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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

LEX COMMUNIQUE 2023 – NATIONAL TRIAL ADVOCACY


& JUDGMENT WRITING COMPETITION

TRIAL PROPOSITION

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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

IN THE COURT OF THE PRINCIPAL SESSION JUDGE, GILMOUR, STUGGART

S.C. NO. 1956 OF 2022

STATE OF STUGGART
V.
MR. SURESH KAMAT
Suresh Kamat and Vinobha were married for 18 years and lives in the city of Gilmour, Stuttgart.
Suresh works for a daily wage as a mason with a construction company. His wife Vinobha was
a tailor. She passed away three years ago due to a sudden cardiac arrest. This couple were
blessed with three children namely Vikram (17 years), Sonu (15 years) and Monika (11 years).
After Vinobha passed away Vikram dropped out of school to meet their daily needs. He worked
as a daily wage worker along with his father. But due to certain untoward friendships, he
stopped working and became addicted to alcohol.

On July 31, 2022 around 2:30 AM in the midnight Suresh woke up to find out that his daughter
Monika was missing. He tried to search her in the surroundings, but he could not trace her.
Monika was wearing a red trouser and red sweater. Having failed to trace her, he went to the
police station and orally reported the matter and on that basis, an offence against unknown
person was registered under Section 363 IPC. The police started the investigation, the police
tried to search for the missing child and in the night at about 03:30 AM, she was found naked
in the courtyard of the building of Government Model School. She was taken to the emergency
of the S.N. Hospital, where she was declared dead. Thereafter a written report was given by
Suresh to the Police Station. There were marks of injuries on her body and bleeding was present
in her private part.He suspects that some unknown person killed her after committing rape.

The police conducted an investigation and recorded statements of several persons acquainted
with the facts and circumstances. On Completion of Investigation, the Investigation Officer
forwarded the final report to the jurisdictional Magistrate Court. The court took cognizance;
served copies of the final report along with statements and other documents. The case was
committed to the Sessions Court, Gilmour, Stuggart for trial.

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A1: Mr. Suresh Kamat- Section 363, Section 302, Section 201, Section 376 (f) of Dravidian
Penal Code, 1860 and Section 5(n) r/w Section 5(m)/6 of POCSO Act, 2012

The case is set for trial on 25/02/2023.

THE LAWS OF DRAVIDIAN ARE IN PARI MATERIA WITH THE LAWS OF INDIA.

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ANNEXURE LIST

ANNEXURE -1 FIRST INFORMATION REPORT

ANNEXURE -2 SPOT MAHAZAR

ANNEXURE -3 AUTOPSY REPORT

ANNEXURE -4 SEIZURE MAHAZAR

ANNEXURE -5 STATEMENT UNDER SECTION 161 CRPC

ANNEXURE -6 FINAL REPORT

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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

ANNEXURE 1 - FIRST INFORMATION REPORT


(Under Sec. 154 of Criminal Procedure Code, 1973)

1. District: Gilmour Police station: N7 Station, Gandhi Road Year: 2022

FIR No. 103/2022 Date: 31/07/2022

2. Act - Dravidian penal code, 1860 Sections: 302, 201, 376, 363 DPC, r/w 3,4 POCSO Act

Occurrence of Offence: 31/07/2022 Time: 01:00 am to 03:00 am

4. Information recorded by: Inspector Himanshu

5. Type of Information Written/ Oral: Written

6. Place of Occurrence: Direction/Distance from Police station: Government Model School,


Irwin Road, Gilmour City, Stuggart State - About 2 kms east from the police station.

7. Complaint/Informant Name: Suresh Kamat, DoB: 19.04.1975; Nationality: Dravidian;


Aadhaar No: DPN12345X; Date of Issue: 22.02.2010; Place of Issue: Gilmour.

