To,

The S.H.O
P.S. _________________
SUBJECT- COMPLAINT AGAINST ACCUSED PERSON
NAMELY _____________, S/o- ___________, R/o-
______________________ FOR COMMITTING THE
OFFENCE OF FRAUD UNDER SECTION 318 BNS AND
FOR COMMITTING OFFENCE OF CRIMINAL BREACH
OF TRUST AND USES FILTHY AND ABUSIVE
LANGUAGES TO THE COMPLAINANT AND
EXTENDED THREAT TO COMPLAINANT IF HE TAKES
ANY LEGAL ACTION THEN COMPLAINANT WILL
FACE DIE CONSEQUENCES OF THIS ACT.

Most Respectfully Submitted -

1. That the complainant is a peace loving and law abiding

citizen of India and has been residing at
__________________________________.

2. That plaintiff and defendant had friendly relation with each

other from a very long time and in the starting of
November 2016, the above named accused person
approached to the complainant and requested for friendly
loan of Rs.______ to start the business and on repeated
request of above named accused person, the complainant
could not refuse and sought time for 2-3 days for
arrangement of loan amount required to accused person.
3. That on 15 November 2016, the above named accused
person again approached to complainant and again
requested to provide a friendly loan as accused person was
in urgent need of money and keeping the respect of
friendly relations complainant provided the loan to the
above named accused person and same was given to
accused person in ____________.
4. That the above named accused person had promised to the
complainant to return the loan amount within 1 months.
5. That after passing of 1 month, on 17 December 2016
complainant contacted to the accused person and requested
to pay the aforesaid loan amount of Rs
_______( Rupees_________ Only) as per their assurance
of 1 month but the accused person requested for time of 2
more month to arrange the amount which was duly
accepted by complainant because of friendly relations.
6. That on dated 20.02.2017, the complainant again
approached to the accused person to return the loan
amount but the accused person having no other option left,
gave a cheque of amount of Rs 2,13,560/ (Rupees Two
Lakh Thirteen Thousand Five Hundred Sixty Only) in
favour of complainant and assured to return the remaining
amount of Rs.___________ after 2 months and further
directed the complainant to present the aforesaid cheque
before the concerned Bank for encashment only upon his
direction and the complainant in good faith followed the
same and wait for the accused person direction to present
the aforesaid cheque for encashment.
7. That since 21.02.2017 complainant has been trying to
contract the accused person to take direction for presenting
the cheque before the bank and to demand back his
remaining loan amount but the defendant neither replying
the mobile calls nor Whatsapp messages which shown the
abrupt change in behaviour and malafide intent of accused
person.
8. That on various occasions when the complainant meet with
the accused person and demanded back his remaining loan
amount and seeks for direction to present the aforesaid
cheque in bank but all the time the accused person makes
vague excuses and tried to ignore the complainant and the
complainant in good faith and under friendly relation
avoided this abruptly rude behaviour of accused person
and gave multiple chances to return back the loan amount
but all the efforts gone in vein.
9. That this abruptly rude behaviour of accused person
continuing many years and complainant not take any legal
action against the accused person only due to friendly
relation with the accused person but the accused person
took advantage of polite behaviour of complainant and
despite repeated request made by the complainant, the
accused person fails to make payment of Rs _____ to the
complainant.
10.That on dated 19.09.2024, when the complainant again
approached to the accused person and demanded back their
loan amount then the accused person instead of returning
the loan amount started uses filthy and abusive languages
 to the complainant and also extended flatly refused to
return back the loan amount to complainant by saying
“Tera Paisa Maine Kharch Kar Diya Hain Ab Mai Tujhe
Tera Ek Rupee Bhi Wapis Nahi DoongaTujhe Jo Karna
Hain Karle” and also extended threat to the complainant
if complainant take any legal action against him then the
complainant will face die consequences and then finding
no alternative the complainant dial 100 No. but the police
take no action against the accused person.
11.That it is pertinent to mention here that the above named
accused person committed the offence of Fraud by
dishonestly taken the loan amount from complainant in
sake of friendly relations and later on committed the
offence of criminal breach of trust by criminal breach of
trust of complainant and for using filthy and abusive
languages to complainant and also for extended threat to
the complainant.
12.That the amount of Rs______ is still due against the
accused person and but the accused person fails to make
the payment.
13.That due to above mentioned acts of accused person, the
life of complainant is ruined as hell and complainant suffer
irreparable loss and injury to her emotional well being and
also financial losses it given a torture to the complainant
and his family members.
14.That it is pertinent to mention here that the Applicant/
Complainant and his Family Members also had an
apprehension that the accused persons at any point of time
 may do anything with the complainant and his family
members to satisfied his ego and anger towards the
complainant.

PRAYER

It is therefore kindly be taken stern legal action

against the accused person by registering the FIR against the
above mentioned accused person and protect the legal rights
of the complainant and his family members from the cruel
hands of the above accused person, in interest of justice.

Delhi
Dated: 20.09.2023 Applicant/ Complainant

COPY SUPPLIED TO -:

1. The Chairman, Human Rights Commission, Copernicus

Marg, New Delhi – 11001.
2. Police Commissioner Of Delhi, Jai Road, Delhi – 11001.
3. The D.C.P Distt _______________