BEFORE THE HON’BLE ADDITIONAL CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 8 of 2024
(On the file of Inspector of Police, Cyber Crime Police Station, Chennai West,
CCD – 1, Chennai)
Kannappan M, M/33 Years,
S/o Mannar raj,
No 4, Kannappaswamy nagar, 27th street,
Kavankarai, puzhal,
Chennai- 600066,
Tamil Nadu. … Petitioner/Defacto Complainant
-Vs-
1) State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 8 of 2024) … Respondent/Investigating Agency
2) ICICI Bank Ltd,
Udaipur, Bapu Bazaar Branch,
Bapu Bazaar, Udaipur – 313001,
State Of Rajasthan.
IFSC Code - ICIC0006933
Email Id: Customer.Care@Icicibank.Com
3) ICICI Bank Ltd,
Tiruttani Branch,
No 23 Subramanya Nagar,
Chennai Bye Pass Tiruttani -631209,
State of Tamilnadu.
IFSC Code - ICIC0004974
Email Id: Customer.Care@Icicibank.Com
4) ICICI Bank,
Changodar Branch,
Block No 563, Changodhar Industrial Area,
Changodhar -382213,
State of Gujarat.
IFSC Code: ICIC0001740
Email Id: Customer.Care@Icicibank.Com
5) ICICI Bank Ltd,
Guwahati – Fancy Bazaar Branch,
Ohio Shopping Complex,
1
Fancy Bazaar, M.G Road, Guwahati – 781001,
State of Assam.
IFSC Code: ICIC0000543
Email Id: Customer.Care@Icicibank.Com
6) ICICI Bank Ltd,
Dobaka Branch,
Rabbani Plaza, Ward No 4,
Main Road, Doboka, Dist Hojai, Assam-782440,
State of Assam.
IFSC Code: ICIC0004926
Email Id: Customer.Care@Icicibank.Com
7) ICICI Bank Ltd,
Kharsia Branch,
Gandhi Chowk, Raigarh Road Kharsia,
Raigarh District - 496 661,
State of Chattisagarh.
IFSC Code: ICIC0002022
Email Id: Customer.Care@Icicibank.Com
8) Punjab National Bank,
Bhilwara, Sanganeri Gate Branch,
Sanganeri Gate, Bhilwara District - 311001,
State of Rajasthan.
IFSC Code- PUNB0090800
Email Id: Care@Pnb.Co.In ... Respondents 2 to 8/Banks
AFFIDAVIT OF KANNAPPAN M
I, Kannappan M, M/33 Years, S/o Mannar Raj, residng No 4,
Kannappaswamy Nagar, 27th Street, Kavankarai, Puzhal, Chennai- 600066, do
hereby solemnly affirm and sincerely states as follows:
1. I am the petitioner herein and defacto complainant in Crime No 8 of 2024 and
as such well acquainted with the facts and circumstances of the case.
2. I most respectfully submit that on 05.10.2023, at about 10.57 am, I received a
message through Telegram ID Divya, regarding a part time job and through
2
www.careerBuilder.co.in asked a few details about me. Later, they contacted me
through various Telegram IDs. One Karthika Nirmal informed me about Airline
ticket booking agent job and informed that I will receive commission. Thereafter,
they asked me to register for the same and I received Rs.700/- for completing my
registration. Later, they instructed to pay Rs. 11,000/- and I received Rs 18,269/-
including my commission. Again they asked me to transfer money. Based on their
instructions I transferred the amount as follows:
S No Amount Payee Account Account Freezed Amount
transferred Details Maintained by
1 Rs 20,000/- A/c No 693305500513 2nd Respondent Rs 12,538.53/-
2 Rs 1,70,000/- A/c No 497405500026 3rd Respondent Rs 10,64,533/-
3 Rs 50,000/- & A/c No 174005500448 4th Respondent Rs 12,777/-
Rs 1,10,000/-
4 Rs 1,40,000/- A/c No 054305501335 5th Respondent Rs 15,68,341/-
5 Rs 30,000/- A/c No 492605500042 6th Respondent Rs 3,70,685/-
6 Rs 30,000/- A/c No 202205004005 7th Respondent Rs 1,56,592.3/-
7 Rs 45,847/- A/c No 0908002100104939 8th Respondent Rs 50,989.87/-
In total, I credited a sum of Rs. 5,95,847 /- to the payee account stated supra
and only a sum of Rs 4,41,117/- (Rupees Four Lakhs Forty-One Thousand One
Hundred and Seventeen Only) has been freezed by the 1 st respondent in his account.
