IN THE COURT OF THE HON'BLE XIX METROPOLITAN MAGISTRATE,CYBERABAD,

AT MIYAPUR

C.C. NO. OF 2014

Between:

D.venkat swamy S/o D.munichandra Bhupal

Age: 58years, occ:Bhel Employee,
R/o: 25-29/18/12, Sri sai nagar
Ramachandrapuram.
... Complainant

AND

D.Trivikrama Bhupal , S/o D.Munichandra Bhupal

Age:51 years, occ: Private Employee;
R/o.H.No.4-79/1,Tara nagar,
Sheri lingampally, chanda nagar,
R.R.District.

... Accused

COMPLAINT UNDER SECTION 190 & 200 OF Cr.P.C.

1. Nature of Offence : Under Sec.406, 423, 448,

2. Place of Offence :
3. Jurisdiction of Police Station : Chandanagar Police Station
4. Date of Offence : 01-07-2014
5. List of Witnesses : 1. Complainant

2. C. Venkata Narayana, S/o. Narayana,

Aged about 56 years; Occ: BHEL Employee;
H.No.6-95/26/1, Huda Colony, Chandanagar,
Ranga Reddy Dist.

3. Bh. V. S. N. Raju, S/o. Late Venkata Raju,

Age about 54 years, Occ: Bhel Employee,
R/o. H.No.2076-A, BHEL Township,
Ramachandrapuram.

The Complainant humbly begs to state and submit as follows:-

The address of the parties are correctly set out in the foregoing cause title. The
Complainant may also be served through its counsels, M/s M/s. R.S. Associates, T. Ratan
Singh, C. Srinath, A. Naresh Lal, G. Raghavender Reddy, B. Chandra Shekar, Advocates,
H.No.24-43/2, Beside Triveni Talent School, Ashok Nagar, Ramachandrapuram, Hyderabad-
32. Cell: 9912428035. for the purpose of Court Summons, Notices etc., from this Hon'ble
Court.

1. The Complainant respectfully submits that this is a case of criminal breach of trust and
criminal trespass and cheating in which the complainant was put a wrongful loss by accused
and continuing trespass with malafide intention in the property of the complainant.
2. The facts are that the Complainant is the absolute owner H.No.4-79/1,Tara nagar,
Sheri lingampally, chanda nagar,R.R.District, The complainant has purchased the open
bearing No. 28/A, survey No. 78 & 79 at Taranagar, by virtue of registered sale deed No.
1333/1988 at District Registrar Rangareddy on 26-02-1988. And subsequently consturcted a
house consisting of Two Rooms by duly obtaining permission from the concerned authorities
and living peacefully with out any hindrance .
3. The complainant further submits that the accused who is the younger brother of the
complainant approached the complainant with the request to provide shelter for temporary
basis and heeding the request of the accused the complaiant permitted the accused to stay
for a temporary basis ; but the

3. The Complainant further submits that he approached the Accused

But acused failed. The accused evaded the issue on one pretext or other by telling the
complainant all sweet stories. The Complainant issued legal notices on _______. All the legal
notices were received and acknowledged by Accused but failed to give any reply. On _______,
the complainant here is lodged a police complaint against the Accused at ________ Police
Station. But the Police of _________does not register any case against Accused.

4. The complainant further submit to this Hon'ble Court that the Accused have
intentionally cheat the public at large and unfortunately complainant is one amongst them
and he was made a scape goat. The accused cheated the complainant.

5. The Complainant submits that the accused has dishonestly and fraudulently induced the
complainant to come and join as a member and misappropriated funds paid by the
complainant and also avoided the payments to the complainant only in order to cheat the
complainant and to cause wrongful loss to the complainant and wrongful gain to him by
adopting fraudulent means thereby the accused has committed offence U/sec.420 of IPC and
406 IPC.

JURISDICTION: The office of the accused is in ________ it falls under _________ Police Station
and this Hon'ble Court is having ample and territorial jurisdiction to try the case.

PRAYER:
It is therefore prayed that this Hon'ble Court may be pleased to refer U/sec.156(3)
CrPC to the P.S._______ for requesting a FIR under Sec.420 and 406 of IPC against the
accused and initiate prosecution against accused and to pass such other order or orders as
may deem fit and proper in the circumstances of the case as otherwise, the complainant
would be put to severe hardship and irreparable loss.
Dated:
Place: Medak Complainant

IDENTIFIED BY ATTESTED BY:

T. Ratan Singh, C. Srinath, A. Naresh Lal, G. Raghavender Reddy, B. Chandra Shekar
Advocate Advocate:: Medak

VERIFICATION

I, do hereby state and verify that this is my name and signature and the facts stated
hereinabove are true and correct to the best of my knowledge, information and belief.

Place:Medak
DATE : COMPLAINANT

LIST OF DOCUMENTS

Sno Date Parties to the Document Particulars of the Document

1
2
3
4
5
6
7

COUNSEL FOR COMPLAINANT COMPLAINANT

Medak
Date:
 IN THE COURT OF THE
IN THE COURT OF THE HON'BLE XIX
METROPOLITAN MAGISTRATE,CYBERABAD,AT
Miyapur

C.C NO. OF 2014

Between:

D.venkat swamy
...Complainan

AND

D.Trivikrama Bhopal
...Accused

COMPLAINT U/S.200 CR.PC.

