1

COMPLAINT FOR CRIMINAL TRESSPASS

IN THE COURT OF JUDICIAL MAGISTRATE FIRST CLASS AT MUZAFFARPUR

C. C. No. 25/03/2016

Ramesh Prashad,

Aged about: 49 years,

Occupation: Manager at Arti Pvt.ltd, Muzaffarpur, Bihar,842001,

Residing at – Quarter No.- 11/A, Govt. Quarter, Chhata chowk, Muzaffarpur, Bihar,842001

…Complainant

Versus

1. Kalua Sinha,
Aged about: 37 years,
Occupation: Worker at Arti Pvt. Ltd,
Residing at- Block No. 11, One BR Colony, Bachra, Muzaffarpur, Bihar, 842001
2. Lalu Chauhan,
Aged about: 40 years,
Occupation: Worker at Arti Private Ltd.,
Residing at- Barigora janta road, Near Ajanta medical hall, P.O.: Rahergora,, East
Singhbhum, Jamshedpur,831016
………Accussed
Complaint for the offence of criminal trespass, hurt and threatening
The complainant above name begs to state most respectfully as under:
1. That the complainant is “factory manager” of Arti private Ltd. The Arti Pvt Ltd
company is having its manufacturing plant at Muzaffarpur MIDC. The company
manufactures various electronic goods and components.
2. That all the accused above named are the workers in the said factory. That on 21/
03/2015 (Twenty First day of March Two thousand fifteen), the accused were just
sitting idle and were not doing any of the job assigned to them, the senior superior
repeatedly told them to stop chit-chatting and not to sit idle and to do their work.
The senior supervisor Mr. Ramesh Prashad then reported the matter to the Factory
Manager i.e the complainant.
3. The complainant submits that the complainant went to the shop lore around 3:30
PM and told the workers i.e. the accused herein that as they are not doing their
work, he would make deduction in their salary.
 2

4. That the accused no. 1 and 2 both thereafter started arguing with the complainant.
The complainant told all the accused that for the last three days they have not
done any work so the employer will not pay them for the same and the left the
shop floor at 4:00 PM.
5. The complainant submits that at around 6:30 in the evening all the accused barged
inside the cabin of the complainant and started abusing the complainant and
threatening him of dire consequences if he deducted their salary. The complainant
called upon all the accused not to use bad language and asked then to leave the
cabin immediate. On this the accused no. 2 caught him by collar and told him to
keep shut.
6. The complainant submits that accused no. 1 that was caring a dagger. He pointed
the dagger to the complainant and told him that he would cut the complainant in
the pieces if he took any action against any of the accused, the complainant was
shocked, horrified and was numb due to the terrorising attack by the accused. the
secretary of this complainant by name Rohit Sharma inform the other officer and
worker about the said attack.
7. The complainant submits that only when other workers and officers came to the
complainant’s cabin then these accused left the cabin.
8. That the complainant submits that none of the accused had obtain any permission
at the gate to enter the Factory premises. There shift was over at 5’clock
afternoon. Thus there entry into the factory premises and inside the cabin of this
complainant is unlawful and unauthorised. Thus the accused have committed the
offence of criminal trespass among other offences punishable under the Indian
Penal Code 1860.
9. That the complainant therefore raised that the all the accused be dealt with
according to law and such other order may please be pass as deemed fit and
appropriate and in the interest of justice.
Place: Muzaffarpur
Date: 25 March 2016
Ramesh Prashad
Complainant
Ratnesh Bharatwas
Advocate for Complainant
 3

BAIL APPLICATION

IN THE COURT OF THE VII METROPOLITAN MAGISTRATE:

CYDERABAD:

AT L.B.NAGAR:A.P.

Cr. M.P.No.4343/2014

in

C.C. No. 10/2014

BETWEEN:

Ramoji,
S/o. Sri Narayana,
Aged about 50 years,
Occupation: Proprietor, Anjali Jewellery Shop, Hayatnagar,,R.R. District
…..Petitioner

AND
State of Andhra Pradesh,
Through Hayatnagar Police Station,
Represented by the Public Prosecutor,
Criminal Court Premises,
Cyderabad,, L.B.Nagar, A.P. …..Respondent

Bail application/petition filed under section 439 of Cr.P.C 1973.

