IN THE COURT OF THE JUDICIAL FIRST CLASS MAGISTRATE, GURUGRAM,

HARYANA
NO. 13 OF 2018

Miss. Hansika, D/o. Radhakrishnan, Student, aged about 21 year, Residing at S.V.
Women Hostel, Gurugram, Permanent residing of 43/790, K.S. Road, Gurugram District
Within jurisdiction of Police Station, Gurugram. ……................................... Complainant

Vs.

Mr. J. Siva Reddy, S/o. Narsimha Reddy, Hindu, aged about 26 years 4 th Year, residing
at Men‟s Hostel, S.V. Engg. College, permanent address 7/90, T. Nagar, Gurugram
District, within Jurisdiction of Police Station, Gurugram ………………. …….. Accused.

COMPLAINT FILED ON BEHALF OF THE COMPLAINANT U/Sec 200 Cr. P.C.

1. That the complaint submits that she is studying III Year B.Tech., in S.V. Engineering
College, Gurugram, she knew the accused well.
2. That the complaint submits that the accused had been behind her for last 6 months, but
she never cared him. He wrote a love letter to her and she admonished him, then one day
he pulled her upper saree in the class room and on her report he suspended college for a
month. This happened on 01.05.2018.
3. That the complainant submits that on 12.05.2018, she came to Gurugram Bus Station
along her friends Yogi, Anitha, Valli to bid forewell to the hockey team of her college
going to Visakhapatnam in Tirumala Express. She came out of the station and went to the
Bus Station at about 8.00 pm along with her friends, she found the accused near auto
stand.
4. That the complaint submits that, while she was bargaining auto the accused came there
and abused her that, she was responsible for his suspension from the college, tried to grab
her right hand. When she protested he immediately stabbed on her left and right cheeks
and also on her back with his fists, she cried loudly and the auto rickshaw drivers and
passengers handed over him to police constable near the Bus Station. But he did not take
the accused to police station that it was a noncognizable offence. Hence thus complaint
was made directly. The complaint therefore prays that the honourable court may be
pleased to take cognizance of the offence U/sec 323 IPC and punish him according to
law.

Advocate for complainant Complainant

 CRIMINAL MISCELLANEOUS PETITION IN THE COURT OF SECOND ADDL.
JUDICIAL MAGISTRATE OF GURUGRAM

CR.L.M.P.NO. OF 2018 M.C.No. 45 OF 2017

D. Dhanarekha …………………………………………………………….…… Petitioner

Vs
D. Arun Kumar …………………………………………………………..….. Respondent

Petition filed on behalf of the Petitioner U/Sec 128 Cr. P.C

1. That the petitioner submits that he filed the above M.C. for grant of separate maintenance
on 31.12.2017 against the respondent seeking a sum of Rs. 500 per month to be awarded.
(2) The Honourable Court, after due contest, by order dated 06.01.2018 granted
maintenance to the petitioner directing the respondent to pay a sum of Rs. 400 per month
to the petitioner from 01.01.2012 and keep praying in future.
2. That the petitioner submits that, the respondent has not paid any maintenance so far, and
these disobeyed the order of this honourable court.
3. That the petitioner further submits that the arrears of maintenance from 01.01.2011 to
31.03.2018 to Rs. 6000/-
4. That the therefore prayed that the honourable court may be pleased to commit the
respondent to prison for such kind has the law required or till he paid the arrears of
maintenance.

Advocate for the Petitioner Petitioner

VERIFICATON
I, the petitioner, to hereby declared that the facts stated above or true and correct to the
facts stated above or true and correct to the best of my knowledge information and belief.
Date:
Petitioner
 IN THE COURT OF THE FIRST CLASS MAGISTRATE,GURUGRAM, HARYANA

Sumit…………………………………………………………………... ……… Petitioner

Vs.
State ……………………………………………………………………….…. Respondent

PETITION FILED ON BEHALF OF THE PETITIONER ACCUSED UNDER SEC.

409 OF IPC
May it please your honour On behalf the above name accused, I beg to apply for his
release on bail on following reasons:
1. That the accused was arrested on 05.1.2019 by theGurugram Police on a charge U/Sec
409 I.P.C. the main complaint against him being that he being the V.A.O. of Peruru
village and as such being a public servant failed to maintain and show accounts for a sum
of Rs. 3,000/- to the Government Treasury.
2. Though offence is non-bailable taking into consideration the fact that, the amount
involved is only Rs. 3000/- it is highly probable that there must be some honest mistake
on the part of the accused for no one would think of Misappropriating such a small
amount as Three Thousands.
3. The accused is a respectable old man of 60 and is certainly not going to abscond.
Moreover his family is resident in the village for over 40 years. His pensions and
provident fund all came to more than Rs. 7000/- and the missed amount will be
compensate by the accused soon.
Due notice of this applications is given to the Police.

PRAYER
Therefore, pray that the said accused may be granted bail and released from the policy
custody where he is for the last 45 days.

