CIVIL PLEADING

IN THE COURT OF CIVIL JUDGE JUNIOR DIVISION,SULTANPUR

Suit No............. of 2019

Raman, S/o Chaman aged 42 years R/o Civil Lines Sultanpur .......Plaintiff

Versus

Mohit, S/o Ramesh aged 40 years R/o 35 Civil Lines Varanasi .......Defendant

Suit for against agent for delivering of account

The plaintiff above named begs to submit as follows:

1. That under a registered general power of attorney executed in march 2-3-2018 Late
Chaman father of the plaintiff, appointed Mohit, the defendant, as his authorised agent
to collect rents of his houses property situated in Sultanpur.
2. That the defendant started collection of rents from the month of April 2019 and has
been doing so till this date.
3. That the said Chaman died in the month of may 2018 leaving behind only the Plaintiff,
his only heir.
4. That the particulars and full details of the collection made by the defendant are not
known to the Plaintiff up to this time. The defendant has not rendered any account of
money received by him in behalf of father of the plaintiff.
5. That the plaintiff several times requested the defendant to deliver up to date the
accounts but he certainly failed to do so deliberately.
6. That the cause of action arose on June 15 2018 and further on June 23 2018 when the
plaintiff demanded up to date accounts from the defendant and defendant refused to do
so.
7. That the parties reside within the local jurisdiction of this court and the court is
competent to try the same.
8. That the value of the suit for the purposes of court fees and jurisdiction is Rs 4000 and
requisite court fee being paid of the same.

PRAYER

1. A full and complete account of the amount realised by the defendant on behalf of the
plaintiff.
2. A decree for the payment of rent collected by the defendant on behalf of the plaintiff.
3. Cost of the suit in favour of the plaintiff.
4. Such other and further relief as the court may deem fit and proper.

Date: XXXX 2019 (Raman)

Place: Sultanpur Plaintiff

Counsel for Plaintiff

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 VERIFICATION

I, X declare that the contents of paras 1 to 8 of this plaint are true to my personal knowledge.
The Plaint and the verification has been verified by me on 20 January 2019 within the
compound of civil court, Sultanpur.

Date: XXXX 2017 (Raman)

Place: Sultanpur Plaintiff

XXXX

Counsel for Plaintiff

AFFIDAVIT

 I Raman, R/o Civil Lines, Sultannpur do hereby solemnly affirm and declare as under:-

1. That I am the son of Chaman and resident of the above said address.
2. That I am staying on the above address.
3.That it is my true statement

                                                                                                                      DEPONENT

VERIFICATION

Verified at Sultanpur on this _________ day of 2019 that the contents of the above affidavit
are true to the best of my knowledge and belief.

DEPONENT

5|Page
 (WRITTEN STATEMENT)

IN THE COURT OF CIVIL JUDGE JUNIOR DIVISION, SULTANPUR

Suit No........ Of 2019

Raman, S/o Chaman aged 42 years R/o Civil Lines Sultanpur .......Plaintiff

Versus

Mohit, S/o Ramesh aged 40 years R/o 35 Civil Lines Sultanpur .......Defendant

Written statement on behalf of Mohit, Defendant above named, is as follows

1. That the content of para 1 of the plaint are denied.

2. That the contents of Para 2 and Para 3 of the plaint are not admitted.
3. That the contents of Para 4 of the plaint are not admitted.
4. That the contents of Para 5 of the plaint are denied.
5. That the contents of Para 6 and Para 8 of the plaint need no reply.
6. That the money and as when received by the defendant was delivered to the plaintiff.
7. That the defendant used to give details of accounts every month to the plaintiff and
the plaintiff used to sign on the account book.
8. That the claim of the plaintiff is false and fabricated and no amount is due on the
defendant.
9. That the suit of the plaintiff may be dismissed with special cost to the defendant.

Date: XXXX 2019 (Mohit)

Place: Sultanpur Defendant
XXXX
Counsel for Defendant

VERIFICATION.

That the contents of Para 1 to 9 of this written statement are true of my personal knowledge.
This has been verified on this 30th January of 2019 within the court compound of Sultanpur.

Date: XXXX 2019 (Mohit)

Place: Sultanpur Defendant

XXXX

Counsel for Defendant

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 (Interlocutory application for attachment of property before judgement)
(Order 38 Rule 5 of CPC)

IN THE COURT OF CIVIL JUDGE, SENIOR JUDGE, AT JAUNPUR

Application No 708/2019
In
Suit No 336/2017

Babloo, S/o Satish

R/o Tarapur, Jaunpur .....Petitioner(Plaintiff)
Versus
Ajeet, S/o Sunil
R/o Rampur, Jaunpur .....Respondent(Defendant)

Application for attachment of property before judgement.

(Order 38, Rule 5 of CPC)
Sir,
The applicant respectfully states as under:
1. That the plaintiff suit is pending in the hon'ble court for suit for recovery of Rs
10 lacs against the defendant. The defendant has received summons.
2. That the defendant has given the advertisement in the newspaper for sale of her
agricultural land.
3. That the defendant has no other property therefore suit of the plaintiff will fail.