8. Basis on which FIR is lodged: Written complaint by Suresh Kamat

9. Details of known/ unknown/ suspected accused with full particulars: Suspected persons;
Known Accused-1; Unknown accused-NA

10. Reason for delay in reporting by the complainant/ informant: NA

11. Particulars of injuries sustained: The victim Monika had abrasions all over her body

12. Particulars of Post Mortem Report: NA

13. Post Mortem report done by: NA

14. Inquest Report/ Unnatural death case no. If any ………. NA

15. Brief facts of case: Today on 31/07/2022 at 03:00 AM, I, Himanshu, Inspector of Police
at N7 Station, Gandhi Road, Crime Branch, when I was on duty, I received a complaint given
by Suresh Kamat, Son of Vimal Kamat, aged 47. I registered an FIR No. 103/2022 U/s 154 of
Cr.PC according to the facts of the case. I hereby submit the details of the above-mentioned
complaint: - Sir I the complainant residing at Door No. 26, Irwin Road, Gilmour City, Stuggart

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State Phone number 989491345. I am a daily wage worker working in a construction company.
I’m married to Vinobha who passed away 4 years ago due to a sudden cardiac arrest. We have
three children Vikram (17 years), Sonu (15 years) and Monika (11 years). Around 02:15 AM
on 31/07/2022 I woke up to drink water and was shocked to see that my daughter Monika is
missing. I woke up both my sons and searched for her but we couldn’t find her anywhere. She
must have been kidnapped.

16. Action taken (Since the above information reveals commission of offence(s) u/s as
mentioned at item no.2): Mr. Saurabh, Rank: Sub- Inspector has taken up the investigation.

17. F.I.R. read over to the complainant admitted to be correctly recorded and a copy given to
the complainant free of costs.

Sd/- Sd/-

Suresh Kamat Saurabh

(Sub-Inspector)

19. Date & Time off dispatch to the court - 31/07/2022

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ANNEXURE 2 - SPOT MAHAZAR

City: Gilmour Police Station: N7, Gandhi Road, Crime Branch

1) FIR Number, charge: 103/2022; Sec. 302, 201, 376, 363 DPC, r/w 3,4 POCSO Act

2) Rank and name of police officer making seizure: Mr. Saurabh, Sub-Inspector of Police,
N7, Gandhi Road, Crime Branch, Gilmour city.

3) Name and address of witnesses

Witness No.1

Name: Kamal, Son of Perumal, aged 37.

Address: Door No.24, Irwin Road, Gilmour city.

Witness No. 2

Name: Surabhi, Wife of Late Dinesh, aged 42.

Address: Door No. 28, Irwin Road, Gilmour city.

4) Spot Mahazar

I visited the crime scene in relation to Crime No.103/2022 registered at N7 Police Station,
Gandhi Road, Crime Branch under Sec.302 201, 376, 363 DPC, r/w 3,4 POCSO Act and
prepared the Spot Mahazar in the presence of above said witnesses. I reached the Scene of
Occurrence at 03:10 AM. The Scene of occurrence is located approximately 2 Km from the N7
Police Station, Gandhi Road. The crime spot is the Government Model School. After a few
minutes of search, we found the victim in an unresponsive condition around 03:30 AM. We
found some blood stains on the spot. We also saw some few torn pieces of victim’s cloth along
with the broken alcohol bottle and I carefully took the same and sealed it in a bag. Then I
immediately called the FSL team to trace the further evidence.

5) Statement of Witness/Panchas

I am Kamal, Son of Perumal, aged 37, residing at the above said address. I am working as a
clerk in Taluk office. Mrs. Surabhi, Wife of Late Dinesh, aged 42, working as a software
engineer, was also present while preparing the spot mahazar. We, the above named Panchas
were asked by Sub- Inspector Mr. Saurabh and three other constables to witness the preparation

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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

of Spot Mahazar for the scene of occurrence. The contents stated in the Spot Mahazar are true.
We have verified the contents and put our signature on this Spot Mahazar.

Sd/-

Mr. Saurabh

(Sub-Inspector)

Sd/-

Signed by Witness No. 1

Sd/-

Signed by Witness No. 2

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ANNEXURE 3 - MEDICAL REPORT

Regarding the body of a girl aged 11 years, named __ Monika Kamat___


Requisition received at ____5.00 A.M on 31/07/2022 from the ___Saurabh (S.I)_____
Of ___Gilmour city with his letter number PM423501 dated 31/07/2022 ‘
Body in charge of police constable no. CN 325L88AC ,named Sunder ‘

Identification and caste marks-


1. Mole on the left cheek
2. A scar on the chin
The body was first seen by the undersigned at 10:00 A.M. on 31/07/2022 ‘
Its condition then was the body was pale in colour
Post mortem commenced at_________12.00 P.M___________on____31/07/2022_______

Appearances found at the Post Mortem The height of the deceased was 3 feet and 10 inches
and her weight was about 15 Kg. In the external examination, it was found that her mouth and
eyes were closed, and the white portion of the eyes were congested. All Teeth are normal.

