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Amreen Ocr

The document outlines a legal case involving a complaint filed by Amreen against Mustaq Ahmad under section 356 of BNS, alleging defamation and character assassination through false statements made on social media. The complaint details various instances of slander and the impact on the complainant's reputation and personal life, including the jeopardy of her upcoming marriage. The document includes necessary information about the parties involved, their legal representatives, and the requested legal actions to be taken by the court.
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© © All Rights Reserved
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0% found this document useful (0 votes)
86 views19 pages

Amreen Ocr

The document outlines a legal case involving a complaint filed by Amreen against Mustaq Ahmad under section 356 of BNS, alleging defamation and character assassination through false statements made on social media. The complaint details various instances of slander and the impact on the complainant's reputation and personal life, including the jeopardy of her upcoming marriage. The document includes necessary information about the parties involved, their legal representatives, and the requested legal actions to be taken by the court.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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()

CASE INFORMATION FORMAT


DISTRICT Pt - ¢ aat Crimlnalb
AN
/ APPE
PLAINTIFF / PETITIONER / COMPLI TT / DECREE HOLDER ETC.
LLAN
PLEASE FILL UP ALL THE RELEVANT FIELD & (*) FIELDS ARE MANDATORY)
S.
No.|
1 | Name of the Pliantiff /| fryeen
Complainant/ Etc.
2 | SloWl/o Dlo
3 | Address K] th,,H Bihay PRATI . OAMA NAGAR
Delhi :

4 | Aadhar Card No. Pin Code:

5 | Gendel | Male O Femal@ Other


T T INDIAN
Nationality [_IN LAAN
ender
6 [ Date of Birth / / Age
7 | Mobile No. e-mail:
8 | Act/Section 356 BNS
9 o " Court Fee Ascetained:
Valuati on of Suit Court Fee paid / Deposited:

10 | Police Station In Criminal Matters only

11 | FLR. No. & Year In Criminal Matters only

s, FIELD & (') F


DEBATER ETC.
DEFENDANT / ACCUSED / RESPONDENT JUDGEMNET ARE MANDATORY)
No.| PLEASE FILL UP ALL THE RELEVANT |IELDS

o e ccusen | Musktagq, Ahmed


Name of The .
1 |Name
E(C.
2 | sfo Wio Dio
Address | T_|L,YmMm FLeDY \—)‘hv(ja‘r Raba ((OJIM‘;
3
=5 o,
|
Britha houSt o Tamia Nagay New clelhy
4 | Aadhar Card No. Pin Code:
sl INDIAN
5 | Gender | Male @fsmaleo Other Nationality other.

6 | Date of Birth / / Age


7 |Mobile No.| e-mail:

S. NT
/ PETITIO
| ADVOCATE FOR PLAINTIFF / COMPLAINA NER / DECRESS HOLDER ETC.

1 |Name of The Advecate, I HimanShu Shaymg


Enrl.No.| 0] 9Sc0 [L023
2 LOffice / Chamber No.

K
3 Mobile No. | e-mail: | 502 1) &€ 1Y
5
susmrreney - L omnshu..Shans.....
PLAINTIFF / PETITIONER / DEFENDANT / ACCUSED | OTHER / ADVOCATE
IN THE COURT OF METROPOLITAN MAGISTRATE SOUTH-EAST
DISTRICT,SAKET COURT, NEW DELHI
Case NO___ 2024

AMREEN ...COMPLAINANT
Vs
MUSTAQ AHMAD ....ACCUSED

INDEX

[ SiNo. | ) Particulars " TPage Nc. ]

MemoOf Parties |
‘f 1
"2 | Complaint U/S 356 of BNS along with supporfing | 2 _}
L Affidavit
q .
3 List of Document
|EXHIBIT “A" Copy of the Screenshot of thel
4
' | 012
a instragram Post of accused person
|
EXHIBIT “B" is the copy of the medical report of the|
5
Complaiant
13
:
-—
| g |
¢ | List of Witness
7 Tcerificate under Section 658 of Indian Evidence in
15 'l6
pursuance of the Electronic Evidence placed on
o Leficylby TheVCompIoinont
"+ ‘
8 Vakalatnama - S
| E— e ——

