CIVIL PLEADINGS

EXERCISE-1 PLAINT

PLAINT
IN THE COURT OF THE III ADDITIONAL JUNIOR CIVIL JUDGE :
CITY CIVIL COURT : AT HYDERABAD.
 O.S. No……………of   2007

 
Mr.MOHIT SHARMA, 
S/o LAKHAN SHARMA, Aged 45 years,
Occ: Local Shopkeeper    
R/o. D.No. 247, Netaji Road,
Hyderabad  ………………………..Plaintiff
 
Vs.
 
Mr.SUDHIR KUMAR, 
S/o NAITIK KUMAR, Aged 47 Years,
Occ: Employee
R/o.D.No.249,NetajiRoad,
Hyderabad.                                       ……………………..…Defendant
 
PLAINT FILED UNDER SECTION 26 READ WITH ORDER VII OF
CPC

I) DESCRIPTION OF THE PLAINTIFFS:

The address for service of all notices and summons of process

to the above named plaintiff is that of his Counsel Mr.
N.Venkateswara Rao, …..,   Hyderabad)
 
II) DESCRIPTION OF THE DEFENDANTS:

The address for service of all summons, notices and process on

the defendants is as stated above in ‘Cause Title’.
 
III. BRIEF FACTS OF THE CASE:
 
1. It is submitted that the Defendant having an acquaintance
with the plaintiff approached him and requested to advance a
hand loan of Rs.25,000/- (Rupees twenty five thousand Rupees
only) to meet his son’s education needs. The Defendant also
proposed to execute a Promissory Note for the said amount
and with a simple interest @ 18% p.a. Due to that
acquaintance, the Plaintiff agreed for the same and thus, the
defendant has borrowed a sum of Rs.25,000/- as hand loan on
1st January, 2005 from the Plaintiff at the Plaintiff’s home
situated at Hyderabad and executed a Promissory Note for the
said amount in favor of the Plaintiff and promised to repay the
said hand loan within a period of 2 years from the date of
execution of the promissory note. It is respectfully submitted
that in spite of repeated oral demands made by the Plaintiff,
the Defendant did not bother to repay the said hand Loan
amount.
 
2.The Plaintiff having vexed with the conduct of the Defendant
avoiding the repayment, got issued a legal notice to the
Defendant on 1st January, 2007 through his Counsel by way of
Regd Post with Ack. Due as well as UCP, to his Residence. The
Defendant received the same on 25th January 2007, neither
paid the amount nor did he respond to the notice. On 10 th
February, 2007. MOHIT SHARMA filed a suit for the recovery of
the debt but did not reply.
 
3.The Plaintiff submits that the Defendant having borrowed
the amount of Rs.25,000/- (Rupees Twenty Five Thousand
only) as hand loan and having executed the promissory not is
bound to repay the same to the Plaintiff who is entitled for
interest on the suit amount from the date of demand i.e.
1st January, 2007 till realization @ 18% p.a. As the Defendant is
avoiding payment, the Plaintiff has left with no option except
to approach this Hon’ble Court by way of this suit. In view of
the above said facts, the Plaintiff is entitled to sue the
defendant.
 
4.The Plaintiff submits that The Defendant is liable to pay the
following outstanding amount:
 
(i) Promissory Note Amount                                : 25,000.00
(ii) Interest on 25,000 @ 18% p.a. From 
01.01.2005 as on date filing of the suit          :    9,000.00
                                                                              ---------------
                                                                                  34,000.00
                                                                               ----------------
 Therefore, the Defendant has to pay a total sum of
Rs.34,000/- (Rupees Thirty Four Thousands Only) to the
Plaintiff as on the date of filing of the present suit. Hence, this
suit.
 
IV. CAUSE OF ACTION : The cause of action for the suit arose
on 01.01.2005 when the Defendant borrowed the amount and
executed pro-note and on 01.01.2007 when the Plaintiff got
issued a legal notice to Defendant calling upon defendant to
repay the amount and still subsists.
 
V. VALUATION: The relief of recovery of money is paid thereon
and the same is sufficient.
 
VI. JURISDICTION: The Plaintiff is residing at Hyderabad and the
Defendant borrowed the said loan amount from the Plaintiff at
the residence of the Plaintiff and hence this Hon’ble Court is
having territorial & pecuniary Jurisdictions to entertain the
present suit.
 
VII. DECLARATION : The Plaintiff has not filed any suit against
the Defendant and no suit is pending between the parties in
respect of the relief being claimed in this suit. 
 
VIII. LIMITATION : The Defendant borrowed the said hand loan
amount on 01.01.2005 and the legal notice issued to the
Defendant on 01.01.2007 and therefore the present suit is
within the limitation.   
 
IX. PRAYER : 

It is therefore, prayed that the hon’ble court may be pleaded

to pass a judgement or decree against the defendant and in
favor of the plaintiff
 
(a) To direct the Defendant to pay a sum of Rs. 34,000/-
together with future interest thereon, from the date of this
suit, till the date of realization of the entire suit claim

(b)To award the costs of this suit;

 
and to pass such other order or orders as this Hon’ble Court
may deem fit and proper in the circumstances of the case in
the interest of Justice.
 

PLACE: PLAINTIFF
.……………….
DATE: COUNSEL FOR THE PLAINTIFF
……………………………………

VERIFICATION
I, Mr. MOHIT SHARMA, S/o. LAKHAN SHARMA, Age 45 years,
Occ: Business, R/o. D.No. 247, Netaji Road, Hyderabad do
hereby declare that the contents of Para III are true and
correct to the best of our knowledge and believed to be true
and correct, and the rest of the paras are on the basis of
information and legal advice and verified and signed by me on
10th February 2007 at the Court of the Additional Junior Civil
Judge: City Civil Court Compounded at Hyderabad.                                              
PLACE: PLAINTIFF
……………..
DATE: PLEADER
……………..

LIST OF DOCUMENTS FILED BY PLAINTIFFS

S.NO. DATES PARTIES DESCRIPTION P.NO.

1. 01.01.2005 Defendant Promissory Note in
& Plaintiff Original
2. 01.01.2007 Defendant Office Copy of the
& Plaintiff Legal Notice
3. 01.01.2007 Defendant Proof of sending
& Plaintiff Legal Notice and
Acknowledgements
in receipt of the
Notice served on
the Defendant.