PRAYER

It is therefore prayed to pass an order for conditional attachment of the defendant

property. Details are given in Annexure 2.

Place-Jaunpur (Babloo)

Date-12/01/2019 Petitioner

XXXX

Counsel for petitioner

7|Page
 (PETITION FOR JUDICIAL SEPARATION UNDER SECTION 10 0F HINDU
MARRIAGE ACT 1955)

IN THE FAMILY COURT, AGRA

Petition No.......2019

Mrs Sanish Singh, W/o Nikhil Singh aged 27

R/o Sikandra, Agra .....Petitioner

Versus

Nikhil Singh, S/o Ajay Singh aged about 36

R/o Sikandra, Agra .....Respondent

The petitioner above named under section 10 of the Hindu Marriage Act 1955 states as
follows:

1. The petitioner submits that she is legally married wife of the respondent. This
marriage was celebrated in the year 2015 at Agra. At the time of marriage the
petitioner's parents gave 25 tolas of gold and Rs. 2,00,000/- in cash as dowry to
the respondent. The marriage was consummated immediately.
2. The petitioner submits that, she is the legally married wife of the respondent.
Their submits that respondent has started his nursing home at Ambrosia colony
and gained good reputation and were happy for 2 years i.e., since 2017 his life
started to have ups and downs.
3. The petitioner submits that the respondent slowly cultivated the bad habits and
became share to alcohol and used to have ephedrine etc. So have slowly began
to lose his sexual potency and attach become a total impotent. When he has
been taken to Fortis Hospital, Delhi, the doctors have concluded that he lost his
potency because of excessive narcotic drugs and alcohol. The respondent
became frustrated in his life. He gave up his practice slowly the petitioner sold
her jewels to maintain the family. Her parents also helped to some extent.
4. The petitioner submits that because of inferiority complex the respondent
started to suspect the character of the petitioner. He used to abuse her with
vulgar and filthy words that, she had illegal connections with others. He used to
abuse her even, if beggar stands in front of the house, as the beggar is awaiting
for her. She tolerate all these mental torture added to this the respondent used to
put cigarettes on her breast thighs and other private parts and burn them. He

8|Page
 enjoys her screaming. Sometimes he gagged her mouth with cloth and subject
her to physical cruelty.
5. The petitioner further submits that on 10.02.2017 he made her naked put the
blade on her left breast and applied chillies powder on the wound she cried
loudly apprehending danger and her neighbour and her mother-in-law came
there and saved her from the clutches of the respondent than on 11.02.2017 she
came away to her parents house. She apprehends danger to her parents house
also. She apprehends danger to her life in the hands of the respondent and it is
impossible for her to live with such sadistic husband. Hence the petition for
Judicial separation Filed.
6. The cause of action for this petition for Judicial Separation arose on 01.02.2015
the date of marriage and also 10.02.2017 when she frightened of her life ran
away to her parents house continues de divindum with the jurisdiction of this
honourable court
7. The petitioner submits that no similar petitioner has been filled so far before
any court.

PRAYER

1. That to pass a decree of judicial separation in favour of the petitioner and

against the respondent.
2. That the respondent may be ordered to pay the costs of the petition to the
petitioner
3. That to pass any other order which the court seems fit in the interest of justice.

Date: 10/10/2019 (Sanish)

Place: Agra Petitioner

XXXX

Counsel for Petitioner

VERIFICATION

I Sanish, the above named petitioner do hereby solemnly state and declare that the
contents of Para 1 to 7 of this petition are true to my knowledge and belief.

Date-10/4/2019 (Sanish)

Place-Agra Petitioner

XXXX
Counsel for Petitioner

9|Page
 (AFFIDAVIT IN SUPPORT OF MATRIMONIAL PETITION)

IN THE FAMILY COURT, AGRA

Notice of Motion No.......of 2019

In

Petition No.......2019

Mrs Sanish Singh, W/o Nikhil Singh aged 27

R/o Sikandra, Agra .....Petitioner

Versus

Nikhil Singh, S/o Ajay Singh aged about 36

R/o Sikandra , Agra .....Respondent

I, Sanish Singh above mentioned petitioner state as follows on solemn affirmation as

under:

1. That I say that I was married to respondent on February 19 2015 at Agra

according to traditional Hindu rites. I had cohabited with the respondent at Agra
but had no issue.
2. That I say that after February 2017 that the respondent started abusing and had
inflicted cruelty towards me.
3. That I say that I have therefore prayed for a judicial separation of said marriage
in said petition.
4. That i therefore submit that this notice of motion made absolute with costs.

