161 Statement

(Criminal Procedure Code, 1973)

Complainant Elavazhagan

I am Elavzhagan F/o Kamali. My Daughter was Mrs.

Kamali, w/o SANTHI AND KAVYA. They were married in 07.03.2019.
Kamali was married to SANTHI AND KAVYA on 07.03.2019, which was
arranged by their parents,
which held at a temple. SANTHI AND KAVYA was continuously
nagging his wife to get more money from her parents as dowry.
Kamali was tortured by SANTHI AND KAVYA both physically as well as
mentally. On 18.05.2019 around 12 PM SANTHI AND KAVYA who
came home hit Kamali badly as a result of which that she fell down
and died. Her husband tried to prove that it was a sudden
provocation but still he tried to destroy the evidence to make the
death seen a natural death.

All the above statement which was given by me without any

coercion.

Accused

Investigation officer
IN THE DISTRICT COURT OF SALEM
Cr No.123/1989

STATE .... PROSECUTION

VERSUS

SANTHI AND KAVYA ......... RESPONDENT

161 STATEMENT

COUNSEL FOR PROSECUTION

WESTLY ANTONY P
 Charge Sheet

(Under Section 173

Cr.P.C)

IN THE COURT OF JUDICIAL MAGISTRATE, SALEM

1.Dist: SALEM P.S: C1 Ammapet P.S Year:2019 F.I.R. No:

13/2019
Date:18/05/2019.

2. Final Report/ charge sheet No: 7654 3. Date

3. S.No Act Sections

1. INDIAN PENAL CODE SEC 304 A & 304B
2.

4. Type of Final Form/ Report: charge sheet/ Not charge sheeted for
want of evidence/ FRT- undetected/FRT- untraced / FRT-offence
abated/FR-unoccured.
Charge sheet
5. If FR unoccured: False/Mistake of fact / Mistake of law/Non-
cognizable/Civil nature. No

6.If charge sheet: Supplementary or Original.

 Original

7.Name of I.O: Raj Rank no: SI

No:5643
(a)Name of Complainant/Informant : Elavazhagan

8. Details of properties / Articles/ Documents recovered/seized

during investigation and relied upon.

9. Particulars of accused persons charge-sheeted: SEC: 304A & 304B

of IPC Section -4 of Women Harassment Act read with 498A of IPC.

Whether verified: yes

 First Information Report

(Under Section 154 Cr.p.c)

1. District: Salem P.S: C1 Police Station Year 2022 FIR

No. 1 Date:18.05.2019

2. Act(s) : The Indian Penal Code Act sec 304A & 304B,

Section -4 of Women Harassment Act read with 498A of IPC

_____________________________________________________

3. (a)
Occurrence of offence Day: Saturday Date From: 18-05-2019
Date To:
4. Place of Occurrence: Ammapet, Salem(a) Direction and
Distance from PS: C1 Police Station Beat Number: I BEAT
(b) Address: 8/79, anna nagar, ammapet, Salem.
(c) In case, outside limit of this police station, then the name of
the P.S:
_____________________________________________________
To be sent requested: -
I am Raj working as Sub Inspector. Today, 18-05-2019 Mr.
Elavazhagan has given the complaint in C1 police station,
Ammapet, Salem. His daughter’s name is Kamali. He
complained about his daughters unnatural death. he requested
to punish the suspect for this activity. I accepted his complaint.
 Based on his complaint under section 304A & 304B the case
has been registered against the husband of his daughter.

5. Action Taken: Since the above report reveals under section

304A & 304B of IPC registered case and took up for
investigation.
___________________________________________________
6. Signature/ Thumb impression of the complainant/Informant :

Signature of the office in-charge, Police station:

7. Date &time of despatch to the court: 18-05-201
Name: Raj
Rank: Sub Inspector of Police No.
____________________________________________________
IN THE DISTRICT COURT OF SALEM
Cr No.123/1989

STATE .... PROSECUTION

VERSUS

SANTHI AND KAVYA........ RESPONDENT

FIR

COUNSEL FOR PROSECUTION

WESTLY ANTONY P
IN THE DISTRICT COURT OF SALEM
Cr No.123/1989

STATE .... PROSECUTION

VERSUS

SANTHI AND KAVYA ......... RESPONDENT

Charge Sheet

COUNSEL FOR PROSECUTION

WESTLY ANTONY P
 IN THE DISTRICT COURT OF SALEM
Cr No.123/1989

STATE OF TAMILNADU
PROSECUTION

Versus

SANTHI AND KAVYA

RESPONDENT

WRITTEN ARGUMENTS ON BEHALF OF PROSECUTION

I, on behalf of the petitioner, would like to bring to your notice the brutal and inhumane
treatment that Kamali had to undergo under her husband, SANTHI AND KAVYA. The
marriage was arranged by their parents, and the ceremony was held at a temple on
10.04.1987. However, since then, SANTHI AND KAVYA was continuously nagging Kamali to
get more money from her parents as dowry.

The petitioner would like to highlight that the practice of dowry is illegal and banned under
the Dowry Prohibition Act, 1961. It is shameful that even in today's age, some people resort
to this heinous practice. Kamali's parents had already given a substantial amount of money
to SANTHI AND KAVYA's family, but it was never enough for him.
Moreover, SANTHI AND KAVYA subjected Kamali to physical and mental torture, making her
life miserable. On 26.4.1988, around 12 PM, SANTHI AND KAVYA came home and hit Kamali
so severely that she fell down and died. He then attempted to cover up the crime and make
it look like a natural death.
The petitioner would also like to emphasize that violence against women is a grave offense
and needs to be dealt with severely.State of Haryana v. Bhajan Lal (1992): In this case, the
Supreme Court has laid down guidelines for the authorities to deal with dowry-related
crimes. The court has observed that such crimes should be dealt with seriously and
punished severely.

State of Punjab v. Iqbal Singh (1991): In this case, the Supreme Court has held that cruelty
against women can take different forms, including physical and mental torture. The court
has also held that cruelty is a ground for divorce and can also be a criminal offense.

Laxman v. State of Maharashtra (2002): In this case, the Supreme Court has observed that
evidence of physical violence and mental torture can be used to prove the charge of
murder.

State of U.P. v. Lal Singh (2007): In this case, the Supreme Court has held that it is the duty
of the trial court to ensure that the prosecution produces all relevant evidence to prove the
charges against the accused. The court has also held that tampering with evidence is a
serious offense and can lead to adverse inferences against the accused.
IN THE DISTRICT COURT OF SALEM
Cr No.123/1989

STATE .... PROSECUTION

VERSUS

SANTHI AND KAVYA RESPONDENT

WRITTEN ARGUMENTS ON BEHALF

OF PROSECUTION

COUNSEL FOR PROSECUTION

WESTLY ANTONY P