IN THE COURT OF xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

CASE NO. …….. of 20xx

Xxxxxxx … Petitioner

Versus
Xxxxxxxx …Respondent
INDEX
S. No. Subject Date Page Court
Fee
1. Memo of Parties Xxxxxxx
2. APPLICATION FOR Xxxxxx
DIRECTION TO
RESPONDENT NO. 1 TO 5
UNDER SECTION 190
CR.P.C READ WITH 172
CR.P.C.
3. Affidavit
4. Fardtalwana 25/-
5. Adhar Card Consent
6. Adhar Card
7. Annexure C-Xx Xxxxxx
(A Copy of xxxx)
8. Vakaltnama Xxxx
Total Rs: /-
NOTE:
1 Power of Attorney is attached.
2. No Similar matter is pending before the Hon'ble Court,
District and Session Court.

xxxxxxxxxxx Xxxxxxxxxxx
DATED:xxxxxx MOB. NO. xxxxxxxxx

ADVOCATE
COUNSEL FOR THE APPLICANT
IN THE COURT OF xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

CASE NO. …….. of xxxx

MEMO OF PARTIES
IN THE MATTER OF:-
1. Xxxxxxxx … COMPLAINANT
VERSUS
1. Xxxxx …Respondents

Xxxxxxxxxxx xxxxxxxxxxxxx
DATED:xxxxxxxxxx MOB. NO. xxxxxxxxxx

ADVOCATE
COUNSEL FOR THE APPLICANT
IN THE COURT OF xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

CASE NO. …….. of xxxx

IN THE MATTER OF:-
Xxxxxxxxxxxxxx … Petitioner

Versus
Xxxxxxxxxxxxxxxxx …Respondent

APPLICATION FOR DIRECTION TO

RESPONDENT NO. 1 TO 5 UNDER SECTION
190 CR.P.C READ WITH 172 CR.P.C IN VIEW
OF “SAKIRI BASU VS. STATE OF U.P.” AND
TO SUBMIT A WEEKLY REPORT OF DIARY
OF INVESTIGATION AND ALSO FOR
MONITORING SURVEILLANCE ON POLICE
INVESTIGATION WHICH IS UNDER POLICE
STATION XXXXXXXXX
XXXXXXXXXXXXXXXXXXXX I.E. ANNEXURE C-
XX AND P.S XXXXXXXXXX AS THE
RESPONDENT NO. 4 IS VIOLATING JUSTICE
AND TWISTING THE FACTS ONLY TO
EXTEND THE BENEFIT TO THE ACCUSED
PERSON.

Sir,
It is respectfully Submitted as under :-
1. That the complainant has filed application for monitoring the

proceedings of the complaint pending with SHO PS

xxxxxxxxxxxx in view of “Sakiri Basu Vs. State of U.P.”

and others on dated 07.12.2007, appeal (CRL) 1685 of 2007,

by the Hon’ble Supreme Court of India to the Registrar

Generals/ Registrars of all the High Courts and send the copy

of judgment through Secretary General of Hon’ble Supreme

Court of India with special circulation to all High Court and

 all are binding upon Judicial system as per Article 141 of the

Constitution of India in view of Para 14 of the judgment is

defined as:

“Any Magistrate empowered under Section 190 may order

such an investigation as above mentioned. The words `as
above mentioned obviously refer to Section 156 (1), which
contemplates investigation by the officer in charge of the
Police Station”
Para 14 to 17 of judgment is very appropriate for every case

to Monitor Police Investigation and the Court has ample

power to monitor.

2. That the complainant has registered xxxxxxxxxx has been

registered against the accused on dated xx.xx.xxxx at PS

xxxxx, xxxxxxxx, but the police is intentionally not filling

the charge-sheet and delaying the process of investigation

due to the political influence of the accused.

3. That the applicant has an apprehension that the accused

person is taking the benefit of good relationship of the police

as well as political persons and the police is not doing

anything and lingering the complaint proceedings which may

be hampered by accused.

4. That the Hon’ble Supreme Court has passed the direction in

Lalita Kumari Vs. State of U.P. regarding the registration of

FIR but the police is violating the provisions of that (Supra)

judgment also.

5. That the present case is having Prima facie evidence against

 the accused. But I.O of this case is intentionally manipulating

the true facts and coloring the story with their penned story

and intentionally nonchalant and proceeding with the diary of

investigation according to section 172 Cr.P.C which is to

required being update by the police weekly before the Court

in the interest of justice.

6. That the accused person is having high contacts and they can

hamper the process of investigation by using bad tactics. So,

the surveillance on investigation is required judicially. So,

the complainant is moving this application to protect the right

and to stop the police from doing wrong and also reported the

Police for providing a cap, so that the police cannot give

wrong benefit to accused person.

7. That the FIR No. xxxxxxxxxxxxxxxxxxxxx have been

registered against unknown persons on the statement of

applicant namely xxxxxxxxxxxx i.e. applicant where the

police have recorded the statement with their own manner.

As it was time, when the applicant was sudden mental trauma

due to death body seen on occurrence spot of his deceased

son namely xxxxxxxxxxxxxxxx aged about xx years (D.O.B

xx.xx.xxxx) but the police have recorded wrongly with

ulterior motive as the police officer namely xxxxxxx have

recorded the statement of the applicant with their own

manner. A copy of xxxxx is herewith annexed as Annexure

C-xx.
8. That the FIR is pending since xx.xx.xxxx but the police is not

doing anything towards that FIR i.e. Annexure C-xx with

this Present application.

