FIRST INFORMATION REPORT

T.S.P.M. Orders 470,500

(Under Section 154 and 157 Cr.P.C)

1. District Hyderabad P.S. CHILKALGUDA Year 2023 FIR No. 810/2023 Date 29-12-2023

2. Acts & Section(s): 405,407,409,417,418,420,467,468,406 IPC,156(3) CrPC

3. a) Occurrence of Offence: Day Monday Date & Time From

Date & Time To Prior To 02-05-2022 14:00:00 Time Period

b) Information Received at P.S.: Date & Time 29-12-2023 18:15:00

General Diary Reference: Entry No 24 Date & Time 29-12-2023 18:15:00

4. Type of Information: Through Post

5. Place of Occurrence:

a) Distance and Direction From P.S.: 1 km, East Beat No.

Seethafalmandi,
b) Address Place Area/Mandal Street/Village SEETHAPHAL MANDI
Chilkalguda

City/District Hyderabad State Telangana PIN

c) In case, outside the limit of this Police Station, then

Name of P.S. District

6. Complainant / Informant:

a) Name Sapa. Srinivas

b) Father's /Husband's Name S.Narsimhulu Late

c) Date/Year of Birth Age 54 Years

d) Nationality India e) Caste

f) Passport No Date of Issue Place of Issue

g) Occupation Mobile No. 9948661574

H.No. 11-2-119/2/A,
Mylargadda,
h) Address House No Area/Mandal Musheerabad Street/Village
Seethafalmandi,
Chilkalguda

City/District HYDERABAD State TELANGANA PIN

7. Details of known/suspected/unknown accused with full particulars:

Serial No : 1

a) Name M/s Sri Laxmee Narsimha Swamy constructions

b) Father's /Husband's Name

c) Occupation d) Caste e) Gender Male

f) Age Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No

i) Email

Serial No : 2

a) Name A. Harinath
b) Father's /Husband's Name Late A Bikshapathi

c) Occupation d) Caste e) Gender Male

f) Age 49 Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No 9059558499

i) Email

Serial No : 3

a) Name M. Rangaiah Gound

b) Father's /Husband's Name Late M Sataiah Goud

c) Occupation d) Caste e) Gender Male

f) Age 55 Nationality India

g) Address

8-5-95/1, Road
No.1, Mallikarjuna
House No Colony, Old Street/Village Area/Mandal
Bowenpally,
Secunderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No 9849201376

i) Email

Serial No : 4

a) Name Rajeshwari Devi

b) Father's /Husband's Name A. Harinath

c) Occupation d) Caste e) Gender Female

f) Age 45 Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No

i) Email

Serial No : 5

a) Name A Harshavardhan

b) Father's /Husband's Name A Harinath

c) Occupation d) Caste e) Gender Male

f) Age 30 Nationality India

g) Address

-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadguda,
Hyderabad
 City/District State PIN

h) Phone(Off) Phone(Resi) Cell No 6304649070

i) Email

Physical features, deformities and other details of the Suspect:

S. No. Sex Date/Year of Birth Build Height (cms) Complexion Identification Marks(s)

1 2 3 4 5 6 7

1 Male

2 Male

3 Male

4 Female

5 Male

Deformalities/
Teeth Hair Eyes Habbit(s) Dress Habit(s) Languages/ Dialect
Peculiarities

