How to write a Police Complaint — to be treated as FIR — u/s 154 of CrPC, 1973
The characters, situations, and incidental criminal offences are purely fictitious and bears no resemblance or relevance to real world people, place or any law enforcement bodies. This is a sample article used for legal eductational and awareness purpose only.
Scenario-1, the following offences under the Indian Penal Code (IPC), 1860 has been identified:
1. Assault and Criminal Force (Sections 323 and 352 IPC): Tara and her husband, Raj, committed assault by beating Mrs. Reena Mathur with a stick, which falls under Section 323 (Punishment for voluntarily causing hurt) of the IPC. Additionally, the use of force and the act of forcefully taking Mrs. Mathur’s thumb impressions on blank papers constitute criminal force, attracting Section 352 (Punishment for assault or criminal force otherwise than on grave provocation).
2. Theft (Section 379 IPC): Tara and Raj’s actions of stealing 4 gold bangles and 5 lakh cash from Mrs. Mathur’s room constitute theft under Section 379 (Punishment for theft) of the IPC.
3. Making Sexually Coloured Remarks (Section 509 IPC): The sexually coloured remarks made by Mr. Raj Lakadwala, husband of Mrs. Tara Lakadwala, fall under Section 509 (Word, gesture, or act intended to insult the modesty of a woman) of the IPC.
4. Criminal Intimidation (Section 506 IPC): The torture and harassment by the step-daughters and their husbands with the intention of usurping Mrs. Mathur’s assets could potentially amount to criminal intimidation under Section 506 (Punishment for criminal intimidation) of the IPC.
5. Conspiracy (Section 120B IPC): If it can be established that the daughters and their husbands conspired to torment Mrs. Mathur for financial gain, they could be charged under Section 120B (Punishment of criminal conspiracy) of the IPC.
Scenario-2, the following offences under the Indian Penal Code (IPC) can be attarcted:
1. Assault (Section 351 IPC): Neeraj’s sudden attack on Dheeraj during the altercation constitutes an assault under Section 351 (Assault) of the IPC.
2. Voluntarily Causing Hurt (Section 323 IPC): The injuries inflicted on Dheeraj during the fight fall under Section 323 (Punishment for voluntarily causing hurt) of the IPC.
3. Grievous Hurt (Section 320 IPC): If the injuries sustained by Dheeraj, including the broken tooth, are severe, Neeraj could be charged with grievous hurt under Section 320 (Punishment for grievous hurt) of the IPC.
4. Criminal Intimidation (Section 506 IPC): Neeraj’s attack could be considered a form of criminal intimidation, invoking Section 506 (Punishment for criminal intimidation) of the IPC.
5. Obstruction of Justice (Section 195 IPC): The act of influencing the refusal to lodge an FIR by Neeraj may amount to obstruction of justice under Section 195 (Giving or fabricating false evidence with intent to procure conviction of capital offense) of the IPC.
6. Abetment (Section 107 IPC): If Neeraj had assistance or encouragement from others in carrying out the attack, they may be charged with abetment under Section 107 (Abetment of a thing) read with Section 351 (Assault) of the IPC.
Here, we shall draft a police complaint — also information to police to be treated as First Information Report, FIR u.s 154 of CrPC, 1973.
To
SHO, Byculla, PS,
Mumbai- 400001
Maharastra
Subject: Complaint against Tara, Raj, and Others for Assault, Theft, and Harassment
Dear Sir,
I, Mrs. Reena Mathur, the victim in the matter, through my counsel, Mr. Harsh Mathur, am writing to bring to your attention a series of criminal acts committed against me by my stepdaughters, Tara, Zara, Teena, Riya, Jaya, Taruna, Seema, and their husbands, specifically Tara’s husband Raj Lakadwala. I am a senior citizen residing at 801, Bombay Towers, Byculla, Mumbai 400001.
I got married to Mr. Raj Mathur in 1995, and he passed away recently, leaving behind seven daughters from his first marriage, now my stepdaughters.
Following Mr. Mathur’s demise, my stepdaughters, along with their husbands, have subjected me to harassment and torture with the intention of usurping my assets.
On 15th October 2022, Tara and her husband Raj visited my residence, physically assaulted me by beating me with a stick, forcefully obtained my thumb impressions on blank papers, and stole 4 gold bangles along with 5 lakhs in cash. The next day, Mr. Raj Lakadwala called me and made sexually coloured remarks, further intensifying the mental trauma. Considering the severity of the situation, I, with the assistance of my relative Mr. Harsh Mathur, approached the police on 15th November 2022 to file this FIR.
I kindly request you to take immediate action on this matter and register an FIR against Tara, Raj, and others involved, for offences under relevant sections of the Indian Penal Code, including but not limited to:
· Section 323 (Punishment for voluntarily causing hurt)
· Section 354 (Assault or criminal force to woman with intent to outrage her modesty)
· Section 379 (Punishment for theft)
· Section 506 (Punishment for criminal intimidation)
· Section 509 (Word, gesture, or act intended to insult the modesty of a woman)
I am providing this complaint to ensure the safety and justice for myself, a vulnerable senior citizen who has been subjected to physical assault, theft, and mental harassment.
Your prompt attention to this matter is requested, and I trust that you will initiate the necessary legal proceedings.
Thank you for your cooperation.
Sincerely,
Mrs. Reena Mathur
Copy to:
The Commissioner of Police, Mumbai