Filed on:

Filed by: T. Ratan Singh, C. Srinath, A. Naresh Lal

G. Raghavender Reddy, B. Chandra Shekar
Counsel for Complainant.

------------------------------
Address for Service:

M/s M/s. R.S. Associates, T. Ratan Singh, C.

Srinath, A. Naresh Lal, G. Raghavender Reddy, B.
Chandra Shekar, Advocates, H.No.24-43/2, Beside
Triveni Talent School, Ashok Nagar,
Ramachandrapuram, Hyderabad-32. Cell:
9912428035.
 IN THE COURT OF THE IN THE COURT OF THE HON'BLE XIX METROPOLITAN
MAGISTRATE,CYBERABAD,AT Miyapur

C.C.NO. OF 2014

Between:

D.venkat swamy
... Complainant
AND

D.Trivikrama Bhopal
... Accused

I, , do hereby appoint and retain

T. Ratan Singh, C. Srinath, A. Naresh Lal, G. Raghavender Reddy, B.

Chandra Shekar
Advocate

Advocate/s to appear for me/us in the above Suit/Appeal/Petition/Case and to conduct

and prosecute or defend the same and all proceedings that may be taken in respect of any
application for execution of any decree or order passed therein. I/We empower my/our
Advocate/s to appear in all miscellaneous proceedings in the above suit or matter till all
decrees or order are fully satisfied, or adjusted, to compromise and obtain the return of
documents and draw any money that might be payable to me/us in the said suit or matter
and I/We do further empower my/our Advocate/s to accept on my/our behalf service of
notice of all or any appeal or petition filed in any court or appeal Reference or Revision with
regard to the said suit or matter before disposal of the same in Honourable Court.

I certified that the executant who is well acquainted with English, read this Vakalatnama
that the contents of this Vakalatnama were read out and explained in Urdu/Hindi/Telugu to
the executant he/she/they being unacquainted with English, who appeared perfectly to
understand the same and signed or put his/her/their name or mark in my presence.

Identified by Sri _______________________________

Executed on ADVOCATE
 IN THE COURT OF THE
IN THE COURT OF THE HON'BLE XIX
METROPOLITAN MAGISTRATE,CYBERABAD,AT
Miyapur

C.C NO. OF 2014

Between:

D.venkat swamy
...Complainan

AND

D.Trivikrama Bhopal
...Accused

VAKALAT
ACCEPTED

FILED ON:

Filed by: T. Ratan Singh, C. Srinath, A. Naresh Lal

G. Raghavender Reddy, B. Chandra Shekar

------------------------------
Address for Service:
M/s M/s. R.S. Associates, T. Ratan Singh, C.
Srinath, A. Naresh Lal, G. Raghavender Reddy, B.
Chandra Shekar, Advocates, H.No.24-43/2, Beside
Triveni Talent School, Ashok Nagar,
Ramachandrapuram, Hyderabad-32. Cell:
9912428035.
 FORM No.7
LIST OF DOCUMENTS
(Rule 16,17 and 102 of Civil Rules of Practice 1983)
(Order VII Rule-14 or Order XIII Rule-1 of the Code of Civil Procedure 1908)

IN THE COURT OF THE IN THE COURT OF THE HON'BLE XIX METROPOLITAN

MAGISTRATE,CYBERABAD,AT Miyapur

C.C.NO. OF 2014

Between:

D.venkat swamy
... Complainant
AND

D.Trivikrama Bhopal
... Accused

List of Document filed by Complainant

Sno. Date of Document Parties of the Description of the

in English Document Documents
Vernacular

Date:
Medak Advocate for Complainant
 IN THE COURT OF THE
IN THE COURT OF THE HON'BLE XIX
METROPOLITAN MAGISTRATE,CYBERABAD,AT
Miyapur

C.C NO. OF 2014

Between:

D.venkat swamy
...Complainan

AND

D.Trivikrama Bhopal
...Accused

LIST OF DOCUMENTS

FILED ON:

FILED BY:

M/s M/s. R.S. Associates, T. Ratan Singh, C.

Srinath, A. Naresh Lal, G. Raghavender Reddy, B.
Chandra Shekar, Advocates, H.No.24-43/2, Beside
Triveni Talent School, Ashok Nagar,
Ramachandrapuram, Hyderabad-32. Cell:
9912428035.

COUNSEL FOR PETITIONER

 FORM No.61
(171 Payment into the Court of Cash/Process Fee Deposit)

IN THE COURT OF THE IN THE COURT OF THE HON'BLE XIX METROPOLITAN

MAGISTRATE,CYBERABAD,AT Miyapur

C.C.NO. OF 2014

Between:

D.venkat swamy
... Complainant
AND

D.Trivikrama Bhopal
... Accused

Class of Allowance
Subsistence

CommissionExpenses of Sale or
and fro the Court House.Travelling allowance to
process is to be executed.

