Prompt to draft Criminal Complaint / FIR

Role: You are an Indian-qualified criminal lawyer experienced in drafting complaints, FIRs and private complaints and in representing victims before police and magistrates.
Draft a high-quality, court-resilient criminal complaint / FIR draft for the Client (to be filed with the appropriate police station or Magistrate). The draft must: (a) satisfy Section-154 CrPC requirements and Lalita Kumari principles on FIR registration, (b) anticipate typical police objections, (c) preserve and list available evidence and investigative steps, and (d) include a short legal memo with statutory/case citations and follow-up steps if police refuse to register.

Please draft a filing-ready Criminal Complaint / FIR draft for our client.

Client data fields (complete before drafting):
– Complainant: [name, age, address, ID proof]
– Accused(s): [name(s)/aliases/address/contacts if known]
– Date(s) & time(s) of incident: [DD/MM/YYYY – time window]
– Place of incident: [exact place / GPS if available]
– Short chronology (attach timeline document)
– Evidence to attach: [medical reports / CCTV / bank transfers / emails / screenshots / witness names & contacts]
– Any previous police complaint / e-FIR / GD: [attach scans]
– Corporate authorisation if organisation is complainant: [attach board resolution]

Deliverables required:
1. Draft FIR/Complaint ready for registration under Section 154 CrPC, with numbered paragraphs, facts → sections mapping, and a clear prayer block (register FIR + preserve evidence + arrest if prima facie).
2. Affidavit of complainant adopting the facts and annexing exhibits.
3. Cover letter to SHO/SP requesting registration & conservation steps (CCTV/bank/phones).
4. Short legal memo (1–2 pages) quoting Lalita Kumari, Arnesh Kumar and Joginder Kumar and recommending immediate next steps if police refuse (s.156(3) application, representation to SP/DGP). :contentReference[oaicite:7]{index=7}
5. Annexure index and preservation notice drafts for CCTV / banks / social platforms.
6. Filing checklist and acknowledgement receipt template.

Mandatory drafting rules:
– Ensure the FIR draft is chronological and fact-specific; cross-reference exhibits for each material fact.
– Include a short “Prima facie offences” table mapping facts to IPC / special statute sections.
– Add a specific request to preserve digital evidence and request 65B compliance steps for later proof.
– If police refuse to register, prepare s.156(3) draft and a private complaint (s.200) in parallel.
– Highlight optional wording (e.g., whether to seek immediate arrest or leave arrest to police discretion) in YELLOW.

Required citations to be included as footnotes: Lalita Kumari v. Govt. of U.P. (2014) (mandatory FIR registration); Arnesh Kumar v. State of Bihar (2014) (arrest safeguards); Joginder Kumar v. State of U.P. (1994) (arrest & judicial safeguards). Also include SOP reference for Zero-FIR/e-FIR and any relevant state DGP circulars available.

Deliver the draft in Word (clean) and a PDF checklist for the client. Highlight urgent preservation actions in red.