IN THE COURT OF HON’BLE _________, (Jurisdiction)

Case No. ____ Of ____

X vs Y

U/s ___/___/___ IPC

P. S. __________

Affidavit of (deponent)___________ aged __ years, S/o _______________________, R/o

______________________________

I, the deponent named above do hereby solemnly affirm and state on oath as under:-

1. That the deponent is the ___________ in the aforesaid case hence is well aware of
the facts and circumstances of the case!

2. That as part of the evidence at this stage, the deponent has to file an Audio CD along
with its transcript.

3. That the recorded Audio is of the conversation that the deponent had with the
accused on __/__/____.

4. That deponent hereby files recorded audio in an Audio CD and the transcript of the
conversation as verbatim. Audio CD and its transcript are filed as part of this affidavit
and marked as Annex 1 and 2.

5. That the deponent confirms that the digital audio file in the Audio CD is the copy to
the originally recorded digital audio file in the original recording device, used by the
deponent for recording.

6. That the deponent further confirms that the contents of the transcript are absolutely
identical and verbatim as the digital audio file in the Audio CD and the originally
recorded digital audio file in the original recording device.

7. That, the deponent is making this present affidavit to certify that:

1. The digital audio file in the Audio CD is the copy of the originally recorded
digital audio file in the original recording device.

2. The contents of the transcript are absolutely identical and verbatim to the
digital audio file in the Audio CD and to the originally recorded digital audio
file in the original recording device.
 8. That this affidavit, therefore, in the facts and circumstances of the case, is sufficient
in compliance with Section 65B of the Evidence Act. The digital audio file has been
copied from the deponent’s recording device, therefore, can be treated as a certified
copy. The annexed Audio CD and the transcript, therefore, are in compliance with the
provisions.

Deponent

Verification

I, (deponent), the deponent, do hereby solemnly affirm and verify that the contents of
paragraph No. 1, 2, 3, 4, 5, 6, 7and 8 are true to my personal knowledge which all I believe to
be true, no material has been concealed in it and no part of the affidavit is false.

So help me God.

Identified, today on in Court, (jurisdiction).

Deponent

Key Requirements for the Certificate

The certificate under Section 65-B(4) must include the following
elements:

1. Identification of the Electronic Record: The certificate must

identify the specific electronic record containing the statement.
2. Description of Production Method: It should describe how
the electronic record was produced.
3. Device Particulars: The certificate must provide details about
any device involved in the production of the electronic record.
4. Compliance with Conditions: It must address the conditions
mentioned in Sub-section 2 of Section 65-B.
5. Signature: The certificate must be signed by a person in a
responsible official position related to the operation of the
relevant device or management of the activities involved.
IN THE COURT _________________________________ PLACE

Case No.XXX/ 20XX

Between

ABC Petitioner

And

XYZ Respondent

CERTIFICATE

( Under Section 65 B Of Evidence Act)

I, ABC ,S/O DEF ,Aged about XX years, R/o XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX do hereby

solemnly affirm and state as follows:

1. I state that I have produced the printouts of e-mails exchanged between me and

respondent, also I have given the print outs of bank statements/ Other Electronic Document

(Mention which document).

2. The printouts and other digital documents taken from the computer owned, maintained,

managed and operated by me and the said computer device and the printer details are as
follows:

OS Name _______________

Version _______________

OS Manufacturer _______________

System Name _______________

System Manufacturer ________________

System Model ________________

Start up disk _____________

Installed Physical Memory _______________

(RAM)

3 I state that the computer output containing the information was produced by the
Computer

during the period over which the Computer was used regularly to store or process
information for
the purposes of the acts referred to in the evidence regularly carried on over that period by
me

having lawful control over the use of the computer.

4. I state that during the said period, information of the kind contained in the electronic
record

or of the kind from which the information so contained is derived was regularly fed into the

computer in the ordinary course of my correspondences with the Respondent.

