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APPLICATION FOR REVISION MEMORANDUM OF CRIMINAL REVISION PETITION UNDER SECTION 397 AND 401 OF CRPC

IN THE HIGH COURT OF PUNJAB AND HARYANA CANDIGARH Crl. R. C. No of 2011

ABC, son of........., aged about........ years, resident of....... AND The State of Punjab Rep by its P.P. High Court of Punjab and Haryana Respondent/Complainant .....Petitioner/appellant/accused

The address for service to the petitioner is that of his counsel M/s. D. N. Goyal & Associates, Advocates, Patiala

The above named petitioner begs to present this memorandum of Criminal Revision Petition to this Honble Court against the judgment made in Cr.A. No. of 2011 on the file of the Court of Sessions judge,.dated for the following among other grounds. Grounds 1. That the order of the lower Court is contrary to law, weight of evidence and probabilities of the case. 2. That the learned Magistrate has erred in law in taking cognizance of the case and as such conviction is liable to be set aside.

3. That the lower Court failed to appreciate the testimony of the investigation of the Investigation Officer as unbelievable and unreliable. 4. That the learned Magistrate was wrong in disbelieving the two respectable and independent witnesses examined on behalf of the defense. 5. That the prosecution failed to prove their case beyond all reasonable doubts. 6. The other grounds that may be urged at the time of hearing of the criminal Revision case. Place: Dated :

Counsel for the Petitioner

Verification:

I, ______, do hereby verify that the contents from paras 1 to ______ are correct and true to the best of my knowledge and personal belief and no part of it is false and nothing material has been concealed therein. Affirmed at Chandigarh this ______. Plaintiff / Defendant

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