Criminal Revision Petition Sessions Court India Draft Sample Specimen

How to Draft Criminal Revision Petition for Sessions Court in India?


         In the court of The Hon’ble Sessions Judge at <City>

                        Revision Petition No.          of 2021


                                     CC No. 3077 of 2019

In the matter of :

<petitioner> S/o <petitioner's father>

Aged about <#> years, Occ. Entrepreneur

Corres. Add: Off. No. 3 <> Appt.,

<Location>Compound, Cantt Road, city - 000000

                                                                                                  ..Petitioner / Complainant


1. Rakesh Mishra s/o unknown, Occ. Dy SP (Police) Sahibabad, UP

R/o Sahibabad

2. Ravi Kumar s/o Unknown, Occ.  Dy. SP (Police) Ghaziabad, UP

R/o Ghaziabad

3. Deepak Sinha s/o unknown, Occ. Private Company Worker

R/o Ghaziabad

                                                                                                  .. Respondent /  Accused



Infographics on Criminal Revision Petition Sessions Court  Draft Sample Specimen


May it Please You Honour,

The humble petition of the petitioner named above most respectfully submits:

This is a petition against the impugned order dated 07-10-2021 passed in the complaint case no. 3077/2019 by the learned Chief Judicial Magistrate <city>. By virtue of the said impugned order the learned magistrate has dismissed the complaint of the petitioner u/s 156/3 of CrPC stating it to be outside the court’s jurisdiction.

The petitioner begs to prefer this petition against the order of the learned Magistrate on the following among other grounds:

Grounds for the Criminal Revision Petition:

1.    The order is based on the police report which says that the incident is of Ghaziabad when the complainant was working at nearby location and complainant also told about his working in that area but complainant was working there until 2010 while the incident started during and after late 2017. Complainant only told in the petition as to how he got acquainted with one of the accused i.e. accused no. 3 by telling he worked with him there and never said that incident took place while he was working there. Besides, it is the same local police of <city> about who the accused No. 1’s report says that it could not find the address of the complainant, while when court ordered probe it found it. So it’s a conflict of interest by the same local police. Hence, the local police report is prima facie unreliable.

2.    When the accused was making complaints against the accused no. 3 as well as accused no. 1 he was always at <city> and the address of the complaints was also <city> on record and not of anywhere else. The complainant’s number whose telecom records complainant sought during his complaints against the accused was always in <city>, he was threatened in <city> only, he never knows who was calling from where at that time. It is only that he knew that the accused lives in Ghaziabad so might be he was calling from there to issue threats. Besides, the accused no. 3 visited <city> and threatened on behalf of his master accused no. 1 to kill the complainant in fake encounter. The complainant discussed this with local police but they never took it on record and issued fake report to the court.

3.    Accused No. 1 created fake documentation by telling that a person from his office visited <city> to find the given address but said there was no such address. Again, he also says that local police also reported to him that there was no such address. This shows that the crime has taken place in <city>.

4.    Accused no. 1’s report itself shows he sent a person viz. Athar from Ghaziabad and the local police to the <city> address of the complainant to meet him. Thus, during the incidents when the complainant was always in <city> and nowhere else the incident is considerable to have taken place only in <city> which is evident by the complainant’s demand on UP government’s jansunwai portal to take telecom operator records which will show that the calls are coming to him and not that he is making calls to the accused while his location was always in <city> which accused no. 1 never did to save his ally. Thus, as all the documentation shows that the complainant was always in <city> while crime took place, the order by the CJM court is an error on the face of record, hence the complainant prays to:

1.    Set the impugned order aside

2.    Order a complaint against all accused under CRPC 156/3



            Petitioner in Person

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