0% found this document useful (0 votes)
446 views32 pages

Gadhave Milind Cri WP Direction

Uploaded by

riyajkhanvajir
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
0% found this document useful (0 votes)
446 views32 pages

Gadhave Milind Cri WP Direction

Uploaded by

riyajkhanvajir
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
You are on page 1/ 32

IN THE HIGH COURT OF JUDICATURE AT

BOMBAY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO. OF 2022.

DISTRICT: SANGLI.

In the matter of Article 226


of the Constitution of India,
1950.
AND
In the matter of provisions of
the Indian Penal Code, 1860.
AND
In the matter of provisions of
Section 482 of Criminal
Procedure Code, 1973.
2

AND
In the matter of the
Maharashtra Protection of
Interest of Depositors (in
Financial Establishments)
Act, 1999.

Milind Balaso Gadhave, )


Aged 36 years, Occu: Business, )
R/o. Behind Bharati Vidyapeeth, )
Pawar Plot, Sangliwadi, Sangli. ).. Petitioner.

-: VERSUS :-

The State of Maharashtra, )


1. Through the Senior P.I., )
Bharati Vidyapeeth Police Station, )
3

Pune City, Pune, )


C.R. No. 448 of 2022. )

2. Through the Senior P.I. )


Kurundwad Police Station, )
Kurundwad, Tal. Shirol, )
District; Kolhapur. )
C.R. No. 109 of 2022. )

3. Through the Senior P.I., )


Vishrambag Police Station, )
Sangli. )
C.R. No. 368 of 2022. )

4. Through the Senior P.I., )


Jaysingpur Police Station, )
Jaysingpur, Tal. Shirol, )
District: Kolhapur. )
C.R. No. 329 of 2022 )

5. Through the Senior P.I., )


Mandangad Police Station, )
District: Ratnagiri. )
C.R. No. 72 of 2022 )
(Notice to be served on the A.P.P. )
High Court, Mumbai) ).. Respondents.
4

TO,

THE HON'BLE THE CHIEF JUSTICE AND HON'BLE

OTHER PUISNE JUDGES OF THIS HON'BLE HIGH

COURT OF JUDICATURE AT BOMBAY.

THE HUMBLE PETITION OF THE

PETITIONER ABOVENAMED.

MOST RESPECTFULLY SHEWETH:-

1. The Petitioner is the Indian Citizen and residing

at the above mentioned address and is entitled to

all fundamental rights enshrined under the

Constitution of India, 1950. This writ petition is

filed under Article 226 of the Constitution of

India, 1950 and section 482 of the Criminal

Procedure Code, thereby seeking direction to

investigate the Crime Register Nos. 448 of 2022

registered with Bharati Vidyapeeth Police Station,

Pune, C.R. No. 109 of 2022 registered with

Kurundwad Police Station, Tal. Shirol, District:

Kolhapur, C.R. No. 368 of 2022 registered with

Vishrambag Police Station, Sangli, C.R. No. 329


5

of 2022 registered with Jaysingpur Police Station,

Tal. Shirol, District: Kolhapur and C.R. No. 72 of

2022 registered with Mandangad Police Station,

District: Ratnagiri, by either one Police Station or

same may be tried together before the Ld.

Sessions Judge, Sangli or the Ld. Additional

Sessions Judge, Jaysingpur, District: Kolhapur.

The facts and circumstances giving rise to filing of

the present Writ Petition are as under:-

2. The Petitioner states and submits that five alleged

crimes are registered against the present

Petitioner before the difference police stations,

wherein the present Petitioner is accused No. 1

the same are as under:-

(i) C.R. No. 448 of 2022 registered with the

Bharati Vidyapeeth Police Station, Pune

u/sec. 406, 419, 420 of I.P.C. and Section

66(c), 66(d) of I. & T. Act filed by one

Complainant namely Poonam Bipin Dalvi

on 09.07.2022, wherein she has allegedly


6

contended that the present Petitioner and

another Accused Avinash Patil has started

M.S. Global, Sangli, Company for Share

market trading and the Accused have

contacted on whats’app and assured as they

are brokers and requested to invest the

amount and induced that the Complainant

will get double amount and therefore as per

the inducement and assurance the

Complainant has deposited the amount of

Rs. 53,22,800/- with the Accused, but the

Accused are deceived her and therefore she

has filed the complaint. In the said offence

the present Petitioner was arrested on

15.08.2022. Hereto annexed and marked

as Exhibit ‘A’ is copy of the remand report

of C.R. No. 448 of 2022 registered with

Bharati Vidyapeeth, Pune.