5 I state that throughout the material part of the said period the computer was operating

properly without affecting the contents of the electronic record or its accuracy or its
contents.

6. I state that the information contained in the electronic record is derived from such

information fed into the computer in the ordinary course.

Place Deponent

Date:

Verification

Verified on this ______, 20XX at _______________ that the contents of the above stated
affidavit is

true to my best of knowledge

 In the hon’ble Court of the Spl Judge for trial of POCSO Cases

At Visakhapatnam

SC: 98/2020C

Between:

Ch.Kanakaraju …Accused

And :

State represented by Spl Public Prosecutor …Complainant

CERTIFICATE

( Under Section 65 B Of Evidence Act)

Affidavit of CHETTI KANAKARAJU, S/O DEGANNA, 43 years, R/o DOOR NO. 13-14-49, NTR
COLONY, BHEEMUNIPATNAM.

I, the deponent named above do hereby solemnly affirm and state as under:-

1. I am the deponent and accused in the aforesaid case hence I am well aware of the
facts and circumstances of the case!

2. That as part of the defense evidence at the stage of filing written statement, the
deponent is filing an Audio CD along with its transcript.

3. That the recorded Audio is of the conversation that the deponent had with the
complainant principal of Kidz garden school and one Subrahmanyam incharge Vice principal
in the Principal chamber in the school on 28-3-2019.

4. That deponent hereby files recorded audio in an Audio CD and the transcript of the
conversation as verbatim. Audio CD and its transcript are filed as part of this affidavit and
marked as Annex I and Annex II

5. That the deponent confirms that the digital audio file in the Audio CD is the copy to
the originally recorded digital audio file in the original recording device which is MOTO C
Mobile, used by the deponent for recording and later transferred to a computer and from
there to pen drive/cd.
6. That the deponent further confirms that the contents of the transcript are absolutely
identical and verbatim as the digital audio file in the Audio CD and the originally recorded
digital audio file in the original recording device.

7. That, the deponent is making this present affidavit to certify that:

a. The digital audio file in the Audio CD is the copy of the originally recorded digital
audio file in the original recording device.

b. The contents of the transcript are absolutely identical and verbatim to the digital
audio file in the Audio CD and to the originally recorded digital audio file in the original
recording device.

8. That this affidavit, therefore, in the facts and circumstances of the case, is sufficient
in compliance with Section 65B of the Evidence Act. The digital audio file has been copied
from the deponent’s recording device, therefore, can be treated as a certified copy. The
annexed Audio CD and the transcript, therefore, are in compliance with the provisions.

Deponent

Verification

I, Ch.Kanakaraju, the deponent, do hereby solemnly affirm and verify that the contents of
paragraph No. 1, 2, 3, 4, 5, 6, 7and 8 are true to my personal knowledge which all I believe to
be true, no material has been concealed in it and no part of the affidavit is false.

DEPONENT

Solemnly affirmed and signed before me on this…..…...day of MAY ,2025 at Visakhapatnam

ADVOCATE.
 In the hon’ble Court of the Spl Judge for trial of POCSO Cases

At Visakhapatnam

SC: 98/2020

Between:

Ch.Kanakaraju …Accused

And :

State represented by Spl Public Prosecutor …Complainant

Crpc 233 (1) petition FILED BY THE ACCUSED

It is respectfully submitted that the accused herein entered on his defense and examined
himself as PW1.The accused wishes to adduce further defense evidence by examining a
student and teacher of kidz garden school, vskp at the relevant time in 2019 namely M.Sai
Pushpa and V.Mounika to disprove the allegations. Hence, he may be permitted and the
petition may be allowed in the interests of justice.

Vskp,

Date: 21-5-2025. Counsel for accused.