Solemnly affirmed at Agra on 2 May 2017 (Sanish)

Petitioner

Date:XXXX2019 XXXXX

Place: Agra Advocates for the petitioner

Before me

Registrar/Superintendent

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 (EXECUTION PETITION)

IN THE COURT OF CIVIL JUDGE, JUNIOR DIVISION, KANPUR

Execution Application No........2018

In the matter of Suit No.......2017

Salman, son of Salim aged about 49

R/o 1017, Civil Lines, Kanpur .......Plaintiff

Versus

Sohel, son of Amir aged about 45

R/o 8/230, Kaka Dev, Kanpur .....Defendant

An application under Rule 11 of Order XXI of CPC

The plaintiff decree holder named above most respectfully submits that he was plaintiff
in Suit No....2017 precise description of which as follows:

1. That the defendant was a tenant of B- 8/230 Kubernagar colony of which

plaintiff is the owner.
2. That on 13-07-2016 the plaintiff gave the notice of eviction to the respondant
due to urgent and bonafide need.
3. That the respondent did not take the notice in proper manner and refused to
evict the house, as well as refused to pay the monthly rent.
4. That the plaintiff had filed a suit for the eviction of the defendant and also from
the recovery of the arrears of rent on 15-04-2016.
5. That the matter has been finally decided plaintiff's favour and no appeal has
been preferred till date.
6. That it is therefore the decreetal amount set forth in proforma attached herein
paid to the plaintiff.
Details of Decree
1. Number of Suit .......2017
2. Name Of Parties (a) X, S/o A aged
about 49 R/0 Civil
lines, Varanasi
(b) Y, S/o B aged about 45
R/o 8/230 Lanka,
Varanasi
3. Date of Decree 18/11/2016
4. Whether appeal preferred against No
5. Any part of decreetal amount or
adjustment set off None
6. Previous Application if any None

11 | P a g e
 7. Amount with interest due upon (a)Possession of house
B-decree or other relief 8/230 Kaka Dev
(b) 17500
8. Against whom to be executed against defendant
9. Mode in which the assistance of (a) by deliver of
possession the court is required B-8/230
Kaka Dev, Kanpur
(b) By recovery of
decreetal retail
amount by
attachment

Description of Property to be attached

Property Amount
1. Motorcycle Rs 30000
2. Refrigerator Rs 9000
3. Cooler Rs 3000
4. Furniture Rs 22000
5. Television Rs 13000
Rs 77000

VERIFICATION

I, X the above named plaintiff that what is stated and estimated in above table is true to best of
my knowledge belief and information.

Date- 13/3/2018 Salman

Place- Kanpur Plaintiff/ Decree Holder

XXX

Counsel for Plaintiff

12 | P a g e
 (AFFIDAVIT IN SUPPORT OF EXECUTION PETITION)

IN THE COURT OF CIVIL JUDGE, JUNIOR DIVISION, KANPUR

Execution Application No........2018

In the matter of Suit No.......2017

Salman, son of Salim aged about 49

R/o 1017, Civil Lines, Kanpur .......Plaintiff

Versus

Sohel, son of Amir aged about 45

R/o 8/230, Kaka Dev, Kanpur .....Defendant

The plaintiff decree holder do hereby affirms as follows:

1. That the plaintiff decree holder is the applicant in present execution application.
2. That the plaintiff is fully acquainted with the fact and circumstances of the case.
3. That the proforma attached with the application contains the true fact.
4. That the statement made above are true and nothing has been concealed.

Date- 13/3/2018 Salman

Place- Kanpur Plaintiff/ Decree Holder

XXXX

Counsel for Plaintiff

13 | P a g e
 (MEMORANDUM OF APPEAL)

(Under Section 96, CPC)

IN THE HIGH COURT OF UTTAR PRADESH AT ALLAHABAD

Civil Appellate Jurisdiction

Civil Appeal No. ... / 2017

Shubham s/o Vijay

123, A B Road, Varanasi, UP                            .........................................  Plaintiff/Appellant

vs.

Prakash s/o Vikash

456, A B Road, Varanasi, UP                            .........................................Defendant/Respondent

(Appeal against judgement and decree passed by District Judge , Varanasi on 10/10/2017 in Suit
No 1234 of 2017)
To,

The Honourable Chief Justice

And the other Judges of the

Honourable Court.
The aformentioned plaintiff-appellant appeals against the judgement and decree of the Court
of District Judge, at Allahabad, passed in Original Suit No 1234 of 2017 between Shubham s/o
Vijay vs Prakash s/o Vikash, dated 10/10/2017, and sets forth the following grounds of
objection to the decree appealed from :-

    Value of the suit:

    Value of appeal:
    Court Fee Paid:

(1) That the orders passed by the Learned Lower Court are contrary to the provisions of law and
the principles of natural justice.

(2) That the findings arrived by the Learned Lower Court are not supported by the evidence on
record.

(3) That the Learned Lower Court committed an error in holding that the house premises are not
required by the plaintiff/appellant for his personal bonafide occupation.

(4) That the copy of the Judgment and the Decree against which this appeal has been preferred
is attached along with.

