IN THE COURT OF CHIEF JUDICIAL MAGISTRATE / CHIEF METROPOLITAN MAGISTRATE
COMPLAINT NO. ……. OF 20…. UNDER SECTION 12 OF THE PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

P/S: In the matter of:

Smt. [Complainant’s Name]
W/o Late Sh. [Husband’s Name]
R/o [Address of the Complainant]

VERSUS

Sh. [Respondent’s Name]
S/o [Father’s Name]
R/o [Address of the Respondent]

COMPLAINT UNDER SECTION 12 OF THE PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005

To,
The Hon’ble Chief Judicial Magistrate / Chief Metropolitan Magistrate,
[Name of Court],

The humble petition of the Complainant above-named most respectfully submits as under:

FACTS OF THE CASE

1. Parties to the Complaint:
   The Respondent is the father-in-law of the Complainant. The Respondent has subjected the Complainant to acts of harassment and domestic violence, intending to evict her from her lawful residence in the matrimonial home.

2. Marriage and Family Details:
   The Complainant was married to Late Sh. [Husband’s Name] on [Date of Marriage] as per Hindu rites and ceremonies. After marriage, the Complainant resided in the matrimonial home, which was a joint family property, along with the Respondent. Two children were born out of the wedlock:

   S. No.	Name of Child	Relation	Age	Current Status
   1	Master [Name]	Son	[Age]	Studying in Class [Class]
   2	Baby [Name]	Daughter	[Age]	Studying in Class [Class]

3. Employment of Deceased Husband:
   Before his demise on [Date of Death], Late Sh. [Husband’s Name] was engaged in the business of manufacturing and trading auto parts under the name M/s [Business Name], operating from a rented factory at [Address].

4. Misappropriation by the Respondent:
   Post the death of the Complainant’s husband, the Respondent unlawfully misappropriated the machinery, tools, raw materials, and other assets from the factory. He also trespassed into the shop owned by the deceased husband and denied the Complainant access to the premises.

5. Economic Harassment:
   The Respondent has taken over the shop and refuses to pay any monetary support to the Complainant, leaving her destitute. The Complainant, who is financially dependent on the income from the shop, is unable to meet her basic needs and those of her children.

6. Abuse and Threats:
   The Respondent frequently subjects the Complainant to verbal abuse, using obscene language. He has also issued threats to forcibly evict her from the second floor of the property and seize the premises.

7. Impact on Health and Safety:
   The Respondent’s actions have adversely affected the physical and mental well-being of the Complainant and her children. He has even expressed his intention to send the children to an orphanage if the Complainant fails to vacate the property.

CAUSE OF ACTION

The Respondent’s continuous acts of harassment, economic deprivation, and threats constitute domestic violence under the Protection of Women from Domestic Violence Act, 2005, thereby necessitating the present complaint.

RELIEFS CLAIMED

In view of the facts and circumstances, the Complainant humbly prays for the following reliefs under the Protection of Women from Domestic Violence Act, 2005:

1. Protection Order (Section 18):
   A direction restraining the Respondent from interfering in the possession of the Complainant in respect of the property, including the second floor and the shop on the ground floor of Property No. [Property Details].

2. Residence Order (Section 19):
   A direction restraining the Respondent from dispossessing the Complainant from the second floor of the property and interfering with her peaceful possession of the shop and other parts of the property as specified in the site plan.

3. Monetary Relief (Section 20):
   A direction to the Respondent to pay Rs. 25,000/- per month towards:

   • Basic necessities: Rs. 15,000/-
   • Educational expenses for the children: Rs. 10,000/-

4. Compensation Order (Section 22):
   An order directing the Respondent to compensate the Complainant for the mental agony, emotional distress, and physical suffering caused by his unlawful acts, as deemed fit by this Hon’ble Court.

PRAYER

It is, therefore, most respectfully prayed that this Hon’ble Court may kindly be pleased to:

1. Grant the reliefs as claimed above under Sections 18, 19, 20, and 22 of the Protection of Women from Domestic Violence Act, 2005.
2. Pass such other orders as this Hon’ble Court may deem fit and proper in the interest of justice.

Complainant
Through Counsel

Verification
Verified at [Location] on this [Date] day of [Month, Year] that the contents of paragraphs 1 to [Number of Paragraphs] of the above complaint are true to the best of my knowledge and belief. Nothing material has been concealed therefrom.

Complainant

(To be accompanied by an affidavit)