FIA Cybercrime Wing · Prevention of Electronic Crimes Act 2016, Section 21
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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_username (accused_address / Online Identity)
VERSUS
COMPLAINT FOR OFFENCES AGAINST MODESTY AND PRIVACY UNDER SECTION 21, PREVENTION OF ELECTRONIC CRIMES ACT 2016
Sir/Madam,
1. I respectfully lodge this complaint against accused_person_name for committing offences against my modesty and privacy under Section 21 of the Prevention of Electronic Crimes Act 2016.
2. That I am complainant_occupation and reside at complainant_address. My privacy and personal dignity are protected by law and require strict enforcement.
3. That accused_person_name, with knowledge and intent, has violation_nature without my consent and has published the same on platform_names.
4. That on incident_date, the accused specific_act_of_harassment.
5. The said material was posted on platform_names on posting_date at url_or_account_details and has not been removed despite my repeated requests.
6. That material_description was created by creation_method and obtained by the accused through unauthorized_access_method.
7. That I did not consent to the creation, possession, or publication of the said material, and the accused had no legal right whatsoever to publish the same.
8. That scope_of_sharing, exposing me to public ridicule, humiliation, and psychological harm.
9. That the accused has persistently continuation_of_harassment despite explicit requests to cease, demonstrating accused_intent.
10. That I have suffered severe emotional distress, psychological trauma, and social ostracism as a result of the accused's conduct.
11. That family_or_professional_impact has been severely affected by the violation of my privacy and the harassment.
12. That the accused's conduct constitutes an offence under Section 21 of PECA 2016, which criminalizes non-consensual exhibition of intimate images, distortion of photographs, and intimidation involving private images.
13. That motive_or_context was the motivation for the accused's conduct.
14. That I have preserved all available evidence including evidence_types and possess digital records of the violation.
15. That accused_person_name is accused_identification and can be located at accused_location_or_contact.
16. That no other adequate remedy is available to me except through criminal prosecution under PECA 2016.
PRAYER
I, therefore, request this Honourable Agency to:
(a) Register a First Information Report (FIR) under Section 21 of the Prevention of Electronic Crimes Act 2016 against accused_person_name;
(b) Direct immediate removal of the intimate or distorted material from platform_names and all archival services;
(c) Investigate the offense and apprehend the accused;
(d) Obtain digital forensics evidence from the devices and accounts used to perpetrate the offense;
(e) Obtain evidence of all persons who accessed, downloaded, or shared the material; and
(f) Prosecute the accused to the fullest extent of law for violation of privacy and modesty.
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 and nothing material has been concealed.
_____________________________ complainant_name Complainant Date: ______________ Through: _____________________________ counsel_name Advocate (if applicable)
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