PLAINTIFF
…………………….
AFFIDAVIT

IN THE COURT OF ADDITIONAL JUNIOR CIVIL JUDGE: CITY CIVIL

COURT AT HYDERABAD
 IN THE MATTER OF MOHIT SHARMA
Vs.
SUDHIR KUMAR
SUIT NO…………………..…....of Year 2007
SUIT FOR RECOVERY OF MONEY
AFFIDAVIT ON BEHALF OF PLAINTIFF

I, MOHIT SHARMA, S/o LAKHAN SHARMA, Aged 45 years, Occ:

Local Shopkeeper R/o. D.No. 247, Netaji Road, Hyderabad  at
present residing at this given address, do hereby solemnly
declare and affirm on oath as under:

1. It is submitted that the Defendant having an acquaintance

with the plaintiff approached him and requested to advance a
hand loan of Rs.25,000/- (Rupees twenty five thousand Rupees
only) to meet his son’s education needs. The Defendant also
proposed to execute a Promissory Note for the said amount
and with a simple interest @ 18% p.a. Due to that
acquaintance, the Plaintiff agreed for the same and thus, the
defendant has borrowed a sum of Rs.25,000/- as hand loan on
1st January, 2005 from the Plaintiff at the Plaintiff’s home
situated at Hyderabad and executed a Promissory Note for the
said amount in favor of the Plaintiff and promised to repay the
said hand loan within a period of 2 years from the date of
execution of the promissory note. It is respectfully submitted
that in spite of repeated oral demands made by the Plaintiff,
the Defendant did not bother to repay the said hand Loan
amount.
2.The Plaintiff having vexed with the conduct of the Defendant
avoiding the repayment, got issued a legal notice to the
Defendant on 1st January, 2007 through his Counsel by way of
Regd Post with Ack. Due as well as UCP, to his Residence. The
Defendant received the same on 25th January 2007, neither
paid the amount nor did he respond to the notice. On 10 th
February, 2007. MOHIT SHARMA filed a suit for the recovery of
the debt but did not reply.
 
3.The Plaintiff submits that the Defendant having borrowed
the amount of Rs.25,000/- (Rupees Twenty Five Thousand
only) as hand loan and having executed the promissory note is
bound to repay the same to the Plaintiff who is entitled for
interest on the suit amount from the date of demand i.e.
1st January, 2007 till realization @ 18% p.a. As the Defendant is
avoiding payment, the Plaintiff has left with no option except
to approach this Hon’ble Court by way of this suit. In view of
the above said facts, the Plaintiff is entitled to sue the
defendant.

I, do hereby affirm that the contents of para 1,2,3 are correct

to my knowledge and belief. Nothing has been concealed
therein.

PLACE: DEPONENT
DATE: ……………………

WRITTEN STATEMENT

IN THE COURT OF THE III ADDITIONAL JUNIOR CIVIL JUDGE :

 CITY CIVIL COURT : AT HYDERABAD.
 O.S. No.                 of   2007

Mr.MOHIT SHARMA, 
S/o LAKHAN SHARMA, Aged 45 years,
Occ: Local Shopkeeper    
R/o. D.No. 247, Netaji Road,
Hyderabad  ………………………..Plaintiff
 
Vs.
 
Mr.SUDHIR KUMAR, 
S/o NAITIK KUMAR, Aged 47 Years,
Occ: Worker
R/o. D.No. 249, Netaji Road,
Hyderabad.                                       ……………………..…Defendant
 

WRITTEN STATEMENT FILED BY THE DEFENDANT

UNDER ORDER VIII, RL.1, C.P.C.
 
1) It is submitted that the defendant has gone through the
averments made in the plaint and affidavit filed in support of the
plaint. The averments, which are not specifically admitted, are
denied. The Plaintiff is put to strict proof of the same. Most of
the averments are not correct and false and the suit is not
maintainable.
 
2) In reply to Para III (1) of the plaint, it is submitted that I have
no acquaintance with the plaintiff and did not approach at any
point of time for hand loan to meet my son’s education and
executed promissory note in favor of the plaintiff. I have
sufficient means to support my family. Hence, there is no
question of taking hand loan from the plaintiff and execution of
promissory note in favor of the plaintiff.
 
3) In reply to para III (2) of the plaint, it is submitted that the notice
issued by the plaintiff was received by me on 15.01.2007. The
contents of the notice are vague and false. Since I did not approach
the plaintiff for any hand loan and executed promissory note, I did
not choose to reply the notice. Hence, the allegations in the notice
are denied.
 
4) In reply to para III (3) of the plaint, it is submitted that I did not
borrow any amount from the plaintiff and executed promissory
note in favor of him. The allegation of the plaintiff is false and I
need not bound to pay any amount to the plaintiff. It is not correct
to say that I have borrowed a sum of Rs.25,000/- from the plaintiff
and executed a promissory note in favor of him.
 
5) In reply to Para III (4) of the plaint, it is submitted that since there
is no amount is borrowed from the plaintiff and executed pro-note,
the figures of outstanding stated in para therein is false and
fabricated one.
 
6) It is submitted that I have never approached the plaintiff for any
amount said to have been borrowed by me and executed pro-note.
Since we reside in the same street and due to rivalry between our
two families regarding some disputes relating to colony problems,
the plaintiff has fabricated the pro-note and filed the present suit
alleging that I have borrowed a sum of Rs.25,000/- from plaintiff
and executed a pro-note.

The plaintiff is trying to mislead this Hon’ble Court and made false
allegations in the plaint.
 
7) The other allegations of the plaint which are not specifically
admitted herein are denied. The plaintiff is put to strict proof of the
same.
 
Hence, it is prayed that this Hon’ble Court may be pleased to
dismiss the suit with costs.
 

PLACE: DEFENDANT
………………………..

COUNSEL FOR THE DEFENDENT

DATE: ……………………………………
 

Verification
 
I, SUDHIR KUMAR, S/o NAITIK KUMAR, Aged 47 Years, Occ:
Worker, R/o. D. No. 249, Netaji Road, Hyderabad, Occ:
Employee, do hereby declare that the facts stated in paras 1 to 7
are true and correct to the best of my knowledge, information
and belief and I believe the same to be true and correct. Hence,
verified on this the     day of June, 2007 at Hyderabad.
 

