium of sending video (e.g. WhatsApp). The accused again sent the same threatening video to his younger brother, Name of accused's younger brother, from his mobile number Accused's mobile number to the latter's number Recipient's mobile number on Date video was sent by Medium of sending video. The accused further sent the same objectionable video to his sister, Name of accused's sister, on Date video was sent to sister, from his mobile number Accused's mobile number to her mobile number Sister's mobile number. The said video thereafter came to the knowledge of the complainant, and every member of the family was shocked to hear its contents. The accused circulated the video among some of the relatives and threatened the complainant that he would spread it among all her relatives and friends, and began making false allegations against her, while threatening in the video that he would commit suicide.
The statement/conversation/transcription of the video is as follows:
“SHRIMAN SHO SAHIB THANA Name of police station addressed in video MAIN Accused's name stated in video BOL RAHA HU MAIN AAJ BAHUT ZYADA PARESHAN CHAL RAHA HU ISKA KARAN YE HAI MERI PATNI Wife's name stated in video KE GAIR SAMBANDH HAI Name of man alleged in video 52 CHANDERLOK AUR Name of man alleged in video BEHROR SE RAAT KO PEECHE KE DARWAZE SE AATE HAI AUR CHALE JAATE HAIN MAIN BOLTA HUT OH APNE LADKE SE DHAUNS DETI HAI BULAUN USKO KARWAUN SIDHA YA CHUP RAHEGA PITWATI HAI MEREKO MAIN DARR KI WAJAH SE CHUP REHTA HU KAI BAAR MUJHE GHAR SE BAHAR NIKALWA CHUKI HAI ISKA KOI BHAROSA NAHI MEREKO GHAR MEIN RAKHEGI YA NAHI, 4 BAAR MUJHE NASHA MUKTI KENDRA MEIN BAND KARWA CHUKI HAI 4 SAAL KE LIYE, WAHA MUJKO PITWATI THI KHANA NAHI DETE THE BAHUT ZYADA PARESHAN KAR RAKHA THA MEREKO AUR DUSRA KAARAN YE HAI KI MERE BAAP DADA KI JO ZAYDAD HAI USME MERE BHAI DONO MEREKO BEDAKHAL KAR RAHE HAIN Name of accused's brother AND Name of accused's brother, MERI PATNI KO DE RAHE HAIN, MERI PATNI KA KOI BHAROSA NAHI MUJHE KAB GHAR SE BAHAR KAR DE ISILIYE MAIN APNA TEESRA HISSA CHAHTA HU, AUR MAIN SULFAZ KHA KE AATAM HATYA KARUNGA USKE ZIMMEDAR Person accused holds responsible in video,Name of accused's brother MERI PATNI Wife's name stated in video, MERA LADKA Son's name stated in video, Name of family member stated in video AUR Name of family member stated in video HONGE. YE VIDEO MAIN INDIA TV DELHI POLICE COMMISSIONER, AUR APNE SAMAJ KE LOGO KO BHEJUNGA TAKI MERE SATH INSAAF HO SAKE DHANYAWAD”
The CD containing the video is annexed as ANNEXURE C-4.
12.That when the complainant and her son confronted the accused about the video, the accused began threatening that he would spread the video among the public at large, relatives, media, police and other social media platforms, and destroy the reputation of the complainant, if one-third share in all the movable and immovable properties was not given to him. The truth, however, is that the movable and immovable properties of his father have already been distributed equally among Grandson's name (grandson), Son's name (son) and Son's name (son) in accordance with his last Will.
14.That it is crystal clear from the aforesaid conversation in the video that the accused is threatening the complainant in order to obtain a one-third share in the properties, and he also speaks of being disowned from the property by the complainant and the brothers, namely Name of accused's brother and Name of accused's brother, which is a clearly false and frivolous statement. The fact is that, on account of the bad and unlawful behaviour and activities of the accused, his father had already severed all relations with him; that is why he had not given the accused any share in his movable and immovable properties and had already executed a Will in respect of his properties. It is pertinent to mention that, owing to the cruel and evil-minded personality of the accused, the mother of the accused has also severed all ties with him, and she too executed a registered Will in favour of Sh. Grandson's name (grandson), Son's name (son) and Son's name (son). A copy of the registered Will dated Date of mother's registered will is annexed herewith as ANNEXURE C-5.