(ii) C.R. No. 109 of 2022 registered with

Kurundwad Police Station, Tal. Shirol,


7

District: Kolhapur, u/sec. 406, 420, 409

r/w. 34 of I.P.C. and u/sec. 3 & 4 of the

Maharashtra Protection of Interest of

Depositors (in Financial Establishments)

Act, 1999 filed by complainant namely

Nirija Babasaheb Patil on 22.05.2022

wherein she has contended that the present

Petitioner and another Accused Suraj

Prakash Chougule, Avinash Patil and

Santosh Jadhav have started M.S. Global,

Sangli, Company for Share market trading

and the Accused have personally contacted

to the complainant and assured as they are

brokers and requested to invest the amount

and induced that the Complainant will get

double amount and therefore upon relying

the assurance given by the Petitioner and

other co-accused the Complainant has time

to time deposited the amount totally of Rs.

44,41,700/- with the Accused, but the

Accused are deceived her and therefore she


8

has filed the complaint. In the present

matter the present Petitioner was arrested.

Hereto annexed and marked as Exhibit ‘B’

is copy of the F.I.R. bearing C.R. No. 109 of

2022 registered with Kurundwad Police

Station, Taluka Shirol, District: Kolhapur.

(iii) C.R. No. 368 of 2022 registered with

Vishrambag Police Station, Sangli u/sec.

406, 420 of I.P.C. and u/sec. 3 of the

Maharashtra Protection of Interest of

Depositors (in Financial Establishments)

Act, 1999 filed by complainant namely

Nilesh Vishwasrao Patil on 24.08.2022,

wherein he has alleged that the present

Petitioner has started M.S. Global, Sangli,

Company for Share market trading and the

Accused has personally contacted to the

complainant and assured as he is broker

and requested to invest the amount and

induced that the Complainant will get


9

double amount and therefore upon relying

the assurance given by the Petitioner, the

Complainant has time to time deposited the

amount totally of Rs. 92,04,517/- with the

Accused, but the Accused are deceived her

and therefore she has filed the complaint.

In the present matter the present Petitioner

was arrested on 13.09.2022. Hereto

annexed and marked as Exhibit ‘C’ is copy

of the C.R. No. 368 of 2022 registered with

Vishrambag Police Station, Sangli.

(iv) C.R. No. 329 of 2022 registered with

Jaysingpur Police Station, Tal. Shirol,

District: Kolhapur u/sec. 406, 420, 409,

504, 506 r/w. 34 of I.P.C. and u/sec. 3 & 4

of the Maharashtra Protection of Interest of

Depositors (in Financial Establishments)

Act, 1999 filed by complainant namely

Suhas Sureshrao Deshpande on 01.10.2022,

wherein he has contended that the present


10

Petitioner and other Accused namely

Avinash Patil, Anil Shivaji Kumbhar,

Virendra Shrikant Sokare and Suesh Bhupal

Redekar have started M.S. Global, Sangli,

Company for Share market trading and the

Accused have personally contacted to the

complainant and assured as they are

brokers and requested to invest the amount

and induced that the Complainant will get

double amount and therefore upon relying

the assurance given by the Petitioner and

other co-accused the Complainant has time

to time deposited the amount totally of Rs.

24,01,840/- with the Accused, but the

Accused are deceived her and therefore she

has filed the complaint. In the present

matter the present Petitioner was arrested

on 11.10.2022. Hereto annexed and marked

as Exhibit ‘D’ is copy of C.R. No. 329 of

2022 registered with Jaysingpur Police

Station, Tal. Shirol, District: Kolhapur.


