Professional Documents
Culture Documents
S.H.O.
Police Station
xxxxx xxxxx,
New Delhi
Sub:- Request for registration of case against Smt. xxxxxx and accomplices
Respected Sir
It is submitted that undersigned got married on xx-xx-xxx with Smt xxxxxxx d/o
xxxxxxx R/o address as per Sikh rituals. Ours was a love marriage after a courtship of 7
yrs. which took place after my mutual consent divorce from my first wife due to
inducement /interference on the part of Smt. xxxxx in our married life. Two children
Master Meet aged 5 yrs and Master Parinit 3 yrs were born from this marriage which
are in the custody of Smt. Xxxxxxxxx. Soon after our marriage Smt. Xxxxxxxxx started
abusing and quarrelling with me on one pretext or the other. To resolve the matter and to
save our marriage I requested in person as well as by way of written submission to the
concerned authorities /officers (Annexure A, Annexure B). But nothing solved our
problems and because of this tension/harassment I got suffered from High Blood Pressure
due to Left Ventricular Hypotrophy (LVH) in my heart and now living on medicines. Smt.
Xxxxxxxxx is of indifferent nature women whose behaviour towards married life was
highly irresponsible as she has no interest in daily household works, cooking, taking care
of children and being social. On 04/10/2007 due to her above mentioned habits she has
mercilessly beaten the minor child Meet, and on enquiring her about the same, she made
quarrel with me and left for her parents home without any reasonable cause and filed a
false complaint in the CAW Cell, Nanak Pura, New Delhi vide no. nnn/2007. Being
employee of Delhi Police, the law and enforcement organisation and remained posted in
CAW Cell, Nanak Pura for more then 5 yrs and by virtue of her experience and
knowledge, she grossly misused the law with the help of Insp. Xxxxxxxxx and Insp.
Xxxxxxxxx, who accomplice her with ulterior motives best known to them. They over
ruled all the laws and regulations despite the instructions in the circular 07/2007 dated
23/03/2007 issued by Commissioner of Police which are evident from the followings:1. List of Stridhan submitted by Smt Xxxxxxxxx (Attached as Annexure C) was not
maintainable as it was not as per Rule 2 of Dowry Prohibition (Maintenance of
List of presents to the bride and bridegroom) Rules of 1985 and is direct
violation of law by Smt. Xxxxxxxxx and hence the same was false and fabricated
which was not even cared by Insp. Xxxxxxxxx, I.O. (the then) of CAW Cell,
Nanak Pura.
2. The undersigned requested in writing (Annexure D) to Joint. C.P., Caw Cell, to
ask Smt. Xxxxxxxxx to submit bills for genuineness of claims of her list of Stridhan
but Insp. Xxxxxxxxx neither cared nor Smt. Xxxxxxxxx submitted any bills to the
satisfaction of the undersigned for her claim and she managed to extort all items
which undersigned has handed over all the items to Smt. Xxxxxxxxx vide list
dated 07/12/2007 (Annexure E).
3. Despite the clear direction /orders of Honble High Court CRL.M.C.7262/2006
dated 23/02/2007 (Annexure 1) and Commissioner of Police Circular no. 07/2007
dated 23/11/2007 (Annexure 2) which states that where there is expenditure of
a huge amount of money without disclosing the source of income , police
should insist upon compliance of Rule 2 of dowry Prohibition (Maintenance of
lists of presents to the Bride and Bridegroom ) rules , 1985 and should not
entertain any complaint if the rules have not been complied with . The source
of income was not verified from the income tax returns of Smt. Xxxxxxxxx, Sh.
Xxxxxxxxx(Father) and Sh. Xxxxxxxxx (Brother) and Smt. Xxxxxxxxx
(Mother). The ruling of the Honble High Court order mentioned above has been
violated and the same was ignored by the I.O. Insp. Xxxxxxxxx and Insp.
Xxxxxxxxx and on their recommendations FIR No. nnn/2008 under section
498A/406/34 of IPC has been registered in Police Station Dabri against
undersigned and his relatives. IPC 406 was intentionally invoked with malafied
intention to frame undersigned even when there is no allegation in FIR regarding
Stridhan not returned. Even the 498A is being registered merely on the statement
of Smt. Xxxxxxxxx where no MLC or other record of any grave injury was
specifically stated by the complainant and hence the FIR is false(Annexure F)
and is an effort to convert failed marriage into a criminal case against undersigned
and his relatives.
4. Smt. Xxxxxxxxx has submitted one complaint dated 25/01/2008 in the office of
Commissioner of Police (Annexure G) in which she admitted that she and her
parents had given dowry to the undersigned. Therefore as per the direction of
Honble High Court CRL.M.C.7262/2006 dated 23/02/2007 and also Circular no.
07/2007 dated 23/11/2007 issued by Ld. Commissioner of Police, Delhi, Smt.
Xxxxxxxxx, her father Sh. Xxxxxxxxx, Mother Smt. Xxxxxxxxx also become
accomplices under section 3 of dowry Prohibition Act, 1961 and appropriate
action should also be taken against them.
5. It is further submitted that WHC Smt. Xxxxxxxxx has already performed gross
misconduct by misusing the Govt. Loan for two wheeler as she had taken a
scooter loan during her posting in CAW Cell, Nanak Pura, New Delhi in the
month of March 2003 but neither purchased any scooter nor intimated the same to
the department (Annexure H :- Salary Slip showing deduction of scooter advance
and Annexure I: RTI reply from PIO, CAW Cell, Nanak Pura, New Delhi) and
hence she is also liable for action under CCS conduct Rules.
6.
Therefore you are requested to kindly register the case for being congnizable
offence ouccrred as per the direction of Honble High and take necessary action
against Smt. Xxxxxxxxx, her father Sh. Xxxxxxxxx, her mother Smt.
Xxxxxxxxx , Insp. Xxxxxxxxx and Insp. Xxxxxxxxx of CAW Cell, Nanak Pura
and Sub Inspector Xxxxxxxxx of P.S. Dabri for Contempt of Court Order and
Gross negligence in performing Govt. Duties and under section 3 of Dowry
Prohibtion Act along with sections 120B, 177, 182, 191, 192, 193, 194, 195, 196,
199, 200, 209, 211, 383, 388, 406, 464 506 and 34 of IPC.
immediately in the case any cognizable offence is reported without starting any
enquiry on the information received as per following orders:-
31. at the stage of registration of a crime or a case on the basis of the information
disclosing a cognizable offence in compliance with the mandate of section 154(1) of the
Code, the concerned police officer cannot embark upon an enquiry as to whether the
information, laid by the informant is reliable and genuine or otherwise and refuse to
register a case on the ground that the information is not reliable or credible. On the other
hand the officer in charge of a police station is statutorily obliged to register a case and
then to proceed with the investigation if he has reason to suspect the commission of an
offence which he is empowered under Section 156 of the Code
to investigate..
c.
to
the
complaints,
within
twenty
four
hours
of
Attachments :
xxxxx
xxxxx xxxxx
Annexure: 1, 2 and A to L
Copy to :1. Secretory, M.H.A., North Block, New Delhi.
2. DCP, South West Distt.
2. S.H.O. Police Station Dabri
Address