COMPLAINANT

Place: New Delhi


Date: / /2024 THROUGH
Sharma
HIMANSHU SHARMA & Hemant Kumar
(Advocates)
Wi +91-7827747775, 8802116924
H-1206, Florida Apartment
Sector 82, Foridabad, Haryana - 121002
TE
IN THE COURT OF METROPOLITAN MAGISTRA
T, NEW DELHI
SOUTH-EAST DISTRICT,SAKET COUR
Case NO____ 2024

...COMPLAINANT
AMREEN

....ACCUSED
MUSTAQ AHMAD
MEMO OF PARTIES

AMREEN
An adult, aged about Years,
Indian Inhabitant,
Residing af B-19 OKHLA
BIHAR PATI, JAMIA NAGAR
DELHI 110074 e COMPLAINANT

Versus

MR. MUSTAQ AHMAD@ARIF 1


An adult, aged about 42 year 1
Indian Inhabitant ]
Residing at PANCHAYAT BHAWAN ]
VILLAGE BHADAS NAGINA MEWATB |
HARYANA 122108 1

[Bte £ Joggl
... Accused
12,4t FLew
Raba Batla hovse Jamiq y

Bl st Gl cofil\mfifim
Place: New Delhi
Date: / /2024
THROUGH
. 0
vk\ A<D b
HEMENT KUMAR SHARMA, & HIMANSHU SHARMA
(Advocates)
| M: +91-7827747775
\V H-1206, Florida Apartment
Sector 82, Faridabad, Haryana - 121002
IN THE COURT OF METROPOLITAN MAGISTRATE
SOUTH-EAST DISTRICT, SAKET COURT, NEW DELHI
Case NO___ 2024

AMREEN ...COMPLAINANT
Vs

MUSTAQ AHMAD ....ACCUSED

SANHITA
COMPLAINT UNDER SECTIONS 356 OF BHARTIYA NYAYA

MOST RESPECTFULLY SHEWITH

is a peace loving,
1. The complainant states that the complainant

permanently Residing at B-19


law abiding citizen of India and

OKHLA BIHAR PATI, JAMIA NAGAR DELHI 110024

t is filing the present


2. The complainant states that the complainan

is defined under
complaint u/s 356 Of BNS ths term defamation

means “Whoever, by words


section 356 of BNS, the defamation

signs or by visible
either spoken or intended fo be read, or by

makes or publishes any imputation concerning


representation,

reason to
any person intending to harm, or knowing or having

believe that such imputation will harm, the reputation of such

except in the cases hereinafter expected, fo


person, is said,

defame that person.”

of
3. The complainant further states that the accused is hereby guilty

slander defamation, the brief ‘acts of the case are as follows:


e

X2
NCT OF DELH| COURT FEE |
DLCTOS0527EX2403M |
05NOV-2024 ‘

|0 M
a. The complainan| further slates that the
complainant is an
Law cibidling cilizen has ago
od repultation in the sociely

b. The complainant further states


G

that o case is alreacly goin


g
on belween the accused and the compla
inant in which
rape charges have been
slapped on accused

. The complainant further states that the accused person


posted photos and videos of complain
ant on social media
i.e Instagram and writes wrong things on it. Copy of
Screenshol of Instagram pos! of accused person s
annexured herewith as ‘A

d.The complainant further states that she is about to get

marnied and accused person called the complainants

inlaws and said bad and immoral things about her.

e. The complainant further slates that accused is also making

several aftempls fo assassinate the character of the

complainant by spreading false rumours and facts amongs!

the mutually known person of accused and complainant.

t. The complainant further states that in accused also called

the Fiance of the complainant stated that “AMREEN IS A


€)
CHARACTERLESS GIRL, SHE IS HAVING LOTS OF BOYFRIEND
AND ALSO DOING IMMORAL ACTIVITIES WITH OTHER PEOPLE
TO EARN MONEY." The complainant further states that the

said statement was per se defamatory, libelous, and

scandalous and was just to defame the complainant.