11

(v) C.R. No. 72 of 2022 registered with

Mandangad Police Station, District:

Ratnagiri, u/sec. 420 r/w. 34 of I.P.C. filed

by complainant namely Yash Dipak

Ghosalkar on 18.10.2022, wherein he has

alleged that the present Petitioner has

started M.S. Global, Sangli Company for

Share market trading and the Petitioner

and other accused namely (1) Nilesh

Shankar Potsure, (2) Mayur Mandlik, (3)

Pravin Janardan Kadam, (4) Yogesh

Shankar Pawar, (5) Vishal Vilas Salvi, (6)

Paresh Pandurang Vane and (7) Nilesh

Ramji Rakte, have personally contacted to

the complainant and assured as they are

brokers and requested to invest the amount

and induced that the Complainant will get

double amount and therefore upon relying

the assurance given by the Petitioner and

other accused, the Complainant has time to

time deposited the amount totally of Rs.


12

60,15,020/- with the Accused, but the

Accused are deceived them and therefore he

has filed the complaint. In the present

matter the present Petitioner was arrested.

Hereto annexed and marked as Exhibit ‘E’

is copy of the C.R. No. 72 of 2022 registered

with Mandangad Police Station, District:

Ratnagri.

3. The Petitioner states and submits that for the

sake of suitability all the crimes are mentioned as

under:-

S.No. C.R.No. Particulars Jurisdiction


of Court

1. 448 of Registered with Bharati Ld. Sessions


2022 Vidyapeeth Police Judge, Pune
Station, Pune, u/sec.
406, 419, 420 of I.P.C.
and Section 66(c),
66(d) of I. & T. Act filed
by one Complainant
namely Poonam Bipin
Dalvi on 09.07.2022

2. 109 of Registered with Ld.


2022 Kurundwad Police Additional
Station, Tal. Shirol, Sessions
District: Kolhapur, Judge,
13

u/sec. 406, 420, 409 Jaysingpur,


r/w. 34 of I.P.C. and Tal. Shirol,
u/sec. 3 & 4 of the District:
Maharashtra Protection Kolhapur.
of Interest of
Depositors (in
Financial
Establishments) Act,
1999 filed by
complainant namely
Nirija Babasaheb Patil
on 22.05.2022.

3. 368 of Registered with Ld. Sessions


2022 Vishrambag Police Judge,
Station, Sangli u/sec. Sangli.
406, 420 of I.P.C. and
u/sec. 3 of the
Maharashtra Protection
of Interest of
Depositors (in
Financial
Establishments) Act,
1999 filed by
complainant namely
Nilesh Vishwasrao Patil
on 24.08.2022.

4. 329 of Registered with Ld.


2022 Jaysingpur Police Additional
Station, Tal. Shirol, Sessions
District: Kolhapur Judge,
u/sec. 406, 420, 409, Jaysingpur,
504, 506 r/w. 34 of Tal. Shirol,
I.P.C. and u/sec. 3 & 4 District:
of the Maharashtra Kolhapur.
Protection of Interest of
Depositors (in
Financial
Establishments) Act,
1999 filed by
14

complainant namely
Suhas Sureshrao
Deshpande on
01.10.2022.

5. 72 of Registered with Ld. Sessions


2022 Mandangad Police Judge,
Station, District: Ratnagiri.
Ratnagiri, u/sec. 420
r/w. 34 of I.P.C. filed by
complainant namely
Yash Dipak Ghosalkar
on 18.10.2022.