Following External Injuries are present over the body.


1. Teeth bite 4 cm. X 3 cm. on the on face.
2. Teeth bite 4 cm. X 3 cm. on chest at nipple.
3. Teeth bite 4 cm. X 3 cm. near the umbilical area.
4. Abrasion and contusion were present on the left side of the forehead.
5. Abrasion 2 cm. X 2 cm. on the front of the nose.
6. Lacerated wound 0.5 cm. X 0.5 cm. on the lower lips.
7. Abrasion and contusion 9 cm. X 2 cm. on the left side of the neck
During Internal Examination the following findings are observed:
1. The brain and its membranes were congested.
2. Lungs were found congested.
3. Heart was in normal condition.
4. Semi-digested food was present in the stomach.
5. Faecal matter and gas were present in the large intestine.
6. In the small intestine digested food and gas was present.
7. Liver was congested and gall bladder was half full.

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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

8. Kidney was congested.


9. Urinary bladder was half filled. On further examination 100 Mg/Ml of Ketamine drug
was found.
10. Hymen was torn.
11. Bleeding was present in the vagina.
12. Uterus was non-gravid.
13. Larynx and Vocal cords were congested.
14. Trachea was also congested, and the hyoid bone was intact.

Post-mortem concluded at 01.00 P.M. Death occurs during 12- 13 hours before post mortem.

Opinion as to cause of death


a. Reserved pending report of ________NIL_______________________________
b. The deceased would appear to have died of Asphyxiation

Station: Gilmour Name: Dr. Preethi


Report Issued: 01/08/2022 Rank: Asst. medical practitioner Sd/-

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ANNEXURE 4 - SEIZURE MAHAZAR

City: Gilmour Police Station: N7, Gandhi Road, Crime Branch

1) FIR Number, charges: 103/2022; Sec. 302, 201, 376, 363 DPC, r/w 3,4 POCSO Act

2) Rank and name of police officer making seizure: C.Saurabh, Sub-Inspector of Police, N7,
Gandhi Road, Crime Branch, Gilmour city.

3) Name and address of witness

Pancha No. 1

Name: Kamal, Son of Perumal, aged 37.

Address: Door No.24, Irwin Road, Gilmour city.

Pancha No. 2

Name: Surabhi, Wife of Late Dinesh, aged 42.

Address: Door No. 28, Irwin Road, Gilmour city.

4) Name and address of the person from whom the materials or where found:

Suresh Kamat, Son of Vimal Kamat, aged 47 years,

Residence: Door No. 26, Irwin Road, Gilmour city.

5) Date, Time of making seizure: 01/08/2022; 12:45 PM

6) List of properties seized with description:

1. Soda Bottle

2. Half-filled Glass with Soda

3. Alcohol

4. Ketamine Tablets

5. Blood-stained Shirt

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7) Reasons for the seizure or nature of suspicious circumstances.

Suresh Kamat (A1) is being suspected for commission of offence charged with Sec.302, 201,
376, 363 DPC, r/w 3,4 POCSO Act in crime No.103/2022 at N7 Police Station, Gandhi Road
for the crime occurred on 31/07/2022 at about 03:00 AM in Government Model School, Irwin
Road, Gilmour City. Based on the examination of witnesses it is suspected that Suresh, the
complainant/ Victim’s father should have committed the act. On basis of the suspicion, we
conducted search in Suresh’s house. I broke open the lock and conducted the search of the
premises. After searching the premises, I found the above articles. All of these were seized in
front of the Panch witnesses.

8) Statement of the Witnesses/ Panchas

I am Kamal, Son of Perumal, aged 37, residing at the above-said address. I am working as a
clerk in the Taluk office. I was asked by the Investigation officer, Saurabh, N7 Police Station,
Gandhi Road to be a panch witness for the present case. Mrs Surabhi, the Neighbor of our
house was also present while the seizure was made. Along with the IO, three police constables
were also present. The IO informed me that Suresh is being suspected for the crime of murder
of his daughter on 31/07/2022 in Government Model School, Irwin Road, Gilmour City and
IO would search Suresh’s house in front of me. We entered the room and found everything to
be in order. The inspector along with the constables searched the entire house and marked the
above exhibits in a sealed bag.

