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Prathap Reddy 91 CR.P.C

The petitioner/complainant filed cases against two respondents/accused under Section 138 of the Negotiable Instruments Act for non-payment of loans. The petitioner/complainant's evidence was closed by the court without recalling him for cross-examination. The petitioner has now filed petitions under Section 311 of the Criminal Procedure Code seeking to recall the petitioner/complainant's evidence for cross-examination in the interest of justice and to avoid irreparable loss, as the cases are coming up for arguments. The petitioner/complainant seeks appropriate orders from the Honorable Court.

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327 views9 pages

Prathap Reddy 91 CR.P.C

The petitioner/complainant filed cases against two respondents/accused under Section 138 of the Negotiable Instruments Act for non-payment of loans. The petitioner/complainant's evidence was closed by the court without recalling him for cross-examination. The petitioner has now filed petitions under Section 311 of the Criminal Procedure Code seeking to recall the petitioner/complainant's evidence for cross-examination in the interest of justice and to avoid irreparable loss, as the cases are coming up for arguments. The petitioner/complainant seeks appropriate orders from the Honorable Court.

Uploaded by

RatanSinghSingh
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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IN THE COURT OF THE HON’BLE IV SPL.

MAGISTRATE
AT: KUKATPALLY

Crl. M.P. No. OF 2018


IN
C.C. No. 209 OF 2018

Between:

B. Pratap Reddy, S/o. Late. Narsimha Reddy ,


Aged about: 64 years Occ: Retd. BHEL Employee,
R/o. H. No.4-71/1/3, Kakatiya Nagar, Road No.2,
Ramachandrapuram, Sangareddy-502032.

…Petitioner/Complainant

AND

K.V.N. Chandra Rao, S/o. K. Nageshwar Rao,


Aged about: 40 years, Occ: Buasiness,
R/o. Kesavini Plot, G-10, Ground Floor,
Vinayaka Nagar, R.C. Puram, Dist: Sangareddy.

…Respondent/Accused

PETITION FLED UNDER SEC. 91 OF Cr. P.C

May it Please your Honour !

It is submitted that the petitioner/complainant filed the above


case under sec. 138 of NI Act against the respondent /accused and the
same is coming for the further evidence.

It is submitted that respondent/accused denied the hand loan


from the petitioner/complainant during the cross examination of the
petitioner/complainant. It is pertinent to mention that the
petitioner/complainant paid the hand loan in installments to the
respondent /accused. The petitioner/complainant wants to examine the
branch manager of the S.B.I BHEL Township Hyderabad, BHEL
Township R.C. Puram Branch as such it is just and necessary to
summon the Bank manager and direct to produce entire details of the
S.B.I BHEL Township Hyderabad, BHEL Township R.C. Puram Bank
A/C. No. 52190382153. It is very crucial evidence to prove the case of
the petitioner/complainant and no prejudice will be caused to the
respondent/accused.

Therefore it is prayed that this Hon’ble court may be pleased to


summon to the Branch Manager , S.B.I BHEL Township Hyderabad,
BHEL Township R.C. Puram Branch, as a witness and direct to produce
::2::

the Bank Statement of the petitioner/complainant for the period


of 01-01-2013 to 01-09-2014 of A/C. No. 52190382153 in the interest
of justice.

Place:
Date : Counsel for Petitioner/Complainant
IN THE COURT OF THE HON’BLE IV SPL. MAGISTRATE
AT: KUKATPALLY

Crl. M.P. No. OF 2018


IN
C.C. No. 210 OF 2018

Between:

B. Pratap Reddy, S/o. Late. Narsimha Reddy ,


Aged about: 64 years Occ: Retd. BHEL Employee,
R/o. H. No.4-71/1/3, Kakatiya Nagar, Road No.2,
Ramachandrapuram, Sangareddy-502032.