8 9 10 11 12 13 14

Place Of

Burn Mark Leucoderma Mole Scar Tattoo

15 16 17 18 19

8. Reasons for delay in reporting by the complainant / informant:

Delay from complainant

9. Particulars of properties stolen/involved (Attach separate sheet, if necessary):

10. Total value of property stolen:

11. Inquest Report/ U.D. Case

12. Contents of the complaint / statement of the complainant or informant:

IN THE COURT OF HON’BLE X ADDL. CHIEF METROPOLITAN MAGISTRATE AT SECUNDERABAD. Honored Sir, Brief facts of the case are that on
29.12.2023 at 18.15 hrs, received a complaint from Sri. Sapa. Srinivas, S/o. S.Narsimhulu Late, Age: 54 years, Occ: Private Employee, R/o H.No. 11-2-119/2/A,
Mylargadda, Seethafalmandi, Chilkalguda, Ph.No.9948661574. In the year 2019 I have seen a house under construction at Seethaphalmandi, Secunderabad and
accordingly I made a phone call to the builder and approached A-1) M/s Sri Laxmee Narsimha Swamy constructions having Office at flat No.501, H.No. 1-3-
183/39/A/B Gandhinagar, Kavadiguda, Hyderabad, A-2) A. Harinath S/o Late A Bikshapathi, Aders 49 YEARS flat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad Mob. No. 9059558499, A-3) M. Rangaiah Gound S/o Late M Sataiah Goud, AREA 55 YEARS R/o 8-5-95/1, Road No.1,
Mallikarjuna Colony, Old Bowenpally, Secunderabad 500011, Mob. No.9849201376, A-4) Rajeshwari Devi, W/o A. Harinath Age: 45 Years, R/o. flat No.501,
H.No. 1-3-183/39/A/B Gandhinagar, Kavadiguda, Hyderabad, A-5) A Harshavardhan S/o A Harinath, Age: 30, Yrs Ro. flat no. 501, H.N. 1-3-183/39/A/B
Gandhinagar, Kavadguda, Hyderabad Mob. No. 630464070. It was agreed that the builder i.e. A2 would sell the house for Rs.33,00,000/- and that he have to pay
30% of the amount initially. He have paid and amount of Rs.5,00,000/- in June, 2019 and later he gave Rs.4 Lakhs and in october 2019 he gave Rs.5 lakhs. He
have paid the remaining amount in the same month in three installments. After he paid the entire amount the accused has executed an agreement of sale in his
favour. Later the accused has stopped receiving my calls as the accused promised to get a loan for him. He have also approached A3 regarding the said house and
the payment made by him and he promised to talk with A2 and settle the matter but due to COVID-19 he could not contact any of them and he was not handed
over the said house by the accused persons. By the end of the 2019 A2 has issued legal notice to me claiming that as he have taken cheques from him and that he
failed to make the payment and for the said notice he have sent reply. Hence he requested to take necessary action. -:Original English typed complaint is enclosed
herewith:- Received on 29.12.2023 at 18.15 hrs: Basing on the contents of the above petition, I, P. Balaraju, SI, registered a case in Cr.No. 810/2023, U/s 405,
407, 409, 417, 418, 420, 467, 468, 406 IPC & 156 (3) Cr.P.C. and case file entrusted to Smt. K.Sabitha, SI for further investigation. Sd/- (Sri P. Balaraju, Sub-
Inspector of Police, Chilkalguda PS, Hyd)

13. Action taken:

Since The above information reveals commission of offence(s) U/s as mentioned at item No:

1) Registered the case and took up the investigation or Name KARUPPAIAH SABITHA

2) Directed to take up the Investigation or Rank: SI No. 8443

3) Refused investigation due to

4) Transferred to P.S District on point of jurisdiction.

F.I.R. read over to the complainant / informant, admitted to be correctly recorded

and a copy given to the complainant /informant, free of cost. R.O.A.C

Signature / Thumb impression of the Signature of Officer in charge, Police Station

14.
complainant / informant.
Name PACHCHU BALARAJU

Rank SI No --

15. Date and time of dispatch to the court:

 CHIEF
HON'BLE X ADDL.
IN THE OURT OF THE
METROPOLITIAN MAGISTRATE, HYDERABAD DISTRICT
AT SECUNDERABAD

C.C. NO. OF 2023

Between:
17el3
31183) Sapa Srinivas
S/o Late Narsimhiu, Aged about 54 years
(1&/1 Occ: Private Service R/o H. No.11-2-119/2/%
Mylargada, Seethaphalmandi, Secunderabad 500060
cey:994- 661S74 ..Complainant
AND

M/s Sri Laxmee Narsimha Swamy constructions

12 Having Office at flat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 9059558499

A. Harinath
S/o Late A Bikshapaihi, Akarn 47 YEne
lat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 9059558499

M. Rangaiah Gound
S/o Late M Sataiah Goud, AdsD SS Y AS

R/o 8-5-95/1, Road No. 1,Mallikarjuna Colony,

Old Bowenpally, Secunderabad 500011,
Mob. No.9849201376

A. Rajeshwari Devi
W/o A. Harinath Aaan 4 S ¥EARS
R/o. flat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
S ivAS
4. A Harshavardhan
S/o A Harinath A 3o VEA
R/o. flat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 6304649070

. Accused

COMPLAINT UNDER SECTION 200 OF Cr.P.C.

