IN THE COURT OF THE HON’BLE___ADDITIONAL CHIEF

METROPOLITAN MAGISTRATE, CITY CIVIL COURTS

AT:MALKAJGIRI
C.C.NO OF 2017
BETWEEN:
Sri. T. Krishna Goud, S/0. Krishna R/o. 4- 59/6, Thumukunta Shamirpet
Mandal Telangana
COMPLAINANT
AND
Sri. P. Shankar, S/o. Krishnaiah R/o. H. No. 37- 379, Somiah Nagar
Jagadgirigutta Quthbullapur Mandal Telangana State

ACCUSED
COMPLAINT FILED U/S.200 OF CR.PC.
OFFENCES COMMITTED BY THE ACCUSED U/S. 138& 142 OF
N.I. ACT

Date of offence: The cheque bearing no. 000008 dated 10/06/2019

was presented for its realization on 3/07/2019 and bounced back due
to in-sufficient funds with a return memo dated 3/07/2019. Further on
19-08-2019 once again the cheque was presented on 19-8-2019 and
the cheque was bounced back once again. And the legal notice was
issued on 28-08-2019 and the accused received on 30-08-2019 and
acknowledgement was not received but obtained postal department's
tracking record. Further the accused sent a legal notice dt. 30-9-2019
through their counsel.
Place of offence: Vijay bank Thumkunta where the complainants
account is maintained and presented for realization.
P.S.Limits: Police Station Shamirpet
List of Witnesses:
1. Complainant Himself.
2.Sri. T. Anjaneyulu, S/o. Krishna Goud
3.
Contd…P/2.
 The complainant humbly submits the facts of this case as under:-

1. That the complainant and the accused are distant relatives and
the accused approached the complainant to lend a sum of Rs.
1,50,000/- ( Rupees. One Lakh and Fifty Thousands only ) as a
hand loan promising to pay back within 3 months. The
complainant having good faith, gave the sum of Rs. 1,50,000/- by
cash to the accused with a condition that as per the promise the
accused has to return the amount within three months.

2. After the completion of three months the complainant

approached the accused to pay back the said amount of Rs.
1,50,000/-. The accused gave a cheque No. 000008 Dt. 10- 06-
2019 for an amount of Rs. 1,50,000/-
3. The complainant presented the cheque at Thumukunta Branch of
Vijaya Bank on 3-7- 2019. The cheque was bounced with a
remark of Insufficient Funds. This was informed to the accused
and the accused requested to represent the same cheque with a
promise to deposit the amount in the account. Accordingly the
complainant deposited the cheque on 19-8-2019. Once again the
cheque was bounced.
4. The complainant was forced to give a statutory legal notice on
28-8-2019 requesting to make arrangements to pay the
borrowed money due to the complainant. In return the accused
gave a Legal Notice.
5. The complainant further submit that the accused has got the
intention to cheat the complainant and deliberately not maintain
sufficient funds in the account and made the complainant to
suffer and loss. The acts, things and deeds of the accused in
issuing the cheque having not maintaining sufficient funds
amounts to deliberate and wanton and thereby the accused has
committed offences u/s 138 and 142 of NI Act and the accused is
liable for punishment u/s 138 and 142 of the NI Act.
LIMITATION
The cheque was issued on 10-6-2019 and presented on 3-7-2019
and again on 19-8-2019. But the cheque was dishonored with a
caption of insufficient funds. The return memos dated 3-7-2019
and 19-8-2019 were received by the complainant from Vijaya
bank Thumukunta Branch. The complainant issued the statutory
notice on 28-8-2019 and the same was received by the accused
on 30-8-2019 as per the postal track.
Contd…p/3
JURISDICTION

The complainant had deposited the cheque bearing 000008

dated 10- 06- 2019 drawn on Andhra bank deposited the cheque
at Vijaya Bank Thumkunta where the complainant is maintaining
the account which is within the local limits of police station
Shameerpet MedchalMalkajgiri district. Hence this honorable
court is having jurisdiction to take cognizance of the offence and
to punish the accused as per law.

PRAYER
In the above facts and circumstances the complainant herein
humbly prays that this Hon'ble Court may be pleased to

1. Take cognizance of the case on file, issue notice to the accused

and enquire the matter and punish the accused with maximum
sentence according to law.

2. and pass an order against the accused for the payment of

compensation U/S. 357 of the CRPC with cost of legal notice etc,
payable to the complainant by the accused for maximum and
pass such other order or orders as this honorable court may
deem fit and proper in the circumstances of the case and in the
interest of justice.
Place: Secunderabad
Date:
Counsel for complainant Complainant

VERIFICATION

I, T. Krishna Goud, S/0. Krishna R/o. 4- 59/6, Thumukunta

Shamirpet Mandal Telangana the complainant herein admit and
verified and state that the contents of the above complaint paras
are true and correct to the best of my knowledge, belief and on
information and hence, verified on this day of ______________.

Complainant
 FORM NO 7. LIST OF DOCUMENTS (RULE 9.10 AND 62)
Under Order VII R-14 Or Order XIII RI of Civil Procedure
IN THE COURT OF THE HON’BLE___ADDITIONAL CHIEF
METROPOLITAN MAGISTRATE, CITY CIVIL COURTS
AT:MALKAJGIRI
C.C.NO OF 2017
BETWEEN:
Sri. T. Krishna Goud, S/0. Krishna R/o. 4- 59/6, Thumukunta Shamirpet
Mandal Telangana
COMPLAINANT
AND
1. Sri. P. Shankar, Smt. Dasari priyanka, w/o: Dasari Sai kranthi,
Somaiah Nagar Jagitgutta Kutbullapur Mandal Ranga Reddy
District

ACCUSED

List of Documents filed by : Complainant __________________

1. Copy of the cheque issued by the accused for Rs. 1,50,000/- Dt.
10-6-2019 bearing no. 000008
2. Return memos two nos from the Andhra Bank presented
through Vijaya bank with a caption of Funds Insufficient
3. Copy of the legal notice issued by the complainant to the
accused dt. 28-8-2019 issued to the accused.
4. Copy of the legal notice received by the complainant counsel
sent by the accused counsel dt. 30- 09- 2019.
5. Postal tracking record obtained by the complainant dt. 30-08-
2019
6. Regd Post Receipts RN 437632196Nl dt. 29-8-19