(5) That the Learned Lower Court has having answered the first issue in the negative decided
the rest of the issues against the appellant, which itself is improper and illegal.
14 | P a g e
(6) That the necessary court fee is paid herewith.

PRAYER

(7) That the appellant, therefore, prays that for the reasons stated above and as may be argued at
the time of hearing, the record and proceedings be called for, this appeal be allowed, the orders
under appeal be set aside and quashed, and orders deemed just and proper be kindly passed.
Further that the cost of this petition be awarded in favour of plaintiff-appellant.

Place: Varanasi                                                                     (Signature of the Plaintiff -Appellant)
Date: 4-10-2017                                                                           

                                                                                                 ( Advocate for Plaintiff-Appellant)

VERIFICATION
 
 I, Shubham , do hereby verify that the contents from paras 1 to 5 are correct and true to the best
of my knowledge and personal belief and no part of it is false and nothing material has been
concealed therein. Affirmed at Varanasi this 4th Day of September 2017.

Date: 4-10-2017 (Signature)

Place: Varanasi Plaintiff-Appellant

Counsel for Plaintiff

15 | P a g e
 (MEMORANDUM OF REVISION)

IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD

Civil Revision Application No.......2017

Ram, S/o Shyam aged about 58 years

R/o Sunderpur, Varanasi ...........Applicant/Defendant
Versus
Lal, S/o Gopal aged about 50 years
R/o Lahartara, Varanasi ...........Opponent/Plaintiff

Civil Revision u/s 115 of C.P.C

To,

The Honourable Chief Justice

And the other Judges of the

Honourable Court.

The applicant named above humbly submits:

1) That the opponent had instituted a suit bearing No 117of 2010 in the court of Civil judge,
Senior Division, Varanasi for recovery of Rs. 50000. On the ground of a promissory note
said to be due on the applicant after selling opponents shop at Lanka hat Varanasi road.
2) That the applicant submits that he had already paid Rs 750000 to the opponent as a cost of
the shop and no cost was due with regard to the said shop.
3) That the court decreed the said suit in the opponent on 28-04-2015 and ordered the applicant
to pay the amount of the decree to the opponent.
4) That the applicant being aggrieved by the said decree and judgement prefers this application
on the following ground:
a) That the decree and judgement passed by the learned judge is illegal and unjust.
b) That the judgement of the learned judge is erroneous in law that by passing the decree
on a promissory note which was not stamped.
c) That the learned judge erred in holding that the promissory note was executed by the
applicant.
d) That the handwriting expert was not called inspite of the repeated request for the
applicant.
e) That the learned judge erred in not appreciating the evidence of the applicant and his
witnesses.
f) The in doing so, the learned judge in the exercise of the jurisdiction has acted with
illegality and a material irregularity.
g) That the said judgement is against justice, equity and good conscience and therefore not
substance in the court.
h) That in the aforesaid circumstances the applicant submits that the Hon'ble court be
pleased to call for the records of the trying court and revise its judgement and decree in
the interest of justice.

Date: 5/12/2017 (Ram)

Place: Varanasi Applicant
XXXX
Counsel for Applicant

16 | P a g e
 (WRIT OF HABEAS CORPUS UNDER ARTICLE 226)

IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD

Writ Petition No........2018

In the Matter of Adarsh

R/o 16/850, GB Colony Gaziabad,
District Gaziabad
A detenue at present in T.P. Nagar Police Station.
And
In the Matter of Article 226 of the Indian Constitution and Article 22(2) of the Constitution
Abhishek, S/o Ajay aged about 38,
Occupation- Business
R/o B16/380; GB Colony, Gaziabad .......Petitioner
Versus

a) State of U.P.
b) Deputy Superintendent of Police, Gaziabad.
Station House Officer, T.N. Nagar, Gaziabad. .........Respondent

To,

The Honourable Chief Justice

And the other Judges of the

Honourable Court.

The petitioner named above humbly submits:

1. That the petitioner is the businessman carrying his business at Sigra and he is a cousin
of the above named detenue.
2. That the above named detenue on 03-03-2018 exchanged some hot words with his
neighbour Mr Z.
3. That on 4-03-2018 the police came and arrested the detenue at about 12:30 PM on the
assurance that after investigation the detenue would be released.
4. That on 05-03-2017 at about 7:00pm when the petitioner went to police for making
inquiry about his brother, the police arrested abused him and told to go back
5. That the detenue has neither been released nor produced before the magistrate within 24
hrs after making the arrest.
6. That the violation of the provision of Article 22(2) of the Constitution of India is made
by above named respondent.
7. That the arrest made by the police in collusion with the detenue neighbour Mr Z.
8. That the detenue is a loyal peaceful peace loving and law abiding citizen and not
connected in any way in criminal activity in his whole life.

