IN THE COURT OF THE HON’BLE ADDL.

JUDICIAL FIRST
CLASS MAGISTRATE, MEDAK, AT SANGAREDDY

Crl. M.P. No. OF 2014

IN
C.C. No. 1050 OF 2012
BETWEEN:

Anil Kumar Jaiswal, S/o Sripuram Kumar Jaiswal

Aged about 45 years,
R/o H.No 16-105, Allwyn Colony, Patancheru,
Dist-Medak-Telangana

…….PETITIONER/ACCUSED No.1

AND

Badal Kumar Naik, S/o K.C.Naik

Aged about 45 years, Occ.: Pvt. Employee
R/o. H. No. 8-121/1, Sree Saidhama Apts.,
Road No-2, JP Colony, Patancheru, Dist-Medak

……..RESPONDENT/COMPLAINANT

PETITION FILED UNDER SECTION 311 OF Cr.P.C.

May please your Honour,

It is submitted that the above said case filed by the respondent

/complainant with false allegations against the petitioner/accused No.1 & 2
and the case is coming for Arguments.

It is further submitted that the petitioner/accused No.1 filed chief

affidavit and along with list of document i.e., Chit Finance Small Book on
28/04/2014 and after posted on 31-07-2014. On 31-07-2014 due to advocate
boycott, this Hon'ble Court closed the defence evidence on same day and
posted for arguments on 07-08-2014. The petitioner/accused No.1 filed a
document and which is necessary and very important document to prove the
case on behalf of the defence side.

It is further submits that the said unmarked exhibit is an crucial

document in this case as such it is necessary to mark the said document i.e.,
Chit Finance Small Book, otherwise the petitioner/accused no.1 will be put to
irreparable loss and injury.
Contd., 2
 :: 2 ::

Therefore the petitioner/accused no.1 prays that this Hon’ble Court may
be pleased to reopen the defendant evidence and mark the said document as
exhibit of D1 and pass such other orders or orders as this Hon’ble Court may
be deem fit and proper in the circumstances of the case.

Place: Sangareddy Petitioner/Accused No.1

Date; 07-08-2014

COUNSEL FOR THE PETITONER/ACCUSED NO.1 & 2

 IN THE COURT OF THE HON’BLE ADDL. JUDICIAL FIRST
CLASS MAGISTRATE, MEDAK, AT SANGAREDDY

Crl. M.P. No. OF 2014

IN
C.C. No. 1050 OF 2012
BETWEEN:

Anil Kumar Jaiswal, S/o Sripuram Kumar Jaiswal

Aged about 45 years,
R/o H.No 16-105, Allwyn Colony, Patancheru,
Dist-Medak-Telangana

…….PETITIONER/ACCUSED No.1

AND

Badal Kumar Naik, S/o K.C.Naik

Aged about 45 years, Occ.: Pvt. Employee
R/o. H. No. 8-121/1, Sree Saidhama Apts.,
Road No-2, JP Colony, Patancheru, Dist-Medak

……..RESPONDENT/COMPLAINANT

PETITION FILED UNDER SECTION 311 OF Cr.P.C.

May please your Honour,

1) It is submitted that the above said case filed by the respondent

/complainant with false allegations against the petitioner/accused No.1 & 2
and the case is coming for Arguments.

2) It is further submitted that the petitioner/accused No.1 filed chief

affidavit before this Hon’ble Court along with list of document i.e., Chit Finance
Small Book on 28/04/2014 and after posted on 31-07-2014. On 31-07-2014
due to advocate boycott, this Hon'ble Court called the matter and closed the
defence evidence on same day and posted for arguments on 07-08-2014. The
petitioner/accused No.1 filed a document which is necessary and very
important document to prove the case on behalf of the defence side.

3) It is further submits that the said unmarked document is an crucial

document in this above case, as such it is necessary to mark the said
document i.e., Chit Finance Small Book on behalf of the petitioner/accused
No.1, otherwise the petitioner/accused no.1 will be put to irreparable loss and
injury.

Contd., 2
 :: 2 ::

4) It is submitted that in this case to recall the DW1 to mark the document
Chit Finance Small Book on behalf of defence side. If the DW1 is not re-called
for marking of document, the petitioner/accused no. 1 may be put to
irreparable loss and damage. It is just and necessary to re-call DW-1 for
further examination to meet the ends of justice particularly to prove the
innocence of the petitioner/accused No. 1.

Therefore it is prayed that this Hon'ble Court may be pleased to re-call

DW-1 for further examination to mark the Chit Finance small book document
and pass such other order or orders as this Hon'ble Court deem fit and proper
in the interest of justice.

Place: Sangareddy
Date:

COUNSEL FOR THE PETITONER/

ACCUSED NO.1 & 2