1. It is humbly submitted that the present application under section 439 of Cr.P.C 1973
is being filed by the petitioner for seeking grant of bail in the fir 10/2014 in
connection with the offence under Section 506 Part II registered at Police Station,
Hayatnagar. The present petition is being moved as the petitioner has been arrested on
01/07/2014 (One July Two Thousand fourteen) in connection with the said FIR. The
petitioner is now in judicial/police custody.
2. The petitioner/ accused is only breadwinner of the family. He has a wife and younger
child and elders in his family and they are entirely dependent on the petitioner.
3. The petitioner is an innocent person and has not committed any offences as alleged by
the respondent no useful purpose would be served by keeping him under custody and
this is a fit case for grant of bail.
4. The petitioner, is a law abiding citizen and so he will not abscond.
5. The petitioner is prepared to furnish substantial sureties for his/her due appearance.
 4

6. That the petitioner has not filed any others similar petition before this or any other
Honourable Court for grant of bail in case of the present FIR.

PRAYER

For the reasons mentioned above it is humbly Prayed that this Hon’ble Court may be
pleased to release/enlarge the petitioner on bail in C.C. No. 10 of 2014 on the file of this
Hon’ble Court pending trial on such terms and conditions and with or without any surety or
security as this Hon’ble Court may deem fit and proper in the interest of justice and fair play.

Place: L.B. Nagar Sd/

Date: 3.07.2014 Ramoji

Place: L.B. Nagar Sd/

Date: 3.07.2014 Snehlata Sneha

(Counsel for Petitioner)

 5

MEMORANDUM OF APPEAL IN SESSION COURT

In the Court of Session Judge of New Delhi

C.A. No. 234 of 2014.

Ramoji,
S/o. Sri Narayana,
Aged about: 50 years,
Occupation: Cement Dealer, Laxminagar, New Delhi 110010 ……Appellant

Versus

Mr. Suresh,

S/o: Lt Sri Chandrakanth,

Aged about 34 years, Hindu,

Occupation: Area Manager, Business India Judicial Maga Limited,

Address: H.No. 56B, New Delhi 110010

….Respondent/ Complainant

Criminal Appeal against the judgment and order due date 25.12 2013 (Twenty fifth
December Two Thousand Thirteen)

In C.C. No. 13 of 2013

That the appellant above named begs to state most respectfully as under:-

1. That the appellant/ Accused being aggrieved and dissatisfied by the judgment and
order passed by the Court of the Judicial Magistrate First class Sessions judge at New
Delhi. In C.C. No 13 of 2014 on 7.01.2014 (Seventh Day of January Two Thousand
Fourteen) date prefers this criminal appeal on following grounds:-
Grounds of Criminal Appeal
(i) That judgment passed by the trial Court is against law, incorrect and
improbable.
(ii) That the trial Court has grossly erred in ignoring the contradictions of
prosecution witnesses.
(iii) That the learned trial Court has not taken into account the documentary
evidence adduced before the Hon’ble Court.
(iv) That the learned trial Court ought to have taken into account the evidence in
totality while passing the judgment and sentence.
(v) That the learned trial Court ought to have held that the appellant/accused is
innocent and has been falsely implicated by the complainant/ respondent.
 6

(vi) That the learned trial Court ought to have given due weightage to the evidence
of the accused.
PRAYER

It is therefore most respectfully prayed that:

(i) This appeal of the appellant may please be allowed and the conviction and
sentence passed by the trial court by its judgment and order date 25.12.2013
(Twenty Fifth Day of December Two Thousand Thirteen) in C.C. No 13 of
2013 may please be set aside.
(ii) Pass any other further orders as deemed fit in the interest of justice.
Place- New Delhi

Date:07.01.2014

Raghu Ram

(Counsel for Petitioner)