17 | P a g e
 PRAYER

In the light of aforesaid circumstances the petitioner humbly and respectfully prays that your
Lordships may graciously pleased:

1. That to order the detenue to be brought before the Hon'ble Court for being dealt with
according to law.
2. That to declare the detention illegal unjust, unfair, unconstitutional.
3. That to order the detenue be set at liberty.

Date: 08/03/2018 Petitioner.

Place: Gaziabad XX

Counsel for Petitioner

18 | P a g e
 (WRIT OF MANDAMUS)

IN THE HON’BLE SUPREME COURT OF INDIA

(Original Civil Jurisdiction)

Writ Petition No.......2017

Sailesh, son of Rudresh, R/O, 33/234 Ambrosia, Barabanki. .............Petitioner

Versus

1. Collector,Barabanki
2. State of U.P ..........Respondents

Petition under Article 32 of the Constitution for the issue of a writ of mandamus.

To,

The Hon’ble the Chief Justice

and his companion Judges of the Hon’ble Supreme Court of India

The above named Petitioner begs to submit as under:

1. That the Petitioner is the owner of a plot of land numbered 22 in Cantonment at Barabanki
detailed in Annexure ‘‘A’’ to this petition.

2. That on 22/12/2016 a notification under Section 4 of the Land Acquisition Act, 1894, was
published that certain land including the Petitioner’s aforesaid plot was needed for a public
purpose.

3. That the Petitioner filed objections to the proposed acquisition of his plot under Section 5-A
of the Act.

4. That the objections filed by the petitioner were heard by the Collector on 01/01/2017 and
thereafter he submitted his report with recommendations to the State Government.

5. That the State Government accepted the report and recommendations of the Collector and
rejected the objections filed by the petitioner.

19 | P a g e
6. That 13/01/2017 the State Government made the declaration under Section 6 of the Act.

7. That on 15/01/2017 the Petitioner received a notice under Section 9 of the Act, to state his
claim to compensation for his plot which was under acquisition.

8. That on 16/01/2017 the Petitioner filed his claim to compensation claiming Rs 20 lacs as
compensation for the acquisition of his plot.

9. That on 21/01/2017 the Collector gave his award determining a sum of only Rs 4 lacs as
compensation for the Petitioner’s plot.

10. That the award was filed in the Collector’s Office and notice of the same was given to the
Petitioner.

11. That the compensation awarded by the Collector for the Petitioner’s plot was grossly
inadequate and the Petitioner did not accept it. On 24/01/2017 the Petitioner made an
application under Section 18 of the Act to the Collector requesting that the matter be referred
for determination to the District Judge.

12. That though under Section 18 the Collector was bound to refer the matter of compensation
to the District Judge he has declined to do so.

PRAYER

It is, therefore, most respectfully prayed that a writ, direction or order in the nature of
mandamus be issued to Respondent No. 1 directing him to refer the matter of compensation for
the Petitioner’s plot for determination to the District Judge.

Date: 30/01/2017 Petitioner’s Signature

Place: Barabanki

Councel for Petitioner

20 | P a g e
 CRIMINAL PLEADING

(Complaint)

IN THE COURT OF THE JUDICIAL FIRST CLASS MAGISTRATE, VARANASI

Criminal Case No 13 of 2017

Sohan, S/o Mohan aged 55 years, Occupation- Business, R/o B/252 A.K.P Nagwa, Varanasi.

..........Complainant

Versus

Rahul, S/o Dinesh aged 60 years. Occupation- Business, R/o B 1/181 Assi, Varanasi.

.............Accused

Offence under section u/s 454/323/504 of Indian Penal Code

May it please your honour, the complainant above named begs to state on solemn affirmation
as follows:

1. That the complainant is permanently residing in A.K.P Nagar, Varanasi and he is a

peace loving person.
2. That on date 12-12-2017 about 11 PM the accused person came to the house of the
complainant with lathi and danda and entered in the house of the complainant and began
to beat the complainant by lathi and Danda as such the complainant received the serious
injuries in his body.
3. That the information of the alleged occurrence was given to the concerned Police
Station at A.K.P Nagar Varanasi but the police did not lodge the FIR against the accuse
persons.
4. That the complainant went to the Sunder Lal Hospital at BHU, Lanka Varanasi on 13-
12-2017 at about 8:00 AM and got examined by the doctor on the duty in emergency
room who prepared the medical report. The injury report is annexed herewith this
complaint.
5. That after that the complainant sent an application to the SSP by the registered post
regarding the aforesaid occurrence, but still no step has been taken by the police
concerned against the accused person. The aforesaid application and receipt of the post
office are annexed herewith this complaint.
6. That the complainant is moving the aforesaid complaint before your honour's court.
7. That the place of occurrence is within your territorial jurisdiction for taking cognizance
of the aforesaid offence.
8. That in the interest of justice and humanity summon the accused person in your
honour's court and penalize him.

21 | P a g e
 PRAYER

It is therefore, prayed that the hon'ble court may be kind enough to take the cognizance of
alleged occurrence and the accused persons be penalized accordingly and oblige.

