IN THE HIGH COURT OF JUDICATURE AT HYDERABAD FOR THE

STATE OF TELANGANA
Crl.P.No. Of 2022

RUNNING INDEX
S.No. Description of the Document Date of Date of Page
Document filing no.
Memorandum of Grounds

EX-P1 Aadhar Card of the Petitioner

EX-P2 Photocopy of FIR No. 130 of 2020

with True Translation (fair copy)

EX-P3 Photocopy of the charge sheet in Fir

No.281 of 2021
EX-P4

EX-P5

Vakalath of the Petitioner no. 1/ De-

facto complainant.

Place: Hyderabad

Date:
COUNSEL FOR PETITIONERS
 MEMORANDUM OF CRIMINAL PETITION
(Under Section482 of Cr.P.C)
HIGH COURT OF JUDICATURE AT HYDERABAD
FOR THE STATE OF TELANGANA
Crl.P.No. Of 2022
Against
FIR. No. 130of 2020
ON THE FILE OF THE HON’BLE JUDICIAL FIRST CLASS MAGISTRATE
(Prohibition and excise Offences) AT NALGONDA

Between:

1. Ginkala Devika,
D/O Ginkala Pullareddy,
Occ: Housewife,
R/o H.No. 273, Shivasai Township,
Narketpally Mandal,
Yellareddy Guda, Nalgonda, Telangana. -508254 ….petitioners/De-facto
Complainant.
And
1. State of Telangana
Rep, by its Public Prosecutor,
For the State of Telangana
High Court of Judicature at Hyderabad.

2. Nibragandla Rama Harshwardhan Reddy.

S/o Venkata Ranga Reddy,
Age: 26 Years, Occ: Private Employee
R/o H.No. 1-111-1/C/269, Raghavendra Colony.
Kondapur, Near RTO Office, Hyderabad. ...De-facto complainant

3. Station House Officer,

Narkatpally Police Station,
Nalgonda. -508 254. ...Respondent.

The address for service of notices and processes on the above named petitioner is that
of her Counsel Kaustubh Akkiraju (21835), A. Srinath, T. Pradyoth, and
Chandrashekhar, C/o Srinath & Pradyoth Law Offices LLP, #Unit Number 127,
downtown Mall, Beside Lotus Hospital, Lakdi-ka-pul, Hyderabad.-500 004.
 PETITION FILED TO EXPEDITE PROCEEDINGS
This memorandum of criminal petition is filed praying to expedite the
proceedings of F.I.R No. 130 of 2020 on the file of the Hon’ble Court of
Judicial First Class Magistrate (Excise & Prohibitions Offences) Court at
Nalgonda wherein the petitioner herein is the complainant and has
complained that the accused have committed offences punishable under
Section 498-A, 354 r/w 34 of the Indian Penal Code, 1860, Section 3, 4 of
the dowry Prohibition Act, 1961 and Section 67, 67A of the Information
Technology Act,2000. The petitioner is a homemaker and is the wife of
Accused No.2 in the current criminal petition. A copy of her Aadhar Card
is herewith annexed as EX-P1.

BRIEF FACTS OF THE CASE

1. The de-facto complainant/petitioner has give a complaint to the Station
House officer, Narketpalli Police station on 30-07-2020 accusing A1
(arrayed herein as respondent No.2) of offences committed under Section
498A of the Indian Penal Code and, Section 4 and 5 of the Dowry
Prohibition Act . The complainant has also accused A1 under the
Information Technology act, 2000. The respondent police registered an
charged sheet bearing No. CC/ 1696/22 and have prima facie charged the
petitioners herein under section 498-A, 354 r/w 34 of the Indian Penal
Code; Section 3, 4 of the Dowry prohibition Act and Section 67, 67A of
the Information Technology Act in the above referred crime and the
police in the delayed manner have filed the charge sheet after two and
half years from the date of the complaint being filed. The improper and
abnormal delay by the police officials in filing the charge sheet caused
severe problems other than the justice that is due to the petitioner herein.
It is also pertinent to note that the statement of the petitioner under
Section 162 of the Criminal Procedure Code has been taken and yet this
inaction had taken place. A photocopy of the same is herewith annexed as
EX-P2

2. The allegation of the petitioner /de-facto complainant is that the Accused

No.2 along with his father, mother and brother has tortured the petitioner
 both mentally and physically for additional dowry. Also, that the
respondent no.2 in the current criminal petition has recorded intimate and
private moments between him and the petitioner and has circulated the
same within their known circles which have caused both severe mental
trauma and humiliation within the society.

3. The petitioner and respondent no.2 got married to each other in the year
2020 and during the time of their marriage, a sum of Rs. 2,00,000/- in
cash, 30 tolas of gold and other household items were given as per their
customs and traditions.

4. That ever since the marriage up until the time of complaint being given to
the 3rd respondent, the petitioner again was tortured by the 2nd respondent
along with his parents for an additional dowry of Rs. 2,00,000/- so that
the respondent no.2 could purchase a Royal Enfield bike.

5. That during the time when the petitioner lived with the 2 nd respondent at
her in-law’s place, in the absence of the petitioner’s husband the
petitioner’s father in law made lewd passes at her which has caused
severe mental trauma affecting her mental well being.

6. In the month of June 2020, the petitioner herein not being able to bear the
torture of the respondent no.2 and his family members came back to her
parental place and has been staying there ever since.

7. That post the petitioner coming back to her parental place in the year
2020, her father in ,law i.e., father of the second respondent in the current
criminal petition had made calls to the petitioner as well as her family
members threatening of dire consequences if the matter is not settled
amicably. Therefore another complaint was lodged by the petitioner
against her father in law and the same was registered as FIR number281
of 2021 dated 05-10-2021 u/s 504 and 506 of IPC. The same is pending
on the file of the Hon’ble Judicial First Class Magistrate (Prohibition and
 Excise Offences) at nalgonda. A photocopy of the same is herewith being
annexed as EX-P3.

