BEFORE HON’BLE COURT OF JUDICIAL MAGISTRATE FIRST

CLASS AT RAIPUR, CHHATTISGARH

Smt. Priyanka Naidu,

W/o Shri J Praksash Naidu
R/o: A/28, Green Orchid,
Avani Vihar, Dal dal seoni,
Mowa, Raipur, C.G
……………………… PETITIONER

V/s

Ms. Parvati Cement and marble Store

……… ………..RESPONDENT

Case Number: 2209/2014

Disposed on 12/10/2018

APPLICATION U/S 258 OF THE CODE OF CRIMINAL

PROCEDURE

MAY IT PLEASE YOUR HONOUR

Petitioner humbly beg to state as under –

1. That, the husband of the petitioner is the accused in the

aforementioned matter.
2. That, husband of the petitioner stays in Andhra Pradesh for
past few years and the health is not is good shape therefore he
is unable to appear before this Hon’ble Court.
3. That the Hon’ble Court on 12/10/18 was pleased to issue
permanent non bailable warrant against the accused.

4. That, Petitioner or her husband had no knowledge about the

proceedings before this Hon’ble Court in the instant matter.

5. That, the notice/ warrant was executed at the previous

address of the accused and their old neighbours gave the
current address of the petitioner for the execution of warrant.

6. That, Petitioner has come to learn from her husband/accused

that he settled the account of complainant long back but he
refused to return his security cheque using his muscle power
and local influence at Rewadi.

7. That, petitioner is staying alone at Raipur with her daughter

and is terrified by Police authorities approaching her for the
execution of warrant.

8. That, petitioner is not in good financial health and has to

spend for the education of her children but due to the
circumstances which have been cropped up in the instant
matter, she is taking loan from her retired father and is ready
to deposit the money before this Hon’ble Court.

9. That, the instant matter is a economic offence and can be

compounded with the permission of Court.

10. That, the Complainant is misusing his dominant position

in the society to harass lone lady by abusing process of law.
 PRAYER

It is, therefore, most respectfully prayed that this Hon’ble

Court may graciously be pleased to:

a) Allow the present Application under Section 258 of the

Criminal Procedure Court and To permit the petitioner to
deposit the cheque amount before this Hon’ble Court and close
the proceedings against her husband and his firm in the
intrest of justice

AND FOR THIS ACT OF KINDNESS, YOUR HUMBLE

PETITIONER, AS IS DUTY BOUND, SHALL EVER PRAY.

DRAWN AND FILED BY

[VIRAT VERMA]
Advocate for the Applicant
Raipur
FILED ON: 7/1/2019 Mob: 7389275931
BEFORE HON’BLE COURT OF JUDICIAL MAGISTRATE FIRST
CLASS AT RAIPUR, CHHATTISGARH

Smt. Priyanka Naidu,

W/o Shri J Praksash Naidu
R/o: A/28, Green Orchid,
Avani Vihar, Dal dal seoni,
Mowa, Raipur, C.G
……………………… PETITIONER

V/s

Ms. Parvati Cement and marble Store

……… ………..RESPONDENT

AFFIDAVIT

I, Priyanka Naidu, W/o Shri J Praksash Naidu , aged 38 years, R/o:

A/28, Green Orchid, Avani Vihar, Dal dal seoni, Mowa, Raipur,
C.G do hereby solemnly affirm and declare as under:-

1. That I am sole petitioner in the abovementioned Petition, as

such, am fully conversant with the facts and circumstances

of the present case and am competent to swear this

affidavit.
2. That I have read and understood the contents of the

accompanying Petition under Section 258 of the Criminal Procedure

Code. The contents of the same are true and correct and nothing

material has been concealed there from. The same has been

drafted by my counsels on my instructions.

DEPONENT

VERIFICATION:

Verified at Raipur on this the day of January, 2019, that

the contents of my above affidavit are true and correct. Nothing

material has been concealed there from.

DEPONENT