. The complainant further states that the aforesaid words

uttered by the accused were lotally false and without any

foundation or occasion for it. The accused willfully and

consciously made the said imputation concerning the

complainant intending tc harm or knowing or having a

reason to believe that such imputation will harm the

reputation of the complainant, particularly when the latter

conduct of the accused, in uttering the words


was the

has lowered the reputation of the


quoted above

eyes and estimation of the general


complainant in the

circle of her friends and acquaintances.


public and large

no justification to utter the


The accused has absolutely

+o abeve mcnh'onzabninidi'z
above quoted words. Due vom pvoble
e¥in
‘Re5port 15 © . marked
dical
g:;rt(gs'?a‘::“ ‘(?::; :‘: me
e

that it s needless to over


. Th:corr,:;lm:om further states
tement was made
dent that ihe said sta
emphasis and itis evi
y the
d wit h the vie w o defame and destro
by the accuse
is baseless,
of com pla ina nt. The said slatement
reputation

r se defamatory.
scandalous and pe
I The complainant furlher stales thal due 1o defamalory

statemont made by the accused the


complainant's
Image

In_public_has_been_rined and bhecause of this the


complainant Mariage is on the verge of collapse

. The complainant further slales that due o the defamatory

stalemaon! mada by the accused the complainant suffered

a huqge loss which cannol be compensaled in terms of

moncy. Tha varous allegations made by the accused

agains! Ihe complainanl have no substance and the

accusocd has made such allegation on dir just fo give mental

and physical harassment fo the complainant. The

complainanl was grievously affected due lo the

defamalory slalement made by the accused.

and
4, The complainant has nol filed any ofher appeal, application

a wiil peliion and/or involving the subject matter of this petition


Supreme
aithar bolore 1his coutl or before Hon'ble High Courl/

Court ol Inclia

al
5. The complainant further states that the complainant is residing

the addros, given in the cause lille situated at Residing al B-19

JAMIA NAGAR DELHI 110024 . The


OKILA - BIHAR PATL

respondont/accused also resic {es in delhi, therefore this Hon'ble

complaint.
court has absolule jurisdiction o entertain the said
@
6. The complainant will rely upon document, list thereof is annexed

therelo.

declares that this complain! is not barred by law


The complainant

of limitation or latches.

court as expeditiously
8. The complainant is approaching this Hon'ble

as possible and there is no delay.

PRAYERS

facts and circumstances the complainant


Under the aforesaid

therefore prays:
the
ased toissue process against
a. This Honorable Court be ple
as
ed under section 356 of BNS
accused persons above nam
the
dealt with according to
amended and be strictly
provisions of law.
the complaint as
leaves to add, alter, or amend
b.That
of the case may require.
the circumstances
deem fit and
order as this court may
c. Any other and further
proper. et
COMPLAINANT

Place: New Delhi


Date: / /2024
UGH
THROUG M'\/«wws\nd

A, & HIMANSHU SHARMA


HEMENT KUMAR SHAR (Advocates)
M: +91-
7827747775
H-1206, Florida Apartment
Haryana - 121001
sector 82, Faridabad,
TE
IN THE COURT OF METROPOLITAN MAGISTRA
NEW DELHI
SOUTH-EAST DISTRICT SAKET COURT.
Case NO 2024

...COMPLAINANT
AMREEN
\y
...ACCUSED
MUSTAQ AHMAD
AEFIDAVIT

iding at B-19 OKHLA BIHAR PATL JAMIA


+1, AMREEN R/Q
as
NAGAR DELHI 110024 do hereby solemnly affirm and declare

under:
and well
~omplainant in the above-cited case
o facts thereof and as such fam ¢ ~ompetent

to swed
of the BNS of
. Tnat L have e Complaint under section 356
may kindly be read
Hon"ble Court. The contents of the same
this affidavit, which are not being
cel of

n for the sake of brevity


Complaint have been
:+ of accompanying
= % instruction and confent
N 3 53) grafted by my counsel under my
WS O explained to me in
have been read over and
@g&g}fi\ thereof
20
’5’-\0 > cular, wiich | admit fo be comrect.
Amrceh
DEPONENT
NGV ]
' 024
VER]F!CATION
__thatthe conten's of the affidavit are