4. The Petitioner states and submits that in all the

C.R.s the Petitioner is in Judicial custody and at

present the Petitioner is Yerwada Central Prison,

Pune. The Petitioner further states and submits

that the jurisdiction of the Kurundwad Police

Station and the jurisdiction of the Jaysingpur

Police Station is with the Ld. Additional Sessions

Judge, Jaysingpur, Tal. Shirol, District: Kolhapur

and the jurisdiction of the Vishrambag Police

Station is with the Ld. Sessions Judge, Sangli,

which are adjacent and near about having

distance of 5 to 7 k.m.
15

5. The Petitioner states and submits that the

allegations made in the above said Crimes are in

the similar nature and the present Petitioner is

permanently residing at Sangli, the C.R. No. 109

of 2022 is registered with Kurundwad Police

Station, Tal. Shirol, District: Kolhapur and the

C.R. No. 329 of 2022 is registered with

Jaysingpur Police Station, Tal. Shirol, District:

Kolhapur and C.R. No. 368 of 2022 registered

with Vishrambag Police Station, Sangli, therefore

the Police Station situated within the vicinity of

Taluka Shirol, District: Kolhapur are near and

adjacent to the Sangli City, and also one C.R. is

registered in Sangli City hence, it is easy and

possible to the Investigating authorities to

investigate the crimes together with at one of the

Investigating Authority including the C.R. No.

448 of 2022 registered with Bharati Vidyapeeth

Police Station, Pune. The Petitioner further states

and submits that except C.R. No. 448 of 2022, in

other C.R. numbers the complainants are residing


16

within the vicinity of the Shirol Taluka, Kolhapur

District and City of Sangli, therefore for better

adjudication of the matter and to avoid conflict

judgments it is just and necessary to investigate

all these crime numbers together and also the

Trial may be conducted either before the Ld.

Sessions Judge, Sangli or the Ld. Additional

Sessions Judge, Jaysingpur, Tal. Shirol, District:

Kolhapur for the convenience of the

complainants. If, the investigation will not

conducted by any one of the investigating

authority and the Trial will not be conducted

before either the Ld. Sessions Judge, Sangli or Ld.

Additional Sessions Judge, Jaysingpur, Tal.

Shirol, District: Kolhapur, the Petitioner will

suffer an irreparable loss, harm and injustice.

Per-contra the Respondents will not suffer any

loss, harm and injustice.

6. The Petitioner craves leave of this Hon’ble Court

to add, amend, alter, delete any of the grounds


17

taken in the present Writ petition and to convert

the present Writ Petition if required.

7. The Petitioner submits that there is no other

equally efficacious remedy available to the

Petitioner than to approach this Hon’ble Court

under Article 226 of the Constitution of India and

section 482 of Criminal Procedure Code. The

reliefs which are prayed for by the Petitioner if

granted will be full and completed.

8. The Petitioner has not filed any other Appeal,

Application, Petition in this Hon’ble Court or in

the Hon’ble Supreme Court of India, touching to

the subject matter of this Writ Petition.

9. The Petitioner has paid the Court Fees of Rs.

___/- to this Petition.

10. The Petitioner undertakes to file the English

Translation of the Marathi documents as and

when directed by this Hon’ble Court.


18

11. The Petitioner, therefore, prays that;

(a) Rule be issued and record and proceedings

be called for;

(b) This Hon’ble Court be pleased to issue a

writ of mandamus or certiorari or any other

appropriate, writ/direction/order in the

nature of writ of mandamus or certiorari

under Article 226 of the Constitution of

India, 1950 and section 482 of Criminal

Procedure Code thereby direct to the

Respondents to investigate all the Crime

Register Nos. 448 of 2022 registered with

Bharati Vidyapeeth Police Station, Pune,

C.R. No. 109 of 2022 registered with

Kurundwad Police Station, Tal. Shirol,

District: Kolhapur, C.R. No. 368 of 2022

registered with Vishrambag Police Station,

Sangli, C.R. No. 329 of 2022 registered with

Jaysingpur Police Station, Tal. Shirol,

District: Kolhapur and C.R. No. 72 of 2022


19

registered with Mandangad Police Station,

District: Ratnagri by any one of the Police

Station.

