IN THE COURT OF THE ADDITIONAL CHIEF

METROPOLITAN MAGISTRATE (ACMM) AT BENGALURU

IN PCR NO. OF 2022

IN CC NO. OF 2022

Ms. Shweta Rao COMPLAINANT

Vs

Mr. Ramesh Iyer ACCUSED

INDEX

Sl. Description Pages

No.
1 Memorandum of Complaint u/s 200 CrPC
2 List of Documents along with Documents
3 Vakalathnama
Place: Bengaluru
Date: 04.05.2022 Advocate for Complainant

IN THE COURT OF THE ADDITIONAL CHIEF

METROPOLITAN MAGISTRATE (ACMM) AT BENGALURU

IN PCR NO. OF 2022 IN

CC NO. OF 2022

Ms. Shweta Rao

 Aged about 25 years
D/o Mr. Rakesh Rao
R/a Flat No. 325, M W Apartments,
2nd cross, K S circle,
J p Nagar, Bangalore – 560078
Email: swetarao@gmail.com
PH No: +91 7975615833 COMPLAINANT

Vs

Mr. Ramesh Iyer

Aged about 27 years
S/o Mr. Mahesh Iyer
R/a #63, SW Apartments,
3rs cross, 1st Phase
JP Nagar, Bangalore – 560078
Email: ramesh23@gmai;.com
Ph No: +91 9243010011 ACCUSED

COMPLAINT UNDER SECTION 200 CODE OF CRIMINAL

PROCEDURE 1973, READ WITH SECTIONS 352, 354, 354D AND
SECTION 509 OF THE INDIAN PENAL CODE, 1860

The Complainant humbly states that:

1. The address of the Parties for the purpose of service of summons through
this Hon’ble Court is as stated above. Summons to the Complainant may
also be served through his Counsel Kumari Krina H Kotecha, Advocate,
#505, 5th Floor, Prestige Elevita, 3rd cross road, MG Road, Bengaluru
560001, Phone +91 9341010011, email krina.corposis@gmail.com.

2. The Complainant, Sri. Sweta Rao works as an Associate at Henchwick Co.

and lives in Flat No. 325, M W Apartments, 2nd cross, K S circle, JP Nagar,
Bangalore – 560078.. The address proof of the Complainant is enclosed
herewith as Document No. 1.

3. The Accused lives in #63, SW Apartments,3rd cross, 1st Phase, JP Nagar,

Bangalore – 560078, Bellandur, Bengaluru 560103. The address proof of the
Accused is enclosed herewith as Document No. 2.
4. On 05.02.2019, around 10 pm IST, the Complainant was returning back
from work, when she suddenly felt the presence of someone following
her. Initially, she was unsure of his identity, however, later after seeing him
a couple of times around her neighbourhood, she figured out his identity
and residence, taking the assistance of some of her neighbours.
However, the accused continued to stalk her persistently, following her to
various places, and making unwarranted advances.

5. Following the above events, on 15.02.2019, when the Complainant was

returning from work, the accused suddenly appeared in front of her,
resisting any further movement of hers. As the complainant tried to resist
the accused's unwelcome advances, he verbally threatened her with
assault and harm if she did not accept his proposal. Despite the
complainant's explicit refusal and objections, the accused continued to
harass her with menacing threats, creating an atmosphere of fear and
distress.

6. Subsequently, in a culmination of the above distressing situation, the

accused physically attacked the complainant when she continued to resist
his advances. The assault involved various acts of physical assault such
as hitting the Complainant, slapping her and pushing her against the wall,
causing significant physical harm and injury to the complainant, for which
she had to receive medical help and treatment.

7. Following these events, on 31.08.2019, the Complainant approached the

jurisdictional JP Nagar Police Station vide complaint dated 21.02.2020,
which was not even acknowledged by the police. The copy of the
complaint is at Document No. 3. Thereafter, the Complainant had
approached the Deputy Commissioner of Police, JP Nagar; and also the
Commissioner of Police, Bengaluru, who acknowledged the complaints.
The copies of the acknowledgments are attached as Document No.4
dated 22.02.2020 and Document No.5 dated 24.02.2020 respectively.