I. Nature of Offence : Under Sec. 405, 407, 409, 417,418, 420, 467,
468 of iPC and 406 IPC.
2. Place of Offence
Seethaphalmandi, Secunderabad
3. Jurisdiction of Police Station: P.S.
Chilkalguda
4. Date of Offence
30-06-2022 continued.
5. List of Witnesses
1. Thirumala Chary

2 Mithilesh Kumar
3. Mohd. Hammiuddin

4. K. Srinivas
The Complainant humbly begs to state and submit as follows

The address of the

parties
correctly set out in the foregoing cause title. The
are

Complainant may also be served through its counsels, M/S

Laxmikala and Sumalatha
J.C.Francis, M. B.
,Advocates having office at 3-3-389/B Chappal Bazar,

S. SRvivAas
z2 achiguda, Hyderabad 500027, Telangana for the purpose of Court Summons
Notices etc., from this Hon'ble Court.

The Complainant respectfully submit that this is a case of Criminal Breach of

Trust, Criminal Breach of Contract, Misappropriation, falsified Documentation and
cheating. in which the complainants was put to wrongfiul loss by accusec

2 The facts are that the Accused herein have committed the offences of

section 405, 407, 409, 417,418, 420 of IPC and 406 1IPC, it is submitted that since
the cause of action of all the complainants herein is one and the same, I am filing a

it is submitted that this is being filed questioning the

single petition. petition
inaction of the respondent police in not registering and investigating the complaint
of the petitioner dated 14-10-2022 as illegal contrary to law and judicial

precedents. it is submitted that all the accused in my complaint dated 14-10-2022

have connived, conspired, and manipulated the Registered property document

submitted to the petitioner on several occasions with reference to the Regisiered

Sale deed and Registered Develop:nent cum General Power of Attorny in

executing a sale agreement with the petitioner on 20-06-2019, with the sole
intention to usurp the petitioner family funds for their personal gain and benefit,
formed to cater to the needs of residential
knowing fully well, the apartment was

families in need of economical support for enjoyment of their family life.

It is relevant to state that the land and the builder. were present at the
3 owner

time of negotiating the purchase of apartment transaction, and they jointly made

statement of executing a sale deed of the unfinished flat to avail a loan of 40 lakhs,

towards which 10% (Ten percent) margin nioney was to b: deposited in the bank

S SRi's
for availing 90% Housing loan that would pay for the total cost of the apartme gt12210

amounting to Rs.41,10,000/- The said apartment had to be handed over to me

within two months from the date of making the advance payment of Rs.5,00,000/-
that was made on 20-06-2019 and having a written agreement made on 20-06-2019

and as per the agreement on further payment made towards, The payment for
GHMC Taxes and mutation of the flat, electricity deposit, water and HMWSSB
deposit and charges, registration charges and fees towards execution of sale deed
of unfinished flat, were made by me, toiwards which said understanding and oral
agreements, a total amount of Rs. 14,10,000/- (Rs. fourteen lakhs ten thousand)
was paid to the accused No.l4, who have collected the said amounts and
to

promised to deliver the apartment into my custody within a period of two months
from the date of receipt of amounts denianded. Wherein I
fulfilled my part of the
agreement. Copies of the land owners sale deed vide doc. No.2375/2018
and
registered D.G.P.A vide doc. No. 1570/2019 alongwith the written agreementis
filed herewith.

5) Believing and trusting their commitments, with the oral and written
undertaking given by Builder and the landlord in the presence of several other third
party purchasers present at the time of negotiation, I was made to believe the
accused to being honest and law abiding Indian citizens, going by the accused
professing to have the local competency to execute the
apartment construction in
abiding by Indian laws, rules and regulations I made a further
payment of Rs. nine
lakhs ten thousand. (Rs.9, 10,000/-) i.c. iom
June 2019 to June 2021. Details
the payment made of the funds collected
of
by the accused is filed herewith.
SSRIN v4S
m m

7) The complainants further submit to this Hon'ble Court that the Accused have
intentionally misappropriated, cheated and swindled the funds which
for the sole purpose of construction and
compliance with the authorities concermed
and to obtain the financial assistance needed to complete the execution of the
unfinished construction. By way of making payment to the authorities concerned
for perfection of the title with the concerned and for
departments, obtaining
financial assistance from the financial institutions based the
on margin money
deposited with the accused to be kept in the bank account along with the title deeds
of the property held by the accused No.l to 3 for obtaining funds to complete the

execution of the multi storied residential complex. In spite of having received the
funds of Rs.14,10,000/- lakhs between the
period of June 2019 to January 2021
the project remained it in the
as was same stage of completion that was seen in the
month of May and June 2019 prior to the entry of the transaction with the Accused,
wherein all the Accused No.l to no.4 the
were present at apartment site located at
Seethaphalmandi. Secunderabad.