PLACE: DEFENDANT
………………………..

COUNSEL FOR THE DEFENDENT

DATE: ………………………………………
 

AFFIDAVIT
IN THE COURT OF ADDITIONAL JUNIOR CIVIL JUDGE: CITY CIVIL
COURT AT HYDERABAD
 IN THE MATTER OF MOHIT SHARMA
Vs.
SUDHIR KUMAR
SUIT NO…………………..…....of Year 2007
SUIT FOR RECOVERY OF MONEY
AFFIDAVIT ON BEHALF OF PLAINTIFF

I, Mr.SUDHIR KUMAR, S/o NAITIK KUMAR, Aged 47 Years,Occ:

Employee, R/o. D.No. 249 , Netaji Road, Hyderabad  at present
residing at this given address, do hereby solemnly declare and
affirm on oath as under:

1) It is submitted that the defendant has gone through the

averments made in the plaint and affidavit filed in support of the
plaint. The averments, which are not specifically admitted, are
denied. The Plaintiff is put to strict proof of the same. Most of
the averments are not correct and false and the suit is not
maintainable.
 
2) In reply to Para III (1) of the plaint, it is submitted that I have
no acquaintance with the plaintiff and did not approach at any
point of time for hand loan to meet my son’s education and
executed promissory note in favor of the plaintiff. I have
sufficient means to support my family. Hence, there is no
question of taking hand loan from the plaintiff and execution of
promissory note in favor of the plaintiff.
 
3) In reply to para III (2) of the plaint, it is submitted that the notice
issued by the plaintiff was received by me on 15.01.2007. The
contents of the notice are vague and false. Since I did not approach
the plaintiff for any hand loan and executed promissory note, I did
not choose to reply the notice. Hence, the allegations in the notice
are denied.
 
4) In reply to para III (3) of the plaint, it is submitted that I did not
borrow any amount from the plaintiff and executed promissory
note in favor of him. The allegation of the plaintiff is false and I
need not bound to pay any amount to the plaintiff. It is not correct
to say that I have borrowed a sum of Rs.25,000/- from the plaintiff
and executed a promissory note in favor of him.
 
5) In reply to Para III (4) of the plaint, it is submitted that since there
is no amount is borrowed from the plaintiff and executed pro-note,
the figures of outstanding stated in para therein is false and
fabricated one.
 
6) It is submitted that I have never approached the plaintiff for any
amount said to have been borrowed by me and executed pro-note.
Since we reside in the same street and due to rivalry between our
two families regarding some disputes relating to colony problems,
the plaintiff has fabricated the pro-note and filed the present suit
alleging that I have borrowed a sum of Rs.25,000/- from plaintiff
and executed a pro-note. The plaintiff is trying to mislead this
Hon’ble Court and made false allegations in the plaint.
 
7) The other allegations of the plaint which are not specifically
admitted herein are denied. The plaintiff is put to strict proof of the
same.
 
Hence, it is prayed that this Hon’ble Court may be pleased to
dismiss the suit with costs.
 
I, do hereby affirm that the contents of para 1,2,3,4,5,6,7 are
correct to my knowledgement and belief. Nothing has been
concealed therein.

PLACE: DEPONENT
DATE: ………………
EXERCISE-2
INTERLOCUTORY APPLICATION

IN THE COURT OF JUNIOR CIVIL JUDGE, TIRUPATI

 I.A. No. of 2013 O.S. No. of 2013

Mr.MOHIT SHARMA, 
S/o LAKHAN SHARMA, Aged 45 years,
Occ: Local Shopkeeper    
R/o. D.No. 247, Netaji Road,
Tirupati ………………………..Plaintiff
 
Vs.
 
Mr.SUDHIR KUMAR, 
S/o NAITIK KUMAR, Aged 47 Years,
Occ: Worker
R/o. D.No. 249, Netaji Road,
Tirupati                                      ……………………..…Defendant
 

Application filed on behalf of the plaintiff under 0rder XXX VII

Rule 5 of C.PC.

Respected Sir/Madam,

The Applicant humbly states as under:

1. It is submitted that the Defendant having an acquaintance

with the plaintiff approached him and requested to advance a
hand loan of Rs.25,000/- (Rupees twenty five thousand Rupees
only) to meet his son’s education needs. The Defendant also
proposed to execute a Promissory Note for the said amount
and with a simple interest @ 18% p.a. Due to that
acquaintance, the Plaintiff agreed for the same and thus, the
defendant has borrowed a sum of Rs.25,000/- as hand loan on
1st January, 2005 from the Plaintiff at the Plaintiff’s home
situated at Hyderabad and executed a Promissory Note for the
said amount in favor of the Plaintiff and promised to repay the
said hand loan within a period of 2 years from the date of
execution of the promissory note. It is respectfully submitted
that in spite of repeated oral demands made by the Plaintiff,
the Defendant did not bother to repay the said hand Loan
amount.
 
2.The Plaintiff having vexed with the conduct of the Defendant
avoiding the repayment, got issued a legal notice to the
Defendant on 1st January, 2007 through his Counsel by way of
Regd Post with Ack. Due as well as UCP, to his Residence. The
Defendant received the same on 25th January 2007, neither
paid the amount nor did he respond to the notice. On 10 th
February, 2007. MOHIT SHARMA filed a suit for the recovery of
the debt but did not reply.
 
3.The Plaintiff submits that the Defendant having borrowed
the amount of Rs.25,000/- (Rupees Twenty Five Thousand
only) as hand loan and having executed the promissory not is
bound to repay the same to the Plaintiff who is entitled for
interest on the suit amount from the date of demand i.e.
1st January, 2007 till realization @ 18% p.a. As the Defendant is
avoiding payment, the Plaintiff has left with no option except
to approach this Hon’ble Court by way of this suit. In view of
the above said facts, the Plaintiff is entitled to sue the
defendant.