I lodged complaint before the 1st respondent police and the same was taken for
investigation in Crime No 8 of 2024 for the offences punishable under Sections 420
of IPC and section 66D of the Information Technology Act, 2000. Based on my
3
complaint, the 1st respondent/police have taken effective steps and blocked payee
account maintained with the 2nd respondent bank. With great pain and sufferings, I
would like to submit that sum of Rs 4,41,117/- (Rupees Four Lakhs Forty-One
Thousand One Hundred and Seventeen Only) i.e., the amount fraudulently usurped
from my account illegally is lying with the 2nd respondent bank.
3. I most respectfully submit that the sum of Rs 4,41,117 /- (Rupees Four Lakhs
Forty-One Thousand One Hundred and Seventeen Only) which was cheated by
unknown person had been freeze by the 1st respondent police is my hard earned
money. Unless the said sum is returned to me, I will suffer huge monetary loss. In
the said circumstances, it is just and necessary that this Hon’ble Court may be
pleased to direct the respondent to return a sum of Rs 4,41,117 /- (Rupees Four
Lakhs Forty-One Thousand One Hundred and Seventeen Only) which was
fraudulently debited from my KVB BANK, A/c No 1154166000016633, Anna
Nagar Branch, Chennai, IFSC KVBL0001154 in the interest of justice.
4. I most respectfully submit that I have been living for a longer period of time
and having permanent roots in that locality. I hereby undertake to abide any
conditions imposed by this Hon’ble Court for returning my hard earned money. I
state that I am citizen of India from birth and living in the above address for several
years. Unless the above application will be allowed, I will be put to irreparable
hardship and loss, on the other hand no prejudice will caused to the respondent
herein.
4
5. I crave leave of this Hon’ble Court to reserve my rights to file
additional application if remaining sum have been freeze by the 1 st respondent
during investigation.
I therefore pray that this Hon’ble Court may be pleased to direct the
i) 2nd respondent bank to return a sum of Rs 12,500/- (Rupees Twelve
Thousand Five Hundred Only)
ii) 3rd respondent to return a sum of Rs 1,70,000/- (Rupees One Lakh Seventy
Thousand Only)
iii) 4th respondent to return a sum of Rs 12,770/- (Rupees Twelve Thousand
Seven Hundred and Seventy Only)
iv) 5th respondent to return a sum of Rs 1,40,000/- (Rupees One Lakh Forty
Thousand Only)
v) 6th respondent to return a sum of Rs 30,000/- (Rupees Thirty Thousand
Only)
vi) 7th respondent to return a sum of Rs 30,000/- (Rupees Thirty Thousand
Only)
vii) 8th respondent to return a sum of Rs 45,847/- (Rupees Forty-Five Thousand
Eight Hundred and Forty-Seven only)
in total a sum of Rs 4,41,117 /- (Rupees Four Lakhs Forty-One Thousand One
Hundred and Seventeen Only) which was fraudulently transfer from my KVB
BANK A/c No 1154166000016633, Anna Nagar Branch, Chennai, IFSC
5
KVBL0001154, pass such further order or orders as this Hon’ble court made deem
fit and proper in the circumstances of the case and thus render justice.
Solemnly affirmed at Egmore, Chennai Before me
on this the 26th day of March 2024
and she signed his name in my presence Advocate :: Chennai
6
BEFORE THE HON’BLE ADDITIONAL CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 8 of 2024
(On the file of Inspector of Police, Cyber Crime Police Station, Chennai West,
CCD – 1, Chennai)
Kannappan M, M/33 Years,
S/o Mannar raj,
No 4, Kannappaswamy nagar, 27th street,
Kavankarai, puzhal,
Chennai- 600066,
Tamil Nadu. … Petitioner/Defacto Complainant
-Vs-
1) State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 8 of 2024) … Respondent/Investigating Agency
2) ICICI Bank Ltd,
Udaipur, Bapu Bazaar Branch,
Bapu Bazaar, Udaipur – 313001,
State Of Rajasthan.