The seizure of the above-mentioned items started at around 12:45 PM and was concluded at
1:00 PM. We have verified the contents and put our signature on this Seizure Mahazar.

Sd/- Sd/-

Signed by Pancha No. 1 Mr. Saurabh (Sub-Inspector)

N7, Gandhi Road, Crime Branch

Sd/-

Signed by Pancha No. 2

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ANNEXURE 5 - STATEMENTS OF WITNESSES


(Under Sec.161 of the Criminal Procedure Code, 1973)

PW 1- Mr. Vikram
I am Vikram, s/o Suresh Kamat aged 17 years. I’m working as a daily wage worker in a
construction company. My mother Vinobha passed away 4 years ago due to heart attack. From
then I stopped my studies to meet our daily needs since my dad is a daily wage worker. I’ve a
younger brother Sonu and a younger sister Monika. My father is a drunkard and often abuses
every one of us. One day my father started sexually abusing my sister, seeing that our
neighbours started to scold my dad and he promised that he will not repeat this anymore and
said he did this since he was drunk and doesn’t know what is happening. There is no such
incident later.

On 31/07/2022 around 2:30 AM, my father woke us up and said that Monika is not in her bed
and that she was missing. We searched everywhere since we couldn’t find her, my father filed
a complaint with the police. I remember my dad feeding my sister that night. I suspect that my
father would have murdered my sister.

PW 2- Mr. Sonu

I’m Sonu, s/o Suresh Kamat aged 15 years. I’m studying in 10th Standard in Government Model
School. My father works as a daily wage worker. My mother Vinobha passed away 4 years ago
due to a heart attack. From then my brother stopped his education and started to work. My
sister is studying in the 6th standard. My sister is very affectionate to my father. One day my
father started sexually abusing my sister, seeing that our neighbours started to scold my dad
and he promised that he’ll not repeat this anymore and said he did this since he was drunk and
did not know what was happening. There was no such incident later. I do not like my father
since he drinks and often beats me whenever he’s drunk. I couldn’t study either due to his
behaviour.

On 31/07/2022 around 2:30 AM my father woke us up and said that Monika is not in her bed
and that she’s missing. We searched everywhere, since we couldn’t find her, my father filed a
complaint with police. That evening I remember my dad feeding my sister that night and gave
her some soft drinks and said he was happy that day. I suspect that my father would’ve
murdered my sister.

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PW 3- Mr. Kamal

I’m Kamal, s/o Perumal aged 37 years, residing at No. 24, Irwin Road, Gilmour City. I’m
Suresh Kamat neighbour and I work as a clerk In Taluk Office. Suresh’s family was a good
one until his wife passed away. He became a Drunkard after that, and he also stopped his elder
son Vikram’s education. He’s a very rugged man. He never listens to anyone and often treats
his children very badly.

On 31/07/2022 around 03:15 AM, police came to us saying that Monika is missing and asked
for our help. I along with my neighbour Surabhi helped them to search in our vicinity and
around 3:30 AM we found the victim Monika in the Government Model School in a pool of
blood. There’s a previous incident of sexual harassment of Suresh with his daughter. So
previously some of the neighbours had scolded him and asked him to watch his actions. I was
a witness and as a Pancha when the spot and seizure mahazar was conducted.

PW 4- Mrs. Surabhi

I’m Surabhi, w/o Late Dinesh aged 42 years. I’m residing at No: 26, Irwin Road, Gilmour City.
I work as a software engineer. I’m Suresh’s neighbour. I had known Vinobha for 8 years. She
was a very kind-hearted woman. She loved her children very much. She had often said that her
husband was abusing her daily and forcefully asking her to have sex with him and was very
rough to her. She suddenly passed away due to cardiac arrest. He started to behave like an
animal after his wife passed away.

On 31/07/2022 around 03:15 AM, police came to search saying that Monika is missing and
asked our help. I along with my neighbour Kamal helped them to search and around 3:30 AM
we found the victim Monika in Government Model School in a pool of blood. There’s a
previous incident of sexual harassment of Suresh with his daughter. I even said that I’ll
complain about this incident to the police but having his children’s future in mind I left him
with a warning.