Ramoji

(Appellant)
 7

MEMORANDUM OF APPEAL TO THE HIGH COURT

IN THE HIGH COURT OF JUDICIAL MAGISTRATE FIRST CLASS AT PATNA

CRIMINAL APPELLATE No. 123 Of 2018

UNDER SECTION 377, Code of Criminal Procedure, 1973

Madhav Mehta,

S/o: Vishal Mehta,

Aged about: 27 years,

Occupation: Businessman,

Address: H.No.56B, Geet apartment, Satratu Colony, Boring Road, Patna 821001

…..Appellant

VERSUS

State of Bihar ....... Respondent

APPEAL AGAINST ORDER OF THE LEARNED SESSION’S JUDGE PATNA 2009

IN

Session’s Trial No. 11 of 2008 State Versus Madhav Mehta

To,

The Hon’ble Chief Justice and his companion Judges of High Court.

The Appellant most respectfully submits the appeal against the aforesaid order of the learned
Sessions judge aforesaid on the following amongst other grounds of appeal.

Grounds of Appeal

1. Because the judgement or order of the learned Sessions judge is illegal and against the
evidence on record.
2. Because the conviction and the sentence passed are against law and against the weight
of evidence on record.
3. Because the conviction and the sentence are not maintainable in law and facts on
record.
 8

PRAYER

It is most respectfully prayed that the appeal may be allowed and the conviction and
sentence passed against the accused persons may be set aside and the accused be
acquitted.

Place: Patna Sd/

Date: 17.08.2009 Madhav Mehta

 9

APPLICATION FOR REVISION IN SESSION COURT

IN THE COURT OF THE SESSIONS JUDGE, CHATRA

Revision Petition No.167of 2018

Dhanu Ram,

S/O: Manu Ram,

Aged about 45 years,

Occupation: Farmer,

Residing at: Gram Kasiyadih thana Tandawa District Chatra.

….Petitioner

VERSUS

Ganjhu Ram,

S/O: Hira Ram,

Aged about 54 years,

Occupation: Farmer,

Resident: Gram Kasiyadih, Thana Tandawa District Chatra. .…Respondent

May It Please Your Honour, The humble petition of the petitioner above named most
respectfully showeth:

The petitioner begs to prefer this petition against the order of the Judicial Magistrate of the
First class, Chhatra, passed in Cr. Case No.145 of 2018 dated 25.04.2018 (Twenty Fifth April
Two Thousand Eighteenth) on the following among other grounds:

Grounds

1. The order of the lower Court is against law.

2. The lower Court has erred in stating that no criminal offence is disclosed. The lower court
has erred in stating that it is a matter for the civil court to decide.

3. The lower Court ought to have found that from the complaint and the sworn statement the
offence under Sections 403,420 and 384, read with Sec. 109 of the I.P.C 1860. against the
accused have been made out for enquiry.

4. The lower court ought not have dismissed the complaint under Section 203 of the Cr. P.C
1973. simply because the accused 1 and 2 happen to be the relations of the complainant.

5. In any event criminal offence under Section 403, I.P.C 1860, at least is clearly made out
both from the complaint and sworn statements.
 10

It is, therefore, prayed that the Hon'ble Court be Pleased to order further inquiry in the above
case.
Place: Chhatra

Date: 23.08.2018

Sd/-

Ganjhu Ram

Sd/-

Dhanu Ram

VERIFICATION

I, Dhanu Ram, do hereby verify that the contents from paras 1 to 4 are correct and true to the
best of my knowledge and personal belief and no part of it is false and nothing material has
been concealed therein. Affirmed at Chhatra this.

Place: Chhatra Sd/

Date: 23.08.2018 Dhanu Ram

 11

REVISION APPLICATION IN HIGH COURT

IN THE COURT OF THE VII METROPOLITAN MAGISTRATE:

CYDERABAD:

AT L.B. NAGAAR, R.R. DISTRICT: A.P.