IFSC Code - ICIC0006933
Email Id: customer.Care@Icicibank.Com
3) ICICI Bank Ltd,
Tiruttani Branch,
No 23 Subramanya Nagar,
Chennai Bye Pass Tiruttani -631209,
State of Tamilnadu.
IFSC Code - ICIC0004974
Email Id: customer.Care@Icicibank.Com
4) ICICI Bank,
Changodar Branch,
Block No 563,
Changodhar Industrial Area,
Changodhar -382213,
State Of Gujarat.
IFSC Code: ICIC0001740
Email Id: Customer.Care@Icicibank.Com
7
5) ICICI Bank Ltd,
Guwahati – Fancy Bazaar Branch,
Ohio Shopping Complex,
Fancy Bazaar, M.G Road, Guwahati – 781001,
State of Assam.
IFSC Code: ICIC0000543
Email Id: customer.Care@Icicibank.Com
6) ICICI Bank Ltd,
Dobaka Branch,
Rabbani Plaza, Ward No 4,
Main Road, Doboka, Dist Hojai, Assam-782440,
State of Assam.
IFSC Code: ICIC0004926
Email Id: customer.Care@Icicibank.Com
7) ICICI Bank Ltd,
Kharsia Branch,
Gandhi Chowk, Raigarh Road Kharsia,
Dist-Raigarh, Chattisagarh -496661,
State Of Chattisagarh.
IFSC Code: ICIC0002022
Email Id: customer.Care@Icicibank.Com
8) Punjab National Bank,
Bhilwara, Sanganeri Gate Branch,
Sanganeri Gate, Bhilwara, Rajasthan-311001,
State Of Rajasthan.
IFSC Code- PUNB0090800
Email Id: care@Pnb.Co.In ... Respondents 2 to 8/Banks
PETITION TO RETURN OF PROPERTY
(Under Section 451 R/W 457 of CRPC)
For the reasons stated in the accompanying affidavit, it is therefore pray that this
Hon’ble Court may be pleased to direct the
i) 2nd respondent bank to return a sum of Rs 12,500/- (Rupees Twelve
Thousand Five Hundred Only)
8
ii) 3rd respondent to return a sum of Rs 1,70,000/- (Rupees One Lakh Seventy
Thousand Only)
iii) 4th respondent to return a sum of Rs 12,770/- (Rupees Twelve Thousand
Seven Hundred and Seventy Only)
iv) 5th respondent to return a sum of Rs 1,40,000/- (Rupees One Lakh Forty
Thousand Only)
v) 6th respondent to return a sum of Rs 30,000/- (Rupees Thirty Thousand
Only)
vi) 7th respondent to return a sum of Rs 30,000/- (Rupees Thirty Thousand
Only)
vii) 8th respondent to return a sum of Rs 45,847/- (Rupees Forty-Five Thousand
Eight Hundred and Forty-Seven only)
in total a sum of Rs 4,41,117 /- (Rupees Four Lakhs Forty-One Thousand One
Hundred and Seventeen Only) which was fraudulently transfer from my KVB Bank
A/c No 1154166000016633, Anna Nagar Branch, Chennai, IFSC KVBL0001154,
pass such further order or orders as this Hon’ble court made deem fit and proper in
the circumstances of the case and thus render justice.
Dated at Egmore, Chennai on this the 26th day of March 2024
COUNSEL FOR PETITIONER/DEFACTO COMPLAINANT
List of Documents:
1) Statement of Accounts
2) First Information Report
9
BEFORE THE HON’BLE ADDITIONAL CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 8 of 2024
(On the file of Inspector of Police, Cyber Crime Police Station, Chennai West,
CCD – 1, Chennai)
Kannappan M, M/33 Years,
S/o Mannar raj, … Petitioner/Defacto Complainant
-Vs-
1) State Rep by Inspector of Police,
Cyber Crime Police Station,
Chennai West, CCD – 1,
Chennai. (FIR No 8 of 2024) … Respondent/Investigating Agency
VAKALATH
I, Kannappan M, M/33 Years, S/o Mannar Raj, do hereby appoint and retain
M/S A.M. AMUTHA GANESH MS 1953/2008, V. JAYAVIGNESHWARI MS
2110/2015, M. BALU MS 380/2018 & K.KEERTHI 5494/2022 Advocates to
appear for us in the above case on our behalf and to plead and we further empower
them to accept on our behalf service of notice of all proceedings in the above case
until disposal of the case.