8 The Complainants submits that the accused has dishonestly and fraudulently
induced the complainant to come and join flat
as a owner member of the
apartment, only in order to usurp, cheat and swindle the
petitioner of their family
savings and personai funds with the sole aim to cause wrongful loss to the

petitioner herein for the accused Nc.! to 4 personal gain and benefits, by
adopting fraudulent means thereby the accused has committed offence U/sec. 405.
407, 409, 417,418, 420,of IPC and 406 IPC inspite of the several visits to the site
sSR'nv
 and to the residence of the Accused no.l to 4, the Accused No.l to 3 absconde

trom their premises and became contact less from the period of May 2021 till iae
Letters sent to the accused were returned by the postal department as no such

person available at the address. The accused no.3 received the letters sent by the
petitioner but failed to respond. It is pertinent to mention that the accused got
issued receipts to the petitioner giving the same wrong addresses mentioned in the
agreements registered with the authorities vide registered deeds. copy of the
receipts received is filed herewith.

9 The petitioner fearing the adverse response and non communication, after
having visited the site and residences of the accused were shocked and pained to
see that the Respondent No.I to 4 had deliberately given false address, thus fearing
the worst of the absconding builder, the petitioner traced the land owner and asked
for an execution of the unfinished apartment towards which Rs. 14.10,000/- was
paid and received by the accused no.i to 4. The accused no.3 informed the
petitioner that the payments were received by accused no. 1. 2 and 4. Hence the
accused no.3 refused to co-operate and expressed his inability to assist the
petitioner. The petitioner having no other option were constrained to intorm the
police authorities on 14-10-2022 to investigate into the unlawful activities of the
used no. I to 4, the accused no. 1,2 and 4 declined to respond to the police
enquiries, and accused no.3 refused to come to the police station to answer for the
said above transaction. Hence the police authorities have instructed the petitioner
to approach the Hon'ble Courts, for directions to proceed against the accused
Hence this petition. Copy of the complaint filed and numbered as 01768 with the

SSRNivas
 with the acknowledgement by the commissioner of police is filed
zzea police along
herewith.

10 JURISDICTION: The apartment location and site office of the accused is

in Chilkalguda zone of Seethphalmandi, Secunderabad District, which falls under

Police Station, hence this Hon'ble Court is having ample and

Chilkalguda
territorial jurisdiction to try the case.

11. PRAYER:

It is therefore prayed that this Hon'ble Court may be pleased to refer U/sec.156(3)
CrPC to the P.S. Chilkalguda for requesting a FIR under Sec. 405, 407, 409,
417.418, 420, of IPC and 406 IPC against the accused and initiate prosecution
against accused and to pass such other order or orders as may deem fit and proper

in the circumstances of the case as otherwise, the complainant would be put to

severe hardship and irreparable loss.

S.SRn'vAS
COMPLAINANT

Date 02/05/2023

Place: Secunderabad

ApveIR
 0 a11S/R3 IN THE CoURT OF THE HidezsEnie.
X ADDL CHIEF METROE AN
MAGISTRATE, HYDERABAD
DISTRICT
NDI

AT SECUNDERABAD
ONE RUPEE

C.C. NO. OF 2023

Pase eca3 Between:

Sapa Srinivas
c+ ..Complainant

AND

M/s Sri Laxmee Narsimha Swamy

constructions And others
Accused
bSapo . ro
harb Cat to Rehen ttGlak COMPLAINT UNDER SECTION 200
OF Cr.P.C.

btentes o uo u07,u0,
4,u6,u6 ot RLam eo u,uIG Filed On: 02/05/2023
bPE,
Coo A to AAu Filed By: Counsel for Complainant

Capont ld Coopy t
S-4 Od t e n Aulose Address for Servicee

wdn lbidsuuot aund Uebiedobbit J.C. Francis

M.B. Laxmikala
Ciet ob dotahntt foud t 3-3-389/B, Chappal Bazar,
Kachiguda, Hyderabad 500027

Reutvnd on 29po 1815 hm

P u e dtretions o) tie tonble A
-

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