PECA Complaint - Electronic Fraud

COMPLAINT TO THE DIRECTOR, CYBERCRIME REPORTING CENTRE Federal Investigation Agency C.O.D. Headquarters, Islamabad

Date: complaint_date

Complainant: complainant_name, son/daughter of complainant_father, resident of complainant_address, CNIC No. complainant_cnic Against: accused_person_name / accused_online_handle (accused_location)

COMPLAINT FOR ELECTRONIC FRAUD UNDER SECTION 14, PREVENTION OF ELECTRONIC CRIMES ACT 2016

Sir/Madam,

1. I respectfully lodge this complaint against accused_person_name for committing the offence of electronic fraud under Section 14 of the Prevention of Electronic Crimes Act 2016, read with the provisions of the Criminal Law (Protection of Economic Interests) Act 1997.

2. That I am a complainant_profession residing at complainant_address, CNIC complainant_cnic. I am a law-abiding citizen of Pakistan and this complaint arises out of criminal fraud perpetrated through electronic means.

3. That accused_person_name deliberately and with criminal intent conducted a fraudulent scheme using electronic devices, information systems, and digital platforms to deceive me and obtain money or property through wrongful means.

4. That the accused's modus operandi involved: fraud_method, thereby deceiving me into believing false_representation.

5. That the fraudulent activity took place between fraud_start_date and fraud_end_date, during which the accused sent fraudulent communications via communication_platform including messages, emails, and calls to my_contact_details.

6. That the accused accessed or caused to be accessed my information system without authorization, specifically unauthorized_access_details, and altered or diverted data or funds.

7. That as a result of the accused's fraudulent conduct, I suffered financial loss amounting to loss_amount_pkr Pakistani Rupees, comprising loss_composition.

8. That the accused's conduct falls under Section 14 of PECA 2016, which criminalizes gaining wrongful access to or causing interference with any information system for the purpose of committing theft, misappropriation, or fraud.

9. That the accused demonstrated intent_element, acting with full knowledge that the conduct was fraudulent, deceptive, and likely to cause financial harm.

10. That I have reported this matter to reporting_channels and have preserved all digital evidence including evidence_types.

11. That accused_identification_details, and the accused's location is accused_current_location.

12. That this conduct constitutes a serious criminal offence not only under PECA 2016 but also under the Pakistan Penal Code, as it involves fraud, wrongful use of computer systems, and financial exploitation.

PRAYER

I, therefore, request this Honourable Agency to:

(a) Register a First Information Report (FIR) under Section 14 of the Prevention of Electronic Crimes Act 2016 and applicable sections of the Pakistan Penal Code;

(b) Investigate the electronic fraud with utmost priority and collect all digital forensic evidence from the accused's devices and accounts;

(c) Trace and apprehend accused_person_name and proceed against him/her according to law;

(d) Direct recovery of the defrauded amount of loss_amount_pkr Pakistani Rupees or its equivalent value;

(e) Secure all digital communications, transaction records, and bank statements related to the fraud;

(f) Block or disable any fraudulent accounts or electronic payment systems used by the accused; and

(g) Take all necessary steps to prosecute the accused to the fullest extent of law.

VERIFICATION

Verified on oath at verification_place on this _____ day of _____, year, that the contents of the above complaint are true and correct to the best of my knowledge and belief.

_____________________________ complainant_name Complainant Date: ______________ Through: _____________________________ counsel_name Advocate (if applicable)