IN THE HON’BLE LE HIGH COURT OF JUDICATURE OF STATE OF

TELANGANA

AT HYDERABD

(ORIGINAL CRIMINAL JURISDICTION)

WRIT PETITION NO_________OF _________2020

S/O _________

Age -----------YEARS

Resident of _________
PETITIONER

Versus

1 STATE OF TENAGANA

Rep by Its Chief Secretary

2. MINISTRY OF HOME AFFAIRS, GOVERNMENT OF TELANAGANA

Rep. by Its Secretary

3. COMMISSIONER OF HYDERABAD. TELANAGANA

4. INSPECTOR OF POLICE, NAMPALLY POLICE STATION , HYDERABD

----RESPONDENTS

AFFIDAVIT FILED BY THE PETITIONER U/O XIX OF CIVIL

PROCEDURE CODE,1908 ALONG WITH WRIT PETITION UNDER
ARTICLE 226 OF THE CONSTITUTION FOR THE ISSUE OF A WRIT OF
MANDAMUS.

To
The Hon’ble Chief Justice and his companion Judges of the Hon’ble
High Court of Judicature at _________.

The above named Petitioner humbly submits as under:

1. That the Petitioner is the resident of …………………Hyderabad

within the local limits of owner the Respondent Nos 3 & 4 Police, of
the Telanagana State ( Respondents Nos 1& 2).

2. That on _1st August, 2020 the petitioner went to the Respondent

No.4 Nampally Police Station to inform and lodge a complaint
against one Mr. C, S/o ………… age 35 years , Resident of ……………..,
within the local limits of Respondents No.3 &4 for threatening and
intimidating him and his family with dire consequences if he don’t
stop construction in the premises of his building situated at and
within the local limits of the Respondents 3 & 4. The Respondent
No.4 police have received the report and directed the petitioner to
come after Two days without giving him any acknowledgement of
receiving the receipt from him. ( Report enclosed as Annexure I)
3. That the Petitioner accordingly went to the Respondent No.4 police
after Two days i.e., on 3rd August , 2020 and enquired the police
about his report and complaint dated 1st August, 2020. The
Respondent No.4 police asked the petitioner to come after few days
as the reported matter is under enquiry.

4. That on 8th August, 2020 the petitioner went to the respondent

No.4 Police Station and insisted them to register his complaint as FIR
and to give him an Acknowledgement towards the same. But the
Respondent No.4 Police refused to register his complaint on the
ground that it is a Civil case and they don’t involve in it.
5. That upon the refusal of the Respondent No4 to register the
complaint lodged by the petitioner dated 1st August,2020, the
Petitioner sent his complaint to the Respondent No.3 , Commissioner
of Police, Hyderabad by Registered post ( Postal receipt, Copy of the
Report enclosed herewith as Annexures I & II) on 10 th August , 2020
and also by an e-mail : Hyderabadpolice @ Telanagana State Gov.
org.in.But no action till date of this Writ Petition in that respect by
the Respondents Nos 3 & 4. Hence this Writ Petition.

6. That the Petitioner states and submits that the acts of

Respondents No.3 & 4 in not registering the complaint and case of
the petitioner is grave and injurious to the life and property of the
Petitioner and his family members as the threats and intimidation by
Mr. C are continuous till date. Hence for this reasons the petitioner
intends to file this Writ Petition seeking a Writ of Mandamus before
this hon’ble Court on the following grounds among the other;

GROUNDS

1.

2.

3.

4.

5.

It is, therefore, most respectfully prayed that a writ, direction or

order in the nature of mandamus be issued to Respondent No. 1 to 4 ,
More particularly Respondents Nos 3 & 4 directing them to register
the case case against Mr.C and to take necessary action and to take
measures to protect the life and property of the petioner and his
family members and also the Respondents No.1 & 2 ensure the
implementation of the fundmantal rights of the petitioner and also to
pass any other direction order to the Respondent No1 to pay Just and
reasonable compensation to the petioner for the daely and hardship
caused by the respondents Nos 3 &4 in the interest of Justice.

BE PLEASED TO CONSIDER

ADVOCATE FOR TH PETITIONER PETITIONER

DATE:

PLACE:

VERIFICATION

DEPONENT/PETITIONER

ATTESTATION

ATTESTING OFFICER

LIST OF DOCUMENTS/ANNEXURES