4. Not only this, it is prayed that, the honourable court may be

pleased to direct that the property described in the schedule
below be attached before judgement passing such further or
other orders as circumstances of the case.
SCHEDULE

5. In Chittoor District, Sri Balaji Registration District, Tirupati

sub district Tirupati town within Tirupati Municipality in ward
No. 8, Town Survey [T.S.] No: 1447, where in D.No. 249, Bazaar
Street a house with R.C.C. Roof with all doors, door frames, all
fittings are with electric service connection measuring 25 feet
east, west and 40 feet north, south and bounded on the east
by the house of T. Rama Lakshmi on the south by Nalinibhai
lane on the west by the house of Bazaar Street.

PLACE: APPLICANT

DATE: ……………………

COUNSEL FOR APPLICANT

…………………………

AFFIDAVIT

IN THE COURT OF JUNIOR CIVIL JUDGE, TIRUPATI

I.A. No. of 2013 O.S. No. of 2013

Mr.MOHIT SHARMA, 
S/o LAKHAN SHARMA, Aged 45 years,
Occ: Local Shopkeeper    
R/o. D.No. 247, Netaji Road,
Tirupati ………………………..Plaintiff
 
Vs.
 
Mr.SUDHIR KUMAR, 
S/o NAITIK KUMAR, Aged 47 Years,
Occ: Worker
R/o. D.No. 249, Netaji Road,
Tirupati                                       ……………………..…Defendant
 
APPLICATION FOR ATTACHMENT OF PROPERTY
AFFIDAVIT ON BEHALF OF PLAINTIFF

I, MOHIT SHARMA, S/o LAKHAN SHARMA, Aged 45 years,Occ:

Local Shopkeeper, R/o. D.No. 247, Netaji Road, Tirupati at
present residing at this given address, do hereby solemnly
declare and affirm on oath as under:
 

1. It is submitted that the Defendant having an acquaintance

with the plaintiff approached him and requested to advance a
hand loan of Rs.25,000/- (Rupees twenty five thousand Rupees
only) to meet his son’s education needs. The Defendant also
proposed to execute a Promissory Note for the said amount
and with a simple interest @ 18% p.a. Due to that
acquaintance, the Plaintiff agreed for the same and thus, the
defendant has borrowed a sum of Rs.25,000/- as hand loan on
1st January, 2005 from the Plaintiff at the Plaintiff’s home
situated at Hyderabad and executed a Promissory Note for the
said amount in favor of the Plaintiff and promised to repay the
said hand loan within a period of 2 years from the date of
execution of the promissory note. It is respectfully submitted
that in spite of repeated oral demands made by the Plaintiff,
the Defendant did not bother to repay the said hand Loan
amount.
 
2.The Plaintiff having vexed with the conduct of the Defendant
avoiding the repayment, got issued a legal notice to the
Defendant on 1st January, 2007 through his Counsel by way of
Regd Post with Ack. Due as well as UCP, to his Residence. The
Defendant received the same on 25th January 2007, neither
paid the amount nor did he respond to the notice. On 10 th
February, 2007. MOHIT SHARMA filed a suit for the recovery of
the debt but did not reply.
 
3.The Plaintiff submits that the Defendant having borrowed
the amount of Rs.25,000/- (Rupees Twenty Five Thousand
only) as hand loan and having executed the promissory not is
bound to repay the same to the Plaintiff who is entitled for
interest on the suit amount from the date of demand i.e.
1st January, 2007 till realization @ 18% p.a. As the Defendant is
avoiding payment, the Plaintiff has left with no option except
to approach this Hon’ble Court by way of this suit. In view of
the above said facts, the Plaintiff is entitled to sue the
defendant.

4. Not only this, it is prayed that, the honourable court may be

pleased to direct that the property described in the schedule
below be attached before judgement passing such further or
other orders as circumstances of the case.

SCHEDULE
5. In Chittoor District, Sri Balaji Registration District, Tirupati
sub district Tirupati town within Tirupati Municipality in ward
No. 8, Town Survey [T.S.] No: 1447, where in D.No. 249, Bazaar
Street a house with R.C.C. Roof with all doors, door frames, all
fittings are with electric service connection measuring 25 feet
east, west and 40 feet north, south and bounded on the east
by the house of T. Rama Lakshmi on the south by Nalinibhai
lane on the west by the house of Bazaar Street.

I, do hereby affirm that the contents of para 1,2,3,4,5 are

correct to my knowledge and belief. Nothing has been
concealed therein.

PLACE: DEPONENT
…………………..

DATE:

EXERCISE-3
ORIGINAL PETITION

In the Family Court Judge, Tirupati

MARRIAGE O.P. No. 17/2011
Smt.KAMLADEVI, Aged 45 years,    
R/o. D.No. 247, Netaji Road,
Tirupati ………………………..Plaintiff
 
Vs.
 
Mr.RAMESH KUMAR
S/o NAITIK KUMAR, Aged 47 Years,
Occ: Worker
R/o. D.No. 249, Netaji Road,
Tirupati                                       ……………………..…Defendant

Petition filed on behalf of the petitioner under section 10

Hindu Marriage Act.

Name of the Petitioner:

Smt. KAMLADEVI, W/o S. RAMESH KUMAR, Hindu aged about

30 years house wife residing at 17-6-93, Brahmin Street,
Tirupati.

The address of the petitioner for the service of notice etc. is as

stated above and also care of her counsel. Smt. V. Geetha,
Advocate, Tirupati.

Name of the Respondent: S. RAMESH KUMAR, S/o. Raja

Reddy, Hindu aged about 32 years, Doctor by Profession,
residing at 8-3-97, G.S. Mada Street, Tirupati.

The address of the respondent for the service of notices etc. is

as stated.

1.The petitioner submits that she is legally married wife of the

respondent. This marriage was celebrated in the year 2008 at
Tirupati. At the time of marriage the petitioner‟s parent‟s gave
25 thulas 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 Reddy & Reddy colony and gained good
reputation and were happy for 2 years i.e., since 2011 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 Appolo Hospital, Madras, 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 infront 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 enjoys her
screamings. Sometimes he gaged her mouth with cloth and
subject her to physical cruelty.

5.The petitioner further submits that on 10.02.2011 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 neighbor and her mother-in-law came there and saved
her from the clutches of the respondent than on 11.02.2011
she 14 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 01.02.2003 the date of marriage and also 10.02.2011
when she frightened of her life ran away to her parents house
continues de divindum with the jurisdiction of this
hounourable court.

