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Yusuf Application

The application is filed under Section 173(8) of CrPC seeking directions to investigate officer to add names of accused persons missing from chargesheet and relevant legal provisions related to forgery. It is submitted that names of certain accused actively involved in assault and vandalism are not included in chargesheet and relevant sections on forgery used by accused are not added.

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29 views5 pages

Yusuf Application

The application is filed under Section 173(8) of CrPC seeking directions to investigate officer to add names of accused persons missing from chargesheet and relevant legal provisions related to forgery. It is submitted that names of certain accused actively involved in assault and vandalism are not included in chargesheet and relevant sections on forgery used by accused are not added.

Uploaded by

Hanzalaahmed
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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INTHECOURTOFSH.SNEHIL SHARMA, LD.

MM,SAKET
COURTS, NEWDELHI

STATE VS MOHD YUSUF & ORS.


FIR NO. 76/2021
U/S.323/341/427/452/506/
R2
NCT OF DELHI COURT FEE
DLCTI948089L2217O 325/482/34 IPC
19-DEC-2022
P.S. JAMIA NAGAR

N.D.O.H.: 20.12.2022

APPLICATION UNDER SECTION 173(8) Cr.P.C. BY AND ONBEHALE


OF COMPLAINANT MOHD AAMIRS/0. MOHTRAM AL
. It is submitted that in the captioned matter the 1O/SHO P.S. Jamia Nagar

has filed chargesheet against the accused persons and the same is pending

consideration/adjudication before this Hon'ble Court on 20.12.2022.

2. It is submitted that the applicant is the complainant in the captioned matter

on whose complaint the FIR No. 76/2021 is registered with P.S. Jamia
Nagar. The applicant has obtained the certified copy of chargesheet and
after perusal of the same it is found that the names of certain accused

persons are missing who were very much involved in the commission of

offence including assaulting the complainant and other family members


besides damaging the properties/cars parked in the basement of the
building where the applicant is residing.
3. It is submitted that one of the paternal cousin brother of the applicant
namely Raza Ali S/o. Naushad Ali was also assaulted by the accused
persons and due to which he suffered grievous injuries and the

MLCs/medical documents are already part of the chargesheet.

4 It is submitted that
subsequent to the above incident the said Raza Ali
himself has lodged a complaint dated 08.03.2021 duly diarized as DD No.
62A of 2021 wherein specifically he has disclosed the names of accused
the
persons as well unidentified persons who were involved in the
as some

commission of the offence. However, the SHO/IO to the


reasons best
known to them, has not made of the named persons as accused
some

persons namely Shahbaz S/o. Shabana and Shaanu S/o.


Nanhe, who were
actively involved in the commission of the offence. Copy of the said
complaint dated 08.03.2021 duly diarized as DD No. 62A of 2021 is
being
annexed herewith for the better perusal
of this Hon'ble Court.

5. It is submitted that apart from the above submissions the


IO/SHO has also
not added the relevant provisions/sections of forgery committed by the
accused persons in connivance with each other as they have been using
fake car number plate which is also evident from the record as the same is
also reflected in the Section 173 Cr.P.C.
report,however, the IO has
completely neglected this point and has not chargesheeted the accused
persons under the relevant penal provisions related to forgery and cheating.

Under the facts and circumstances as mentioned


above, it is prayed
from this Hon'ble Court that it may be
pleased to issue necessary directions
to the IO/SHO concerned to
take necessary steps and further file

ww
investigation report pertaining to the facts mentioned in the present
application, in the interest of justice

NEW DELHI APPLICANT


DATED: 20|i21 92

THROUGH

M.N. SIDDIQUI& ASsOCIATEs


Advocates
Chamber No.225, Lawyers Chambers,
Saket Courts, New Delhi-1 10017
Tel.: 9810126707,

E-mail: siddiquimnó[email protected]
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