Drafting- Criminal Complaint u/s 500 (Criminal Defamation) sample

IN THE COURT OF CHIEF METROPOLITAN MAGISTRATE DELHI, DELHI

Dr. Kanhaiya Sukumar
Age 30, Phd Scholar, JNU
R/at- Room No 38, B Blok
JNU Campus, New Delhi, 111001

                                                                                                                                  Complainant

                     Vs

1) Shri Sudheer Dalal
 News Editor
 Chee News
 R/at 39 Lutyens Bunglow
Prithviraj Road, 111007

2) Shri Rohit Dalal
News Editar
Fraud Tak
R/at 40, Lutyens Bunglow

                                                                                                                                     Accused

                                                                                                                   Criminal Complaint U/s 
                                                                                                                   U/s 500 of IPC


          The complainant above named begs to state as under-:
  1. That the Complainant was part of rally organized for student election in Delhi University in September 2016.

  2. That the speech was delivered by complainant on evils of caste and communalism

  3. That the video was shot by students on mobile of that speech

  4. That the journalists of Chee News and Fraud Tak were present during speech, who recorded a speech

  5. That the recorded speech later was doctored by News channel and complainant was shown to shout some slogans like "Pakistan Zindabad".

  6. That the complainant affirm on oath that no such slogans were shouted.

  7. That the accused then aired those doctored video to show complainant in bad light

  8. That the accused are news anchors with an agenda in the garb of journalism due to their preference for certain political ideology

  9. That this complainant thereafter lodged a criminal complaint against the accused in Lutyens Police station against these news anchors.

  10. That the cause of action for this complaint first arose on 4 September 2016 and hence, this complaint filed today is well within limitation.

  11. That the offence has been committed within the local limits of the jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to try and decide this complaint

  12. That the complainant therefore, prays that the accused be kindly charged with and tried for the offence punishable u/s 494 R/W 500 of the Indian Penal Code and punished according to law.


 New Delhi:                                                                                                             Sd/-
Dated:   /   / 2016                                                                                       (Kanhaiya Sukumar)
                                                                                                                    Complainant   



                                                  VERIFICATION

I Kanhaiya Sukumar, Age 30 years, R/at Room No 38, B Block, do hereby state on solemn affirmation that the contents of above complaint are true and correct to best of my knowledge and belief and hence I have signed it today on the above mentioned date at Pune.
                                                                                                                      
                                                                                                                               Sd/-
                                                                                                                      (Kanhaiya Sukumar)

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