District: North 24 Parganas

In The Court Of The Ld. ACJM, Barrackpore,

Complaint under sections 323, 354, 380, 447, 448 and 34 of the INDIAN PENAL CODE In the matter of:Smt. Pinki Sarkar w/o Sri Swapan Sarkar Address: 104, Nirsingha Nagar(A), A.K. Mukherjee Road P.O. Baranagar P.S. Baranagar Kolkata 700090 .Complainant .vs. 1) Sri Bhabotosh Sarkar s/o Sri Dipu Sarkar Address: 106, Nirsingha Nagar(A), A.K. Mukherjee Road P.O. Baranagar P.S. Baranagar Kolkata 700090

2) Smt. Barnali Sarkar w/o Sri Bhabotosh Sarkar Address: 106, Nirsingha Nagar(A), A.K. Mukherjee Road P.O. Baranagar P.S. Baranagar Kolkata 700090

3) Sri Bapi Das s/o Sri Haribhakta Das Address: 110, Nirsingha Nagar(A), A.K. Mukherjee Road P.O. Baranagar P.S. Baranagar Kolkata 700090

4) Smt. Swarnali Das w/o Sri Bapi Das Address: 110, Nirsingha Nagar(A),

A.K. Mukherjee Road P.O. Baranagar P.S. Baranagar Kolkata 700090

5) Sri Bapi Porua s/o Sri Niranjan Porua Address: 115, Nirsingha Nagar(A), A.K. Mukherjee Road P.O. Baranagar P.S. Baranagar Kolkata 700090 6) Sri Sanjib Porua s/o Sri Bapi Porua Address: 115, Nirsingha Nagar(A), A.K. Mukherjee Road P.O. Baranagar P.S. Baranagar Kolkata 700090 ..Accused Persons

The humble petition of the Complainant; Most respectfully sheweth as under:-

1. That on 01/08/2013, around 6 P.M. your applicant, being a housewife, was engaged at her household work alone with only her minor son as her husband was absent at that time on his work. 2. That suddenly a ruckus broke out just outside her house and upon inquiring it was found that accused no. 2 and 4 were involved in the said ruckus. Upon requesting them to stop their garrulous behavior, accd. no. 2 and 4 suddenly started assaulting your applicant. As soon as she started shouting for help, the accd no. 2 and 4 flew away for the moment. 3. That only after a few minutes the accd no. 2 and 4, accompanied with the other accused no. 1, 3, 5 and 6 returned to your applicants house and called her out. On refusing to come out of her house, all the accused persons forcefully and unlawfully entered into her house in order to teach her a lesson.

4. That your applicant was mortally terrified upon facing such an incident. As she was about to call for help, accused no. 2 and 4 grabbed her by her throat and tried to suffocate her. At the same time accused no. 1 and 3 aggressed in to molest her. They mutilated her nighty, which she was wearing at the time. In the meantime accused no. 5 and 6 were ransacking the whole house, destroying the furniture and other household objects. 5. That when faced with such a terrible consequence, your applicant tried to break free, the accd. no. 2 and 4 struck her severely on her head and stomach by fists and blows, and in the process uprooting her tuft of hair. On your applicant being subdued with pain accd. no. 1 and 3 started to touch her private parts and molested her while accd. no. 2 and 4 tried to hold your applicant still by grabbing her arms and legs.

6. That at this very moment the minor son of your applicant broke into a frenzy of crying and shrieking. Alarmed by the same, the accused persons left your applicant in an injured state and robbed off Rupees 5000 from your applicants house along with her silver chain and a pair of golden ear rings that she was wearing at the moment.

7. That upon hearing the shrieks and cry of your applicants child, a few neighbours had rushed to the spot and rescued her from the clutches of the accused persons. 8. That your applicant subsequently informed the local Club Committee about the incident who advised her to lodge information to the local P.S. 9. That upon visiting the local Police Station, i.e. Baranagar P.S., they refused to lodge a formal FIR, and only accepted a General Diary ( G.D.E. No. 66/13, dt. 1/08/13). Your applicant had also carried the mutilated nighty with her but the Police did not seize the same either.

10. That on the following morning, 02/08/2013, when your applicants husband went to accused no. 1 and 6 to enquire about yesterdays incident, they threatened him with dire consequences, stating that if he does not limit himself that very moment, his wife, i.e., your applicant would definitely and completely be raped and he would be murdered. Threatening him in local lingo they said Porer bar tor bouke rape korbo r toke mayer bhoge pathie debo. 11. That the husband of your petitioner hastily returned home and went to Baranagar P.S. once again to report the

incident. But once again they were refused by the Police of any cooperation whatsoever.

12. That your applicant visited the Baranagar State General Hospital on 03/08/2013 to treat her injuries when her health deteriorated and the reason was attributed by the visiting doctor to the blows she suffered on 01/08/2013 at the hands of the accused, the medical report of which has been annexed herein. 13. That the incident has taken place within the jurisdiction of the Court of the Ld. A.C.J.M. Barrackpore. 14. That the names of the witnesses for the said incident are: Smt. Tumpa Chakroborty w/o Sri Bapi Chakraborty Smt. Gayatri Naskar w/o Sri Shyamal Naskar Smt. Purnima Ghosh Smt. Laxmi Das w/o Sri Jitu Das All residing at Nirsingha Nagar(A), A.K. Mukherjee Road P.O. Baranagar P.S. Baranagar

Who will prove the case beyond reasonable doubt. 15. A photocopy of the General Diary (G.D.E. No. 66/13, dt. 1/08/13) at Baranagor Police Station and Medical Report of the Baranagar State General Hospital dt. 03/08/2013 has been annexed herein. Under the above circumstances, it is prayed before Your Honour to send this application of complaint to the I.C. , Baranagore P.S. for causing investigation after treating the same as F.I.R. for the abovementioned incident, u/s 156(3) of the CrPC and pass such other order or orders as Your Honour deems fit and necessary. . For which act of kindness your applicant, duty bound shall ever pray .

Dated.. Barrackpore