Section 138 NI Act Complaint

IN THE COURT OF THE [courtName] Criminal Complaint No. _____ of 2024 IN THE MATTER OF: [complainantName] ... Complainant VERSUS [accusedName] ... Accused COMPLAINT UNDER SECTION 138 READ WITH SECTION 141 OF THE NEGOTIABLE INSTRUMENTS ACT, 1881 MOST RESPECTFULLY SHOWETH: 1. That the Complainant is [description]. 2. That the Accused is [description]. 3. That the Accused issued a cheque bearing No. [chequeNo] dated [date] for Rs. [chequeAmount] in favour of the Complainant for [reason]. 4. That the cheque was returned unpaid by the bank with the remark [reason]. 5. That the Complainant issued a legal notice dated [date] to the Accused. 6. That the Accused failed to make the payment within 15 days of the receipt of the notice. PRAYER: It is, therefore, most respectfully prayed that this Hon'ble Court may be pleased to: 1. Summon, try and punish the Accused under Section 138 of the NI Act; 2. Award compensation to the Complainant under Section 357 CrPC; 3. Pass any other order as this Hon'ble Court may deem fit and proper. COMPLAINANT VERIFICATION: Verified at [place] on this [date] that the contents of paragraphs 1 to 6 are true to my knowledge and contents of paragraph 7 are based on legal advice believed to be true.