In the court of the Hon’ble XIII Addl Cheif Metropolitan Magistrate

At:-Nampally.

Crl.M.P.No. of 2011
In
Crime No.28/2011
Between:-
Smt.S.Santhosh Kumari,
W/o.Rajendra Prasad, Aged:-
Occ:-House wife,
R/o.Q.No.G-25, P & T Colony,
Chikkadapally, Hyderabad.

…Petitioner/
Owner of the Articles.
AND
The State of A.P.
Through P.S.C.I.D., Hyd.
…Respondent/
Complainant.

PETITION FILED UNDER SECTION 451, R/W SECTION 457 OF CR.P.C

May it please your Honour,

1. The petitioner humbly submits that the petitioner herein filed a case against the

accused persons at Police Station C.I.D. and the Police C.I.D has registered a crime

vide crime no.28/2011 for the offence under section 498(A) & 406 of I.P.C. The

respondent also seized the gold articles of the petitioner, during the investigation from

the possession of the accused persons (Husband & In-Laws).

2. The Petitioner/Owner of the articles humbly submits that the petitioner is the

Owner of the gold articles listed below:

a).Long Chain :: 50.100 gms.

b).Nalla Pusala Chain :: 27.000gms
 c).Muthayala Chain :: 28.900gms
(Pachalu, & Kempula Billa)
d).Bangles (4 in No) :: 38.300gms
e).Ear Rings & Tops :: 7.300gms
f).Ring :: 5.200gms
g).Chain :: 11.900gms
h)Engagement Ring :: 4.700gms
i).Nose ring :: 0.600gms.

3. The petitioner further submits that if the gold articles were not released/returned

to the petitioner, the petitioner will suffer irreparable loss and agony. Cont..2

// 2 //

4. The petitioner further submits that the petitioner is ready and willing to produce

the said gold articles as and when directed by this Hon’ble Court and also undertake not

change any of the articles.

5. The petitioner submits that the above said seized gold articles are stationed at

P.S.C.I.D. without any protection and it is causing severe hardship to the petitioner

without the said articles to move in day in day out life.

6. The petitioner submits that the petitioner is ready to furnish acceptable surety

before this Hon’ble Court for the release of the said gold articles.

It is therefore prayed that this Hon’ble Court may be pleased to pass an order,

directing the Station House Officer of P.S.C.I.D to deposit the said gold articles i.e.

a).Long Chain :: 50.100 gms.

b).Nalla Pusala Chain :: 27.000gms
c).Muthayala Chain :: 28.900gms
(Pachalu, & Kempula Billa)
d).Bangles (4 in No) :: 38.300gms
e).Ear Rings & Tops :: 7.300gms
f).Ring :: 5.200gms
 g).Chain :: 11.900gms
h)Engagement Ring :: 4.700gms
i).Nose ring :: 0.600gms.

before this Hon’ble Court and the same may be ordered for interim custody to the

petitioner/owner of the gold articles and consequently pass such other order or orders

as this Hon’ble Court may deem fit and proper in the circumstances of the case and in

the interest of justice.

Place:Nampally.
Date.30-7-2011 PETITIONER/
OWNER OF THE ARTICLES.

Counsel for the petitioner/Owner of the articles.

In the court of the Hon’ble XIII

Addl Cheif Metropolitan
Magistrate
At:-Nampally.

Crl.M.P.No. of 2011
In
Crime No.28/2011
Between:-
Smt.S.Santhosh Kumari,
…Petitioner/
Owner of the Articles.

AND

The State of A.P.

Through P.S.C.I.D., Hyd.
…Respondent/
Complainant.

PETITION FILED UNDER SECTION

451, R/W SECTION 457 OF CR.P.C

FILED ON:-

Filed by:

=======================================
M/s. M.Sridhar (AP/523/2005)
Advocates

# 2-2-1075/20/A, (114), D.No.102, 1st

Floor, Tilak Nagar X Roads, Shivam
Road, Amberpet, Hyd-13.

=======================================
Counsel for the ……………………..