8. That it is pertinent to note the fact that the father in law of the petitioner
herein is a police officer and is working as an ARHC (Assistant Reserve
Head Constable) at Hyderabad. The petitioner fears that since her father
in law is a police officer himself and is acquainted to many a high
ranking officials, he might try and de-rail the case or cause further
irrevocable damage to the same.

9. The petitioner for the same seeks protection order and residential order
and also sought for the return of dowry of Rs. 2, 00,000/-, 30 tulas of gold
and Rs.1, 00,000/- worth household articles which were given at the time
of marriage from the respondents. The Hon’ble Court observed that the
petitioner has been subjected to domestic violence in the hands of
petitioner no.1 to 3 and directed the officer in charge of the nearest police
station where the petitioner resides to provide assistance in the
implementation of the said order in favor of the petitioner. The petitioner
herein states that when she went to her Husband’s house along with the
District welfare officer Protection officer, under P.W.D.C Act 2005
R.R.Dist., on 13-05-2022 but the respondent did not allow her to enter in
to their house, this clearly shows that the defendant disobeyed the order
of the Hon’ble court. The petitioner in the same matter has filed another
petition in the court of judicial magistrate of first class at Nallagonda
under section 31(1) of D.V.C act. The same is affixed as EX-P4

10. The hon’ble court in furtherance to the judgment passed, has order the
nearest police station to provide assistance in the implementation of the
protection passes in favor of petitioner, even after that, the police has not
been complying with the order, which is causing severe problem to the
petitioner, in addition to that, the police is constantly calling upon the
petitioner to resolve the issue by settlement with the respondents. Due to
which the petitioner feels they have a threat from the respondent. The
respondent no’s 1 to 3 were hereby ordered to prohibit from
 communicating with the petitioner in any form which may lead to
domestic violence.

11. That the Hon’ble Court on 25-03-2022 directed the respondents to pay
Rs.3000/- for alternative accommodation, further a sum of Rs.10,000/-
has to be deposited in to the S.B account of the petitioner on or before
10th of every month effecting from the date of petition i.e. 12-01-2021
and also granted Rs. 2,00,000/- .It is submitted that the respondent failed
either to pay the arrears of maintenance along with interest, even though
the respondent has got sufficient means to pay the said amount since he is
drawing the monthly pension of Rs. 2,00,000 apart from which he has
movable and immovable properties on his name by which he has got
sufficient means to pay the amount.

12. It is submitted that due to non compliance of the orders of the Hon’ble
court by the respondent, the aggrieved party suffering a lot as she has no
other source of income to maintain herself. It is submitted that the prices
of the essential commodities are touching to sky and the parents of the
petitioner is unable to maintain the petitioner with meger income. The
petitioner is badly in need of money for the basic necessities. The
aggrieved party on the same matter has lodged another petition against
the respondent under section 20(3) of D.V.C. ACT r/w section 125(3) in
the court of the judicial magistrate of first class at nallagonda
IN THE HON’BLE HIGH COURT FOR
THE STATE OF TELANGANA AT
HYDERABAD
Crl.P.No. of 2022

MEMORANDUM OF CRIMINAL
PETITION

Filed on:

Filed by:

KAUSTUBH AKKIRAJU
A. SRINATH
T. PRADYOTH
J. HARISH
P. CHANDRASHEKAR
Counsel for the petitioner

Address for Service

Unit No. 127, Downtown Mall,
Beside Lotus Hospital, Lakdi-ka-pul
Hyderabad. -500 004
 HON'BLE HIGH COURT OF JUDICATURE FOR THE STATE OF
TELANGANA AT HYDERABAD
Crl.P.No. of 2022
Between: …Petitioner

And
I/We, ….Respondent

do hereby appoint and retain

KAUSTUBH AKKIRAJU (21385)
A. SRINATH
T. PRADYOTH
J. HARISH
P. CHANDRASHEKAR
SRINATH & PRADYOTH LAW OFFICES LLP

To appear for me/us in the above Suit/ Appeal / Petition Case and to conduct and prosecute
and defend the same and all proceedings that may be taken in respect of any application for
execution of any decree or order passed therein. I/We empower my / our Advocates/s to
appeal in all miscellaneous proceedings in the above Suit or matter till and decrees or order
are fully satisfied, or adjusted, to compromise and obtain the return of documents and draw
any money that might be payable to me/us in the said suit or matter and I/We do further
empower my our Advocate/s to accept on my/our behalf service of notice of all or any appeal
or petition filed in any court or appeal Reference or Revision with regard to the said suit or
matter before disposal of the same in Honorable Court.

Certified that the executants who is well acquainted with English, read this Vakalatnama that
the contents of this Vakalatnama were read out and explained in Urdu/Hindi/Telugu to the
executants/s he/she they being unacquainted with English, who appeared perfectly to
understand the same and signed or put this/her/ their name/s or mark/s in my presence.

Identified by:

Executed on day of ,2022 Advocate

IN THE HON’BLE HIGH COURT FOR
THE STATE OF TELANGANA AT
HYDERABAD
Crl.P.M.P.No. of 2022
In
Crl.P.No. of 2022

DISPENSE WITH PETITION

Filed on:

Filed by:

KAUSTUBH AKKIRAJU
A. SRINATH
T. PRADYOTH
J. HARISH
P. CHANDRASHEKAR
Counsel for the petitioner

Address for Service

Unit No. 127, Downtown Mall,
Beside Lotus Hospital, Lakdi-ka-pul
Hyderabad. -500 004