Advocate for accused

 CRIMINAL APPEAL AND REVISION MEMORANDUM OF APPEAL IN THE
COURT OF THE DISTRICT AND SESSIONS JUDGE AT GURUGRAM

CRIMINAL APPEAL NO: 101 OF 2019

For the following among grounds the Appellant here in begs to prefer this appeal against
the judgement dated ………………….. of judicial Magistrate, F.C., Gurugram in
criminal case No: 101 of 2019, convicting the appellant U/Sec 411 I.P.C and sentencing
him to U/go, 6 months R.I. and to pay a fine of Rs. 300/-

GROUNDS
1. That the conviction is bad in law.
2. That the Judgment of the lower court offends Sec. 367 of the Cr.P.C.
3. That the learned magistrate should have inferred from the conduct of your petitioner
deposed to by the investigating officer, that he was absolutely straight forward in his
dealings. The conduct of your petitioner as has been deposited to by P.Ws. No. 52 and 4
would hardly be consistent with his guilty knowledge.
4. That the learned Magistrate should have taken into accent the representation made to him
by the alleged thief.
5. That the learned Magistrate should have bellered that the articles were purchased
bonafide for proper market price and inferred from that the absence of any guilty
knowledge of your petitioner.
6. That the articles sold were common articles of everyday use to be found in possession of
people of even modest means.
7. That the learned Magistrate should have disbelieved the evidence of P.W.s No: 56 and 7
who identified the parker pen and the Wallet alleged to belong to Sri Anand and should
have hold that they were ordinary, 30 common articles incapable of identification in the
absence of any special mark or name.
8. That the learned Magistrate should have believed the defence witnesses who disposed to
having seen the articles sold to the appellant some five months prior to the incident.
9. That the Lower Court ought to have given the benefit of responsible doubt to the
appellant and acquitted him.

PRAYER
In the circumstances stated above, the petitioner prays that your honour may be pleased
to admit the appeal, call for the record.
Release your petitioner pending disposal of the appeal on bail and after hearing the case,
set aside the order of conviction and sentence or pass such other order as the ends of
Justice may call for and your petitioner, as in duty bound, shall ever pray
 IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS, GURUGRAM,
HARYANA

Criminal Complaint No. 112/2019

Shri Vikrant Verma age 35 years, resident of 121,Sector -51, Gurugram

……………………..Complainant
Versus
Shri Ajay Chaudhary age 30 years, resident of 11/1072,C2 Palam Vihar Gurugram
………………………...Accused
A COMPLAINT U/S 138 OF THE NEGOTIABLEINSTRUMENTSACT& SECTION
420 OF THEINDIANPENALCODE

The complainant above named submits this complaint, praying to state as follows:
1. That the complainant is a resident of the within mentioned address, and he has been
running his business of hardware in the name and style as M/s STD Sales Corporation,
Gurugram.
2. That the accused had been a customer of the complainant for the last ten years purchasing
goods from time to time.
3. That since there has been business relationship between the complainant and the accused
and also that the complainant could repose faith in the accused, he used to accept the
cheques issued by the accused against the purchased by the accused.
4. That during the recent past, there have been various transactions between the complainant
and the accused as detailed below:
5. That the complainant submits and says that the above mentioned cheques were issued by
the accused at the time of delivery of goods and materials supplied to him by the
complainant, with an implied promise on the part of the accused that on the presentment
of these cheques, they will be honoured.
6. That, however, all these cheques, have been dishonoured by the bankers of the
complainant, and the same have been returned to the complainant with endorsement
"Insufficiency of Funds in the Account of the Drawer".
7. That the complainant says that had the complainant known that the cheques issued by the
accused would be dishonored, the complainant would never have delivered the materials
and goods to the accused.
8. That the complainant does hereby reiterate that the cheques which were issued by the
accused in discharge of his liability have been dishonored for the reason of insufficiency
of funds in his account.
9. That the complainant is also surprised that since the date of dishonor of cheques, he has
been making serious and sincere efforts to contact the accused personally, but
unfortunately the accused has been at large and not being available, and his whereabouts
are also not known to the complainant.
10. That taking into consideration such a typical position created by the accused, the
complainant has come to a tacit conclusion and also inferred that the accused took the
delivery of goods by deceiving and cheating the complainant when he issued the cheques
knowing it fully well that he had neither sufficient balance in his bank account, nor had
11. he made any alternative arrangements for crediting the necessary amount against the
same.
12. That from the total behaviour on the part of the accused, it is apparent that he is not only
liable civilly but also guilty of the criminal offences under the provisions of criminal laws
particularly under section 420 of the Indian Penal Code 1860 and under section 138 of
the Negotiable Instruments Act 1881.
13. That the cheques were presented to the bankers of the complainant on.... the same were
returned to the complainant on......for....insufficiency of funds in his account.
14. That the complainant has accordingly served a notice, dated.......on the accused,
demanding payment of the said amount of Rs. 80,000/-, but the accused did not do so,
and hence, this complaint.
15. That the cause of action for this complaint first arose on..... and hence, this complaint
filed today is well within limitation.
16. That the offence has been committed within the local limits of the jurisdiction of this
Court, and hence, this Hon'ble Court hasjurisdiction to try and decide this complaint.
17. That the necessary court-fee is paid herewith.
18. That the complainant, therefore, prays that -
A. The accused be charged with and tried for the offence punishable u/s 138 of the
Negotiable Instruments Act and also u/s 420 of the Indian Penal Code and punished
according to law;
B. This complainant be awarded from the accused the said amount of Rs. 80,000/- along
with interest @ 18% p.a. from the date of the issue of the said cheques till the date of
payment; and
C. Any other orders in the interest of justice be kindly passed.

Gurugram,
Dated: COMPLAINANT