Date: [Insert Date]
From:
Mona Mulla
D/O Salim Khan
Perkit House No. 1-116/A,
Near Bus Stand, Behind Yaseen Hotel,
Pincode 503224
To:
The Station House Officer,
Armoor,
Police Station in Armoor Ho
Pincode 503224
Subject: Complaint under section 316,318 ___ of BNS Regarding Illegal Sale of Co-Owned
Property fraudulently.
Dear Sir/Madam,
I, Mona Mulla D/O Late Salim Khan, co-owner of the property situated at House No. 1-116/A,
near the bus stand behind Yaseen Hotel, would like to bring to your notice a matter of urgent
concern regarding the illegal sale of my co-owned property by my brother, Mr. Alim Khan.
On Oct 17, 2024, I received a phone call from Mr. Alim Khan, who informed me that he
intends to sell the house without my consent. He also mentioned that one Mr. Shaffi, a
businessman, is ready to purchase the house, again, without my will and consent. This
action is in clear violation of my legal rights as a co-owner of the property.
This unauthorized attempt to sell the property is illegal and punishable under the following
sections:
Bhartiya Nyaya Sanhita:
1. Section 316: Criminal Breach of Trust – Mr. Alim Khan's action of attempting to sell the
property without my consent constitutes a breach of trust, as he is entrusted with managing
the property as a co-owner.
2. Section 318: Cheating – The act of attempting to sell the property without obtaining my
consent is an act of deception and fraud, which causes potential harm to my legal rights and
interests.
3. Section ___: Acts done by several persons in furtherance of common intention – If Mr.
Shaffi is involved in the illegal transaction knowingly, both parties may be jointly
responsible.
Section 50 CPC: Protection of Co-Owner's Rights – As per the Civil Code, all co-owners must
provide their consent before any sale of joint property takes place. Selling the property
without consent violates my rights.
Section 52 CPC: Prevention of Illegal Sale of Joint Property – The Civil Code bars any
transaction that attempts to transfer property ownership without the co-owner’s approval.
I am also filing the case under Code of Civil Procedure (CPC):
1. Order 39, Rule 1 & 2: Temporary Injunctions – I request that the honorable court issue an
injunction to prevent the sale or transfer of the property until this matter is legally resolved.
2. Section 151: Inherent Powers of the Court – I request the court to exercise its inherent
powers to prevent any misuse of authority or property rights by Mr. Alim Khan.
In light of the above violations, I request you to take immediate legal action to prevent any
illegal sale or transfer of the property and ensure that my rights as a co-owner are
protected. I am prepared to provide further documentation and evidence as required.
Thank you for your prompt attention to this matter.