C.C.No. 10 of 2005

IN THE HIGH COURT OF JUDICATURE OF AT HYDERABAD:

ANDHRA PRADESH

Criminal Revision Petition No. 11 of 2006

BETWEEN:

Ramoji,

S/o. Sri Narayana,

Aged about: 50 years,

Occupation: Proprietor, Anjali Jewellery Shop, Hayatnagar,,R.R. District

…..Petitioner/ Accused

AND

State of Andhra Pradesh,

Through Hayatnagar Police Station,

Represented by the Public Prosecutor,

Criminal Court Premises, Cyderabad,, L.B.Nagar, A.P. …..Respondent

The above named revision petitioner craves leave of this Hon’ble Court to state most
respectfully as follows:-

I. The above named petitioner /accused files the present Criminal Revision Petition
having aggrieved by the judgement dated 03.04.2005 (Third April Two Thousand
five) of the court of the VII Metropolitan Magistrate: Cyderabad, at L.B. Nagar,
R.R. District, A.P. in C.C. No. 10 of 2006, inter alia, on the following:
II. Grounds of revision
i. The Hon’ble Appellate court has grossly erred in confirming the judgment
of the trail court as well as the sentence. The said decision is against law,
improper and against the probabilities of the case.
ii. That by giving undue weightage to the evidence of PWs, both the court
have convicted this petitioner to undergo 2 years of rigorous imprisonment
is bad in law and needs to be rectified as the same has resulted in gross
miscarriage of justice.
 12

iii. The court’s below have ignored the discrepancies of PWs in their cross
examination.
iv. The court below have not decided the case on legal and admissible
evidence and were swayed away by considerations not relevant for the
purpose of deciding the relevant questions before it.
v. The Hon’ble court below have overlooked the material evidence while
passing the order convicting this petitioner.
This Revision Petitioner therefore prays that Hon’ble court may be pleased to (a) Set-aside
the judgment of the Cyderabad session court at Hyderabad passed in C.C. No. 10 of 2006 and
consequently quash the same as illegal, arbitrary without jurisdiction and against settled
principles of law and procedure and to pass such other or further order or orders as this
Hon’ble Court may deem fit and proper in the light of fact and circumstances of the case.
Place- Kothapet Sd/

Date- 10.12.2015 Ramoji

Place- Kothapet Sd/

Date- 10.12.2015 Anant Raj

VERIFICATION

I, Mrs. Anita, on my behalf and also on behalf of the petitioner 2 and 3 do hereby declare
that the facts stated above area true and correct to the best of my knowledge, information and
belief. Hence verified.

Place: Hyderabad Sd/

Date: 12.2.2005 Ramoji

 13

CRIMINAL MISCELLANEOUS PETITION

Abhineet Raj

Aged about: 25 years,

Occupation: Mechanic,

Resident of: Karhara, Post: Fatehpur, Police station: Tekari

Gaya, Bihar, 824236

….Petitioner/ Accused’s Father

Versus

State of Bihar …..Prosecution

Petition no: 73 of 2018

State v. Ayesha and Suhani

F.I.R. No.: 89 of 2018

Police Station: Tekari

Offence Under Section: 109 of Cr.P.C. 1973

APPLICATION FOR SEEKING CUSTODY OF ACCUSED ANANT UNDER SECTION

98 of Cr.P.C. 1973
Respectfully Showeth,

The Petitioner respectfully submits

1. That he is the father of accused Ayesha who is under 18 (eighteen) years of age.
2. That after 4 (four) days of missing, the petitioner’s daughter Ayesha, the petitioner
got information that she is in Protective Home, Gaya.
3. That the petitioner also came to know that she was arrested with another girl, Suhani.
In the night of 26.08.2018 (Twenty sixth day of August two thousand eighteen).
4. That the petitioner has a bonafide believe that both the girls are innocent and they
were roaming in the night because they forgot the way of reaching home.
5. That the petitioner is fully willing to take the custody of Ayesha. The petitioner
assures the court that he will provide a safe and proper custody to Ayesha.
 14

6. That the petitioner undertakes to produce her in the honourable court whenever
required.
7. That, it is, therefore, prayed to the honourable court that an order may be passed
providing custody of daughter Ayesha to the petitioner till final disposal of the case.

