IN THE COURT OF THE HON’BLE CHIEF METROPOLITAN

MAGISTRATE :AT HANAMKONDA.

PRIVATE COMPLAINT S.R.No. /2018.

Between:

Smt. B. Vijaya Lakshmi, W/o. B. Sai Vikram,

R/o. Flat No. A1, Sri Kanya Towers,
New Shayampet, Huntur Road, Waranagal Dist. …..Complainant.

AND

1) B.Sai Vikram, S/o.B.Sai Prakash,

Age: 32 years, Occ: Software Engineer.

2) B.Sai Prakash, S/o.B.Srinivasa Murthy,

Age: 64 years, Occ: Retd.Employee.

Both are residing at the Flat No.203,

Ganesha Apartments, Near RTC Cross Roads,
Hyderabad 500020.
…..Accused 1 and 2.

COMPLAINT FILED UNDER SECTION 200 OF Cr.P.C.

1. Name of the Complainant. : Smt. B. Vijaya Lakshmi.

2. Name of the accused persons. : B.Sai Vikram and another.

3. Nature of offence. : Criminal Breach of Trust, Cheating,

Criminal Intimidation and Insult.

4. Offence Under Section. : 406, 420, 506, 509 of IPC r/w section
511 of IPC.

5. Place and date of offence. : Between the limits of Women Police

Station Rangampet.

6. Distance from P.S to the

Place of offence. : 3 kms.

7. List of witnesses. : 1. Complainant.

2. Suman, common friend of

complainant and accused.
Brief facts of the case:

1. Complainant above named beg to submit the following few lines for your

kind consideration and necessary action.

2. It is submitted that Complainant’s case in nutshell is that she married to B.

Sai Vikram on 25.10.2012 at Sunil Gardens, Mulug Road, Warangal according to

Hindu rites and customs. At the time of marriage her parents had given gold

articles worth Rs. 30,00,000/- (Rupees Thirty lakhs only) containing three different

gold items which are more fully described in the schedule appended here below.

DETAILS OF GOLD ORNAMENTS.

Gold Bangles,
Chandra Haram (Necklace)
Mangalasutram,
Ring
two silver glasses
Rs. 1,50,000/- in cash &
Big Haaram (Necklace),
Vanke,
Nalla Poosala Chain,
two big siler plates,
big silver Chembu
Rs. 50,000/- towards purchase of clothes

After certain period her married life, disputes arose between the complainant and

1st Accused and therefore, in order to restore the conjugal rights she filed O.P.

345/2015 on the file of Hon’ble Judge, Family Court at Hyderabad and similarly 1st

Accused also had filed O.P. 315/2016 on the file of Hon’ble Judge Family Court at

Warangal seeking divorce. Thereafter she had filed DVC in order to claim

maintenance towards sustenance for herself and her son.

3. It is submitted that recently on 18.08.2018 one Mr. Soma Suman, S/o.

Satyanarayana, R/o. 13-3-45/1, Mattewada, Warangal (who is a common friend of

her in-laws and herself) had informed that her husband, Mr. B. Sai Vikram and his

father Mr. Sai Prakash had sold away the gold ornaments worth of Rs. 30,00,000/-
(gold weighing about 120 tolas), which were given by her father at the time of

marriage. Moreover, Mr. Soma Suman also revealed that her husband leaving the

present company at Uppal and jumping the jurisdiction of your police station very

shortly.

4. It is respectfully submit that immediately she tapped available sources to

confirm the selling of her gold ornaments by them. After she had concrete

information that Mr. Sai Vikram and Mr. Sai Prakash had cheated her by selling

away all gold articles which were given to him under a trust. B.Sai Vikram and Sai

Prakash are supposed to maintain, uphold the trust she posed in them but they have

behaved contrararily and they have brought wrongful loss to her to the tune of Rs.

30,00,000/-.