7.The value of the petition for the purpose of court fee is of Rs.
…….. Net and fixed court fee of Rs. 10/- paid V/Sec of A.P.C.F. &
S.V. Act.

8.The petitioner submits that no similar petitioner has been

filled so far before any court.

Prayer

The petitioner therefore prays that the honourable court may

be pleased to pass an order and decree.

(a) Declare that the marriage has been dissolved by judicial

separation.

(b) Direct the respondent to pay cost of the petition. And pass
such others and further orders as it deem fit and proper in the
circumstances of the case.
PLACE: PETITIONER

…………………

DATE: Advocate for petitioner Petitioner

……………………………..

VERIFICATION

I, the petitioner do here by declare that the facts state above

are true and correct to the best of my knowledge and belief
and signed this verification on this the 25.02.2011 at Tirupati.

LIST OF DOCUMENTS

1) 01.02.2008 marriage invitation card.

2) Doctor prescription with wound certificate.

PLACE: PETITIONER

…………………

DATE Advocate for petitioner Petitioner

…………………………

EXERCISE-4
Execution Petition

In the Court of Civil Judge, Junior Division, Varanasi

 Execution Application No........2012
In the matter of Suit No.......2011

X, son of A aged about 49

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

Versus

Y, son of B aged about 45

R/o 8/230, Kubernagar, Varanasi .....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....2011 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- 2010 the plaintiff gave the notice of eviction

to the respondent 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- 2010.
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 .......2011

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 Kubernagar,
Varanasi

3. Date of Decree 18/11/2010

4. Whether appeal preferred against No

5. Any part of decreetal amount or

adjustment set off None

6. Previous Application if any None

7. Amount with interest due upon

(a)Possession of house
(b)-decree or other relief 8/230 Kubernagar Colony

8. Against whom to be executed against defendant

9. Mode in which the assistance of

(a) by deliver of possession

the court is required of B-8/230 Kubernagar
Colony, Varanasi

(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

I, ………………… pray that the total amount of Rs.77000 together

with interest at 10% per annum up to the date of payment and
the cost of taking of this execution, be released by the
attachment and sell of the given property of the defendant as
per annexed list and paid to me.

PLACE………… DECREE HOLDER

………………………..

DATE………….. THROUGH COUNSEL

………………………….

I, do hereby verify that the contents of this execution

application are true and correct to my knowledge and belief.
Nothing has been concealed therein.

PLACE…………… DECREE HOLDER

………………………..
DATE…………….. THROUGH COUNSEL

………………………

Affidavit in Support of Execution Petition

In the Court of Civil Judge, Junior Division, Varanasi
Execution Application No........2012
In the matter of Suit No.......2011
 X, son of A aged about 49
R/o 1017, Civil Lines, Varanasi .......Plaintiff

Versus

Y, son of B aged about 45

R/o 8/230, Kubernagar, Varanasi .....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- 13/32012 X
Place- Varanasi Plaintiff/ Decree Holder
XXXXXXXX

EXERCISE-5
Memorandum of Appeal
 In the High Court of Madhya Pradesh, Indore
Civil Appeal No. ... / 2009
Under Section 96 of CPC, 1908.

A. B. s/o B. C.
123, A B Road, Indore, MP                            ..................................
.......  Plaintiff/Appellant
Vs.
M. N. s/o O. P.
456, A B Road, Indore, MP                            
.........................................Defendant/Respondent

Memorandum of Appeal

The aforementioned plaintiff-appellant appeals against the

judgement and decree of the Court of Civil Judge Class II, at
Indore, passed in Original Suit No 1234 of 2009 between A. B
s/o B. C vs M.N s/o O. P., dated 10/10/2009.

TO,
The Hon’ble Chief Justice and Companion and other respected
Judges of the High Court,
The Appellant most respectfully submits that:

(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 alongwith.

(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.

(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 favor of plaintiff-appellant.

Any other order which may be deemed fit in the interest of the
justice may be passed in favor of the appellant.

PLACE: APPELLANT
………………..
DATE: ADVOCATE FOR THE APPELLANT
……………………………………….

Verification
 I, ______, 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 Indore this 4th Day of
September 2009.

PLACE: APPELLANT
………………..
DATE: ADVOCATE FOR THE APPELLANT
……………………………………….

EXERCISE-6-REVISION PETITION
 APPLICATION FOR REVISION
SECTION 115, C.P.C

In the High Court of Judicature, Allahabad,

Civil Appeal No. ... / 2009
Under Section 96 of CPC, 1908.

A. B. s/o B. C.
123, A B Road, Indore, MP                            ...............................
..........  Petitioner
Vs.
M. N. s/o O. P.
456, A B Road, Indore, MP                            
.........................................
Defendant/Respondent

Respected Sir/Madam,
The petitioner above mentioned
submits this Petition for revision U/Sec 115, C.P.C. against the
decree of the District Judge at Chittoor dated 15.02.2010
reversing the decree of the Civil Judge of Chittoor, dated the
25.07.2009, passed in Suit No: 315 of 1996 valued At
Rs.52,000/-.

To,
The Chief Justice or his/her companion of the High Court above
stated,
The Petitioner above mentioned submits as follows that:
The revision application of the petitioner against order
dated…………in year….., suit no………of year……. In the court
of……………..,District, between the parties stated above in
which the petitioner is the defendant preferred on the
following amongst other grounds of revision under the
statement of the case in brief as follows:

(1) That the applicant was the plaintiff in the aforesaid suit
which had been brought U/Sec 9 of the specific Relief Act.

(2) That the suit was decreed by the Munsif, but the District
Judge on appeal has reversed the Munisifs decree.

(3) That U/ the law no appeal lay to the District Judge from the
Munsifs Decree, and the District Judge from therefore
exercised a Jurisdiction which was not vested in him by law.

PRAYER

Therefore, the applicant prays that this Honourable Court will

call for the record of the case and set aside the said decree of
the District Judge and restore that of the Munsif and award
him cost in all courts.

Any other order which may be deemed fit in the interest of

justice may be passed in favor of the petitioner.