Place: Gaya

Date: 31/08/2018 Signature of Petitioner

 15

PETITION FOR MAINTENANCE UNDER SECTION 125 OF Cr.P.C 1973

IN THE COURT OF THE FAMILY JUDGE: CRIMINAL COURTS NAMPALLY:

AT HYDERABAD : ANDHRA PRADESH

M.C. No. 39 of 2006

BETWEEN:

1) Smt. Anita,
W/o Sri Suresh,
Aged about 29 years,
Occupation: Housewife,
Address: H.No. 200A,
Chikkadpally,
Hyderabad,
Andhra Pradesh.

2) Master Venu,
S/o: Sri Suresh,
Aged about 3 years,
Minor rep. By Anita Mother & Natural Guardian
Occupation: Student
Address: H.No. 200A
Chikkadpally
Hyderabad
Andhra Pradesh

3) Master Sreenu,
S/o: Sri Suresh
Aged about 2 years
Minor rep. By Mrs. Anita Mother & Natural Guardian
Occupation: Student
Address: H.No. 200A
Chikkadpally
Hyderabad
Andhra Pradesh Petitioners 1to 3

AND

Mr. Suresh,
S/o: Lt Sri Chandrakanth
Aged about 34 years, Hindu,
Occupation: Area Manager,
Business India Limited
Address: H.No. 56B
New Delhi 110010
 16

PETITION FOR MAINTENANCE UNDER SECTION 125 CR.P.C. 1973 ON

BEHALF OF PETITIONERS 1TO 3

The Petitioner above named submits most respectfully as under:

1) Address for service of summons, notices etc. On the above named petitioners is the
same as that of their counsel Shri Raghvendra, Family Court Premises, Hyderabad,
A.P.
2) Address for service of summons, notices etc. In respect of the respondent is the same
as that mentioned above in the cause title.
3) The petitioner No. 1. Is the wife of respondent and the petitioners No. 2 and 3 are the
minor children of both the first petitioner and the respondent.
4) The petitioner submits that the petitioner and the opponent are Hindus and were
married on 25.07.1998 (Twenty Fifth July Nineteen Ninty Eight) as per Hindu Vedic
rites and ceremonies.
5) The petitioner submits that after the solemnization of marriage the petitioner went to
her matrimonial house to stay with her husband i.e. the opponent herein.
6) The petitioner states that the opponent was and is habituated to drinking. During the
petitioners stay at her matrimonial house the opponent would constantly pick up
quarrel with the petitioner, he would come drunk to the house and mercilessly beat the
petitioner. Due to all this petitioner left her matrimonial house and went to reside at
her father’s house at Hyderabad.
7) The petitioner submits that she left her matrimonial home on 14.02.2004(Fourteenth
February two thousand four) and since then the petitioner has been living with her
parents. The petitioner’s father is a worker in a flourmill. He has to look after his two
sons and wife along with petitioner. The petitioner submits that she is unable to
maintain herself.
8) The petitioner submits that the opponent is working as a Area Manager in Business
India Limited and is drawing a salary of Rs.50,000/- ( Rupees Fifty thousand only)
per month. The opponent has no other financial responsibilities. His parents are not
alive.
9) The petitioner submits that the opponent has not bothered to talk to this petitioner
after she left the matrimonial home. When the petitioner through letter dated
21.05.2004 (Twenty First day of May Two Thousand Four) called upon the opponent
to pay her maintenance, as she has no other means to maintain herself, the opponent
has not bothered to reply to the said letter till date nor has provided any money to the
petitioner in lieu of maintenance.
10) The petitioner submits that the opponent should pay an amount of Rs. 20,000/-
(Rupees Twenty thousand only) per month as maintenance to the petitioner for the
reasons stated hereinabove.
 17

PRAYER

For the reasons mentioned above it is humbly prayed that this Hon’ble Court may be pleased
to pass an order directing the respondent to pay a monthly maintenance amount of Rs.5000/-
(Rupees Five Thousand only) for the petitioner and Rs.15,000/- (Rupees Fifteen Thousand)
for the maintenance of children and for the expenses towards education and medical aid etc.
In the interest of justice.

Place: Hyderabad Sd/

Date: 12.2.2005 Petitioner

Place: Hyderabad Sd/

Date: 12.2.2005 Counsel for the petitioner