Complaint for Defamation

 IN THE COURT OF JUDICIAL MAGISTRATE FIRST CLASS ___________________________

 Cri. Case No ___________of 20)_________________

 

C___________ ___________________

_______________________________________________________________________________Complainant 

v. 

___________________________________________________Accused 

Offences under Sections 500,501.1.P.C.

 

May It Please Your Worship,

The above named complaint states as under: 

1. That the complainant is a respectable resident of ____________

(Name of Place), and carries respect in the city.

2. That the accused a transporter having a fleet of trucks, is a resident of__________________.(Name of Place) and has affiliations with the leader of Pradesh Congress party. 

3. That the complainant is a ____________________and as such is in the highest esteem.

4.That the complainant  _________________________________.

5. That there is political rivalry between the complainant and the accused for the last about ten years. 

6. That the complainant is also a prospective  _____________________ ________________. 

7.  That with a view to defame, malign and lower down the image of the complainant ____________________________intentionally made the false imputation to harm the reputation of the complainant. 

8. That the accused got the defamatory hand bills published on__________________ under hi signature ______________,

(Name of Place) . The hand-bills contained imputation showing the complainant as 'robber', 'brothel keeper' and 'smuggler' know­ing full well that these imputations are complainant's character assassination and are false, shall definitely lower down the public image of the complainant. The accused got them intentionally published, circulated and pasted on the walls of______________________________.

9.  That the imputations are false and intentional and have actually lowered down the image and character of the complainant in the public at large and party workers in particular. 

10. That in the aforesaid circumstances the accused has committed the offence of defamation punishable under section 500 and 501 of the Indian Penal Code. 

11. That the complainant prays that the Hon'ble Court may be pleased to issue necessary process against the accused so that he may be dealt with according to law. The complainant craves leave of the court to produce documents and witnesses when required. 

Solemnly affirmed as aforesaid. 

Dated ___________________at_________________ (Name of Place). 

Complaint drawn by                                                                             Sd/- 

Sd/-                                                                             Complainant 

Complainant's Advocate. 

IN THE COURT OF JUDICIAL MAGISTRATE FIRST CLASS,______________

Criminal Complainant No_________________

 

C(Complainant'sBriefDescription)________________________________________________                                     

_________________________________Complainant 

v. 

A (Accused's Brief Description)__________________________                _______________________________Accused 

 

Offence under Sec. 500 of I.P.C.

 

May it please your Worship, 

I, the above named complainant, beg to state on solemn affirmation as follows that: 

1. I have been serving in the Deputy Commissioner's office at (Name of Place); and I carry a very high reputation as honest employee of the office. I know the accused as my neighbour for the last five years. 

2.  On the ___________ when I was talking with my colleagues in the lunch time in my office, the accused suddenly reached there and started calling me as "Gunda, Robber and Brothel Keeper" and further asked me "to return at once the amount of Rs. _____________that I have given you." 

3.  I have tried to convince the accused that I have not committed any theft or robbery and therefore he must not impute such baseless and absurd allegations against me, but he was not satisfied and he again said "Give my money immediately otherwise you will face dire consequences." 

4.  On the____________________ the accused came to my office at ____________________a.m. and distributed written pamphlets to all the employees of my office. The pamphlets contained the aforesaid scandalous remarks against me and also my caricature escorted by police. One pamphlet is annexed hereto and is marked as Exhibit 'A'. 

5. The imputation made by the accused is false and baseless. The accused has made the imputation with a view to malign and injure my reputation in my office. 

6.  I have suffered a loss of reputation and mental agony due to the above false imputation alleged against me by the accused. As a result of this false imputation my colleagues shun, avoid sitting and talking with me. 

7. The accused has been residing at.....which is within the local limits of this Court, therefore, this Hon'ble Court has jurisdiction to grant appropriate relief in the interest of justice. 

8. I, therefore, submit that the accused has committed the offence punishable under Section 500 of the Indian Penal Code and the Hon'ble Court may be pleased to issue strict process against the accused so that he may be dealt with according to law. Solemnly affirmed as aforesaid at ___________________________

Sd/- 

This____________________ Complainant 

Exhibit 'A' and witnesses.