15.That the accused had already demonstrated, in the aforesaid conversation through the circulated video, that he is not mentally and psychologically fit, and there is a possibility that the accused might take the step of committing suicide or circulate the objectionable video among the masses, i.e., relatives, friends, neighbours or the general public; if the accused circulates the same, it would result in loss of reputation to the complainant. Moreover, it is an admitted fact that the accused is an alcoholic and has a past record of being sent to rehabilitation centres for treatment. This clearly shows that the accused bears a grudge against the complainant. It is for this reason that the complainant has registered a complaint against the accused with the SHO, P.S. Police station, Delhi, regarding the said act of the accused. A copy of the said complaint is annexed as ANNEXURE C-6.
16.That the accused is creating hindrance, interference and disturbance to the complainant in peacefully using and enjoying her property, with bad motives and the evil intention of grabbing all the movable and immovable properties of the complainant, and for this purpose the accused is prepared to resort to every possible means to harass the complainant.
Circulation of the video/jurisdiction:-
17.That the video made by the accused has been circulated at various places through WhatsApp. Further, the video was recorded from his shop bearing no. 10-3596, Location of accused's shop, Delhi, and was circulated to all recipients from the same shop at Location of accused's shop, Delhi, which falls within the jurisdiction of this Hon'ble Court. This Hon'ble Court therefore has jurisdiction to entertain the aforesaid complaint and to proceed thereon.
18.That by reason of the "defamatory video", i.e., the act of making and circulating the "defamatory video" in question, the accused is liable for the irreversible and unquantifiable damage caused by making false, baseless, scandalous and malicious content/statements/allegations against the complainant. The complainant further submits that at this juncture it is very difficult to assess the exact loss suffered by her, since the complainant is possessed of assets worth lakhs of rupees, and she reserves the right to initiate other legal remedies, i.e., civil and criminal proceedings against the accused, in future.
19.That it is settled law that every person has a right to have his reputation preserved inviolate. This right of reputation is acknowledged as an inherent personal right of every individual and is "a jus in rem". Where a wrongful act is found to have been committed which affects a person's reputation, it amounts to defamation, for which the aggrieved person becomes entitled to damages. It is pertinent to mention that the right to reputation has already been recognised as a fundamental right under Article 21 of the Constitution of India.
20.That the right to freedom of speech and expression carries with it a duty and responsibility not to abuse such freedom in furtherance of personal vendetta against any particular individual. In the present case, the facts stated hereinabove disclose that the circulation of the defamatory and vilifying video was purposely carried out by the accused with an ulterior motive to malign the image of the complainant and to wreak vengeance against her.
21.That the accused eroded the reputation of the complainant by sending the video to the relatives, friends and other platforms of the complainant, in consequence of which the complainant began receiving calls from all quarters seeking explanations. The employees, friends and well-wishers of the complainant were shocked and surprised to see the defamatory video, which is still available on the mobile phones of the relatives. Subsequently, the complainant as well as other family members started receiving various calls from relatives and friends inquiring about the 'defamatory video' containing defamatory content, including defamatory statements made about the complainant, purely with an intention to lower the impeccable reputation of the complainant in the eyes of her relatives, friends and the public at large, and is therefore clearly defamatory and libellous. The said defamatory contents of the video have the sole objective of causing damage to the reputation and goodwill of the complainant, which she had gained multi-fold over the last few years. In one of its landmark judgments, the Hon'ble Supreme Court quoted from the 'Mahabharat' to explain the importance of 'reputation' in a person's life.
In Kiran Bedi and Jinder Singh Vs. Committee of Inquiry AIR 1989 SC 714, it was held as under:
The following words of caution uttered by Lord Arjun in the Bhagavad Gita with regard to dishonour or loss of reputation may usefully be quoted:
"Akirtim chapi bhutani kathayishyanti te 'vyayam,
Sambhavitasya chakirtir maranad atirichyate"
(Men will recount thy perpetual dishonour, and to one highly esteemed, dishonour exceedeth death.)
22.That the accused made various mischievous and malevolent contents and comments, which are false and concocted in nature and defamatory of the complainant. The accused incorporated the same in the impugned video and further used unverified information going far beyond the facts. When the same was communicated to friends and relatives, it had a bad effect upon the innocent minds of the friends, relatives and the public at large, and was done by the accused to tarnish and malign the reputation of the complainant and to destroy her reputation in society.
23.That the accused did all this to settle a personal vendetta against the complainant and, more particularly, to prejudicially affect the goodwill of the complainant. It is pertinent to mention that the accused hatched a plan to malign the reputation of the complainant to enrich himself at the cost of the reputation of the complainant.
24.That the actions of the accused amount to libel and slander. The sole intention of the accused behind making and circulating the video is to fulfil his personal vendetta against the complainant.