(c) This Hon’ble Court be pleased to issue a

writ of mandamus or certiorari or any other

appropriate, writ/direction/order in the

nature of writ of mandamus or certiorari

under Article 226 of the Constitution of

India, 1950 and section 482 of Criminal

Procedure Code thereby direct the

Respondents to conduct the Trial together

of all the Crime Register Nos. 448 of 2022

registered with Bharati Vidyapeeth Police

Station, Pune, C.R. No. 109 of 2022

registered with Kurundwad Police Station,

Tal. Shirol, District: Kolhapur, C.R. No. 368

of 2022 registered with Vishrambag Police

Station, Sangli, C.R. No. 329 of 2022

registered with Jaysingpur Police Station,

Tal. Shirol, District: Kolhapur and C.R. No.


20

72 of 2022 registered with Mandangad

Police Station, District: Ratnagri either

before the Ld. Sessions Judge, Sangli or the

Ld. Additional Sessions Judge, Jaysingpur,

District: Kolhapur;

(d) Pending the hearing and final disposal of

the present Writ Petition, this Hon’ble

Court be pleased to direct the Respondents

to investigate all the Crime Register Nos.

448 of 2022 registered with Bharati

Vidyapeeth Police Station, Pune, C.R. No.

109 of 2022 registered with Kurundwad

Police Station, Tal. Shirol, District:

Kolhapur, C.R. No. 368 of 2022 registered

with Vishrambag Police Station, Sangli,

C.R. No. 329 of 2022 registered with

Jaysingpur Police Station, Tal. Shirol,

District: Kolhapur and C.R. No. 72 of 2022

registered with Mandangad Police Station,


21

District: Ratnagri by any one of the Police

Station.

(e) Pending the hearing and final disposal of

the present Writ Petition, this Hon’ble

Court be pleased to direct the Respondents

to conduct the Trial together of all the

Crime Register Nos. 448 of 2022 registered

with Bharati Vidyapeeth Police Station,

Pune, C.R. No. 109 of 2022 registered with

Kurundwad Police Station, Tal. Shirol,

District: Kolhapur, C.R. No. 368 of 2022

registered with Vishrambag Police Station,

Sangli and C.R. No. 329 of 2022 registered

with Jaysingpur Police Station, Tal. Shirol,

District: Kolhapur and C.R. No. 72 of 2022

registered with Mandangad Police Station,

District: Ratnagri either before the Ld.

Sessions Judge, Sangli or the Ld. Additional

Sessions Judge, Jaysingpur, District:

Kolhapur;
22

(f) Interim/ad-interim relief in terms of prayer

clause (d) and (e) above;

(g) The Petitioner is at present detained at

Yerwada Central Prison, Pune, therefore the

Affidavit in support of this Writ Petition

may be dispensed with;

(h) Such other and further reliefs be granted as

the nature and circumstances of the case

may be require.

AND FOR THIS ACT OF KINDNESS AND

JUSTICE THE PETITIONER SHALL AS DUTY

BOUND FOR EVER PRAY.

MUMBAI.
DATE: /11/2022. (NAGESH Y. CHAVAN)
Advocate for the Petitioner.
23

IN THE HIGH COURT OF JUDICATURE AT


BOMBAY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO. OF 2022.

DISTRICT: SANGLI.
Milind Balaso Gadhave. .. Petitioner.
-: VERSUS :-
The State of Maharashtra & Ors. .. Respondents.
SYNOPSIS

I. CHALLENGE IN BRIEF:-
------ This writ petition is filed under Article 226 of
the Constitution of India, 1950 and section 482 of the
Criminal Procedure Code, thereby seeking direction to
investigate the Crime Register Nos. 448 of 2022 registered
with Bharati Vidyapeeth Police Station, Pune, C.R. No. 109
of 2022 registered with Kurundwad Police Station, Tal.
Shirol, District: Kolhapur, C.R. No. 368 of 2022 registered
with Vishrambag Police Station, Sangli, C.R. No. 329 of
2022 registered with Jaysingpur Police Station, Tal.
Shirol, District: Kolhapur and C.R. No. 72 of 2022
registered with Mandangad Police Station, District:
Ratnagri by either one Police Station or same may be tried
together before the Ld. Sessions Judge, Sangli or the Ld.
Additional Sessions Judge, Jaysingpur, District: Kolhapur.
II. DATES & EVENTS:-
24