Date: 14/12/2017 Sohan

Place: Varanasi Complainant

XXXXX
Counsel for Complainant

22 | P a g e
 (CRIMINAL MISCELLANEOUS PETITION)

IN THE COURT OF SECOND ADDL. JUDICIAL MAGISTRATE AT KANPUR

Criminal Misc. Petition No........of 2018

Rohan, S/o Sailendra aged 30 years, Occupation- Business, R/o Yasoda Nagar, at Kanpur
…..Petitioner

Versus

Saurabh, S/o Vinay ages 35 years, Occupation- Business, R/o Kedwai Nagar, at
Kanpur. .......Respondent

Petition filed on behalf of the Petitioner U/Sec 128 Cr. P.C

(1) The petitioner submits that he filed the above M.C. for grant of separate maintenance on
31.12.2017 against the respondent seeking a sum of Rs. 500 per month to be awarded.

(2) The Honourable Court, after due contest, by order dated 06.01.2018 granted maintenance
to the petitioner directing the respondent to pay a sum of Rs. 400 per month to the
petitioner from 01.01.2018 and keep praying in future.

(3) The petitioner submits that, the respondent has not paid any maintenance so far, and these
disobeyed the order of this honourable court.

(4) The petitioner further submits that the arrears of maintenance from 01.01.2017 to
31.03.2018 to Rs. 6000/-

(5) It is therefore prayed that the honourable court may be pleased to commit the respondent
to prison for such kind as the law required or till he paid the arrears of maintenance.
PRAYER
It is therefore must humbly prayed that in the light of aforesaid circumstances the hon'ble court
may be pleased to adjudge hold and declare
(1) That the petition is maintainable u/s128 of crpc.
(2) That to pass the order to pay the maintenance with arrears.
(3) That to pass any other order which the hon'ble court may think fit for the end of justice.

Date: 2/04/20178 Rohan

Place: Kanpur Petitioner

Advocate for Petitioner

23 | P a g e
 VERIFICATON

I Rohan, the petitioner, to hereby declared that the facts stated above or true and correct to the
facts stated above or true and correct to the best of my knowledge information and belief.

Date: 2/04/2018 Rohan

Place: Kanpur Petitioner’s Signature

XXXXXXX

Advocate for Petitioner

24 | P a g e
 (BAIL APPLICATION)

IN THE COURT OF JUDICIAL MAGISTRATE, IST CLASS, AZAMGARH

Criminal Miscellaneous Application No...... of 2017

Suyash, S/o Rajendra aged about 55 years, R/o B-30/441 Nagwa, Azamgarh .......Applicant

Versus

State of U.P. .......Respondent

FIR No. : _____ Dated _____ Police Station: S.K. Nagar

Offence Under Sections: 323 and 325 of IPC

Application for Bail Under Section 437 of CrPC

Respectfully Sheweth:

1. That the applicant is facing trial before this Hon'ble Court in case titled as State of U.P
vs Suyash for the offence under Sections 323 and 325 of IPC.
2. That this Hon'ble court was pleased to issue a Warrant and the Police has accordingly
arrested the accused/applicant.
3. That the applicant was not at all involved in the crime alleged in the said case.
4. That the applicant is a permanent resident of Azamgarh and earning livelihood by
working as a fruit vendor in trains. 
5. The applicant has his old parents dependent upon him and the applicant is the only
bread earner for the family.
6. That by getting the accused/applicant arrested the accused has been deprived of his
valuable fundamental right of liberty by abuse of powers and process of law by the
complainant. 
7. That the applicant is willing to furnish surety and bail bonds to the satisfaction of this
learned court in case he is ordered to be released on bail. 
8. That the applicant will abide by all the conditions as imposed by this Honourable Court.

PRAYER

It is, therefore, most respectfully prayed that this application for bail may kindly be allowed
in the interest of justice and the applicant be released on bail upon such conditions as this
Honorable Court may deem fit.

Date: XXXX 2017 Suyash

Place: Azamgarh Applicant’s Signature

XXXXXXX

Advocate for Applicant

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 AFFIDAVIT IN SUPPORT

IN THE COURT OF JUDICIAL MAGISTRATE, IST CLASS, AZAMGARH

Suyash, S/o Rajendra aged about 55 years, R/o B-30/441 Nagwa, Azamgarh ........Applicant

Versus

State of U.P. .......Respondent

  

Affidavit in support of the application under Section 437 of CrPC 

I, Suyash , do hereby solemnly affirm and declare as under:- 

1. That the accompanying application under section 437 CrPC has been drafted at my instance
and under my instructions. 

2. That the contents of paras 1 to 8 are true and correct to the best of my knowledge. 

3. That I further solemnly affirm and declare that this affidavit of mine is correct and true, no
part of it is false and nothing material has been concealed therein. 

Affirmed here at Azamgarh on XXXX. 

