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MEMORANDUM OF CRIMINAL ORIGINAL PETITION

(Filed Under Section 482 of Criminal Procedure Code)

IN THE HIGH COURT OF JUDICATURE AT MADRAS

MADRAS MADURAI BENCH. MADURAI

(Criminal Jurisdiction)

Crl.O.P. (MD) No of 2013

In

C.S.R. No. 474 /2018

(On the file of the Respondent Police)

Chellammal FM/26
D/o C. Mani,
90/9, Ganesapuram,
Nayakkar Street,
Karaikudi,
Sivagangai ---- Petitioner

Vs

The State rep by

1. The Superindent of Police,

Sivagangai District,
Sivagangai
2. The Inspector of Police,
All Women Police Station,
Karaikudi,
Madurai. ---- Respondent / Complainant

PETITION FOR REGISTRATION OF F.I.R.

The Address for Service of all process and notices on the Petitioner

is that of his councel is M/s Santhiveeran Law Office,

A.S. MURUGAN M.A.B.L., Santhiveeran Illam, at No. 1,

Subramaniyapuram 4th Street, Madurai 625 011.

The address for service on the respondents is as stated above.

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The Petitioner begs to submit as follows :-

1) The Petitioner respectfully submits that she is a Law abiding

citizen and she is hailing from a respectable family and aged about 26

Years. On the Strength of a Complaint lodged by the respondent No. 2,

All Women Police Station, The Inspector of Police in

C.S.R. No. 438 /2018, C.S.R. No. 474 /2018 and another one Petition

sent as Speed Post by the Petitioner, the respondent Police have not take

any action so far.

2) It is submitted that the Petitioner is Currently lives in his Father’s

House. The Petitioner was married about eight years ago with N. Mani

in front of their Parents. On that time, The Parents of Son-in-Law

approached the Petitioner’s Parents to gave them a 25 pounds Gold

Jewels as Dowry. But, Due to the Poverty, Petitioner’s Parents gave 13

Pounds as Dowry. After a week of completing marriage, The

Petitioner’s Husband scolded her, “you must bring balance jewels from

your Father”. Also, The Petitioner’s Husband was brutally beats his wife

(Petitioner) for that above mentioned Jewels problem. On that situation,

the Petitioner has one baby boy. After that, The Petitioner’s Husband

was brutal to his wife (Petitioner). But the Petitioner did not take any

violence for his Husband’s Horrible activities, because the Petitioner

only thoughts her son’s future.

3) As they (The Petitioner Husband’s family) sent Petitioner to her

father’s House to bring a money for build a New House. The Petitioner
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told that incidents to her Father. The Petitioner’s Father mobilized Rs.

90,000/- (Ninety Thousand Only)from surroundings by think about my

life and also the Petitioner’s Father gave that amount to the Petitioner

and sent her to her Husband’s House.

4) Again, the Petitioner’s Husband tortured her to gave her 13 pounds

Gold Jewels to him for build New House. Hence, the Petitioner gave her

total dowry jewels to her Husband. But the above mentioned 13 pounds

Gold Jewels did not return to the Petitioner then.

5) On that Situation, The Petitioner’s Husband have an adultery to the

neighbor house lady. Her Name is Kanmani. Also The Petitioner’s

Husband Continuosly tortured the Petitioner by listening Kanmani’s

Utterance. So, the Petitioner get fear and went to his Father’s Home.

Hence the Petitioner devotes his life for caring her father and keep her

son to study education and also she lose her Jewels, food, shelter and

also her whole life and finally she got a depression. So, she filed a

petition on 30-09-2018 in All Women Police Station

(CSR No. 438/2018) to get a solution to recover her Husband from

Kanmani.

6) Hence, The Police gave a solution to the Petitioner by The

Petitioner’s Husband told that he don’t affair with kanmani and also

caring well his wife and his son. But after they went to home, The

Petitioner’s Husband continued to torture Petitioner and also asked how

she filed a petition against him. And he continuously tortured her and
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tends her to suicide by told her , “you go outside and leave me alone; or

you would die”. Moreover, by Kanmani and her mother

Muthu (w/o Raman) tends Petitioner’s Husband, On 12-10-2018 at the

time of 6:30 pm, The Petitioner’s Husband drunk and induce Petitioner

for Unnatural Sex. The Petitioner told with cry that she did not do it.

But, The Petitioner’s Husband strangled the Petitioners neck to

murdered her and also told, “No! you must do it like a Prostitute!”.

Hereby The Petitioner was unable to bear the torture from her husband,

She went to her Father’s House and got a First Aid in Karaikudi Govt.

Hospital. Hence The Petitioner and her son would face any peril at

anytime.

It is therefore prayed that this Hon’ble Court may be pleased to

direct the 2nd respondent herein to register the case on the basis of the

complaint given by the Petitioner dated 30-09-2018 in accordance with

law and conduct the investigation as against the accused persons and

pass such other orders as this Hon’ble Court may deem fit and proper in

the circumstances of the case and thus render justice,.

Dated at Madurai on this 27th day of November, 2018.

COUSEL FOR PETITIONER