 In the hon’ble Court of the Spl Judge for trial of POCSO Cases

At Visakhapatnam

SC: 98/2020

Between:

Ch.Kanakaraju …Accused

And :

State represented by Spl Public Prosecutor …Complainant

Written statement u/s Crpc 233 (2) FILED BY THE ACCUSED

May it please your honour:

The accused respectfully submits :

1.that he worked as Telugu teacher in KIdz Garden School for more than 6 years without any
remark.

2.that his salary was very low, without any increase and unable to sustain himself, he wanted
to quit the job in Jan 2019, but the Principal of the School began to create problems for him.

3.that during that time, he was not allowed to bring certain conduct and discipline issues
pertaining to some students before the parents meeting and instead it was projected by the
Principal as if the teacher himself was harassing those students and tried to extort money
saying that if Rs: 75,000/- was not paid, a complaint would be lodged by the school against
him for harassing the girls.

4.that though he insisted that the girls be put in front of him and make such allegations, the
principal did not bring them before him and showed some complaints written on paper.,

5. that unable to bear the harassment from the school he quit the job in Jan 2019 itself.

6. that even though he quit the job , he was forced to regularly come to the school and meet
the illegal demand of money under the threat of complaint.

7. that his certificate was illegally held by the school.

8. that he had been going to school from Jan 2019 to April 2019 asking the school to return
his certificate and leave him.
9. that during one of the visits on 28th March 2019 he happened to audio record the
conversation between him, the Vice Principal and the Principal in the Principal’s chamber
10. that the conversation clearly shows how much pressure the school exercised on him to
meet the illegal demand of Rs: 75,000/- , to take forceful apology letters or else to face the
complaint to be lodged with the police.

10.that the conversation shows that he owed the school only ten or fifteen thousand rupees
and that too his two-month salary arrears still pending to be paid, and that he cannot meet
the illegal demand of Rs 75,000/-.

11. that the conversation shows the vice principal saying –‘ manaki entha kavali ‘ and the
principal answering ‘75’

Had the teacher really owed that much money to the school, the wording should have been
‘ manaki entha ravali’ and not entha kavali…

So it is clear cut case of extortion by the school.

12.that he visited the school on 28 April , 2019 and finally stated that he cannot any longer
meet their illegal money demands.

13.that hearing this, the Principal and vice Principal grew wild and took him near police
station but did not take him inside or make complaint but instead took him to his house
from there.

14. that the principal abused him and his sister at his home before everybody in the locality
in the name of caste and also tried to disturb his marital life by making false allegation
before his wife.

15. the his family ,very much disturbed over the principal’s behaviour, complained before
the police. The police called the teacher but she sought some time saying that she would
settle the matter and instead went and lodged this POCSO case in the meanwhile. The police
later filed SC & ST atrocity case against the Principal.

16.that the principal exercised undue pressure and supervision over the girl students who
are prosecution witnesses in the case.

17.that there are CC TV cameras almost in all vital places in the school. That is why every
statement of the girl shows as if the incident had happened one year ago and not in the
current times so that it is convenient to say that the footage is not available.

18. that it is not in the knowledge of the girl students' parents and no parent is examined.
Had the allegations been true, the students would normally complain to their parents first.
Therefore it is the Principal who cooked up all these allegations with the active support of
the Vice Principal.
19.that no alleged complaints in writing made by the girls in Jan 2019 were seized and
produced in the case.
20. that the accused did not commit any offence and there is huge delay of about 4 months
from Jan 2019 to May 2019 in reporting the case. Had the allegations been true, the
Principal would also have been charged by the police for the delay.

The accused is herewith filing the audio record and transcript of the conversation mentioned
above along with 65B certificate and the same may be considered to check the truth and
veracity of the prosecution case.

It is respectfully submitted that the device containing said audio record was dead for some
time, and the accused was unable to retrieve it in time to confront the same with the de
facto complainant Principal, during her cross-examination. However, it is retrieved now after
the repair of the device and is therefore being filed with the written statement.

The accused prays that the hon’ble Court may be pleased to consider the written statement
in the light of evidence lead by the prosecution to appreciate the truthfulness or otherwise
of the case of the prosecution and probabilities of the case lying in favour of the accused.