25.That it is submitted that the accused has failed to abide by the minimum moral standards and there has been a complete failure to comply with the ethical standards expected of him. It is submitted that the accused is attempting to garner excessive, adverse and false publicity, thereby injuring the reputation of the complainant, and in such cases the inherent power vests in this Hon'ble Court to interdict and restrain the accused from carrying out such a vilification campaign against the complainant.
26.That the defamatory video is still widely available with relatives and friends and is continuing to malign the image of, and cause damage to, the complainant. The accused has thus made himself liable to be prosecuted in accordance with law.
27.That the complainant has no other speedy and efficacious remedy at present against the accused, and the repeated denigration of the character of the complainant by the accused is plainly defamatory and serves no public interest, nor does it have any legitimate connection with public discourse and debate.
28.That it is therefore thoroughly derogatory on the part of the accused to have made the statements which have eroded the well-earned reputation and character of the complainant.
29.That the complainant respectfully submits that it is an utterly criminal act on the part of the accused to first make a video containing false allegations and then circulate the same along with a threat to commit suicide. Such outrageous acts constitute the most daring acts of criminal defamation. Accordingly, the accused is fully responsible for criminally defaming the good name and reputation of the complainant.
30.That, as such, the accused has committed a blatant act of defamation in respect of the name and character of the complainant.
31.That the complainant respectfully submits that, through the "defamatory video", the accused made allegations against her, assassinated her character, levelled the gravest allegations of extra-marital relations/illicit relations with other persons, and threatened the complainant that if she did not give him money or a share in the property, he would commit suicide and hold the complainant and all other family members responsible, thereby ruthlessly destroying her reputation. The accused is therefore liable to be held accountable for his acts. Accordingly, his false statements have incalculably injured the reputation of the complainant.
32.That by expressing false outrage at every turn, the accused has most brutally damaged the reputation and character of the complainant.
33.That the complainant respectfully submits that she is at a loss to identify the true meaning of the aforesaid statements. Nevertheless, they suggest a derogatory reference to her.
34.That by making false and baseless allegations against the character of the complainant, the accused has committed a grave defamation of the character and reputation of the complainant. Therefore, the accused has committed a severe defamation of the character and reputation of the complainant.
35.That the complainant offers below a general argument on the non-applicability of the exceptions to Section 499 of the Indian Penal Code, 1860:
36.That the complainant respectfully submits that the statements and allegations of the accused are far from true, and even where true, they are solely calculated to inflict injury upon the reputation of the complainant without any legitimate aim apparent on their face. Further, the comments of the accused are far too extensive and intrusive, and were made by the accused to humiliate the complainant and to render her an object of contempt and ridicule. Similarly, knowingly, deliberately and intentionally fabricating stories, inventing fictions and characters, and fabricating statements are acts of falsehood which cannot, by any stretch of imagination, be considered normal or proper.
37.Actual harm upon the complainant: The complainant respectfully submits, as already discussed in the abovementioned Paragraph number, that her reputation has been gravely injured and harmed by the accused, and that every grievance raised in this complaint against the acts of the accused may be read as including the further grievance that those acts were calculated to injure and harm the reputation of the complainant, and that the same have indeed caused actual injury and harm to the reputation of the complainant.
38.That in the circumstances set out above, the accused is liable to be punished under Sections 354, 499, 500, 503 and 509 of the Indian Penal Code, 1860.
39.That the Complainant respectfully submits that the video was filmed and circulated on Date video was filmed and circulated. The present Complaint has been filed within the period of limitation prescribed under Section 468 of the Criminal Procedure Code, 1973, and is accordingly within time.
40.That the requisite Court fees have been affixed for the filing of the present Complaint.
PRAYER
It is, therefore, most respectfully prayed that in view of the distressing circumstances narrated above, this Hon'ble Court may graciously be pleased to:
(a)summon the accused to answer a charge of having committed criminal defamation of the Complainant within the meaning of Section 499 of the Indian Penal Code, 1860; and
(b)summon the accused to answer a charge of having known, or having reason to believe, that his act and imputation would harm the reputation of the Complainant, and of having caused actual harm to her reputation, within the meaning of Section 499 of the Indian Penal Code, 1860; and
(c)adjudge the accused as guilty, whether upon plea or upon trial, and subject them, individually, to the due and full punishment in terms of Sections 354, 500, 503 and 509 of the Indian Penal Code, 1860; and
(d)pass such other or further order or direction as this Hon'ble Court may deem fit and proper in the interests of justice.