Date:XXXX Signature of Applicant

Place: 
Counsel for Applicant

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 (ANTICIPATROY BAIL APPLICATION)

IN THE HIGH COURT OF JUDICATURE OF MADRAS

(Criminal Original Jurisdiction)

Crl.O.P.No..... of 2018
In
Crime.No. Not known of 2018
(On the file of the Inspector of Police. Police Station, Guindy,
Chennai)

Suyash, S/o Rajendra aged about 45 years, Occupation- Business, R/o 30/21, Lanka Madras
.......Petitioner/Accused

Versus
State of Tamil Nadu,
Rep. by its Inspector of Police,
Police Station,
Guindy, Chennai,
....Respondent/Complainant

PETITION FOR ANTICIPATORY BAIL FILED UNDER SECTION 438 OF Cr.P.C

MOST RESPECTFULLY SUBMITTED AS UNDER:

1. That the present FIR has been registered on false and bogus facts. The facts stated in the FIR
are fabricated, concocted and without any basis.

2. That the police has falsely implicated the applicant in the present case, the applicant is a
respectable citizen of the society and is not involved any criminal case.

3. That the facts stated in the complainant against the applicant are civil disputes and does not
constitute any criminal offence at all.

4. That the applicant is not required in any kind of investigation nor any kind of custodial
interrogation is required.

5. That the applicant is having very good antecedents, he belongs to good family and there is no
criminal case pending against them.

6. That the applicant is a permanent resident and there are no chances of his absconding from
the course of justice.

7. That the applicant undertakes to present himself before the police/court as and when directed.

8. That the applicant undertakes that he will not, directly or indirectly make any inducement,
threat or promise to any person acquainted with the facts of the case so as to dissuade him from
disclosing such facts to the Court or to any police officer.

9. That the applicant further undertakes not to tamper with the evidence or the witnesses in any
manner.

10. That the applicant shall not leave India without the previous permission of the Court.
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11. That the applicant is ready and willing to accept any other conditions as may be imposed by
the Court or the police in connection with the case.

PRAYER

It is therefore prayed that the court may direct the release the applicant on bail in the event of
his arrest by the police. Any other order which the court may deem fit and proper in the facts
and circumstances of the case may be also passed in favour of the applicant.

Date: XXXX2018 Suyash

Applicant
Place: Madras XXXXXXXX
Counsel for Applicant

AFFIDAVIT

I Suyash, S/o Rajendra aged about 45 years, Occupation- Business, R/o 30/21, Lanka Madras
solemnly affirm and state as follows:

1.That I am the petitioner in the above noted case.

2.That the facts stated above are true to the best of my knowledge and belief.

Identified by:

Date: XXXX2018 Signature of Petitioner

Place: Madras Counsel for Petitioner

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 CRIMINAL APPEAL

IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE AT LUCKNOW

CRIMINAL APPEAL NO: 101 OF 2017
For the following among grounds the Appellant here in begs to prefer this appeal against the
judgement dated ………………….. of judicial Magistrate, F.C., Lucknow in criminal case No:
101 of 2017, convicting the appellant U/Sec 411 I.P.C and sentencing him to U/go, 6 months
R.I. and to pay a fine of Rs. 300/-
GROUNDS
1. That the conviction is bad in law.
2. That the Judgement of the lower court offends Sec. 367 of the Cr.P.C.
3. That the learned magistrate should have inferred from the conduct of your petitioner deposed
to by the investigating officer, that he was absolutely straight forward in his dealings.  The
conduct of your petitioner as has been deposited to by P.Ws. No. 52 and 4 would hardly be
consistent with his guilty knowledge.
4. That the learned Magistrate should have taken into accent the representation made to him by
the alleged thief.
5. That the learned Magistrate should have bellered that the articles were purchased bonafide for
proper market price and inferred from that the absence of any guilty knowledge of your
petitioner.
6. That the articles sold were common articles of everyday use to be found in possession of
people of even modest means.
7. That the learned Magistrate should have disbelieved the evidence of P.W.s No: 56 and 7 who
identified the parker pen and the Wallet alleged to belong to Sri Anand and should have hold
that they were ordinary, common articles incapable of identification in the absence of any
special mark or name.
8. That the learned Magistrate should have believed the defence witnesses who disposed to
having seen the articles sold to the appellant some five months prior to the incident.
9. That the Lower Court ought to have given the benefit of responsible doubt to the appellant
and acquitted him.
PRAYER
In the circumstances stated above, the petitioner prays that your honour may be pleased to admit
the appeal, call for the record.
Release your petitioner pending disposal of the appeal on bail and after hearing the case, set
aside the order of conviction and sentence or pass such other order as the ends of Justice may
call for and your petitioner, as in duty bound, shall ever pray.

Date: XX Suyash

Place: Lucknow Appellant

XXXX

Counsel for Appellant

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 REVISION APPLICATION

IN THE HIGH COURT OF JUDICATURE AT HYDERABAD

Criminal Revision No..… of 2018

In the matter of an application U/Sec. 439, Cr. P.C.