Piech
DEPONENT
@
STRATE
IN THE COURT OF METROPOLITAN MAGI
COUR T, HEW DELHI
SOUTH-EAST DISTRICT,SAKET
Case NO 2024

.. .COMPLAINANT
AMREEN
Vs
....ACCUSED
MUSTAQ AHMAD

OF
LISTT TN
WI
LIS OF ES SESES
WITNES S

1. Complainant
nt
2. Fiance of the complaina
Flon'ble Court
h permission of this
3. Any other witness wit

Andcen
COMPLAINANT

place: New Delhi


Date: / /2024
THROUGH

"Hv an ‘)\"‘/
SHARMA
NT KU MA R SH AR MA, & HIMANSHU
HEME (Advoccdes)
M: +91-
7827747775
artment
H-1206, Florida Ap
121002
bad, Haryana -
sector 82, farida
MAGISTRATE
IN THE COURT OF METROPOLITAN
T, NEW DELHI
SOUTH-EAST DISTRICT, SAKET COUR
Case NO____2024

...COMPLAINANT
AMREEN
Vs
...ACCUSED
MUSTAQ AHMAD

LIST OF DOCUMENT
.
’/’f cge \
- Particul ars
Sl
No.
-
o TExhbi AT
OF OF STAGRAM\
SCREENSHOT ~ IN
copy \

ACCO UN T OF ACC USE D

02. [ Exhibit g
OF ACCUSED
COPY OF CALL DETAILS
L_J
,/I
L,_,iI,,
a@n
COMPLAINANT

Place: New Delhi


Date: / /2024
THROUGH
i anSh <
HU SHARMA
SHARMA, & HIMANS
HEMENT KUMAR (Advoccl'es)
M: +91- 7827747775
artment
H-1206, Florida Ap
d, Haryana - 12 1 1002
Sector 82, Faridaba
19 likes
who was using me for 4 years
aarifchoudhary813 The family
| separated my way from
and because of their dirty actions
instead of repeating their dirty actions and telling Allah
them
want to cheat money again by trapping me in false case.
they age, she talks to her
When the woman Is of my mother's
of her and her daughter's
Jawyer and tries to filea false case daughter lie caught from
molestation. Thanks to Allah mother | kept a relationship for
that
cotv and video but | am ashamed such
Allah humiliate
so long with such poor people. May and hereafter and protect
greedy, greedy people In this world
all the brothers. Amen.
#ihut #makkari #farebi #dhokha#badmashi #batlahouse
#beiman #cc ty #sach #jamia #jamianagar
ice
#okhlavihar #delhi #delhipol
View 1 comment

24 March + See Original


19 likes
aarifchoudhary813 W1 @
4 T ATIR T O
R FH wmfimfifim
ad m#amwbmmflmb mmmwfim
AT HA S TAIN... more
View 1 comment
uMarch-SuThnmflon
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IN THE COURT OF METROPOLITAN MAGISTRATE
SOUTH-EAST DISTRICT,SAKET COURT, NEW DELHI
Case NO 2024

AMREEN ...COMPLAINANT
'S
MUSTAQ AHMAD ....ACCUSED

CERTIFICATE UNDER SECTION 65B OF INDIAN EVIDENCE ACT, 1872


ISSUED BY MRS. RANGEETA.

That I, AMREEN R/O Residing at B-19 OKHLA BIHAR PATI, JAMIA


NAGAR DELHI 110024 do hereby solemnly affirm and declare as

under:

1. I say that [ am the Complainant in the above-captioned matter, authorised to


represent the Complainant in the present matter, well conversant with the facts
and circumstances of the case, and thus competent to swear this affidavit.
state that 1 have produced the printouts of the following documents, filed

g with the Complaint under Section 356 of BNS


Copy of the screenshot of instagram post of accused person as

EXHIBIT A
ii. Copy of screenshot of call details of accused as EXHIBIT B
3. I state that the printouts of the afore-mentioned documents are taken from the
mobile phone (“8506075514) owned, maintained, managed, and operated by
me (“Computer”) and the same is under my control and there is no possibility
of its data being tampered.
(1
4. 1 state that the Mobile output containing, the information was produced by the
Mobile during the period over which the Mobile was used repularly o store
or process information for the purposes of the s relerred toin the evidence
the use
regularly carried on over that period by me having, lawlul control over
of the Mobile.
the kind contained in the
5. 1 state that during the said period, information ol
information so contained is
electronic record or of the kind from which the
was regularly fed into the Mobile in the ordinary course of my
derived
correspondence with the Accused.
part of the said period, the Mobile was
6. 1 state that, throughout the material
rd or
pro per ly wit hou t aff ect ing the contents of the electronic reco
operating
its accuracy or its contents.
is derived from
that the inf orm ati on cont a rin ed in the electronic record
7. I state
in the ordinar. Y course.
ach in formation fed into the Mobile
Yt
@lf‘f‘l’()NluNT