8. Details of specific offences committed by the Accused, are as

follows:

As under Indian Penal Code, 1860

a. Sec 352 & 354: The Accused had been constantly following the
Complainant and has been making unwanted advances towards
her. The Accused has not only assaulted the Complainant mentally,
but also physically. The accused also threatened her with assault on
resisting his unwelcomed behaviour and rejecting his proposal,
creating an atmosphere of distress and fear, and causing significant
 physical harm and injury to the Complainant, thereby committing the
crimes of assault, use of criminal force and outraging her modesty
as described under the above sections in the IPC.

b. Sec 354D: The Accused, from the date above mentioned, started
following the Complainant and stalking her. He constantly tried to get
in contact with her, he did so persistently even after clear indication of
disinterest, causing fear and distress to the Complainant, thereby
committing the crime of Stalking as described in the IPC.

c. SEC 509: the Accused would time and again utter insulting words
and make certain gestures and invade her privacy, thus making her
feel uncomfortable and unsafe, thereby committing the crime of
insulting the modesty of a woman as described in the IPC.

9. The Accused is currently residing at #63, SW Apartments, 3rd cross, 1st

Phase JP Nagar, Bangalore – 560078 from where the acts of theft and
other offences as detailed above were committed by her. The offences
made out in this complaint took place at Bengaluru within the jurisdiction
of this Hon`ble Court.

10. From the above instances, it is clear that even after the Complainant
approached the jurisdictional JP Nagar police station, the jurisdictional DCP,
JP Nagar, and the Commissioner of Police Bengaluru City, no action was
taken. Each time the Complainant approached the aforementioned police
officers, they refused to take action stating that the facts are merely
presumptive in nature, the apprehension of which could be resolved amicably
by just speaking to the accused and that no real threat exists and therefore, no
action has been taken by any of them. The police officials refused to entertain the
complaint. The Complainant is therefore left with no other option but to
approach this Hon’ble Court for justice, in accordance with law.

PRAYER

THEREFORE, the Complainant prays that this Hon`ble Court may be

pleased to:

a. Register this complaint against the three Accused persons and take
cognizance of the offences punishable under sections 352, 354,
354D and 509 of The Indian Penal Code 1860, by securing the
Accused before this Hon`ble Court and protection from any potential harm
from the accused during investigation, conducting a fair trial, and
 punishing the Accused with the maximum possible sentence, in
accordance with law, and;

b. Grant such other relief/s in the circumstances of the case, as deemed

appropriate by this Hon’ble Court, in the interest of justice and equity.

Bengaluru
04.05.2022 Advocate for ComplainantComplainant

List of Witnesses:

1. Complainant
2. The names of other witnesses will be furnished in due course.

VERIFICATION

I, Shweta Rao, the Complainant in above named submit that whatever is

stated in the above paragraphs is true and correct to the best of my
knowledge, information and belief.

Bengaluru
04.05.2022 Complainant
 IN THE COURT OF THE ADDITIONAL CHIEF
METROPOLITAN MAGISTRATE (ACMM) AT BENGALURU

IN PCR NO. OF 2022 IN

CC NO. OF 2022

Ms. Shweta Rao COMPLAINANT

Vs

Mr. Ramesh Iyer ACCUSED

LIST OF DOCUMENTS

ocument No.
Description Pages
1 Address proof of the Complainant
2 Address proof of the Accused
3 Copy of complaint
4 Copy of acknowledgement by the Deputy Commissioner of
Police, JP Nagar
5 Copy of acknowledgement by the Commissioner of Police,
Bengaluru

Place: Bengaluru
Date: 04.05.2022 Advocate for Complainant