…Petitioner/Complainant

AND

R. Satya Narayana, W/o. Rama Krishna,


Aged about: 54 years, Occ: Stock Verification Officer,
R/o. SPR Three Homes, H.No.102, Madhavapuri Hills,
P.J.R.Colony, Mandal Ameenpur, Sangareddy-502032.

…Respondent/Accused

PETITION FLED UNDER SEC. 91 OF Cr. P.C

May it Please your Honour !

It is submitted that the petitioner/complainant filed the above


case under sec. 138 of NI Act against the respondent /accused and the
same is coming for the further evidence.

It is submitted that respondent/accused denied the hand loan


from the petitioner/complainant during the cross examination of the
petitioner/complainant. It is pertinent to mention that the
petitioner/complainant paid the hand loan in installments to the
respondent /accused. The petitioner/complainant wants to examine the
branch manager of the S.B.I BHEL Township Hyderabad, BHEL
Township R.C. Puram Branch as such it is just and necessary to
summon the Bank manager and direct to produce entire details of the
S.B.I BHEL Township Hyderabad, BHEL Township R.C. Puram Bank
A/C. No. 52190382153. It is very crucial evidence to prove the case of
the petitioner/complainant and no prejudice will be caused to the
respondent/accused.

Therefore it is prayed that this Hon’ble court may be pleased to


summon to the Branch Manager , S.B.I BHEL Township Hyderabad,
BHEL Township R.C. Puram Branch, as a witness and direct to produce
::2::

the Bank Statement of the petitioner/complainant for the period


of 01-01-2013 to 01-09-2014 of A/C. No. 52190382153 in the interest
of justice.

Place:
Date : Counsel for Petitioner/Complainant
IN THE COURT OF THE HON’BLE III SPL. MAGISTRATE
AT: KUKATPALLY
Crl. M.P. No. OF 2018
IN
C.C. No. 210 OF 2018

Between:

B. Pratap Reddy, S/o. Late. Narsimha Reddy ,


Aged about: 64 years Occ: Retd. BHEL Employee,
R/o. H. No.4-71/1/3, Kakatiya Nagar, Road No.2,
Ramachandrapuram, Sangareddy-502032.

…Petitioner/Complainant

AND

R. Satya Narayana, W/o. Rama Krishna,


Aged about: 54 years, Occ: Stock Verification Officer,
R/o. SPR Three Homes, H.No.102, Madhavapuri Hills,
P.J.R.Colony, Mandal Ameenpur, Sangareddy-502032.

…Respondent/Accused

PETITION FLED UNDER SEC. 311 OF Cr. P.C

May it Please your Honour !

It is submitted that the petitioner/complainant filed the above


case under sec. 138 of NI Act against the respondent /accused and it is
coming for the Arguments.

It is submitted that this Hon'ble Court already Conducted the


chief and cross of PW-1 and posted for further evidence of the
petitioner/complainant, petitioner/complainant filed petition under
section 91 Cr.P.C it was allowed. The petitioner/complainant Not paid
the process fee on 05-11-2018. That day this Hon’ble court was closed
the Evidence of the petitioner/complainant. If the petitioner/complainant
evidence not re-called the petitioner may be put to irreparable loss and
damage. It is just and necessary to re-call the evidence of the
petitioner/complainant for cross-examination to meet the ends of justice
particularly to prove the innocence of the petitioner.

Therefore it is prayed that this Hon’ble Court may be pleased to


re-call the evidence of complainant and pass such other order or orders
as this Hon’ble court deem fit and proper in the interest of justice.

Place:
Date : Counsel for Petitioner/Complainant

IN THE COURT OF THE HON’BLE III SPL. MAGISTRATE


AT: KUKATPALLY
Crl. M.P. No. OF 2019
IN
C.C. No. 209 OF 2018

Between:

B. Pratap Reddy, S/o. Late. Narsimha Reddy ,


Aged about: 64 years Occ: Retd. BHEL Employee,
R/o. H. No.4-71/1/3, Kakatiya Nagar, Road No.2,
Ramachandrapuram, Sangareddy-502032.

