Draft Complaint For Cyber Crime

Note: The Drafts are being provided only for reference purposes and on basis of facts provided. Adab Singh Kapoor & Associates will not be responsible for any further use of the Drafts.


I, ABZ, am a user of Facebook since the year 2006. Never have I faced any problem with this space, but recently I have been subjected to something that has disturbed me tremendously. I have been receiving morphed nude pictures of me by unknown users directly in my inbox. I have no idea how to go about making a complaint. Could you please help?


Economic Offences Wing,
Near Mandir Marg Police Station,
Mandir Marg,
New Delhi - 1100XX

The SHO,
New Delhi - 1100XX

Subject: Complaint under Section 66(e), 67 and 67(a) of the Information Technology Act, 2000 along with Section 509 of the Indian Penal Code, 1860 for Punishment for Violation of Privacy, Punishment for publishing or transmitting obscene material in electronic form, Punishment for publishing or transmitting of material containing sexually act, etc. in electronic form and words, gesture or act intended to insult the modesty of a woman.

I, introduce myself as ______________ d/o.w/o__________r/o_________________ aged_________ currently employed as/studying at_______________.

I am a regular user of Internet and social networking sites especially 'Facebook'. Never have I faced any problems in using this website however recently I have started to receive explicit messages from 'unknown users'. These users have not only been sending me messages but has also gone to the extent of morphing my pictures with nude and obscene pictures downloaded from the internet and has been sending them in my inbox. These users may also have obtained unauthorized access to my images, by planting a spy camera in a public place, such as a changing room in a Mall, etc. I also fear that he may have also sent it to others especially to people in my friend list and to my colleagues.

(Copy of facebook messenger/inbox with messages received from these unknown users has been enclosed)

I suspect that these messages may be from a particular person who is making these fake accounts repeatedly or from different persons with common intentions of harassing, maligning and defaming me.

The detailed sequence of the events is as under:

That I had created my Facebook account (Social networking website) in the year 2006 and have been using this account since then without any interference or obstructions. That I have been using this account to chat with my friends, to stay socially active in my circle and to reconnect with people.

That since the last few months, I have been receiving explicit and obscene material in my facebook inbox from unknown users. These users have been sending me sexual content which is grossly offensive and has a menacing character. Such images, if made public would do me damage beyond repair and I would be devastated.

That I have blocked all these users from my account but each time I block such a user; I again start receiving obscene and sexual content from another user. Moreover, I have never replied to these messages.

That on _____________, I again received a message from a user at about ___________ a.m./ p.m. As soon as I opened the message I was shocked to see a morphed picture of myself.

Soon thereafter, on _____________, I received another similar message, with my picture in the nude and with another nude man. I have tried to report the matter to facebook and have also 'reported abuse' the account, but each time the account gets blocked, I start to receiving such content from a different account

The very next day, when I went to office/school, I heard a group of persons indirectly commenting on the pictures. I was then convinced that these pictures have been circulated. I was so embarrassed that I went back home.

Earlier, I did not inform anyone as I was very embarrased, however, I am now constrained to take recourse to legal action and want to punish the guilty for the untold harassment and misery caused to me.

It is further to be noted that my facebook account is being used by me since 2006 and many of my friends and family are on my facebook. I am scared that these images will be posted on my facebook "WALL." I am afraid that these images may have been circulated elsewhere also and may have already been used for immoral purposes.

I am traumatized by receiving these messages and request you to kindly take proper and prompt action against these users/persons as my reputation as well as the reputation of my family is in danger. Also, if no action is taken against these users/persons there would be irreparable damage that I would have to suffer. I have made a note of all the user ids for your perusal and investigation.

In the light of the above factual backdrop it is submitted that the following offences are made out against these 'unknown users';

Punishment for Violation of Privacy under section 66 (e) of the Information Technology Act, 2000 Punishment for publishing or transmitting obscene material in electronic form under section 67 of the Information Technology Act, 2000 Punishment for publishing or transmitting of material containing sexually act, etc. in electronic form under section 67 (a) of the Information Technology Act, 2000 and Words, gesture or Act intended to insult the modesty of a woman under section 509 of the Indian Penal Code, 1860

I would request you to promptly investigate into the aforesaid offences, against the unknowns users and take strict action against them in law.

Thanking you in advance for your efforts.


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