Place:Complainant
Date:Through
Name of complainant's counsel
Counsel
Address:MOB: Complainant's mobile number | Email: Complainant's email address
IN THE COURT OF THE LD. CHIEF METROPOLITAN MAGISTRATE,
TIS HAZARI COURTS, DELHI
COMPLAINT NO. Complaint number/Year
IN RE:
Smt. Complainant's name….. COMPLAINANT
VERSUS
Sh. Respondent's name…. RESPONDENT
P.S. Police station
LIST OF WITNESSES
1.The Complainant herself
2.Sh. Son's name (witness) S/o Sh. Father's name of son witness (Son of the Complainant)
3.Sh. Brother-in-law's name (witness) S/o Late Sh. Father's name of brother-in-law witness (Brother-in-law of the Complainant)
4.Sh. Brother-in-law's name (witness) S/o Late Sh. Father's name of brother-in-law witness (Brother-in-law of the Complainant)
5.Smt. Sister-in-law's name (witness) (Sister-in-law of the Complainant)
Place:Complainant
Date:Through Counsel
Address: MOB: Complainant's mobile number | Email: Complainant's email address
IN THE COURT OF THE LD. CHIEF METROPOLITAN MAGISTRATE,
TIS HAZARI COURTS, DELHI
COMPLAINT NO. Complaint number/Year
IN RE:
Smt. Complainant's name….. COMPLAINANT
VERSUS
Sh. Respondent's name…. RESPONDENT
P.S. Police station
LIST OF DOCUMENTS
| S NO | PARTICULARS | PAGE NO |
|---|---|---|
| 1. | Annexure C-1: Copy of the Aadhaar Card of the Complainant |
| 2. | Annexure C-2: Copy of the WILL of Late Sh. Name of deceased testator |
| 3. | Annexure C-3: Copy of the notice dated Date of newspaper notice published in the newspaper by the Sub-Registrar, Sub-registrar office |
| 4. | Annexure C-4: Original CD of the defamatory video |
| 5. | Annexure C-5: Copy of the registered WILL dated Date of mother's registered will of Smt. Mother's name |
| 6. | Annexure C-6: Copy of the police complaint dated Date of police complaint |
Place:Complainant
Date:Through
Counsel
MOB: Complainant's mobile number
Email: Complainant's email address
IN THE COURT OF THE LD. CHIEF METROPOLITAN MAGISTRATE,
TIS HAZARI COURTS, DELHI
COMPLAINT NO. Complaint number/Year
IN RE:
Smt. Complainant's name….. COMPLAINANT
VERSUS
Sh. Respondent's name…. RESPONDENT
P.S. Police station
CERTIFICATE UNDER SECTION 65B OF THE INDIAN EVIDENCE ACT, 1872
1.I, Deponent's name, W/o Sh. Husband's name of deponent, R/o Deponent's residence, do hereby certify as under:
2.That the video containing the defamatory statements made by the accused is saved on my mobile phone and computer, was in my possession, and a printout was taken from my printer. The same is in my safe custody and has been annexed to the present Complaint by way of a CD.
3.That the computer, printer and mobile phone from which the video was copied onto the CD remained in my lawful custody and control. The computer used for copying the video onto the CD was, at the relevant time, operating properly, and nothing was observed that would affect the electronic record or the accuracy of its contents. The process of copying the video from the computer involved retrieving the data directly from the mobile phone, and the only human intervention was the giving of the copying command.
4.That in the facts and circumstances of the case, this Certificate may be taken as sufficient compliance with Section 65B of the Indian Evidence Act, 1872.
Signature of deponent
IN THE COURT OF THE LD. CHIEF METROPOLITAN MAGISTRATE,
TIS HAZARI COURTS, DELHI
COMPLAINT NO. Complaint number/Year
IN RE:
Smt. Complainant's name….. COMPLAINANT
VERSUS
Sh. Respondent's name…. RESPONDENT
AFFIDAVIT
I, Deponent's name, W/o Husband's name of deponent, aged about Age of deponent years, R/o Deponent's residence, do hereby solemnly affirm and declare on oath as under:
1.That the deponent is the Complainant in the present complaint case.
2.That, being fully conversant with the facts and circumstances of the case, the deponent is competent to swear this affidavit, and the contents of the present complaint have been set out at her instance and instructions. The deponent has read the contents of the complaint and has understood the same in the vernacular.
3.That the reliefs claimed in the complaint are urgent, inasmuch as the Complainant is facing great hardship and has been harassed by the accused.
4.That the facts stated herein are true and correct to the best of my knowledge and belief, and nothing material has been concealed therefrom.
Deponent
VERIFICATION
Verified at Delhi on this Date of verification day of Month of verification, Year, that the contents of the above affidavit are correct and true to the best of my knowledge and belief, that no part of it is false, and that nothing material has been concealed therefrom.
Deponent