PW 5- Dr. Preethi

I’m Dr Preethi, 45 years old, wife, of Dr. Raj Kapoor. I’m working as an assistant medical
practitioner at SN Hospital which is located on Mount Road, Gilmour City. I received the
requisition for a post-mortem of the body of an 11-year-old girl named Monika Kamat on

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31/07/2022 by 05:00 AM. From Saurabh, Sub-Inspector of Police, N7 Police Station, Gandhi
Road, Gilmour city. The body was first seen by me by 10.00 AM and I started the post-mortem
on 31/07/2022 at 11.00 AM. Two identification marks were found on her body i.e. one mole
on her left cheek and a scar on her chin. The height of the deceased was 3 feet and 10 inches
and her weight was about 15 Kg. In the external examination, it was found that her mouth and
eyes were closed and the white portion of the eyes were congested. All Teeth are
normal. Following External Injuries are present over the body. Teeth bite 4 cm. X 3 cm. on the
on face. Teeth bite 4 cm. X 3 cm. on chest at nipple. Teeth bite 4 cm. X 3 cm. near the umbilical
area. Abrasion and contusion was present on the left side of the forehead. Abrasion 2 cm. X 2
cm. on the front of the nose. Lacerated wound 0.5 cm. X 0.5 cm. on the lower lips. Abrasion
and contusion 9 cm. X 2 cm. on the left side of the neck. During Internal Examination the
following findings are observed. The brain and its membranes were congested. Lungs were
found congested. Heart was empty. Half-digested food was present in the stomach. Faecal
matter and gas was present in the large intestine. In the small intestine digested food and gas
was present. Liver was congested and gall bladder was half full. Kidney was congested. Urinary
bladder was half filled. On further examination 100 Mg/Ml of Ketamine drug was found.
Hymen was torn. Bleeding was present in the vagina. Uterus was non gravid. Larynx and Vocal
cords were congested. Trachea was also congested and the hyoid bone was intact. I concluded
the Post mortem at 01.00 P.M. Death occurs during 12- 13 hours before post mortem. The
reason of death is Asphyxiation.

DW 1- Mr. Suresh Kamat

I’m Suresh Kamat, s/o Vimal Kamat, aged 47, residing at No.26, Irwin road, Gilmour City.
I’m working as a daily wage worker in a construction company, I married Vinobha 18 years
ago. She was a very loving wife. We have three children Vikram, Sonu and Monika. She was
taking tuition to the students and that’s how we met our daily needs since my salary was very
meagre. She passed away 4 years ago due to a sudden cardiac arrest. Thereafter my eldest son
stopped his education and started working with me to meet our needs. Recently due to an
untoward friendship, he started to take drugs and became addicted to alcohol. Even after
continuous warnings he never listened to my words. My other 2 children continued their
education in Government Model School. Of the three children, my daughter Monika is very
attached to me.

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On 31/07/2022 around 2:15 AM, I suddenly woke up to drink water and found that my daughter
is not in her bed. Hence I woke my sons Vikram and Sonu up to search for her. When I asked
Vikram whether he has seen her, he was blabbering. Vikram was heavily drunk. Hence, Sonu
and I searched for Monika but the same was in vain. Hence around 03:00 AM I rushed to the
police station and filed a complaint. Later the police came and searched for her and found her
lying dead in the ground of Government Model School. She was lying in a pool of blood. I told
the police that someone must have kidnapped and raped her. But the police arrested me after
accusing falsely. How can I rape my own child?

DW 2- Mr. Raman

I’m Raman, s/o Babu, aged 45, residing at No. 45/A, VKN Road, Gilmour City. I work as a
daily wage worker in a construction company. I work along with Suresh Kamat. I recently
learned that Suresh was arrested for allegedly raping and murdering his daughter. His eldest
son Vikram is also working with us. Vikram became addicted to alcohol and often creates rucks
with everyone. He’s unaware of what will happen if he’s drunk. Suresh loves his daughter very
much. He would’ve never done this.

