Typical Complaint/FIR in 498a (Part 1)

This is an example of a typical complaint made by a 498a wife to the CAW Cell. Such complaints are usually transformed into FIRs verbatim. Rare is the case when an FIR is a modified form of such a complaint. It is not unheard of that a chargesheet was a verbatim copy of the initial complaint.

To the DCP 6th September 20xx
Crime Against Women Cell
New Delhi

Subject – Complaint for torture, cruelty, harassment and dowry demand against husband, mother-in-law, and father-in-law, all residents of house number such and such, so and so colony, New Delhi-1100xx

Respected Sir,
I, Mrs. 498a, got married to husband on xx/yy/20zz at New Delhi. This alliance was through an advertisement given in the newspaper by my mother-in-law. Our meeting was fixed up at such and such location, and on such and such date, our families met each other and I spoke to future husband for only half an hour. In that half hour I was the person who was speaking, my future husband spoke very little. My future husband gave an impression of being an introvert. Since it was a brief meeting and everything appeared to be fine, both the families agreed to the alliance. Also, since it was a second marriage for both me and my future husband, and our families were very keen that things work out. I was also willing to make adjustments, therefore, nothing much was looked into. I have not seen earlier divorce decree of husband and was never given any detail of his earlier marriage. His parents only disclosed that his divorce has recently been finalized. After this meeting I met my husband only on the day of marriage.

Before marriage, my husband never called me on the phone also. I did not feel anything amiss and felt that it was due to his introverted nature. My mother-in-law was however, calling up my mother regularly to know what all purchases had been made and specifically asked my mother to give cash of Rs. 1,00,000/- and at the time of engagement in cash to my husband. She also asked my mother to give at least 2 gold sets in marriage.

Finally we got married on xx/yy/20zz. The marriage function was preceded with an engagement ceremony at such and such venue in such and such location. On such and such date which was on the insistence of my mother-in-law. Since it was a second marriage, I as well as my parents wanted a low-key marriage, but my parents were forced to host this function also. In the engagement ceremony, apart from gold and diamond ring to my husband, the family members of my husband were given gifts and cash as per the demands of my mother-in-law.

The marriage function was hosted by my parents for a baraat of about 200 people at such and such venue in such and such location, New Delhi. At the marriage ceremony also family members of my husband were given gifts and cash as per the demands of my mother-in-law.

Once we reached the matrimonial home at about 11 pm, all the family members including my husband and his parents quickly climbed the stair case and left me behind. I followed everyone and seeing a door ajar with all lights on, entered the house. As we reached home my mother-in-law asked me to hand over the jewellery to her since my parents had not given me an almirah in marriage. I found this a little strange but quietly took everything off except my engagement ring and two gold bangles and handed it over to my mother-in-law. I have not seen the rest of my jewellery since that day. When everyone had left, my mother-in-law told me that my parents should have at least given a Santro car if nothing more. She said that my husband could have gone to his office in a new car after his marriage. I told my mother-in-law that me and my husband can both earn and buy a car.

My husband had no conversation with me that night except this that he was expecting that my parents would give a Santro car at which I kept quiet. He also said that we should have a baby. Even on the first night, before I was shown the bedroom which we had to share, my mother-in-law warned me that if I don't give them a kid then this marriage is finished. Throughout my stay in my marital home my mother-in-law used to abuse me and even slapped me. On the second day of marriage we again went to my parents' house for a phera, when again my parents had to give gifts and cash to my husband and his family as per their demand. That day my mother-in-law asked my mother to hand over all the sagan cash received by me during the marriage and same was handed over to my mother-in-law. This incident left an unpleasant impression in my mind.

On xx/yy/20zz in the morning my husband woke up at 6:30 am to get ready for work, while he abused me, called me names and was getting ready I asked him if he had planned for a honeymoon trip, he point blank said no as I do not like to go out.

No one in my in-laws place cared for me even when I was suffering from fever. On xx/yy/20zz I woke up with fever and I told my husband that I have fever. He did not say anything to me or give any medicine to me. I told my mother-in-law that I have fever. She said that since I was the wife of xyz, his breakfast, lunch and dinner were my responsibility and under all circumstances, I have to cook for him. I started crying and cooked my husband's breakfast and lunch. After sometime I told my mother-in-law that I want to go home for a few days as I am not well. She did not allow me to go. Then I called my father and asked him to come and take me to a doctor. At around 7-7:30 in the evening my parents came and took me to the doctor.

I had to visit a skin specialist on xx/yy/20zz. Since I had taken already appointment with the doctor, I asked my husband to take me to the doctor. He simply refused saying that you may go alone or ask your dad to take you. I again called up my father and requested him to take me to the doctor.

After about 10 days of marriage I wanted money since I had no money at all. I asked my husband to give me some money he refused saying that take money from my mother and not from me. Since I had no money at all with me and wanted to buy a few personal things, I asked my mother-in-law to give me Rs 1000/-. She asked me what all I needed and when I told her she said that Rs 500/- is sufficient and that I should not over spend. She also said that I do not do the household work properly. I was cooking breakfast for all of us. Cooking lunch for my husband and packing it up in the morning and since it was winter time making hot food for my mother-in-law and father-in-law. I was also washing clothes and was kept busy in the kitchen throughout the day by my mother-in-law and was abused whenever I failed to do anything as per her instruction.

My husband has some strange habits. He would eat his breakfast no sooner he woke up in the morning without even brushing his teeth or washing his face. He did not take a bath for days together despite my insistence and was very unhygienic. He would eat his dinner the moment he entered the house after coming home from office around 6-6:15 pm. On xx/yy/20zz when he came home from his office he said that I need egg along with milk. I gave him 2 eggs along with milk after 5 minutes. When he finished eating he asked to give him bread along with milk saying that he did not have milk while he was eating egg. I was surprised to hear all this I told him that you just had milk along with eggs, he said is that so I don't remember. On xx/yy/20zz I saw a lot of medicines kept in my husband's almirah. I asked him about the medicines he said that these are my mother's medicines. I asked why are these medicines lying here. He had no answer for this.

On the next week off again on Sunday this time in the morning I asked him that let's go out for a movie, since xyz cinema is just close by to abc colony. He refused again that I will not go. I asked him the reason of refusal. He said I will not go out in any public area, bomb must be planted outside it and I will die. He would come up with strange reasons to avoid going out which was troubling me since I was made to feel that I was there only to ensure the birth of a child. Thus, he avoided taking me out at all costs for reasons best known to him. I am a regular visitor to the temple in xyz area every Saturday about which I had told my husband on the very first day we had met. Even there he took me only two times (on xx/yy/20zz and xx/yy/20zz) and with great reluctance.

You may also wish to read Typical Complaint/FIR in 498a (Part 2) and/or FIR in 498a Cases and/or Arrest!! (OR Who is Joginder Kumar?) and/or What is the CAW Cell Process After a 498a Complaint is made by a Wife? and/or Conditions at the Women's Police Station and/or Conditions at the Delhi High Court and/or Interrogation and Investigation by the Police in Dowry Cases.

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Published by Manish Udar

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Last updated on 20th September 2013
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