…Petitioner/Complainant

AND

K.V.N. Chandra Rao, S/o. K. Nageshwar Rao,


Aged about: 40 years, Occ: Buasiness,
R/o. Kesavini Plot, G-10, Ground Floor,
Vinayaka Nagar, R.C. Puram, Dist: Sangareddy.

…Respondent/Accused

PETITION FLED UNDER SEC. 311 OF Cr. P.C

May it Please your Honour !

It is submitted that the petitioner/complainant filed the above


case under sec. 138 of NI Act against the respondent /accused and it is
coming for the Arguments.

It is submitted that this Hon'ble Court already Conducted the chief


and cross of PW-1 and posted for further evidence of the
petitioner/complainant, petitioner/complainant filed petition under
section 91 Cr.P.C it was allowed. This Hon’ble court was closed the
Evidence of the petitioner/complainant. If the petitioner/complainant
evidence not re-called the petitioner may be put to irreparable loss and
damage. It is just and necessary to re-call the evidence of the
petitioner/complainant for cross-examination to meet the ends of justice
particularly to prove the innocence of the petitioner and other grounds
will be urged at the time of the argument.

Therefore it is prayed that this Hon’ble Court may be pleased to


re-call the evidence of complainant and pass such other order or orders
as this Hon’ble court deem fit and proper in the interest of justice.
Place:
Date : Counsel for Petitioner/Complainant

IN THE COURT OF THE


HON’BLE III SPL.
MAGISTRATE,
AT: KUKATPALLY

Crl. M.P. No. OF 2019


IN
C.C. No. 210 OF 2018

BETWEEN:

B. Pratap Reddy

…Petitioner/Complainant

AND

R. Satya Narayana
…Respondent/Accused

PETITION FLED UNDER SEC.


311 OF Cr. P.C

FILED ON:

FILED BY: Counsel for


Petitioner/Complainant
___________________________
M/s. R.S. ASSOCIATES,
T. RATAN SINGH,
A. ASHWIN GOUD,
ADVOCATES,
#24-43/2, Beside Triveni Talent
School, Ashoknagar, R.C. Puram,
HYDERABAD-32.
IN THE COURT OF THE HON’BLE III SPL. MAGISTRATE
AT: KUKATPALLY
Crl. M.P. No. OF 2018
IN
C.C. No. 210 OF 2018

Between:

B. Pratap Reddy, S/o. Late. Narsimha Reddy ,


Aged about: 64 years Occ: Retd. BHEL Employee,
R/o. H. No.4-71/1/3, Kakatiya Nagar, Road No.2,
Ramachandrapuram, Sangareddy-502032.

…Petitioner/Complainant

AND

R. Satya Narayana, W/o. Rama Krishna,


Aged about: 54 years, Occ: Stock Verification Officer,
R/o. SPR Three Homes, H.No.102, Madhavapuri Hills,
P.J.R.Colony, Mandal Ameenpur, Sangareddy-502032.

…Respondent/Accused

PETITION FLED UNDER SEC. 311 OF Cr. P.C

May it Please your Honour !

It is submitted that the petitioner/complainant filed the above


case under sec. 138 of NI Act against the respondent /accused and it is
coming for the Arguments.

It is submitted that this Hon'ble Court already Conducted the


chief and cross of PW-1 and posted for further evidence of the
petitioner/complainant, petitioner/complainant filed petition under
section 91 Cr.P.C it was allowed. This Hon’ble court was closed the
Evidence of the petitioner/complainant. If the petitioner/complainant
evidence not re-open the petitioner may be put to irreparable loss and
damage. It is just and necessary to re-open the evidence of the
petitioner/complainant for cross-examination to meet the ends of justice
particularly to prove the innocence of the petitioner.

Therefore it is prayed that this Hon’ble Court may be pleased to


re-open the evidence of complainant and pass such other order or
orders as this Hon’ble court deem fit and proper in the interest of justice.

Place:
Date : Counsel for Petitioner/Complainant

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