IN THE COURT OF THE PRL.
DISTRICT AND SESSIONS COURT :: AT
KHAMMAM
Crl.M.P.No /2024
In
Crime No.593/2024 of PS Khanapuram Haveli, , Khammam .
Between:
Modugu Ashok, S/o Basavaiah, 32 years, SC-Madiga, Auto Driver, R/o
YSR Colony Khammam, Native of Jannaram village of Enkoor Mandal
Cell 9505314310
.Petitioner/Accused
And
The State, PS Khanapuram through Public Prosecutor, Khammam
District
..Complainant/Respondent
PETITION FILED UNDER SEC. 483 of BNSS. for GRANT OF BAIL
The Petitioner most respectfully submits as under:-
1 That the Petitioner/Accused has been falsely implicated in the
above said crime No.593/2024 of PS Khanapuram, Khammam for the
offences u/s 69 of BNS Act 2023. The Petitioner/Accused was
arrested on 13-11-2024 and produced before the Hon’ble II Addl.
Judicial First Class Magistrate, Khammam and on the same day he
was remanded to judicial custody.
2 This is a case of Cheating with false promises and diverted the
victim woman from her husband and used her physically on the
pretext of marriage and failed do so, which Occurred prior to
23.10.2024 at YSR Colony Khammam and reported on 13.11.2024 at
10.00 hours by the complainant Victim woman, Wherein the accused
Modugu Ashok S/o Basavaiah, 32yrs, Madiga, Car driver R/o YSR
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Colony Khammam approached the complainant/victim woman who is
married and having three children and saying deceitful words that he
loved the victim woman and to give divorce to her husband and will
marry her and on believing the deceitful words of accused the victim
woman also loved him and in the name marriage the accused used
her physically with her consent and the victim woman separated from
her husband along with her children and asked the accused about the
marriage, but the accused dragged from time to time and finally he
refused to marry her and there by cheated the victim woman in the
name of marriage. The place of offence falls under the limits of PS
Khanapuram Haveli and within the territorial Jurisdiction of the
Hon'ble Court.
3 The brief facts of the case are that on 13.11.2024 at 10.00
hours the victim womatv.complainant came to P'S and lodged a
Telugu written petition in which she stated that she is resident of YSR
Colony Khammam and her marriage was performed with Bama Sring
S/o Lachiram, Ro YSR Colony Khammam on 12.02.2012 and after the
marriage both they lived happily for some period and during their
marital life they blessed with three children. Her husband eking out
their livelihood by doing Medical representative. While they are
residing at YSR Colony one Modugu Ashok So Basavainh, 32yrs,
Madiga, Madiga, Car driver also residing in YSR Colony and abour 15
year back he approached her and saying deceitful words that he
loved her and to come with him and due to his deceitful words she is
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also agreed to his propose and mean while he used her physically on
the name of love and marriage and says that to give divorce to her
husband and he is also give divorce to his wife and later he will marry
her. Since then she was residing separately from her husband and
asked the Ashok about the marriage. But he dragged from time to
time and finally on 23.10.2024 she along with her three children went
to the said Ashok and asked about the marriage, but he refused to
marry her and do as her wish. Later she noticed that the said Ashok
saying deceitful words and approached her knowingly as she was
marriage and having three children and on the pretext of marriage
physically meet her with her consent and finally refused to marry her.
So she requested to take necessary action against him and do justice.
4 In the entire complaint given by the de facto-complainant the
defacto complainant with all false allegations. In her report still
staying with her husband. As a neighbouring families, the defacto
complainant out of her necessity borrowed an amount of Rs1,44,000/-
and the same was transferred from the account of the
Petitioner/accused to the defacto complainant’ account. Later the
petitioner/accused demanded the defacto complainant to repay the
same. With that demand the defacto complainant come with story of
having illegal relationship with her . Infact the Petitioner/accused is a
married person and he is having his own family and he has to look
after his family and his old aged mother. But the defacto complainant
not interested to repay amount borrowed and plotted the above story
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with a intention to avoid the repayment of the above borrowed
amount.
Moreover the defacto complainant is a married lady and having
3 children and leading her life with her husband.
Moreover no where it was whispered in the entire complaint the
date from which both are acquaint with one another and in
relationship. Its simply a story created by the defacto complainant
only to avoid the repayment. Moreover this Petitioner really any such
relationship with this defacto complainant , the defacto complainant
might have stopped the marriage of the Petitioner that was taken
place recently four months back which is in her knowledge as near by
resident..
It is only to make belittle the Petitioner before the wife of
Petitioner and to avoid the payment, the petitioner knitted the above
illegal relation with all false and concocted stories only to harass the
petitioner.
5 But however the Petitioner/accused ready to prove his
innocence by way of facing the trial.
6 The Petitioner/accused is an innocence person he is nothing to
do with the alleged offence.
7 That the Petitioner/Accused is the only bread winner of his
family and he has to look after his old aged mother and his further
detention would be cause much inconvenience and it become
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hardship to his family moreover he has a responsibility to look after
his old age mother and his wife.
8 The Petitioner/Accused is ready to furnish security to the
satisfaction of this Hon’ble Court in the event of his enlargement on
bail.
9 The Petitioner/Accused is ready to prove are innocence by way
of facing the trial and is ready abide by the conditions if any imposed
by the Hon’ble court.
10 This is the 1st bail application of its kind and no similar
application is pending any other court much less before the Hon’ble
High Court of , Hyderabad for the State of Telangana and State of
Andhra Pradesh
11 Therefore, it is prayed that the Hon’ble court may be pleased to
enlarge the Petitioner/Accused on bail, in the interest of the justice.
Khammam,
Date: - -2024 Advocate for Petitioner/Accused
Verification: I,Modugu Narayanamma, W.o Basavaiah, Khammam
mother of the Petitoiner/accused of Accused is authorized by the
Accused to appoint Sri Gorantla Shanta RaoAdvocate, Khammam to
appear and defend the accused in the above Crime NO. 593/2024 of
PS Khanapuram Haveli, Khammam District and that no other person
has been authorized to appoint any other advocate.
Signature of the
Interest person on behalf of the Accused
Khammam
Dt: - -2024 Attester Advocate
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IN THE COURT OF THE PRL.
DISTRICT AND SESSIONS
COURT :: AT KHAMMAM
Crl.M.P.No /2024
In
Crime No.593/2024 of PS
Khanapuram Haveli, ,
Khammam .
Between:
Modugu Ashok
.Petitioner/Accused
And
The State, PS Khanapuram
through Public Prosecutor,
Khammam District
..Complainant/Respondent
PETITION FILED UNDER SEC.
483 of BNSS. for GRANT OF
BAIL
Filed by:
Sri Gorantla Shantha Rao
Sri Yerra Gnanesh
Sri N Arun Kumar
Advocates,Khammam
