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IN THE COURT OF THE HONBLE VII ADDL. CHIEF METROPOLITAN

MAGISTRATE: AT HYDERABAD
CC No.

OF 2014

Between:
Kashimshetty Karunasagar S/o K.Krishnaiah
Age: 35 Yrs, Occ: Practising Advocate,
R/o H.No. 9-4-35/2, Mahankali Thota, Champapet,
Hyderabad- 500 079
...

Complainant

AND
Mrs. Kalvakuntla Kavitha W/o D.R. Anil Kumar
Age: 36 Yrs, Occ: Member of Parliament, Nizambad
parliament Constituency.
R/o H.No.8-2-310/A/31A, Flat No.202,
Hilltop Residency, Plot No.214,
Road No.14, Banjara Hills,
Hyderabad
.

Accused

Place of Offence

H.No. 17-2-481/1, 1st Floor, Beside ICICI ATM,

Saidabad main Raod, Kurmaguda, Hyderabad 059.

Date of Offence

Nature of Offence

Offence U/Sec. 124-A,153-B & 505 of IPC

Name of P.S.

P.S. Madannapet

Witnesses

1. Complainant himself.

20.07.2014

COMPLAINT FILED U/SECTION 200 OF Cr.P.C

The complainant humbly submits as follows:
1.

The Complainant submits that the complainant is a law abiding citizen

bearing true faith and allegiance to the constitution of India as by law

established or uphold the sovereignty and integrity of India and hails from
respectable family of the society.
2.

The Complainant further submits that on 20.07.2014 while the

complainant was going through a E-paper of English daily The Indian

express at his office he has gone through an interview titled No One

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Guides us In Parliament published in the daily where the daily has
interviewed the Accused, one Anupriya patel and Pratap simha first-time
MPs of TRS, APNA DAL & BJP respectively, and when the complainant has
gone through the interview he was shocked and annoyed seeing the remarks
of the accused herein while answering questions of the interviewer.
3.

The complainant herein submits that the accused while replying to a

question posed by the interviewer has said that JAMMU & KASHMIR AND
TELANGANA WERE BOTH FORCEFULLY AND AT THE SAME TIME
ANNEXED TO THE INDIAN UNION. WHEN I SAY I FEEL STORNGLY.
ITS BECAUSE WE WERE BOTH SEPARATE COUNTRIES, BUT WERE
MERGED WITH THE INDAIN UNION AFTER INDEPENDECE. IN 1947,
WE WERE NOT PART OF INDIA. THEN THE TROUBLES REALLY
STARTED. NONE OF OUR PEOPLE WAS VERY RICH BEFORE. SO ITS
FROM THE PEOPLES PROSPECTIVE THAT IVE STARTED READING
ABOUT JAMMU & KASHMIR.
4.

The complainant further more submits that the accused further made

remarks that WE NEED TO COME OUT CLEAN ON JAMMU & KASHMIR,

FEW PARTS WERE NOT OURS, WE SHOULD AGREE, WE SHOULD
REDRAW THE INTERNATIONAL LINES, AND MOVE ON. DEVELOPMENT
IS SUFFERING AND YOU SEE FREQUENT BOMBINGS and so, the
remarks of the accused has kick started controversy and raised wide spread
debate and got published in many dailies.
5.

The complainant further submits that the princely state of Kashmir in

its entirety is an integral, invisible, inalienable part of India according to the

ACCESSION INSTRUMENT OF 1947 and as per the Article 3 of
Constitution of India, and further the Indian Parliament unanimously
adopted a resolution on February 22, 1994, emphasizing that Jammu and

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Kashmir was an integral part of India, and that Pakistan must vacate parts of
the state under its occupation and the whole meaning and purpose of an
Instrument of Accession is that princely sates surrendered whatever
autonomy they had to become part of the system after the lapsing into the
Indian Union.
6.

The complainant further submits that the remarks of the accused

attempt to excite disaffection to be created against the Union of India and

the

Government

of

India

which

have

lawful

governments

thereby

emboldening the militant groups in the respective States owing allegiance to

enemy countries to seek secession from India. The accused having taken an
oath to uphold the sovereignty and integrity of India, has chosen to take an
anti-national and anti-Indian stand in commenting on the legitimacy of
accession of the respective States in the Union of States, which is India,
thereby deliberately causing disaffection with the Union of India. Under
Article 1 of the Constitution of India, India is a Union of States, including
the States of Jammu and Kashmir and the erstwhile princely State of
Hyderabad.
7.