i /x(,\ *@‘:' Nk, VERIFICATION


%E*‘/o o/
7V 20 ofof OctobeOctober r 2024 that the contents of the
t y gfl é\ v “De lhi on this iy
D Ver i @@ fi%
GO
my knowledge and belief and that nothing
is true to the best of
0‘@0& fiated affidavit amYc o

concealed therefrom.
h material has been DEPONENT
CERTIFIED THE PEPONENT'
Shii/ Bt / SNt
wwwmm%fiwwp
Dbl are ...
that the co. *
have baar .
wue and z.o:rec. 10 the ~Hofegdge”

I
iy ll Ly
IN THE COURTOF __M¢tNYOpnl Hrn Meagisbyale, Soud
= caxt, h
Dislucd
Z s
Sult / Appeal No. Saked T (ouv JURISDICTION OF 202

Inre :-
A—rn reen Plaintiff(s) ¢, Petitioner(s)
Appellant(s) Complainant(s)
VERSUS
Musta q Ahmad Defendant(s) /Respondent(s) / Accused
KNOW ALL to whom these present shall come that I/ We, P ceen

The above named & nppPQ cinend do hereby appoint

fdv HProanshs Shesrea Adv Hemenr Kumay San

Sendhya keshyal
22 2 , ? w 0 QG 2 L S THLY in the above-noted case authorize him:-
o8I
called the advocate/s to be my/our Advocate
case in this court or in any other court in which the same may be tried
To act, appear and plead in the above-noted
court by melus.
or heard and also in the appellate court including High court subject to payment of fees separately for each
To sign file, verify and present pleadings, appeals cross-objecti ons or petitions for [
| 2
executions review, revision, withdrawal, compromise or other petitions or affidavits or other
documents as may be deemed necessary or proper for the prosecution of the said case in allits | £
stages subject to payment of fees for each stage. -
o file and take back documents, to admit and/or g~ny the docuiments or opposite party.
or
To withdraw or compromise the said case or submit to arbitration any differences
disputes that may arise touching or in any manner relating to the said case.
To take execution proceedings on paying separate fee.
and to
To deposit, draw and receive money, cheques, case and grant receipts hereof
for the progress and in the
do all other acts and things which may be necessary to be done
course of the prosecution on the said case.
seby
o appoint and instruct any other Legal Practitioner authorizing him to exercise the power
on our behalf.
conferred upon the Advocate whenever he may think fit to do so and to sign the power of attorney
all acts done by the Advocate or
And I/ We the undersigned do hereby agree to ratify and confirm
his substitute in the matt er as mylour own facts, as if done by mefus to all intents and purpose.
And I'We undertake that I/ We or my/our duly authorise d agent would appear in court and all hearings
andwillinformtheAdvoc ate forappe arancew henthe caseis called.
And IWe undersigned do hereby agree not to hold the advocate of his substitut
e responsible for the result of
be of the Advocate which he shall receive
the said case. The adjournment co sts whenever ordered by the court shall
andretainforhims elf.
And I/We undersigned d o hereby agree thatin the event of the whole or partof the fee agreed by me/us to be
said case until the
paid to the advocate remaining unpai d he shall be entitied to withdraw from the prosecution of thethat once the fee is
onl; agree
same is paid up. The fee settle is ly for the above case and above Court. I/We hereby
whatsoever and if the case prolongs for
paid,I/We will not be entitied for the refund of the same in any case
morethan 3yearsthe original fee shall be paid again by me/us
whichhave
nts
hand r tothese presents the conteof
INWITHNESS WHERE OF |/We dohereuntosetmy/ou

stood
by me/usonthis ............. G woonnonodayof. ONISUSS .202
beenundert
Accepted subject to the terms of the fees
Client Client
?\WT\S“ Ity
dvocate | Identity the Signature/Thumb Impression of the Below Mentioned Person,
‘Who Has been Signed in my presence. The Client.

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