------ That five alleged crimes are registered


against the present Petitioner before the difference police
stations, wherein the present Petitioner is accused No. 1.
09.07.2022. That C.R. No. 448 of 2022 registered
with the Bharati Vidyapeeth Police Station, Pune u/sec.
406, 419, 420 of I.P.C. and Section 66(c), 66(d) of
Information & Technology Act filed by one Complainant
namely Poonam Bipin Dalvi, wherein she has allegedly
contended that the present Petitioner and another
Accused Avinash Patil has started M.S. Global, Sangli,
Company for Share market trading and the Accused have
contacted on whats’app and assured as they are brokers
and requested to invest the amount and induced that the
Complainant will get double amount and therefore as per
the inducement and assurance the Complainant has
deposited the amount of Rs. 53,22,800/- with the
Accused, but the Accused are deceived her and therefore
she has filed the complaint.
15.08.2022. In the said offence the present Petitioner
was arrested.
22.05.2022. That C.R. No. 109 of 2022 registered
with Kurundwad Police Station, Tal. Shirol, District:
Kolhapur, u/sec. 406, 420, 409 r/w. 34 of I.P.C. and
u/sec. 3 & 4 of the Maharashtra Protection of Interest of
Depositors (in Financial Establishments) Act, 1999 filed
by complainant namely Nirija Babasaheb Patil wherein
she has contended that the present Petitioner and another
Accused Suraj Prakash Chougule, Avinash Patil and
25

Santosh Jadhav have started M.S. Global, Sangli,


Company for Share market trading and the Accused have
personally contacted to the complainant and assured as
they are brokers and requested to invest the amount and
induced that the Complainant will get double amount and
therefore upon relying the assurance given by the
Petitioner and other co-accused the Complainant has time
to time deposited the amount totally of Rs. 44,41,700/-
with the Accused, but the Accused are deceived her and
therefore she has filed the complaint.
-------- In the present matter the present
Petitioner was arrested.
24.08.2022. That C.R. No. 368 of 2022 registered
with Vishrambag Police Station, Sangli u/sec. 406, 420 of
I.P.C. and u/sec. 3 of the Maharashtra Protection of
Interest of Depositors (in Financial Establishments) Act,
1999 filed by complainant namely Nilesh Vishwasrao Patil,
wherein he has alleged that the present Petitioner has
started M.S. Global, Sangli, Company for Share market
trading and the Accused has personally contacted to the
complainant and assured as he is broker and requested to
invest the amount and induced that the Complainant will
get double amount and therefore upon relying the
assurance given by the Petitioner, the Complainant has
time to time deposited the amount totally of Rs.
92,04,517/- with the Accused, but the Accused are
deceived her and therefore she has filed the complaint.
26

13.09.2022. In the present matter the present


Petitioner was arrested.
01.10.2022. That C.R. No. 329 of 2022 registered
with Jaysingpur Police Station, Tal. Shirol, District:
Kolhapur u/sec. 406, 420, 409, 504, 506 r/w. 34 of I.P.C.
and u/sec. 3 & 4 of the Maharashtra Protection of Interest
of Depositors (in Financial Establishments) Act, 1999 filed
by complainant namely Suhas Sureshrao Deshpande,
wherein he has contended that the present Petitioner and
other Accused namely Avinash Patil, Anil Shivaji
Kumbhar, Virendra Shrikant Sokare and Suesh Bhupal
Redekar have started M.S. Global, Sangli, Company for
Share market trading and the Accused have personally
contacted to the complainant and assured as they are
brokers and requested to invest the amount and induced
that the Complainant will get double amount and
therefore upon relying the assurance given by the
Petitioner and other co-accused the Complainant has time
to time deposited the amount totally of Rs. 24,01,840/-
with the Accused, but the Accused are deceived her and
therefore she has filed the complaint.
11.10.2022. In the present matter the present
Petitioner was arrested.
18.10.2022. That C.R. No. 72 of 2022 registered with
Mandangad Police Station, District: Ratnagiri, u/sec. 420
r/w. 34 of I.P.C. filed by complainant namely Yash Dipak
Ghosalkar, wherein he has alleged that the present
Petitioner has started M.S. Global, Sangli Company for
27

