Draft of Criminal Revision Written Arguments in Sessions Court in India
Draft of Criminal Revision Written Arguments in Sessions Court in India
Before The Hon’ble Sessions Court
In the matter of
___________________
________________________, India
Vs
Dr. _______ & Othrs.
Criminal Revision Petition No. ___ of 20__ . In CC No. ____ of 20__
Documented Arguments and Application
Latest Known Particulars of the Opposite
Parties:
1. Dr. ______ (Addl. SP, STF, ID No. ______)
___________________________________________
2. Ravi _______ (SP, ________)
O/o The Superintendent of Police,_________ District
3. ______
__________________________
4. The State of _______
The petitioner prays to state:
1. That the petitioner submitted talwana to the registry
which informed that all the 3 accused have been sent court’s notice via
ordinary post.
2. The petitioner submitted another talwana 2nd
time, about which registry told that court’s summon has been sent to them by najarat at their original addresses at
____. However, the petitioner sent the same notice through registered post
on his part which got returned.
3. That the petitioner submitted another talwana 3rd
time and the
accused no. 1 and 2 received the court’s notice at their
current addresses. However, petitioner is not aware of the status of the
court’s notice to the accused no. 3.
4. That the last point of formal response from the accused
no. 3 was through ______ police station so the petitioner filed talwana and as
informed by the registry, 2nd notice by this hon’ble court (as cited in point
no. 2 above) sent through najarat was received at that address, whose police
officials first contacted and responded on the complaint against the accused
no. 3.
5. That all the incidents took place in _____. The
victimized petitioner had always been in _____ during the incidents, made
complaints to all authorities viz. National Human Rights Commission, State
Human Rights Commission, IGRS portal, PMO portal, etc. while being in _____ and using the ____ address
only, received threats while being in ______ on phone with his
location in _____, received all forged documents i.e. bogus police reports by
the accused no. 1 and 2 while being in ______.
The petitioner never knew where the accused no. 3 actually
was during incident while making threatening calls on behalf of the accused no.
1. It is only assumption that accused no. 3 was in _____ as he sometime
told that his address was ____, while the person can be anywhere in the
world while making calls to anyone.
Similarly, to the victimized petitioner, accused no 1 and 2
are only stating that they were posted in ________, but while creating the
forged police documents they could be at any place as the reports were
submitted by them online only. But the victim accessed the reports on IGRS
portal while being in _____ only.
6. That all the police personnel who stated on the IGRS portal
viz.
Athar(subordinate of accused no.1) and local ______ police
(on
whose response the forged report of accused no. 1 is based,
as he himself stated) that the address of the complainant does not exist must
have been in ______ for verification to state so.
7. Nowhere in the complaint petition to the Hon’ble CJM court
it was mentioned that incident took place in ______ while it is only that
the local police appears to have cunningly furnished such report to the CJM
court in favoritism or alignment with the accused no. 1 and 2 working within
the same department. Thus, the impugned order of the Hon’ble CJM court is based
only on the local police fake report or the local police mis-guidance that lead
to (and combined with) an illusive impression of the incident having taken
place at ______ only by assuming the introduction of the accused no. 3 who
first met the petitioner in ________ when he used to state that he lived in __________,
which was during the year 20__ to 20__.
The local police report says that the incident took place
when the complainant was working with accused no. 3 in _________, which was actually
during 2008-2010 only, while the incident started since the year 20__ onwards.
It is also not known whether accused no. 1 and 2 were in
______ during 2008-2010. So it is only the year 2017 and thereafter when the
incident is taking place and during this time complainant has been in ______ only.
8. That the notice sent by this hon’ble court to the accused
no. 1, 2
and 3 through ordinary post and najarat the 1st and
2nd time (as cited in points 1 and 2 above) at their
_________ addresses be taken on record.
9. That this hon’ble court may kindly expedite the process of issuing the final order in view of the threats faced by the petitioner from
the accused.
10. That kindly consider the prayer of relief sought as asked
in this criminal revision petition no. ___ of 20__ to as:
i. That this Hon'ble Court may be pleased to Quash and set
aside the order under revision.
ii. That the case be remanded to trial court for further
evidence in accordance with law while stating that the cause of incident is ___ and only
_____ jurisdiction is applicable so that the petitioner is enabled with a
facility to act for lodging an FIR or a complaint (u/s 200) against the accused
nos. 1, 2 and 3 according to the applicable CrPC procedures.
ii. Any other relief as this hon’ble court deems appropriate.
Yours faithfully,
Date: / /202_ Petitioner