PLACE: PETITIONER
……………….
DATE COUNSEL/ADVOCATE
…………………………….
 EXERCISE-7
Writ Petition under Article 226

IN THE HIGH COURT OF MADHYA PRADESH

PRINCIPAL SEAT AT JABALPUR / BENCH AT INDORE /BENCH
AT GWALIOR
Writ Petition No. ………… / 20…….
Cause Title
Petitioner : The name, age, father/husband’s name,
occupation
and complete address and fax number with S.T.D.
Code and e-mail address, if any;
Vs.
Respondent : The name, age, father/husband’s name,
occupation,
and complete address and fax number with S.T.D.
Code and e-mail address, if any;

(Writ Petition under Article 226 of the Constitution of India)

To,
The Chief Justice or his/her companion of the High Court above
stated,
The Petitioner above mentioned submits as follows that:

1. Particulars of the cause/order against which the petition is

made:
(1) Date of Order / Notification / Circular / Policy / Decision
etc : N. A.

(2) Passed in (Case or File Number) :  N. A.

(3) Passed by (Name and designation of the Court, Authority,

Tribunal etc.) :  N. A.
(4) Subject-matter in brief : The petitioners are final year law
students pursuing LLB (3 Year Degree Course, Semester
System) from Govt. Law College, Indore, which is affiliated to
Devi Ahiliya Vishwa Vidyalaya (referred hereinafter as DAVV in
brief) and they intend to pursue LLM in academic session
2009-2010. They also intend to appear in Civil Judge Class II
Examination, which is being conducted by Honourable High
Court of M. P. in September 2009.
This petition is filed by the petitioners challenging -
a.    the inaction of DAVV and its inordinate delay in conducting
LLB 6th semester exam, which was to be held in May 2009 and
the result of which was to be declared in June 2009.
b.    the arbitrary and illegal award of marks in one practical
subject named “Moot Court, Pre-trial Preparation and
Participation in Trial Proceedings”.
As these actions are preventing the petitioners from – 
a.    pursuing LLM in the academic session 2009-2010
b.    appearing in Civil Judges Class II Examination to be
conducted by Honourable High Court of M. P. in September
2009.
2. A declaration that no matter pending: Petitioners declare
that no matter relating to the subject matter of this petition
has been previously instituted or is pending in any Court,
authority or tribunal at the instance of the petitioners.

3. Details of remedies exhausted: Petitioners have given

written representation to Registrar, DAVV as well as to Vice
Chancellor, DAVV on 03/06/2009. They have also personally
met with the Registrar as well as the Vice Chancellor seeking
redressal to their grievances. However, no attempt has been
made to safeguard the future of the petitioners and other
similarly placed students.

4. Delay, if any, in filing the petition: Petitioners declare that

there is no delay in filing of this petition. 

5. Facts of the case: (Give a concise statement of facts in

chronological order in separate paragraphs)

6. Grounds urged :

6.1    Because the petitioners future is at stake as they are

unable to take admissions in other colleges and universities of
India for LLM courses due to late conduction of examinations.
Complete one year of petitioners is being wasted because of
this inaction and irresponsible attitude of Respondent No. 1.

6.2    Because even School of Law Respondent No. 3, which is

run by DAVV, is not allowing the petitioners to appear in their
entrance exam for LLM.

6.3    Because due to low marks awarded to the petitioners in

the practical subject, they have been rendered uncompetitive
to secure admission in LLM courses in colleges affiliated to
DAVV on the basis of merit. The low marks awarded in the
practical subject also look bad on the petitioners’ resume and
adversely affect the petitioners’ chances of securing a job or
other career related activities.

6.4    Because the Petitioners are unable to appear in Civil

Judge Class II examination which is being conducted in
September 2009 for no fault of theirs.

6.5    Because petitioners are being denied their fundamental

right to work due to delay in obtaining Sanad.
6.6    Because it is a duty of DAVV to conduct exams fairly and
on time, which it has failed to do.
6.7    Because it is a duty of Respondent No. 2, to evaluate the
students fairly in Practical subjects, which it has failed to
perform.
7. Relief Prayed for: Petitioners pray that this Honourable
Court may be pleased to:
7.1    By issuing a writ of mandamus or any other appropriate
write, order, or direction, direct the Respondent No 1 and 2 to
conduct the exams of 6th semester of LLB course and declare
the result without further delay.
7.2    Respondent No. 3, be directed to permit the petitioners
to appear for their entrance examination for LLM and be given
provisional admission if they are successful in the entrance
examination.
7.3    Respondent No 1 and 2 be directed to either – 
a.    Ignore the marks in this subject for calculation of
aggregate percentage for LLB Degree. It is worth mentioning
that that DAVV already does ignore the marks for Paper 5 of
Semester 5, which is also a practical subject.
b.    Rationalise the marks given in the practical subject of
“Moot Court, Pretrial Preparation, and Participation in Trial
Proceedings”.

7.4    Cost of this petition be awarded to the petitioners.

7.5    Any other relief, which this Honourable Court deems fit in
the peculiar facts and circumstances of the case.

8. Interim Relief: The petitioners pray that Respondents 1 and

2 be directed to conduct LLB 6th semester exam and declare
the result without any further delay.

9. Documents relied on but not in possession of the petitioner:

9.1    List of marks obtained by students of all Law colleges

affiliated to DAVV in the practical subject of “Moot Court,
Pretrial Preparation, and Participation in Trial Proceedings”
in March 2009.

9.2    Submissions of students who scored above 80 marks or

below 60 marks of Respondent No. 2, as well as other colleges
affiliated to DAVV made towards the subject of Moot Court
(Paper 4 of 5th semester).

10. Caveat: That no notice of lodging a caveat by the

respondents has been received by the petitioners.

PLACE: PETITIONER
………………..
DATE: ADVOCATE FOR THE PETITIONER
………………………………………

Verification
 I, ______, do hereby verify that the contents from paras 1 to
10 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 Indore this 4th Day of
September 2009.

PLACE: PETITIONER
………………..
DATE: ADVOCATE FOR THE PETITIONER
……………………………………….
 EXERCISE-8

Writ Petition under Article 32

IN THE HON’BLE SUPREME COURT OF INDIA, NEW DELHI

(Original Criminal Jurisdiction)

Writ Petition No_________of _________20 _________

A _________ aged about _________ son of

__________________., resident _________
Petitioner;

Versus

1. Additional Secretary, Ministry of Finance,

Government of_________.
2. The Superintendent, _________ Jail _________
3. The State of_________ Respondents.