Samar , residing at Nacharam, Hyderabad …….. Petitioner/ Accused

Vs.

The State of A.P.                           ……..…. Respondent

In the matter of a Revision from the order of conviction passed U/Sec 324, I.P.C. on
30.01.20108 by the learned presidency magistrate sixth court, Hyderabad.

To His lordship the Chief Justice and the Puisne Judge of the said honourable court.

THE HUMBLE PETITION OF THE ABOVE NAMED PETITIONER MOST

RESPECTFULLY SHEWETH

In the matter of an application U/sec. 439, Cr. P.C.

Sachin, residing at Nacharam, Hyderabad    ………. Petitioner / Accused

Vs.

The state of A.P.                            …………. Respondent

In the matter of a Revision from the order of conviction passed U/sec 324, I.P.C. on 30.01.2018
by the learned presidency magistrate sixth Court, Hyderabad.

To,

His lordship the Chief Justice and

the judge of the said honourable Court.

THE HUMBLE PETITION OF THE ABOVE NAMED PETITIONER MOST

RESPECTFULLY SHEWETH

That the learned president Magistrate convicted the applicant and one Mukesh Rao under the
mentioned section and sentenced him to undergo Vigorous imprisonment for a period of four
month and to pay a five of Rs.100 or in default to undergo further R.I. for 15 days.

Being aggrieved by the aforesaid order, your petitioner begs to more the honourable court in its
Revisional Jurisdiction on the following.

Grounds

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1. That the order of the lower court is against law.
2. That the learned presidency magistrate erect in believing the complaints who were interested
witness.
3. That the learned presidency magistrate was wrong in dis-believing the two respectable and
independent witnesses examined on behalf of the defence.
4. The learned magistrate has erred in not complying with the mandatory provisions of the Cr.
P.C. whereby an opportunity to explain away the circumstances appearing against them was
refused.
5. The learned magistrate has not maintained a full record of the evidence and hence certain
admissions by the prosecution given in their cross examination are not available.

PRAYER

The petitioner therefore prays that your lordship may be graciously pleased to call for the record
of the case and issue a rule upon the presidency.

Magistrate, sixth court and upon the opposite party to show cause why the aforesaid, order
complained of should not be vacated and to release the petitioner on bail pending the disposal of
this revision applications and your lordships may be pleased to pass such other order or orders
as the circumstances of the case demand.

And your petitioner, as in duty bound, shall ever pray.

Date:XXXX2018 Sachin
Petitioner
Place: Hyderabad xxx
Counsel for Petitioner

VERIFICATION

I, Sachin do hereby verify that the contents from paras 1 to 5 are correct and true to the best of
my knowledge and personal belief and no part of it is false and nothing material has been
concealed therein.

Date:XXXX2018 Petitioner

Place: Hyderabad
Counsel for Petitioner

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 FIRST INFORMATION REPORT

(Under Section 145 & 157 Cr.P.C.)

1. Chittoor District, Tiruchanoor Police, 2018, FIR No. 102, Date: 15-04-2018
2. (i) Act ………………………….. Sections : ……………………………
(ii) Act ………………………….. Sections : ……………………………
(iii) Other Acts & Sections: ……………………………………………
3. (a) Occurrence of Office: March, 31st, Monday, Night between 10.30 to 11.00 pm
(b) Information received from B. Ajay Kumar and K. NareshBabu at the Police Station
about 11.25 pm, 31st March, 2018.
(c) General Diary Reference Entry No(s): 42, Time: 11.30 pm 31st March, 2018.  
4. Type of Information : Written/ Oral
5. (a) Place of Occurrence : Tiruchanoor Road, Near Mango Mandi, Varanasi.
(b) Address: Srinivasapuram, Tiruchanoor Road, Varanasi-517 503
Varanasi Rural, Tiruchanoor Police Station Limits.
6. Complainant/ Informant
(a) Name: Satish Kumar,  
(b) Father‟s Name: Dinesh Rao
(c) Date/ Year of Birth: 24-10-1994
(d) Nationality: Indian
(e) Passport No ………. Date of issue………… Place of issue ……….
(f) Occupation: Business
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(g) Address: Telephone Colony, Srinivasa Puram, Varanasi.   
 7.  Details of known/ suspected/ unknown/ accused with full particulars. (Attach
separate sheet if necessary) …………………………………………………………….
8. Physical features deformities and other details of the suspect:
……………………………………………………………………
9. Contents of the Complaint/ Statement of the complainant or informant (Attach
separate sheets, if required).
10. Action taken.  Since the above report reveals commission of offence (s) u/S as
mentioned at Item No. 2 Registered the case and took up the investigation/ directed
……………… Rank ……………… to take up the investigation FIR read over to the
Complainant/ Informant, admitted to be correctly recorded and a copy given to the
Complainant/ Informant free of cost.

Signature of the Officer-in-charge Police

Station
XXXXX
Tiruchanoor Police Station, Varanasi

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