In,

The court of Chief Judicial Magistrate,

Gaya .
Complaint case no /2018

Name and address of complaint.

Vijay Paswan S/O- Late Jagroop Paswan, R/O- Village- Bakraur, P.S.- Bodhgaya, District-
Gaya.
Name and address of accused .
Raj Kumar Yadav S/O- Etwari Yadav, R/O- Village- Demania, P.S.- Barachatty, District –
Gaya.
Name and address of witness.
1. Purusottam Sharma, S/O- Yamuna Sharma, R/O- Mohalla Ramdhanpur, P.S.-
Kotwali, District- Gaya.
2. Upendra Kumar, S/O- Late Ganesh Paswan, R/O- Mohalla- Katari, P.S.- Chandauti,
District- Gaya.

Other witnesses shall be cited later on.

Place of occurrence.

Residence of complainant and residence of accused.

Date and time of occurrence.

17.01.18,30.07.18,18.08.18 and 17.10.18

Offence .

406,420 IPC and 138 N.I. Act

That the complainant

begs to submit as follows.

Most Respectfully Sheweth.

1. That the complainant is a peace loving and law abiding citizen.

2. That the accused and complainant were known to each other since long.
3. That the complainant was in need of a piece of land which upon the accused
agreed him to give him land and accordingly demanded Rs.2,00,000/- (Two
Lakhs) as an advance and accordingly the complainant trusting on him and
on 17.01.18 gave two lakhs at the residence of complainant.
4. That on 17.01.18 the accused assured the complainant to give him land in
three months but time lapsed and he did not give land to complainant and
every time made excuses.
 5. That as the accused was not giving land to complainant hence he started
demanding his money and on such on 30.07.2018 the accused at his
residence gave a cheque of Punjab Natinoal Bank bearing Cheque no. 842512
worth Rs. Two Lakhs in favour of complainant.
6. That the complainant trusting on accused accepted the cheque and presented
the same in his bank on which upon on 18.08.18 the cheque given by accused
bounced as the bank gave a remark as the Account is blocked and a legal
notice had been given to you on 10.09.18 then you had assured to pay Rs.
Tow Lakhs on 25.09.18 within 10 days, but had been failed again. Again I had
demanded my money then you answered that he had deposited the money in
his Bank Account. Again I deposited the said cheque for clearance, but again
the said cheque had been dishonoured on 17.10.18.
7. That the accused knowing this fact issued a cheque that his account is
blocked amount to cheating.
8. That the complainant trusted on accused and on the other hand he cheated
complainant with a malafide intention.
9. That the complainant has got all legal proof to prove his case before
competent jurisdiction.
10. That the complainant has given two lakhs to accused and the accused with
wrong motive has issued the cheque knowing all the facts.
11. That thereafter the complainant through his lawyer sent again legal notice on
16.11.18 demanding his money but the accused neither replied nor retained
the amount, hence this complaint case is being filed.
12. That the complainant and his witnesses are ready to prove his case.

It is, therefore, paryed that your

honour may be pleased to take
cognizance in this case and
summon the accused for trail.

And for this the complainant shall ever pray.

Gaya, Dated 12.12.18 Complainant’s signature