Share market trading and the Petitioner and other accused


namely (1) Nilesh Shankar Potsure, (2) Mayur Mandlik,
(3) Pravin Janardan Kadam, (4) Yogesh Shankar Pawar,
(5) Vishal Vilas Salvi, (6) Paresh Pandurang Vane and (7)
Nilesh Ramji Rakte, have personally contacted to the
complainant and assured as they are brokers and
requested to invest the amount and induced that the
Complainant will get double amount and therefore upon
relying the assurance given by the Petitioner and other
accused, the Complainant has time to time deposited the
amount totally of Rs. 60,15,020/- with the Accused, but
the Accused are deceived them and therefore he has filed
the complaint. In the present matter the present Petitioner
was arrested.
--------- That in all the C.R.s the Petitioner is in
Judicial custody and at present the Petitioner is Yerwada
Central Prison, Pune. That the jurisdiction of the
Kurundwad Police Station and the jurisdiction of the
Jaysingpur Police Station is with the Ld. Additional
Sessions Judge, Jaysingpur, Tal. Shirol, District: Kolhapur
and the jurisdiction of the Vishrambag Police Station is
with the Ld. Sessions Judge, Sangli, which are adjacent
and near about having distance of 5 to 7 k.m.
---------- Hence the present Writ Petition.

III. POINTS TO BE URGED:-


As averred in the memo of Writ Petition.
28

IV. ACTS TO BE REFERRED


1. Maharashtra Protection of Interest of Depositors (in
Financial Establishments) Act, 1999.
2. Criminal Procedure Code.
3. Indian Penal Code.
4. Constitution of India.

V. AUTHORITIES TO BE CITED:-
At present nil.

MUMBAI.
DATE: /11/2022. (NAGESH Y. CHAVAN)
Advocate for the Petitioner.
29

IN THE HIGH COURT OF JUDICATURE AT BOMBAY


CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO. OF 2022.
DISTRICT: SANGLI.
Milind Balaso Gadhave. .. Petitioner.
-: VERSUS :-
The State of Maharashtra & Ors. .. Respondents.

I N D E X
S.No. Particulars of documents Page Nos.
1. Synopsis.
2. Memo of Criminal Writ Petition.
3. Exhibit ‘A’
True copy of the remand report of C.R.
No. 448 of 2022 registered with
Bharati Vidyapeeth, Pune.

4. Exhibit ‘B’
True copy of the F.I.R. bearing C.R.
No. 109 of 2022 registered with
Kurundwad Police Station, Taluka
Shirol, District: Kolhapur.

5. Exhibit ‘C’
True copy of the C.R. No. 368 of 2022
registered with Vishrambag Police
Station, Sangli.

6. Exhibit ‘D’
True copy of C.R. No. 329 of 2022
registered with Jaysingpur Police
Station, Tal. Shirol, District: Kolhapur.
30

7. Exhibit ‘E’
True copy of the C.R. No. 72 of 2022
registered with Mandangad Police
Station, District: Ratnagri.

8. Vakalatnama.
LAST PAGE NO.
31

IN THE HIGH COURT OF JUDICATURE AT


BOMBAY
CRIMINAL APPELLATE JURISDICTION
CRIMINAL WRIT PETITION NO. /2022.
DISTRICT: SANGLI.
Milind Balaso Gadhave. .. Petitioner.
-: VERSUS :-
The State of Maharashtra & Ors.
.. Respondents.

MEMO OF PETITION

Dated this __ day of November, 2022.

MR. NAGESH Y. CHAVAN,


Advocate for the Petitioner,
Office: 4/28, 2nd floor, Building No. 32,
Rajabahadur Mension, Hamam Street,
Below Kumar Computers
Behind Bombay Stock Exchange,
Fort, Mumbai – 400 001
Advocate Code: I2444
Mob. No. 9860771081
Email:- nageshchavan1981@gmail.com
32

You might also like