5. It is submitted that again on 22.08.2018 when she called her husband in

order to enquiry as to in which marwadi shop they have sold away the gold

articles, instead of replying her in decent manner he had uttered and abused her in

filthy language which she cannot speak or write here but she is supplying the

VOICE RECORDED CD of that conversation. Once the CD is played, she need

not mention about any other fact but straight away, the Police will come to

conclusion that her complaint’s averments are true and correct. Complainant to

state that as such she deprived in the hands of said B.Sai Vikram and his parents.

Further, more he has also brought wrongful loss to her to the tune of Rs.

30,00,000/- i.e. by selling away her gold articles which were given to them by her

father and she have all evidence to prove that her father had given gold and cash

and also accepted all their demands to perform marriage on a very large scale and
her father spent all his hard earnings on her marriage as she the only daughter and

to see her ever happily after marriage. However all her dreams and her father’s

dreams have been shattered by criminal acts committed by Mr.Sai Vikram and his

parents.

6. It is respectfully submitted that on 25-08-2018 the Complainant have

approached the Inspector of Police, P.S.Subedari along with the present complaint

and laid it before him and requested him to take appropriate action. However, the

said Inspector of Police has advised me to approach the SHO, W.P.S.Rangampet,

instead of approaching him. However, on approaching the Rangampet Police

Station, the complainant found no officer sitting in the said Police Station and she

has been told that there is a meeting with the Commissioner of Police,

Hanamkonda, Warangal District and the Officer In-charge of the said Police

Station also a part of the meeting. She has waited till 4PM on that date but the

officer did not turn up. It is further submit that i.e. on 27-08-2018 also she has

approached the WPS Rangampet along with one lady counsel by name Rama Devi

and tried to lodge a complaint. However, they said this is civil in nature and the

dispute is between husband and wife and that the matters are pending before

Family Court they could not do nothing. Despite of complainant informing the

WPS Rangampet that divorce was granted and there is no legal relationship

between them therefore, misappropriation of gold jewellery to the tune of

Rs.30lakhs is amounting to a straight case of 406 and 420 of IPC and on asking,

accused No.1 and accused No.2 abused her in very filthy language. The entire

abuses made by the 1st Accused is recorded on the Mobile Phone and the same is

converted in a CD which is supplied herewith.

7. It is further submitted that as the concerned Police both SHO’s of both

Police Stations i.e., SHO, P.S.Subedari and WPS Rangampet could not take any

action as stated above and as a result for record sake we sent Complaints by

Registered Post with Ack Due to concerned police along with a report to the

Commissioner of Police, Hanamkonda for favour of information and necessary

action, and the receipts of the Registered Posts are herewith filed for the kind

perusal of the above Hon’ble Court. Hence the complainant is approaching this

Hon’ble Court to take appropriate action against the accused persons as per Law.

It is, therefore, prayed that the above Hon’ble Court may be pleased to

forward the present complaint to the Station House Officer, Women Police Station

Rangampet, Hanamkonda under section 156(3) of Cr.P.C. for further investigation

and report and pass such other order or orders as may be deemed fit and proper in

the interest of justice.

Dated: 28-08-2018
Place: Hanamkonda. COMPLAINANT.

COUNSEL FOR THE COMPLAINANT.

VERIFICATION

I, Balakavi Vijaya Lakshmi, W/o.B.Sai Vikram, Age 27yrs, R/o. Flat No. A1,

Sri Kanya Towers, New Shayampet, Huntur Road, Waranagal District do hereby

state and verify that this is my name and signature and the facts stated herein

above are true and correct to the best of my knowledge, information and belief.

Dated: 28-08-2018
Place: Hanamkonda. COMPLAINANT.

COUNSEL FOR THE COMPLAINANT.

 IN THE COURT OF THE HON’BLE CHIEF
METROPOLITAN MAGISTRATE:
AT HANAMKONDA.

Pvt.Complaint S.R.No. /2018.

Between

B.Vijaya Lakshmi. …..Complainant.

AND

B.Sai Vikram and another. …..Accused 1 & 2.

COMPLAINT FILED UNDER SECTION

200 OF Cr.P.C.

Filed on: 28-08-2018.

Filed by:

Counsel for the Complainant.