Sanjeevji - i would not be able to suggest the contents for the 313 statement as I am not aware of the facts of the case against the accused. Besides I am not aware of evidences recorded against the accused in the case. I am also not aware of the Defense of the accused. As a general proposition in a criminal case there can be only two defenses i.e.
1. Total denial. 2. If total denial is not possible justify the facts. You claim you have a good defense in which case you justify the facts if any against you by explaning under 313 statement. However if the prosecution has not led any facts against the accused then you do not owe any explanation at all.
I find from your query that you are loosing focus on the case against the accused as is evident from the query that you want the complainant to be punished by means of your 313 statement. It is just not possible. So at the moment forget about complainant being punished but focus on your defense and explain every thing from defense point of you in respect of facts and circumstances that are against the accused and which has emerged in the trial.
Please note I have only made general observations and the accused and his lawyer has to decide the strategy as they would be having the full facts and circumstance of the case. Thanks