PETITION FOR THE ISSUE OF WRIT OF HABEAS CORPUS

UNDER ARTICLE 32 OF THE CONSTITUTION OF INDIA

To 
The Hon’ble the Chief Justice and his companion Judges of the
Court aforesaid, the humble petition of the above named
Petitioner most respectfully sheweth: 

1. That the petitioner is a resident of _________. and he was

living peacefully at his residence at the place aforesaid. 

2. That on _________. Respondent No. 1 made an order under

Section 3 of the Conservation of Foreign Exchange and
Prevention of Smuggling Activities Act, 1974 by which he
directed that the Petitioner shall be arrested and detained for
a period of three months. A copy of the order is annexed
herewith as Annexure ‘‘A’’.
3. That the Petitioner was arrested the same day and was
detained in _________Jail. The grounds of detention were not
supplied to the petitioner on that day. The grounds were
actually supplied on_________. A copy of the grounds supplied
is annexed herewith as Annexure ‘‘B’’. 

4. That on _________. the Petitioner submitted a

representation against his detention through Respondent No.
2 but the same was considered by the Advisory Board after
one month and was rejected on _________. . . . 
5. That the grounds of detention supplied to the Petitioner
were in English which language the Petitioner does not know. 
6. That the orders of detention of the Petitioner are illegal,
improper and without jurisdiction on the following: 

GROUNDS
1. Because the Conservation of Foreign Exchange and
Prevention of Smuggling Activities Act, 1974, is
unconstitutional and void as it is beyond the legislative
competence of Parliament. 
2. Because the order has been passed by an officer not duly
authorised. 

3. Because the grounds were supplied after undue delay. 

4. Because the grounds are in English which language the
Petitioner does not know and this has prevented him from
making an effective representation. 

5. Because the grounds are irrelevant to the object of the Act. 

6. Because the grounds are vague. 

7. Because there was undue delay in the disposal of the

representation submitted by the petitioner. Wherefore it is
respectfully prayed that this Hon’ble Court may be pleased to
issue a writ in the nature of Habeas Corpus to the opposite
parties quashing the order of detention and directing that the
Petitioner be set at liberty forthwith. 

PLACE: PLAINTIFF
………………..
DATE:
 CRIMINAL PLEADING
EXERCISE-9 CRIMINAL COMPLAINT

IN THE COURT OF THE JUDICIAL FIRST CLASS MAGISTRATE,

VARANASI, C.C.

NO. 13 OF 2012

Miss. KAJAL, D/o. SHIV PRASAD, Hindu, Student, aged about 21

year studying in III Year
Batch, B.Tech., S.V. Engg, College, Varanasi,
Residing at S.V. Women Hostel, Varanasi,
Permanent residing of 43/790, K.S. Road, Rajampet, Kadapa
District
Within jurisdiction of East Police Station, Varanasi.

……... Complainant

Vs.

Mr. J. Siva Reddy, S/o. Narsimha Reddy, Hindu, aged about 26

years 4th Year, B.Tech
student, residing at Men‟s Hostel, S.V. Engg. College,
permanent address 7/90, T. Nagar,
Rajampet, Kadapa District, within Jurisdiction of East Police
Station, Varanasi.

…….. Accused.
 COMPLAINT FILED ON BEHALF OF THE COMPLAINANT
U/Sec 200 Cr. P.C.

(1) The complaint submits that she is studying III Year B.Tech.,
in S.V. Engineering College, Varanasi, she knew the accused
well.

(2) The complaint submits that the accused had been behind
her for last 6 months, but she never cared him. He wrote a
love letter to her and she admonished him, then one day he
pulled her upper saree in the class room and on her report he
suspended college for a month. This happened on 01.05.2012.

(3) The complainant submits that on 12.05.2012, she came to

Varanasi Bus Station along her friends Yogi, Anitha, Valli to bid
forewell to the hockey team of her college going to
Visakhapatnam in Tirumala Express. She came out of the
station and went to the Bus Station at about 8.00 pm along
with her friends, she found the accused near auto stand.

(4) The complaint submits that, while she was bargaining auto
the accused came there and abused her that, she was
responsible for his suspension from the college, tried to grab
her right hand. When she protested he immediately stabbed
on her left and right cheeks and also on her back with his fists,
she cried loudly and the auto rickshaw drivers and passengers
handed over him to police constable near the Bus Station. But
he did not take the accused to police station that it was a
noncognizable offence.

Hence thus complaint was made directly.The complaint

therefore prays that the honourable court may be pleased to
take cognizance of the offence U/sec 323 IPC and punish him
according to law
 xxxxxxxx xxxxxx
Advocate for complainant Complainant
 EXERCISE-10
CRIMINAL MISCELLENEOUS PETITION

In The Court of Second Addl. Judicial Magistrate,Tirupati

Criminal Misc. Petition No........2012
X, S/o A aged 30 years, Occupation- Business, R/o Lanka,
Tirupati.
.........Petitioner
Versus
Y, S/o B ages 35 years, Occupation- Business, R/o Seergate,
Tirupati.
............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 31.12.2011 against the
respondent seeking a sum of Rs. 500 per month to be
awarded.

(2) The Honourable Court, after due contest, by order dated

06.01.2012 granted maintenance to the petitioner directing
the respondent to pay a sum of Rs. 400 per month to the
petitioner from 01.01.2012 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 01.01.2011 to 31.03.2012 to Rs. 6000/-
(5) It is therefore prayed that the honourable court may be
pleased to commit the respondent to prison for such kind has
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 honble 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.

PLACE: PLAINTIFF
………………..
DATE: ADVOCATE FOR THE PLAINTIFF
……………………………………….

VERIFICATON

I, 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.