Visakhapatnam,

Date : 27-5-2025. Accused.

 In the hon’ble Court of the Spl Judge for trial of POCSO Cases

At Visakhapatnam

SC: 98/2020C

Between:

Ch.Kanakaraju …Accused

And :

State represented by Spl Public Prosecutor …Complainant

CERTIFICATE

( Under Section 65 B (4) Of Evidence Act)

Affidavit of CHETTI KANAKARAJU, S/O DEGANNA, 43 years, occupation: Telugu teacher,R/o

DOOR NO. 13-14-49, NTR COLONY, BHEEMUNIPATNAM.

I, the deponent named above do hereby solemnly affirm and state as under:-

1. I am the deponent and accused in the aforesaid case hence I am well aware of the
facts and circumstances of the case and I also know basic computer operations.

2. That as part of the defense evidence at the stage of filing written statement, the
deponent filed an Audio CD along with its transcript.

3. That the recorded Audio is of the conversation that the deponent had with the
complainant principal of Kidz garden school and one Subrahmanyam incharge Vice principal
in the Principal chamber in the school on 28-3-2019 wherein the School people demanded
Rs:75,000/- from the accused on the pretext that there was a complaint against him and also
withheld his certificates.

4. That the deponent filed recorded audio in an Audio CD and the transcript of the
conversation as verbatim. Audio CD and its transcript were filed as part of this affidavit and
marked as Annex I and Annex II.

5. That the deponent confirms that the digital audio file in the Audio CD is the copy to
the originally recorded digital audio file in the original recording device which is his MOTO C
Mobile, used by the deponent for recording and later transferred to his computer/laptop HP
Pavilion g6 and from there to pen drive/CD.
6. That the deponent further confirms that the contents of the transcript are absolutely
identical and verbatim as the digital audio file in the Audio CD and the originally recorded
digital audio file in the original recording device.

7. That, the deponent is making this present affidavit to certify that:

a. The digital audio file in the Audio CD is the copy of the originally recorded digital
audio file in the original recording device.

b. The contents of the transcript are absolutely identical and verbatim to the digital
audio file in the Audio CD and to the originally recorded digital audio file in the original
recording device.

c. that the Moto C mobile which held the original voice record in digital form and the
Hp g6 laptop to which the record was transferred for copying and later making pen drive/cd
of the audio clip as output from it, were in the lawful custody of the deponent and in proper
working condition, used in the regular course of operations at the relevant time in full
compliance of sec 65B(2) of IE Act.

8. That this affidavit, therefore, in the facts and circumstances of the case, is sufficient
in compliance with Section 65B of the Evidence Act. The digital audio file has been copied
from the deponent’s recording device, therefore, can be treated as a certified copy. The
annexures Audio CD and the transcript, therefore, are in compliance with the provisions.

Deponent

Verification

I, Ch.Kanakaraju, the deponent, do hereby solemnly affirm and verify that the contents of
paragraph No. 1, 2, 3, 4, 5, 6, 7and 8 are true to my personal knowledge which all I believe to
be true, no material has been concealed in it and no part of the affidavit is false.

DEPONENT

Solemnly affirmed and signed before me on this…..…...day of July ,2025 at Visakhapatnam

ADVOCATE.
 In the hon’ble Court of the Spl Judge for trial of POCSO Cases

At Visakhapatnam

SC: 98/2020

Between:

Ch.Kanakaraju …Accused

And :

State represented by Spl Public Prosecutor …Complainant

Memo FILED BY THE ACCUSED

It is respectfully submitted that the accused is herewith filing a full-fledged 65B certificate
under the Indian Evidence Act for the digital record filed earlier at the time of submitting the
written statement of the accused. Hence, the same may be permitted in the interests of
justice.

Vskp,

Date: 1-7-2025. Counsel for accused.