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IN THE COURT OF THE HONBLE XI ADDITIONAL CHIEF METROPOLITAN MAGISATRATE

AT: SECUNDERABAD

CRL.M.P .No. OF 2013

IN

C .C. No. 334 OF 2010
BETWEEN :

SMT. KANDUR JHANSI,
W/o Raghuram Raju;
R/o Near Government School,
Yarasangam Village,
Saidhapuram Mandal, Nellore Dist,.
PETITIONER/ACCUSED
AND

THE STATE OF A.P.
Through P.S. Trimulgiri,
Represented By Public Prosecutor

RESPONDENT/COMPLAINANT

PETITION FILED UNDER SECTION 70(2) OF CODE OF CRIMINAL PROCEDURE


May it please your honor!

1. It is submitted that, the above petitioner is accused. The crime was registered
with Trimulgiri police vide crime No.228 of 2007. Thereafter being in receipt of
knowledge of the said case, the petitioner accused approached the Honble
High Court of the Andhra Pradesh and obtained anticipatory bail under the
orders passed in Crl. M.P.No.1505 of 2010. Subsequently the petitioner
furnished the sureties and bonds as directed by the Honble High Court of the
Andhra Pradesh.

2. It is submitted that, thereafter the petitioner was made aware about the
present CC on the file before this Honble Court through Mr. N Damodar Raju,
who stood as the surety for the petitioner herein. On verification of the file
before this Honble Court, it was learned by the petitioner that this Honble
Court was pleased to issue Non-bailable Warrant against the petitioner herein
on 09.07.2013.

3. It is submitted that, here it is pertinent to mention that the petitioner herein
had never at any point of time received any summon from this Honble Court,
as such the petitioner herein could not appear before this Honble Court. In
the event the petitioner would have received any summon / notice from this
Honble Court the petitioner would have surely appeared before this Honble
Court.

4. It is submitted that, it is for the aforementioned reason the petitioner could
not appear before this court on the 09.07.2013, resulting which subject matter
NBW was issued. The petitioner vide this petition seeks this Honble to re-call
NBW issued against him, in pursuance of reasons mentioned herein above.

5. It is submitted that, in the event the present petition is not allowed, then the
petitioner shall put to irreparable loss and injury which cannot be compensated
in any manner. The petitioner ready and willing to comply with any condition
as imposed by this Honble Court in pursuance of re-calling the NBW.

Therefore for the aforementioned facts and circumstances, it is prayed that this
Honble Commission may be pleased to Re-call the NBW issued on 09.07.2013 and pass
other such Order/s or Direction/s as this Honble Commission deems fit and proper in
the circumstances of the case and in the best interest of Justice & Equity.

PLACE: Secunderabad

DATE:

COUNSEL FOR PETITIONER