Munsiff where process isVillage, Taluq, District,

court houseDistance in miles from the

Name and Description of
which money is deposited

Person on whom or on
which deposit made. Nature of process to be

and order if any under

Allowance
issued for purpose for

whose property the

AMOUNT

Process Fees
D.Trivikrama Bhopal S/o
D.Munichandram
Age: years,occ:
R/o.H.no.4-79/1,Tara nagar,
Lingampally,chanda nagar,
R.R.District.

It is requested that the sum of Rs.______ may be received from the purpose above mentioned.

Date: Advocate for Plaintiff

Medak
 IN THE COURT OF THE
IN THE COURT OF THE HON'BLE XIX
METROPOLITAN MAGISTRATE,CYBERABAD,AT
Miyapur

C.C NO. OF 2014

Between:

D.venkat swamy
...Complainan

AND

D.Trivikrama Bhopal
...Accused

PROCESS FORM

FILED ON:

FILED BY:

M/s M/s. R.S. Associates, T. Ratan Singh, C.

Srinath, A. Naresh Lal, G. Raghavender Reddy, B.
Chandra Shekar, Advocates, H.No.24-43/2, Beside
Triveni Talent School, Ashok Nagar,
Ramachandrapuram, Hyderabad-32. Cell:
9912428035.

ADVOCATE FOR COMPLAINANT

 SUMMONS TO AN ACCUSED PERSON SUMMONS TO AN ACCUSED PERSON
(Sec.61 of CrPC) (Sec.61 of CrPC)

IN THE COURT OF THE IN THE COURT OF THE IN THE COURT OF THE IN THE COURT OF THE
HON'BLE XIX METROPOLITAN HON'BLE XIX METROPOLITAN
MAGISTRATE,CYBERABAD,AT Miyapur MAGISTRATE,CYBERABAD,AT Miyapur

C.C.No. OF 2014 C.C.No. OF 2014

Between:
Between:
D.venkat swamy
Complainant D.venkat swamy
AND Complainant
D.Trivikrama Bhopal AND
Accused D.Trivikrama Bhopal
To Accused
D.Trivikrama Bhopal S/o D.Munichandram To
Age: years,occ: D.Trivikrama Bhopal S/o D.Munichandram
R/o.H.no.4-79/1,Tara nagar, Age: years,occ:
Lingampally,chanda nagar, R/o.H.no.4-79/1,Tara nagar,
R.R.District. Lingampally,chanda nagar,
R.R.District.

Whereas your attendance is necessary answer to

Charge of __________________ Whereas your attendance is necessary answer to
___________________________________________ Charge of __________________
___________________________________________
You are hereby directed to appear in person or by
Pleader before the Hon’ble IN THE COURT OF THE You are hereby directed to appear in person or by
HON'BLE XIX METROPOLITAN Pleader before the Hon’ble IN THE COURT OF THE
MAGISTRATE,CYBERABAD,AT Miyapur on the day HON'BLE XIX METROPOLITAN
_____________ 10-30 AM Dated this __________ day MAGISTRATE,CYBERABAD,AT Miyapur on the day
__________ 2014. _____________ 10-30 AM Dated this __________ day
__________ 2014.

Seal Magistrate
Seal Magistrate

SUMMONS TO AN ACCUSED PERSON SUMMONS TO AN ACCUSED PERSON

(Sec.61 of CrPC) (Sec.61 of CrPC)

IN THE COURT OF THE IN THE COURT OF THE IN THE COURT OF THE IN THE COURT OF THE
HON'BLE XIX METROPOLITAN HON'BLE XIX METROPOLITAN
MAGISTRATE,CYBERABAD,AT Miyapur MAGISTRATE,CYBERABAD,AT Miyapur

C.C.No. OF 2014 C.C.No. OF 2014

Between:
Between:
D.venkat swamy
D.venkat swamy Complainant
Complainant AND
AND D.Trivikrama Bhopal
D.Trivikrama Bhopal Accused
Accused To
To D.Trivikrama Bhopal S/o D.Munichandram
D.Trivikrama Bhopal S/o D.Munichandram Age: years,occ:
Age: years,occ: R/o.H.no.4-79/1,Tara nagar,
R/o.H.no.4-79/1,Tara nagar, Lingampally,chanda nagar,
Lingampally,chanda nagar, R.R.District.
R.R.District.

Whereas your attendance is necessary answer to

Whereas your attendance is necessary answer to Charge of __________________
Charge of __________________ ___________________________________________
___________________________________________
You are hereby directed to appear in person or by
You are hereby directed to appear in person or by Pleader before the Hon’ble IN THE COURT OF THE
Pleader before the Hon’ble IN THE COURT OF THE HON'BLE XIX METROPOLITAN
HON'BLE XIX METROPOLITAN MAGISTRATE,CYBERABAD,AT Miyapur on the day
MAGISTRATE,CYBERABAD,AT Miyapur on the day _____________ 10-30 AM Dated this __________ day
_____________ 10-30 AM Dated this __________ day __________ 2014.
__________ 2014.

Seal Magistrate
Seal Magistrate