MEMORANDUM OF CRIMINAL REVISION CASE

UNDER SECTION 397 & 401 OF CRIMINAL PROCEDURE CODE, 1973

Crl.M.P.No.1816/2014 in CC No.199 of2013

In the Court of the XV Addl.Judge-cum_XIX Addl.Chief Metropolitan
Magistrate, Hyderabad.

IN THE HIGH COURT OF JUDICATURE AT HYDERABAD FOR THE

STATE OF TELANGANA AND THE STATE OF ANDHRA PRADESH

Crl.R.C.No. OF 2015

BETWEEN:

P.V.L.Narsimha Rao,
S/o.Late.Raghavendra Rao
Aged about 52years,Occ: Private Employee,
R/o.Plot No.8, Green Park Enclave, Kapra,
Hyderabad-500062
...Accused/Petitioner
AND

1.M/s. Vinutna Chit Fund Pvt.Ltd.

Rep.by its M.D.D.Ramagovinda Reddy,
S/o.Sitarama Reddy, aged 55years,
Occ: Business, R/o. 3-6-462/8, 1st Floor,
Sundersadan, Street No.5,
Himayath Nagar, Hyderabad.

2. D.Ramagovinda Reddy,
S/o.Sitarama Reddy, aged 55years,
Occ: Business, R/o. 3-6-462/8, 1st Floor,
Sundersadan, Street No.5,
Himayath Nagar, Hyderabad.
 
...Complainant/Respondent
 
The address for service of all notices and process on the above

named petitioner is that of his counsel M/s Vladimeer Khatoon,

Advocate H.No.16-11-16/G/S-2, Flat NO.401, Sai Sagar Sudha

Residency, Prashanth Nagar, Malakpet, Hyderabad-500036.

The above named petitioner begs to file this Criminal Revision Case

against the judgment and sentence passed by the learned XV

Addl.Judge-cum_XIX Addl.Chief Metropolitan Magistrate, Hyderabad. in

Crl.M.P.No.1816/2014 in CC No.199 of2013, dated 20-2-2015 for the

following grounds among other:

 GROUNDS

1. The judgment of the learned Judge is illegal, improper and

incorrect.

2. The learned Judge erred in holding that the petitioner-complainant

is not entitled for the relief of directing the Registrar of companies to

produce statement of account, form No.11, declaration form and

minutes book etc., and ought not have dismissed it which amounts to

denial of opportunity to place necessary evidence to prove the case of

the petitioner-complainant.

3. The lower court failed to see the fact that the previous

application seeking to direct the Respondent/Accused No.1 and 2 to

produce the said documents but not against the witness as narrated

in the Crl.M.P.No.1816/2014.

4. The lower court erred in considering the fact that the previous

application was partly allowed and i.e. to direct the

Respondents/Accused No/1& 2 to produce the Statement of account

and remaining reliefs are rejected.

5. The lower court ought to have considered the fact that it is

because of the failure on thepart of the respondents-accused 1 & 2 in

not producing the required documents, the petitoner complainant was

constrained to file the Crl.M.P.No.1816/2014 and as such the lower

court ought to have allowed it without dismissing the same.

6. The dismissal of the Crl.M.P.No.1816/2014 by the lower court is

nothing but denial of opportunity to the petitioner in proving his case

which is against to the principles of natural justice.

7. The lower court failed to take into consider the so called memo

filed by the respondents/accused No.1 and 2 filed memo on 29-09-

2014 that the petitioner/ Complainant is having all the relevant

receipts, respondents No.2/Accused No.2 discontinued the chit

business due to increase of defaults in the chit business, that

respondent No.1/ Accused No.1 represented by respondent

No.2/Accused No.2 further stated some miscreants destroyed the

books of respondent No.1/Accused No.1 in the business of respondent

No.2/Accused No.2 in a right and perspective manner.

8. The lower court failed to consider the fact that the petitioner-

complaint filed the application vide in Crl.M.P.No.1816/2014 filed

seeking direction to the registrar of company in view of the failure on

the respondents to to produce the said documents.

9. The lower court ought to have allowed the

Cr.M.P.No.1816/2014 instead of dismissing the same.

DATE:26-3-2015.
Hyderabad Counsel For petitioner.
 HYDERABAD. :: District

IN THE HIGH COURT OF JUDICATURE

AT HYDERABAD FOR THE STATE OF
TELANGANA AND THE STATE OF
ANDHRA PRADESH

Crl.R.C.No. OF 2015
IN

Crl.A.No. OF 2015

Crl.M.P.No.1816/2014 in CC No.199
of2013

(On the file of the

XV Addl.Judge-cum_XIX Addl.Chief
Metropolitan Magistrate, Hyderabad.)