9. That, day of occurrence the deceased reached at home about

xx:xx PM after calling on about xx:xx PM to his sister

namely xxxxxx. Then, had conversation with mother of

deceased namely xxxxx and stated somebody needs money

Rs. xx,xxx/- get it be ready. Then, he came on his car and

parked the same and took the scooty along with Rs. xx,xxx/-

left the home about xx:xx PM. Thereafter, the murder

information got in the knowledge of petitioner at xx:xx PM.

10. That the xxxx is establishing the link of evidence and

abetment of crime and planned murder. Even the police have

not investigated the whatsapp chat of dated xx.xx.xxxx and

xx.xx.xxxx which is most important to decide the fate of case

as the accused has made the confession before the relatives is

highly doubtful and it is try to save the culprits or local

congress politician who is being the veil and the deceased

was holding the post of xxxxxxxx and he was very closed to

xxxxxxxxxxxxx. Earlier, before the occurrence two months

back threaten given by local Congress leader namely

xxxxxxxxxx and others. Even threaten to applicant at home

for life threat and it is clear murder done under political

vendetta. So, the police are trying to shade the new color and

trying to save the accused who are behind the veil and cut
 down the chain of investigation by recording the confession

of accused.

11. That the amount Rs. xxxxxx/- is also highly doubtful because

the mother of deceased has given Rs. xxxxx/- (xxx Rupees

Notes to deceased) and he already having Rs. xxxx/-. But the

police is showing only Rs. xxxxx/-. So, the investigation is

having the clear latches and ulterior motive which is trying to

save the original culprits.

12. That the police have derailing the investigation and made a

story of Rs. xx,xxx/- which was created by police as without

investigating the Whatsapp chat and the investigation is

shoddy.

13. That the present FIR is required to be monitored in view of

the above said judgment Sakiri Basu Vs. State of U.P. and

also required to be Complying with the guidelines of the

judgment given to all Registrar Generals of Hon’ble High

Court/Registrars of Hon’ble High Court and in this judgment

declared ambit Power of Magistrate. Now, the Magistrate has

been duly defined and discussed under Section 156 and 190

Cr.P.C. properly. So, this filled Application against the

pending FIR before the Police is required to be monitored as

according to the proceedings investigation and it is also

requested to update the Court on weekly basis by the police

authority i.e. Respondent No. 2 to 5.

14. That a court fee stamp of Rs.10/- is affixed on it.

 PRAYER
It is, therefore, most humbly prayed that this Hon’ble Court may graciously be
pleased to:-
a. Allow/ Grant for application for direction to Respondent no.
1 to 5 under section 190 Cr.P.C read with 172 Cr.P.C in view
of “Sakiri Basu vs. State of U.P.” And to submit a weekly
report of diary of investigation and also for monitoring
surveillance on police investigation which is under Police
Station xxxxxxxx xxxxxxx i.e. Annexure C-xx and P.S
xxxxxxxx as the respondent no. 4 is violating justice and
twisting the facts only to extend the benefit to the accused
person and also direction to police submits charge-sheet;
B. It is further direct that the Respondent no. 1 to 5 submit
status report on weekly record along with dairies under
section 172 Cr.P.C basis till the filing of challan;
C. Pass such other or further orders as this Hon’ble Court may

deem fit and proper in facts and circumstances of the case.

Bathinda Submitted By:-

Date: xxxxxxx

Xxxxxxxxxxxx

Through Counsel:-

xxxxxxxxxx xxxxxxxxx
DATED:xx.xx.xxxx MOB. NO. xxxxxxxxxx

ADVOCATE
COUNSEL FOR THE APPLICANT
IN THE COURT OF xxxxxxxxxxxxxxxxxxxxx

CASE NO. …….. of 20xx

IN THE MATTER OF:-

Xxxxxxxxxxx … Petitioner

Versus
Xxxxxxxxxxx …Respondent

APPLICATION FOR DIRECTION TO RESPONDENT

NO. 1 TO 5 UNDER SECTION 190 CR.P.C READ WITH
172 CR.P.C IN VIEW OF “SAKIRI BASU VS. STATE OF
U.P.” AND TO SUBMIT A WEEKLY REPORT OF
DIARY OF INVESTIGATION AND ALSO FOR
MONITORING SURVEILLANCE ON POLICE
INVESTIGATION WHICH IS UNDER POLICE
STATION XXXXXXXXX XXXXXXXXXXXXXXXXXXXX I.E.
ANNEXURE C-XX AND P.S XXXXXXXXXX AS THE
RESPONDENT NO. 4 IS VIOLATING JUSTICE AND
TWISTING THE FACTS ONLY TO EXTEND THE
BENEFIT TO THE ACCUSED PERSON.

Affidavit
I, xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx,
xxxxxx do hereby solemnly affirm and declare as under:-

1. That deponent is an applicant in the above said application.

2. That the application has been drafted and prepared by
counsel as per our instructions and information given by me
to our counsel and the averments contained in the
application are reiterated, which may be read and treated as
a part of this affidavit.
3. That the contents of the application have been read over and
explained to me by my counsel and I have heard the contents
of the same and I have put my signatures and verified the
same after hearing, understanding and admitting the same to
be correct.
4. That I shall abide by any order(s) that may be passed by this
 Hon’ble court in the present application.

Date xxxxxxxxxx Deponent

Verification:
I, the above named deponent do hereby solemnly affirm and declare that the
above statement of mine is true and correct to the best of my knowledge and
belief. Nothing has been concealed therein

Date xxxxxxxxxx
Deponent