SIGNATURE OF PETITIONER
I certify that the contents of this Vakalatnama were read over and explained in
English in my presence to the Executants who appeared perfectly to understand the
same and made their signature in my presence.
Executed before this the 26th day of March 2024
Before Me
Advocate :: Chennai
We accept the Vakalathnama COUNSEL FOR PETITIONER
Address for Service; No 155 Thambu Chetty Street, IV Floor, Chennai - 600 001
CellNo:9094790987,amuthaganeshadvocate@gmail.com
10
BEFORE THE HON’BLE ADDITIONAL
CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 8 of 2024
(On the file of Inspector of Police, Cyber
Crime Police Station, Chennai West,
CCD – 1, Chennai)
Kannappan M, M/33 Years,
S/o Mannar Raj,
… Petitioner/Defacto Complainant
-Vs-
State Rep by Inspector of Police,
Cyber Crime Police Station & another
(FIR No 8 of 2024)
… Respondent/Investigating Agency
PETITION TO RETURN OF PROPERTY
(Under Section 451 R/W 457 of CRPC
M/S A.M. AMUTHA GANESH MS 1953/08
V. JAYAVIGNESHWARI MS 2110/15
M. BALU MS 380/2018
K. KEERTHI MS 5494/2022
COUNSEL FOR PETITIONER
Cell No 9094790987
11
BEFORE THE HON’BLE ADDITIONAL
CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 8 of 2024
(On the file of Inspector of Police, Cyber
Crime Police Station, Chennai West,
CCD – 1, Chennai)
Kannappan M, M/33 Years,
S/o Mannar Raj,
… Petitioner/Defacto Complainant
-Vs-
State Rep by Inspector of Police,
Cyber Crime Police Station & another
(FIR No 8 of 2024)
… Respondent/Investigating Agency
AFFIDAVIT OF KANNAPAN M
M/S A.M. AMUTHA GANESH MS 1953/08
V. JAYAVIGNESHWARI MS 2110/15
M. BALU MS 380/2018
K. KEERTHI MS 5494/2022
COUNSEL FOR PETITIONER
Cell No 9094790987
12
BEFORE THE HON’BLE ADDITIONAL
CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 8 of 2024
(On the file of Inspector of Police, Cyber
Crime Police Station, Chennai West,
CCD – 1, Chennai)
Kannappan M, M/33 Years,
S/o Mannar Raj,
… Petitioner/Defacto Complainant
-Vs-
State Rep by Inspector of Police,
Cyber Crime Police Station & another
(FIR No 8 of 2024)
… Respondent/Investigating Agency
VAKALATH
M/S A.M. AMUTHA GANESH MS 1953/08
V. JAYAVIGNESHWARI MS 2110/15
M. BALU MS 380/2018
K. KEERTHI MS 5494/2022
COUNSEL FOR PETITIONER
Cell No 9094790987
13
BEFORE THE HON’BLE ADDITIONAL
CHIEF METROPOLITAIN
MAGISTRATE AT EGMORE
CRL M P No of 2024
in
FIR No 8 of 2024
(On the file of Inspector of Police, Cyber
Crime Police Station, Chennai West,
CCD – 1, Chennai)
Kannappan M, M/33 Years,
S/o Mannar raj,
… Petitioner/Defacto Complainant
-Vs-
State Rep by Inspector of Police,
Cyber Crime Police Station & another
(FIR No 8 of 2024)
… Respondent/Investigating Agency
DOC No:
DESCRIPTION:
M/S A.M. AMUTHA GANESH MS 1953/08
V. JAYAVIGNESHWARI MS 2110/15
M. BALU MS 380/2018
K. KEERTHI MS 5494/2022
COUNSEL FOR PETITIONER
Cell No 9094790987
14
