Draft of Criminal Revision Written Arguments in Sessions Court in India

 

How to draft Written Arguments under Criminal Revision, in India?


How to draft an application for change of contents in a petition, in India?


 Draft of Criminal Revision Written Arguments in Sessions Court in India

Infographics showing criminal revision


 

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 _______

 

 

 In the matter as above, the petitioner prays to file documented arguments as follows including an application (clause no. 7 of this document) to revise the relief sought from this hon’ble court in the aforesaid matter.

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 









Drafting of Written Arguments under Criminal Revision in India

Drafting an application for change of contents in a petition in India

Sample Draft, Draft Specimen, Draft Example

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