MEMORANDUM OF GROUNDS
 

 
 
 
 
 
 
 
 

 
 
Filed By:
 
M/s Vladimeer Khatoon (12068)
Advocate
H.No.16-11-16/G/S-2,Flat
NO.401, Sai Sagar Sudha
Residency, Prashanth Nagar,
Malakpet, Hyderabad-500036.

Counsel for petitioner

 HIGH COURT
 
CRIMINAL PETITION
 
 
Crl.R.C.M.P.NO. OF 2015
 
IN
 
Crl.R.C.NO. OF 2015
 
 
 
HYDERABAD. District
 
 
P.V.L.Narsimha Rao
…Petitioner/Accused
 

By Vladimeer Khatoon (12068)

 
NATURE OF APPLICATION
(UNDER SEC. 397(1) Cr.P.C.)
 
 
The Hon’ble Court may be pleased to
grant stay of all further proceedings in
CC No.199/2013 on the file of XV
Addl.Judge-cum_XIX Addl.Chief
Metropolitan Magistrate, Hyderabad
pening disposal of the present Criminal
Revision petition and pass such other
order or orders may deem fit and proper
in the circumstances of the case.

 
 
 
PRESENTED ON: 26-3-2015. 
 
REPRESENTED ON:
 
FILED ON: 26-3-2015. 
 HIGH COURT
 
CRIMINAL REVISION CASE
 
 
Crl.R.C.NO. OF 2015
 
 
P.V.L.Narsimha Rao
... Petitioner/Accused
 

By Vladimeer Khatoon (12068)

HYDERABAD. District

Case No. of 2015 on the file

of JMFC

Of the of JMFC

Crl.M.P.No.1816/2014 in CC No.199
of2013
on the file of the
XV Addl.Judge-cum_XIX Addl.Chief
Metropolitan Magistrate, Hyderabad.

Order Dismissing the petition in

Crl.M.P.No.1816/2014 in CC No.199 of
2013.

Date of Order: 20-2-2015

Orders are solicited on the following

1. Notice to the Public Prosecutor
2. Notice to accused
3. Notice to Complainant (or other side)
4. Post before a single Judge
Or
Post before a Bench of two judges

5. Print for Court

Or
Print at Party’s Cost
Or
Do not print
N.B. If stay is ordered, the case will be
posted without printing

To be heard on
Crl.MP.No.
 IN THE HIGH COURT OF JUDICATURE AT HYDERABAD FOR THE
STATE OF TELANGANA AND THE STATE OF ANDHRA PRADESH
 
 
Crl.R.C.No. OF 2015
 
RUNNING INDEX
 
 
 
Sl. Exhibi Description of Date of Date of Pag
No t Document Documen filing of e
. t Documen No.
t
1.   Grounds   26-3-2015. 1
2.   Certified copy of the 20-2-2015  -do- Filed
Judgment passed in
Crl.M.P.No.1816/201
4 in CC No.199
of2013
3.   Xerox copy of the 20-2-2015  -do-  
Judgment passed in
Crl.M.P.No.1816/201
4 in CC No.199
of2013
    -do-  
  Memo of    
Appearance 
           
           
           
           

 
 
 
DATE: 26-3-2015. 
Hyderabad Counsel for the Petitioner
 
 
 MEMO OF APPEARANCE

IN THE HIGH COURT OF JUDICATURE AT HYDERABAD FOR THE

STATE OF TELANGANA AND THE STATE OF ANDHRA PRADESH

CRL.R.C.No. OF 2015

BETWEEN:

P.V.L.Narsimha Rao,
S/o.Late.Raghavendra Rao
Aged about 52years,Occ: Private Employee,
R/o.Plot No.8, Green Park Enclave, Kapra,
Hyderabad-500062
...Petitioner/Accused
AND

1.M/s. Vinutna Chit Fund Pvt.Ltd.

Rep.by its M.D.D.Ramagovinda Reddy,
S/o.Sitarama Reddy, aged 55years,
Occ: Business, R/o. 3-6-462/8, 1st Floor,
Sundersadan, Street No.5,
Himayath Nagar, Hyderabad.

2. D.Ramagovinda Reddy,
S/o.Sitarama Reddy, aged 55years,
Occ: Business, R/o. 3-6-462/8, 1st Floor,
Sundersadan, Street No.5,
Himayath Nagar, Hyderabad.
 
