RTI Sample: False POCSO Allegation by Wife Against Husband’s Younger Brother – Complaint at PS Dwarka North, Delhi

RTI Application – Seeking Information Regarding False POCSO Case Filed by Wife Against Husband’s Younger Brother at PS Dwarka North, Delhi

Applicant:
Mr. Sandeep Khanna
Flat No. 204, Lotus Residency,
Sector 12, Dwarka, New Delhi – 110078
Email: sandeep.khanna2025@mail.com
Phone: 9810XXXX77
Date: 10 February 2025

To,
The Public Information Officer (PIO),
Office of the Deputy Commissioner of Police,
South-West District, Delhi Police,
Dwarka Sector 23, New Delhi – 110077

Subject: Seeking information under RTI Act, 2005 regarding FIR No. 76/2025 registered at PS Dwarka North on complaint of my estranged wife Mrs. Neha Khanna, wherein false POCSO charges were leveled against my younger brother Rohit Khanna (aged 16 years, Class XI student).

Background:
I, the undersigned, married Mrs. Neha Khanna on 18 February 2021 at a community hall in Sector 10, Dwarka. Matrimonial disputes arose due to her continuous demands for transfer of my flat into her name. On 12 January 2025, she left the matrimonial home and on 15 January 2025 lodged a false complaint at PS Dwarka North alleging that my younger brother Rohit attempted to molest her 9-year-old daughter (stepdaughter to me) under fabricated circumstances. Based on her complaint, FIR No. 76/2025 was registered under Sections 354 IPC and POCSO Act. The allegations are false and intended only to pressurize me and my family into property transfer and monetary settlement.

Information Sought:
Please provide certified copies/information for the following points under RTI Act, 2005:

1. Certified copy of FIR No. 76/2025 registered at PS Dwarka North.
2. Certified copy of written complaint filed by Mrs. Neha Khanna on 15.01.2025.
3. Certified copy of statement of alleged victim recorded under Section 164 CrPC before Magistrate.
4. Certified copy of medical examination report of alleged victim conducted at DDU Hospital.
5. Certified copy of school attendance records of my brother Rohit Khanna on the alleged date of incident (12.01.2025) as submitted to IO.
6. Certified copy of preliminary inquiry report by Women’s Cell before registration of FIR.
7. Name, rank, and contact number of IO investigating FIR No. 76/2025.
8. Certified copy of DD entry made prior to FIR registration on 15.01.2025.
9. Certified copy of call details of complainant on 12.01.2025–15.01.2025 as collected by police.
10. Certified copy of CCTV footage from Lotus Residency Society submitted by RWAs to police.
11. Certified copy of neighbours’ statements recorded under Section 161 CrPC regarding alleged incident.
12. Provide details of counselling done by CAW Cell Dwarka in January 2025 in this case.
13. Certified copy of forensic psychological evaluation report of minor victim (if conducted).
14. Certified copy of IO’s site inspection report and sketch of alleged incident spot.
15. Provide details whether District Child Welfare Committee (CWC) was involved in inquiry.
16. Certified copy of notice issued to me under Section 41A CrPC.
17. Provide details whether my brother Rohit (aged 16) was illegally detained without juvenile board order.
18. Certified copy of Juvenile Justice Board (JJB) order in this case (if produced before JJB).
19. Certified copy of anticipatory bail application filed by my brother and police’s objections thereto.
20. Provide details whether case diary entries record involvement of any NGO influencing complainant.
21. Certified copy of verification of medical age of Rohit Khanna confirming he is 16 years and minor.
22. Certified copy of representation filed by me on 20.01.2025 alleging false implication.
23. Certified copy of acknowledgment of representation received by ACP Dwarka Sector 23.
24. Certified copy of psychological counselling records of alleged victim maintained by CWC.
25. Certified copy of guidance note circulated by DCP South-West in Jan 2025 on handling POCSO cases.
26. Provide details of all steps taken by police to verify if allegations were motivated by property dispute.
27. Certified copy of call recordings between complainant and her relatives seized during inquiry.
28. Certified copy of IO’s letter to RWA Secretary requesting CCTV and verification.
29. Certified copy of reply received from RWA Secretary of Lotus Residency.
30. Provide details whether Delhi Police sought guidance from Special POCSO Court at Dwarka Courts.
31. Certified copy of all medical prescriptions of alleged victim collected by IO.
32. Certified copy of file noting regarding decision to add POCSO sections.
33. Provide number of false POCSO FIRs registered in South-West District in 2024–25.
34. Provide certified copy of vigilance inquiry (if conducted) into conduct of IO.
35. Provide details whether police protection was provided to my family after false case registration.
36. Certified copy of any direction issued by Hon’ble Delhi High Court in connected bail application.
37. Certified copy of any SIT recommendation for investigating false POCSO misuse.
38. Provide certified copy of disciplinary actions against complainant if complaint proven false.
39. Certified copy of affidavit of complainant filed during mediation in CAW Cell.
40. Certified copy of chargesheet filed before Special POCSO Court Dwarka (if filed).
41. Provide details whether case transferred to Crime Against Women Cell for parallel inquiry.
42. Certified copy of all documents submitted by complainant to police alleging harassment.
43. Certified copy of representations received by police from my parents regarding harassment.
44. Provide certified copy of all remand applications and orders passed by Magistrate.
45. Certified copy of FIR closure/cancellation report (if prepared).
46. Certified copy of forensic report of digital evidence submitted by complainant (if any).
47. Certified copy of medico-legal certificate of my brother Rohit Khanna (if taken).
48. Provide details whether police considered Section 182 IPC for false complaint.
49. Certified copy of entire note sheet maintained in this case till 05.02.2025.
50. Provide number of pending matrimonial cases involving POCSO misuse in Dwarka Courts (2024–25).

Relief Sought:
Please provide certified, true, legible copies of the above documents/information under RTI Act, 2005. In case of denial, reasons under RTI Act sections must be provided.

Place: New Delhi
Date: 10 February 2025

Applicant’s Signature:
Sandeep Khanna

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Disclaimer: The persons named in this sample are not real — identities hidden for privacy. This sample is for illustrative and educational purposes only.