PLACE: PLAINTIFF
………………..
DATE: ADVOCATE FOR THE PLAINTIFF
……………………………………….
 EXERCISE-11
BAIL PETITION

IN THE COURT OF _________

Applicant

Versus

Respondents

FIR No. : _____ Dated _____ Police Station: _____ 

Offence Under Sections: _____ 
Application under Section 437 of CrPC for the grant of Bail

Respectfully Sheweth: 
1. That the applicant has been involved in a false and frivolous
case by one Sh. ____ by lodging a complaint with the SHOPS
____ on ____ for offence under sections __ of the IPC. The
applicant/accused has been arrested by the Police of Police
Station: ____ subsequent to the above complaint. 
2. That it is submitted that the allegations made against the
applicant/accused are false, frivolous and vexatious and lack in
the material substance. The applicant belongs to a very
reputed family in his locality. The allegations are that __ 
3. That the applicant/accused is a permanent resident of ____
and earning livelihood by _____. The applicant has his old
parents dependent upon him and the applicant is the only
bread earner for the family. 
4. That the applicant/accused is innocent and has been
involved falsely due to the personal grudge to settle the score
against the applicant/accused _____ OR due to enmity and
family feud. It is submitted that the complainant is an
influential and high-handed person.____ 
5. That by getting the applicant/accused arrested the applicant
has been deprived of his valuable fundamental right of liberty
by abuse of powers and process of law by the complainant.
____ 

6. 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. The applicant is also willing to join the
investigations and bind himself by the terms and conditions
laid down by the law or by this Honble court. It is further
submitted that the applicant is not at all required for the
investigations. However, if the applicant is required for
investigation, the applicant/accused undertakes to be present
as and when required in accordance with the law. 

7. That neither any recovery is to be effected from the

applicant nor the applicant is in a position to temper with the
prosecution evidence. The applicant will associate with the
investigation whenever required to do so.  It is, therefore,
most respectfully prayed that:- 

(a) That the applicant may be ordered to be released on bail

and this application for bail may kindly be allowed; 

(b) That till the decision of this application interim bail may be
granted to the applicant; 

(c) That the directions may be issued to the police to get the
applicant/accused medically examined at the immediately; 
(d) Such other orders be also passed in favour of the applicant
as deemed fit and proper in the facts and circumstances of the
case and in the interest of justice. 
PLACE: APPLICANT
………………..
DATE: ADVOCATE FOR THE APPLICANT
……………………………………….

Note:- 
1. This application is filed through the _____ father and next
friend of the applicant/accused, Sh. ____ . It is, therefore,
prayed that the application of the applicant/accused may
kindly be allowed and the applicant/accused may kindly be
released on interim bail in the interest of Justice. 

2. That the applicant/accused is under police custody.

Therefore, the requirement of affidavit and signature may
kindly be dispensed with. 

PLACE: APPLICANT
………………..
DATE: ADVOCATE FOR THE APPLICANT
……………………………………….
 AFFIDAVIT IN SUPPORT
IN THE COURT OF ___

Applicant

Versus

Respondent

Affidavit in support of the application under Section 437 of

CrPC

I, ______, 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 _____ 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 Coimbatore on ______. 
Deponent
 EXERCISE-13
ANTICIPATORY BAIL

IN THE COURT OF DISTRICT AND SESSIONS JUDGE, AT -- -- --

IN THE MATTER OF
STATE
VS
Police Station -- -- -- -- -- -- -- -- -- -- -- -- -- -
FIR NO. Yet to be filed
U/S Section 66A of ITA 2008 and other sections of IPC such as
295A,505,499

APPLICATION U/S 438 CRPC FOR GRANT OF ANTICIPATORY

BAIL ON BEHALF OF THE ACCUSED-- -- -- -- -- -- -- -- -- -- -- -- -- --

-- -- -- .
Respected Sir/Madam,
The applicant most respectfully submits as
follows:

1. That I, Sri/Smt ……………………… s/d/o ………………… residing

at……………………………………….. have posted the content as
indicated in annexure to this application

2. That based on the precedents of the actions initiated by

Police in different parts of the country in recent days and more
particularly in the cases of Government of Puducherry Vs Ravi
Srinivasan on the complaint made by one Sri Karti
Chidambaram and State of Maharashtra Vs MsShaheenDadha
on the complaint of one Sri BhushanSanke, there is a
reasonable probability of a false and bogus case being hoisted
on me with malafied intentions,
3. That I have no malicious intentions in making this post which
I have made as a free Citizen of India under the Freedom of
Expression guaranteed to me by the Constitution of India
under article 19(1)

4. That the police may falsely implicate the applicant in any

case, the applicant is a respectable citizen of the society and is
not involved any criminal
5. That the postings does not constitute any criminal offence
under any law in India.
6. That the applicant is not required in any kind of investigation
nor any kind of custodial interrogation is required.
7. That the applicant is having very good antecedents, he
belongs to good family and there is no criminal case pending
against them.
8. That the applicant is a permanent resident and there are no
chances of their absconding from the course of justice.
9. That the applicant undertakes to present himself before the
court as and when directed.
10. That the applicant undertakes to cooperate with the police
during the course of investigation.
11. That the applicant undertakes not to tamper with the
evidence or the witnesses in any manner. It is therefore prayed
that the court may direct that the applicant shall be released
on bail in the event of their 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
favor of the applicant.
PLACE: APPLICANT
………………..
DATE: ADVOCATE FOR THE APPLICANT
……………………………………….
 EXERCISE-14
CRIMINAL APPEAL

IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE AT

VARANASI
MohitRaghuvanshi, residing at Nacharam, Hyderabad ……..
Appellant

Vs.

The State of U.P. …. State

CRIMINAL APPEAL NO: 101 OF 2010

For the following among grounds the Appellant here in begs to

prefer this appeal against the judgement dated …………………..
of judicial Magistrate, F.C., Varanasi in criminal case No: 101 of
2010, 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/-

Respected Sir/Madam,
The appellant most respectfully submits
the appeal on the following groungs:

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.

PLACE: APPLICANT

……………………….

DATE: COUNSEL FOR THE APPLICANT

……………………………………
 EXERCISE-15
REVISION APPLICATION

IN THE HIGH COURT OF JUDICATURE AT HYDERABAD

CRIMINAL REVISIONAL JURISDICTION
In the matter of an application U/Sec. 439, Cr. P.C.
MohitRaghuvanshi, 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 30.01.2010 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.

Premchand Das, 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
30.01.2010 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 MukeshRao 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

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.

PLACE: APPELLANT

…………………….

DATE: COUNSEL FOR THE APPELLANT

……………………………………………