...Respondent/Complainant

To

The Registrar
High Court
Hyderabad.

Sir,

Please enter my/our appearance in the above matter on behalf

of the Petitioner.

By Vladimeer Khatoon (12068) 

Counsel for Petitioner
DATE:26-3-2015.
Hyderabad
 HYDERABAD. :: District

IN THE HIGH COURT OF JUDICATURE

AT HYDERABAD FOR THE STATE OF
TELANGANA AND THE STATE OF
ANDHRA PRADESH

Crl.R.C. NO. OF 2015

MEMO OF APPEARANCE

Filed By:
 
M/s Vladimeer Khatoon (12068)
Advocate
H.No.16-11-16/G/S-2,Flat
NO.401, Sai Sagar Sudha
Residency, Prashanth Nagar,
Malakpet, Hyderabad-500036.
 
Counsel for Petitioner
 MEMORANDUM OF CRIMINAL MISC. PETITION
 
(UNDER SEC. 482 OF CRIMINAL PROCEDURE CODE)
 
IN THE HIGH COURT OF JUDICATURE AT HYDERABAD FOR THE
STATE OF TELANGANA AND THE STATE OF ANDHRA PRADESH
 
 
CRL.R.C.M.P.No. OF 2015
IN
CRL.R.C.NO. OF 2015
 
BETWEEN:
 
P.V.L.Narsimha Rao,
S/o.Late.Raghavendra Rao
Aged about 52years,Occ: Private Employee,
R/o.Plot No.8, Green Park Enclave, Kapra,
Hyderabad-500062
..Petitioner/s
AND
 
1.M/s. Vinutna Chit Fund Pvt.Ltd.
Rep.by its M.D.D.Ramagovinda Reddy,
S/o.Sitarama Reddy, aged 55years,
Occ: Business, R/o. 3-6-462/8, 1st Floor,
Sundersadan, Street No.5,
Himayath Nagar, Hyderabad.

2. D.Ramagovinda Reddy,
S/o.Sitarama Reddy, aged 55years,
Occ: Business, R/o. 3-6-462/8, 1st Floor,
Sundersadan, Street No.5,
Himayath Nagar, Hyderabad.

..Respondent/s
 

For the reasons stated in the accompanying criminal petition, it is

therefore prayed that this Hon'ble Court may be pleased to dispense

with filing of the original certified copy of Crl.M.P.No.1816/2014 in CC

No.199 of2013, dated 20-2-2015 on the file of XV Addl.Judge-

cum_XIX Addl.Chief Metropolitan Magistrate, Hyderabad. before this

Hon’ble Court and pass such other order or orders as this Hon’ble

Court may deem fit and proper in the circumstances of the case.

Hyderabad Counsel for the Petitioner

DATE: 26-3-2015. 
 
 
 HYDERABAD. District
 
 
 
IN THE HIGH COURT OF JUDICATURE
AT HYDERABAD FOR THE STATE OF
TELANGANA AND THE STATE OF
ANDHRA PRADESH

 
CRL.R.C.M.P.NO. OF 2015
 
IN
 
CRL.R.C.No. OF 2015
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

DISPENSEWITH PETITION
 
 
 
 
 
 
 
 
 
 
 
Filed By:
 
M/s Vladimeer Khatoon (12068)
Advocate
H.No.16-11-16/G/S-2,Flat
NO.401, Sai Sagar Sudha
Residency, Prashanth Nagar,
Malakpet, Hyderabad-500036.

 
Counsel for Petitioner
 
 HIGH COURT
 
CRIMINAL MISC.PETITION
 
 
CRL.R.C.M.P.NO. OF 2015
 
IN
 
CRL.R.C.NO. OF 2015
 
 
 
HYDERABAD. District
 
 
P.V.L.Narsimha Rao
... Petitioner
 
By Vladimeer Khatoon (12068)
 
NATURE OF APPLICATION
(UNDER SEC. 482 Cr.P.C.)
 
 
The Hon’ble Court may be pleased to
dispense with certified copy of
Crl.M.P.No.1816/2014 in CC No.199
of2013, dated 20-2-2015 on the file
of XV Addl.Judge-cum_XIX Addl.Chief
Metropolitan Magistrate, Hyderabad.
before this Hon’ble Court and pass
such other order or orders as this
Hon’ble Court may deem fit and
proper in the circumstances of the
case.

 
PRESENTED ON: 26-3-2015. 
 
REPRESENTED ON:
 
FILED ON: 26-3-2015.