Format of 138 n.i act complaint

IN the Court of First A.C.J.M, Haridwar 1. Complaint No. /2011 A……………………………………………………………………….Haridwar-249403, Uttrakhand Complaint filed by its ………………………………………………………R/O………….Haridwar-249407 appointed him by company directors by passed the resolution in a meeting. Versus Romany hydro chemical Co., ……………………………….Secunderbad-09, Hyderabad Through his Managing Director Complaint u/s 138 & 142 of the N. I. Act 1881 as amended by Act of 1988. PS- Ranipur The complaint respectfully submits as under. 1. That the complainant is engaged in Herbal product manufacturing business. Company situated at sidcul abovesaid address. 2. That a cheque No XXXXX dated XXXX drawn by accused co. on the HSBC Bank, Hyderabad for Rs 1,87,680/- from account No -XXXXXXX maintained by company with the said bank payable to complainant for part payment of goods XXXX & XXX-90 (total cost of said goods is Rs. *****/-) delivered by complainant to accused on dated ****** through GR No. ****** Jaipur Golden Transport Co. Pvt. Ltd 3. That complainant was produced said cheque for collection to the bank on Bank of Baroda, A/c N. *********, Chandra charya Chowk, Ranipur, Haridwar (Uttrakhand) at dated ******* for received cash of part payment and the said cheque was dishonored by the said Bank for insufficiency of the funds in the account. Complainant have received the information about the dishonor of the cheque on dated *******with Bank's Memo dated ***** The accused had thus dishonest and guilty intention right from the beginning at the time he issued the aforesaid cheque 4. That the accused has paid Rs. *****/- by cheque no. ****** dt.****** out of said total amount Rs.*******/-. In this way Rs.***** still pending on accused side out of total said amount. The accused has provided two cheque no. ***** (for Rs. *****/-) and ***** ( for Rs. *******/-) to complainant. Both cheques produced in same bank, same time & date. Dishonored by same reason in same date & time. Said bank return Both cheques details mention in one memo filed with complaint. Both said cheque cases filed in court separate today. 5. That the complainant immediately thereafter contacted the accused and apprised him about the dishonoring of the said cheque but the accused did not pay any head. 6. That complainant make demand notice on accused through his lawyer Mr. R. K. prajapati by registered notice dated *******(Receipt enclosed) to make the cheque payment of Rs ******* to accused within fifteen days of the receipt of said notice, The accused having received the said notice and has failed to make payment within 15 days of the receipt of the said legal notice. Neither furnished registry notice nor enclosed A.D. has received till filing complaint. 7. That the complainants submit that the accused has issued the cheque without sufficient fund in the bank account thereafter the accused committed the offence u/s 138 NI act. 8. That the cause of action arose after the expiry of 15 days of receipt of the aforesaid legal notice and due to nonpayment of the amount by the accused. 9. That the complaint has filed within one month from the date of expiry of the 15 days time given under the law for the payment of the said money. The said cheque was issued at *****presented ******* at the said bank where the cheque was return as unpaid by complaints bank and so this Hon’ble court has the jurisdiction to take cognizance of the offence. Its therefore prayed the accused may be summoned to face the trial under 138NI Act and punished in accordance by law. Its also prayed that Hon’ble court may be pleased to order of Rs. Rs ***** ( Cheque amount ******* - ******* paid amount by cheque = ******) for the payment of the compensation of the fine amount u/s 357 of the Cr.pc read with sec.117 of N. I. Act as Cheque amount, Bank service charges, notice charges, advocate fees. Dated: ******** Complainant *********************** IN the Court of First A.C.J.M, Haridwar Complaint No. /2012 >>>>>>>>>>>>>>> Versus >>>>>>>>>>>>>>>>> Complaint u/s 138 & 142 of the N. I. Act 1881 as amended by Act of 1988. PS- Ranipur List of Documents List of witness 1 Dishonored cheque 1. Complainant 2. Bank return Memo 2. The Manager/Official bank 3. Post office incharge 3. Copy of notice 4. Any other witness with 4. Registry Envelop …… permission of court 5. Registry Notice dated ……….. 6. Postal receipt 7. Purchase order dated ………….. 8. Payment & order latter ………… 9. Delivery latter No. ………………. 10. Invoice dated …………………….. 11. Special power of attorney Complainant