DW 3- Mr. Gowtham

I’m Gowtham, s/o Raju, aged 20, residing at No. 32B3, New Street, Gilmour City. I’m
Vikram’s friend and co-worker. I knew Suresh’s Uncle also since we all work together. Vikram
and I have been friends for 7 years since we studied in the same school. Vikram was very good
until his mom was alive. After that, he became addicted to alcohol and drugs. Suresh uncle was
always worried about Vikram. I recently heard that Suresh’s uncle was arrested for the Rape
and Murder of his daughter Monika. I was shocked to hear this, because I too have a sister and
she used to play with Monika and uncle took care of her very well. He could never commit
such crime since he loves his daughter very much.

DW 4- Mr. Karan

I’m Karan, s/o Sunil, aged 40 years, residing at No. 32B, Irwin Road, Gilmour city. I live a few
houses next to Suresh Kamat’s house. My family is very close to Suresh’s family. Vinobha
passed away 4 years ago, from then Monika comes to my wife for minor helps since I too have
a daughter of Monika’s age. My daughter Pranika also goes to their house to play. I recently
heard that Suresh was arrested for the rape and murder of his daughter Monika. So far until we
know there were no complaints about Suresh’s behaviour. He takes care of my daughter like

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his own kid. He would’ve never done such act. He once said that he was working hard to give
a beautiful life to his daughter.

DW 5- Mrs. Madhuri

I’m Madhuri, w/o Ramesh, aged 42 years, residing at Block 3, Krishna Enclave, NKS road,
Gilmour city. I’m Suresh’s younger sister. After my both my parents passed away, my brother
worked and gave me a good education, and got me married to my husband. He loved Vinobha
and got married to her and had three children. Vinobha was also working to meet the ends.
After she passed away Vikram started working along with Suresh. I came to know that Suresh
was arrested for the Rape and Murder of Monika. I can never believe this since I have been
seeing Suresh since the day I was born. He took care of Vinobha very well. He loves Monika
more than his two sons. He even started saving for Monika’s marriage. He would always talk
about Monika and make her happy and beautiful. He would never commit such a crime even
in his dreams.

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ANNEXURE 6 - FINAL REPORT


(Under Sec.173 of the Code of Criminal Procedure Code, 1973)
In the Court of Chief Judicial Magistrate, Gilmour.
1. District: Gilmour
FIR No.: 103/2022
Year: 2022
Date of F.I.R: 31/07/2022
2. Final Report No.: 93/2022
3. Date: 20/10/2022
4. Sections of Law:
4a. Mr. Suresh Kamat – Sec. 302, 363, 376(f), 201 of Dravidian Penal Code, 1860 & Section
5(n) r/w Section 5(m)/6 of POCSO Act, 2012
5. Type of Final Report: Charge sheet
6. If Final Report un-Occured/False/ Mistake of Law: Not Applicable
/Mistake of Fact/ Non-Cognizable/ Civil Cases
7. If charge sheeted: Original
Original/Supplementary
8. Name of Investigating Officer: Mr. Saurabh, Rank: Sub- Inspector
9. Name of the Complainant: Mr. Suresh Kamat
10. Details of Properties/ Articles/ Documents seized
during investigation and relied upon
10.1 Soda Bottle
10.2 Half-filled Glass with Soda
10.3 Alcohol
10.4 Ketamine Tablets
10.5 Blood stained Shirt
11. (11.1) Particulars of accused persons charge sheeted:
Name : Suresh Kamat
Father’s Name: Vimal Kamat
Year/Date of Birth: 19/04/1975

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Sex: Male
Nationality: Dravidian
Religion: Hindu
Occupation: Daily wage worker
Address: Residing at Door no. 26, Irwin Road, Gilmour city, Stuggart State.
Whether Verified: Yes
Date of Arrest: 01/08/2022
Under Acts & Sections: Sec. 302, 201, 376, 363 DPC, r/w 3,4 POCSO Act
Status of the Accused: Judicial Custody
12. Particulars of Witnesses examined
1 Mr. Vikram – Son of the Accused, PW1
2. Mr. Sonu – Son of the Accused, PW2
3. Mr. Kamal - Neighbour, PW 3
4. Mrs. Surabhi – Neighbour, PW4
5. Dr. Preethi – Doctor, PW5
6. Mr. Saurabh – Investigating Officer, PW6
7. Mr. Suresh Kamat– Accused, DW1
8. Mr. Raman – Friend, DW2
9. Mr. Gowtham – Friend of Vikram, DW3
10. Mr. Karan – Neighbour, DW4
11. Mrs. Madhuri – Accused’s sister, DW5
13. If FIR is false, indicate action taken or
proposed to be taken u/s 182, 211 IPC: Not false, allegations in the FIR are true.
14. Brief Facts of case:
(14.1) On 31/07/2022 at 03:00 AM, the police received a complaint from Mr. Suresh
Kamat, aged 47, residing at No. 26, Irwin Road, Gilmour city, Stuggart State that he was
married to Vinobha 18 years ago and his wife passed away 4 years ago due to sudden cardiac
arrest. He has three children, 2 sons and a daughter his daughter was missing while he woke
up to drink water around 02:30 AM. He woke up his sons to search her which went in vain.

