IN THE COURT OF THE SPL. J.F.C.M.

(FOR PROHIBITION AND

EXCISE OFFENCES) AT NALGONDA.

Crl.M.P. No. OF 2014

IN
C.C.NO. 542 OF 2012
Between:

A. Venkatesham S/o Maraiah Aged 46 years, Occ: Business

R/o Siddartha Colony, D.V.K. road, Nalgonda town and District.
………….Petitioner/Accused
AND

Dokuri Prabhakar Reddy S/o Ram Narsimha Reddy Aged 48 years, Occ:
Business R/o Siddhartha Colony D.V.K. Road, Nalgonda town and District.

……….. Respondent/Complainant

PETITION FILED U/S 145 (2) OF N.I. ACT R/W 311 OF Cr.P.C.

1) It is submitted that the respondent launched the above proceedings against

the petitioner with forged documents by way of material alterations and
insertions over Ex.P-1 i.e., Promissory note.

2) It is submitted that the respondent with collusion of Pw-2 and one Burri
Janardhan Reddy, S/o Ram Reddy, R/o Ramagiri, Nalgonda town and District, in
the Ex.P-1 the amount column Rs.10,00,000/- was altered to 70,00,000/- by
altering the 1 to 7 and claiming as total consideration under Ex.P-1 is
Rs.70,00,000/-, and as per the evidence of the respondent and Pw-2 who
disposed before the Hon’ble court that the entire contents over Ex.P-1 scribed by
the one Burri Janardhan Reddy.

3) It is submitted that as a matter of fact actually the petitioner was scribed the
amount column as 10,00,000/- and date column 5.12.2010 in Ex.P-1 as the
version of the respondent that the one Burri Janardhan Reddy was scribed of
entire the contents of Ex.P-1, but the amount column and date columns was filled
up by the petitioner himself, as such the petitioner already launched criminal
prosecution U/Sec. 200 of Cr.P.C. against the respondent and Pw-2 and the said
Burri Janardhan Reddy in view of U/sec. 195 of Cr.P.C., and the same was
registered by Nalgonda I town Police station with Crime No.241/2012 for the
offences U/secs. 417,418,420, 463 to 465, 467 to 469, 471, 474 R/W 34 of I.P.C.
the copy of the F.I.R was already marked as Ex.D-2 which is pending for
investigation.
Contd…2
 // 2 //

4) It is submitted that in the above proceedings the petitioner expected the

appearance of the said Burri Janardhan Reddy as a witness on behalf of the
respondent, but in view of defense of petition the respondent wontedly avoided
to produce the said Burri Janardhan Reddy before the Hon’ble court as a witness.

5) It is submitted that to prove the defense of the petitioner the Burri Janardhan
Reddy is just and essential for examination before the Hon’ble court to confront
of the Hand writing over Ex.P-1 and also the hand writing of the Burri
Janardhan Reddy is required to compare the hand writing over the Ex.P-1 to
send Hand writing expert.

6) It is submitted that in the above stated facts and circumstances it is just

and necessary to summon the said Burri Janardhan Reddy to give the evidence
as it is essential to the decision of the case.

Therefore the Hon’ble court may be pleased to issue summons to the said
Burri Janardhan Reddy, S/o Ram Reddy, R/o Ramagiri locality of Nalgonda
town and District as a witness in the above proceedings, in the interest of justice.

Nalgonda, Petitioner/Accused

12-08-2014
(A.Venkatesham)

Advocate for the petitioner/Accused.

 IN THE COURT OF THE SPL.
J.F.C.M.(FOR PROH & EXCISE
OFFENCES): AT NALGONDA

Crl.M.P.NO. OF 2014
IN
C.C.NO. 542 OF 2012

Between:-
A. Venkatesham
.
……Petitioner/Accused

AND

D. Prabhakar Reddy.

…Respondent/Complainant.

PETITION FILED U/S 145 (2)

OF N.I ACT R/W 311 OF Cr.P.C.

Filed on: 18 -03-2013

Filed by the Petitioner/Accused

Address for service:

Kampati Venkateshwarlu
Advocate, Nalgonda