The complainant further more submits that It is a matter of historic

evidence that the erstwhile Nizam VII forced the military action upon himself
and Razakars who numbered up to 200,000 at the height of the conflict swore to uphold Islamic domination in Hyderabad and the Deccan plateau in
the face of growing public opinion amongst the majority Hindu population
favouring the accession of Hyderabad into the Indian Union, by openly
proclaiming his desire to accede to Pakistan, which is by then an enemy
State of India and had vowed to hoist the Asafia flag on the Red Fort. By
seeking to show allegiance to such seditious behavior, the accused have
committed acts of sedition against India and its Government. The untold

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miseries, arson, killing, rape and looting of masses under the Nizam VII,
actively supported by a few groups necessitating an intervention by the
Government of India, upon the request of the population of the erstwhile
princely State are recorded in history. The accused by her statement, has
thus belittled the martyrdom of the natives of this country and also the
sacrifices of Indian jawans who led the action against the oppressive rule of
Nizam VII, Razakars and their henchmen.
8.

The complainant further more submits that the accused chose to

raise such issues only to further their sectarian, polarizing, parochial

and partisan political agenda thereby questioning the rule of law in
this country. The statements of the accused have a tendency to
prejudice national integration, has the effect of creating disharmony
between the people of Telangana and the rest of the country,
deliberately raised to further her political agenda.
9.

The complainant further submits that the accused has not so far

denied the statements made in Indian Express, in spite of wide

spread condemnation from civil society and the masses of the State
of Telangana. By disregarding the sacrifices made by the officers of
Indian army in the matter of liberation of Hyderabad, which the
accused mischievously refers to as forcible annexation, without any
sense of history or contemporaneous events, has created a situation
whereby the jawans in the Army would feel a disquiet or cause him
to disregard in his duties towards the nation. The action to liberate
the erstwhile princely State from the clutches of Nizam VII,
Razakars and their sympathizers was taken on the public demand for
such intervention by the masses of the State all of which are
recorded in the books of history.

10.

The petitioner further more submits that the remarks passed by the

accused have boosted and encouraged the spirit of separatist organizations

and terrorists backed by the ISI of Pakistan, who have waged war against
Indian union for separate state of Jammu & Kashmir and they have openly
welcomed the statement of the accused which was passed in their favour,
and many dailies in Pakistan have welcomed the statement and published
the same proudly and are liable to misunderstand, misquote it and alter
Indias stated established invariable position for decades.
11.

The complainant further more submits that the complainant is put to

lot of trouble and mental agony after seeing the interview and is put to
mental shock, that the accused being an responsible Member of parliament
and a law maker who took oath under Article 99 of constitution of India
In the name of the god/ solemnly affirm to bear true faith and
allegiance to the constitution of India as by law established and
uphold the sovereignty and integrity of India has passed such remarks
irresponsibly and deliberately that it inadvertently casts serious doubts on
the territorial integrity and legitimacy of the Indian Union.
12.

The cause of action arose on 20.07.2014 when the interview of the

accused was published in the English daily The Indian express and the same
was read by the complainant and still continuing.

13.

The Complainant submits that this Honble court has got wide

jurisdiction to try the accused and as the office of the complainant is situated
in the jurisdiction of P.S. Madannapet and hence this Honble court has got
vide jurisdiction to try the accused.

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Therefore the complainant prays that this Honble Court may be
pleased to take cognizance against the accused u/Sec. 124-A, 153-B, 505 of
IPC summon to stand trial and suffer punishment for the offences in
accordance with law in the interest of justice.
Hyderabad
Dt. 30-07-2014

COMPLAINANT
VERIFICATION

I, the above named complainant herein, do hereby declare that the

above mentioned facts are true and correct to the best of my knowledge,
belief and information, hence verified the same on this the 30th day of July,
2014 at Hyderabad.

COMPLAINANT
LIST OF DOCUMENTS
1.

Copy of interview published in E-paper of The Indian express Dt.

20.07.2014.

2.

Copy of Agreement of Accession of state of J&K Dt. 26.10.1947.

3.

Copy of article published in E-paper of DailyTimes (Pakistan daily) Dt.

22.07.2014

4.

Copy of article published in E-paper The Citizen Dt. 24.07.2014

COMPLAINANT