(14.2) After receiving the complaint from Suresh Kamat, I visited the crime scene
around 03:15 AM. The Scene of occurrence is located approximately 2 Km from the N7 Police

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Station, Gandhi Road. The crime spot is The Government Model School, Irwin Road, Gilmour
City. We entered the school and searched every available classroom. Later one of our
constables and Suresh found the victim Monika near the bushes in the ground. We immediately
informed to the FSL Team and once they arrived, we sent the body for the post mortem

(14.3) I enquired with the sons and neighbours of the accused and marked them as
prosecution witnesses. I then further enquired Friends and relatives of the accused and marked
them as defence witnesses. While enquiring the sons of the accused we came to know the real
instance of the situation and decided to arrest Suresh since the offence was made out. The
statement of the panchas are also vital for the arrest of Suresh.

(14.3) At about, 12:45 PM, I seized the following articles in front of the panchas.

1. Soda Bottle
2. Half-filled Glass with Soda
3. Alcohol
4. Ketamine Tablets
5. Blood stained Shirt
(14.5) I received the post-mortem report two later and it clearly showed the signs of
rape and murder. After a week I received the FSL Report. It showed the presence of DNA of
both Vikram and the Accused Suresh.

(14.8) All the aforesaid offences have been committed within the jurisdiction of this
Hon’ble Court. Hence, this Hon’ble Court has the jurisdiction to try the above offences. It is,
therefore, prayed that this Hon’ble Court may be pleased to take cognizance of the offence as
mentioned above against each of the aforesaid accused persons and issue process to them to
start trial in accordance with the law.

15. Dispatched on - 21/10/2022


16. Number of Enclosures
Sd/-
Saurabh
Sub-Inspector, N7 Station, Gandhi Road,
Gilmour city, Stuggart State.

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EXHIBIT LIST

EXHIBIT - 1 Rough Sketch

EXHIBIT - 2 Map

EXHIBIT – 3 Soda Bottle

EXHIBIT – 4 Half-filled glass with Soda

EXHIBIT – 5 Alcohol

EXHIBIT – 6 Ketamine Tablets

EXHIBIT – 7 Blood stained shirt

EXHIBIT - 8 CCTV Snap

EXHIBIT - 9 Blood Stains

EXHIBIT - 10 Broken Alcohol Bottle in crime scene

EXHIBIT - 11 Torn piece of Victim’s cloth

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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

EXHIBIT – 1

ROUGH SKETCH

BUSHES (CRIME SPOT)

PLAYGROUND

SCHOOL, BUILDING

ENTRANCE GATE

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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

EXHIBIT – 2
MAP

GOVERNMENT
MODEL SCHOOL

IRWIN ROAD

- Kamal’s House

- Suresh’s House

- Surabhi’s House

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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

EXHIBIT – 3
SODA BOTTLE

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EXHIBIT – 4
HALF FILLED GLASS WITH SODA

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EXHIBIT – 5
ALCOHOL

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EXHIBIT -6
KETAMINE DRUG

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EXHIBIT – 7
BLOOD STAINED SHIRT

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EXHIBIT – 8
CCTV IMAGE

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EXHIBIT – 9
BLOOD STAINS

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EXHIBIT – 10
BROKEN ALCOHOL BOTTLE

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LEX COMMUNIQUE- NATIONAL TRIAL ADVOCACY COMPETITION-2023

EXHIBIT -11
TORN VICTIM’S CLOTH

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