MEMORANDUM OF CRIMINAL ORIGINAL PETITION

[Under Section 482 of Cr.P.C]

IN THE HIGH COURT OF JUDICATURE AT MADRAS

(Criminal Jurisdiction)

Crl.O.P.No. of 2019

ABC
W/o CAB,
Maiyanur– village,
KANVAIPUDUR
Villupuram District.

….PETITIONER/A 14

/VS/
The State represented by.

Inspector of Police
Pagandaikuttusalai police station
( in crime number: 118/2016)
….RESPONDENTs

PETITION FOR DIRECTION

The address for service of all notices and processes on the

Petitioner is that of his counsels M/S DAM, J.S.YAM and PAM
at No.64,Catholic center, Gate No:4,Mclean Street, Armenian
Street, Chennai – 600 001.

The address for service of all notices and processes on the

Respondents is the same as stated above in the cause title.

1. The Petitioner submits that a case has been registered against

her in Cr.No.118/2016 U/s 147,148,294(b),323,324,506(2),307
IPC and Section 4 of Tamil Nadu Prohibition of Harassment of
Women Act on the file of the Respondent police dated
31.10.2016 and subsequently Final Form / Report has been
filed and the sections are altered as
147,148,149,294(b),323,324,325,506(2),307 IPC 3(2)(va), 3(1)
 (r), 3(1)(s) of The Scheduled Caste and the Scheduled Tribes
(Prevention of Atrocities) Amendment Act 2015 and the case is
pending before the Special Court for Communal Violence,
Villupuram.
2. The Petitioner submits that the alleged case of the prosecution
is due to previous enmity the petitioner along with other four
accused unlawfully assembled with deadly weapons used filthy
language, causing hurt, criminally intimidated, attempted to
commit murder and committed alleged offences against the
defacto complainant and other witnesses who belong to
Scheduled caste community.
3. The Petitioner submits that the date of occurrence is on
30.10.2016 and the FIR was registered on 31.10.2016 and in
the complaint given by the defacto complainant nothing was
stated that the petitioners/accused used the name of the
scduled caste community and humiliated them but later with
malicious intention the sections have been altered to the
sections of The Scheduled Caste and the Scheduled Tribes
(Prevention of Atrocities) Amendment Act 2015.
4. The Petitioner submits that the entire allegations is false and
nothing is reliable on the complaint and in order to harass and
blackmail the petitioner the defato complainant has given the
false complaint to the respondent police station and the
petitioner further submits that there is no truth in the
prosecution case and she has been falsely implicated with
malafide intention and ulterior motive.
5. The Petitioner submits that the investigation in this case is over
and charge sheet has been filed and the case is pending for
trial and the all the co accused in this case already have been
released on bail.
6. The Petitioner submits that she is innocent and she has not
committed any offence and she is a respectable law abiding
citizen and she will not evade the due process of law.
7. The Petitioner submits that she is the permanent resident of
the above address and she is ready to abide by any condition
which is imposed upon her.
8. The petitioner submits that no prejudice would be caused to
th respondent if the petitioner is given the suitable direction,
since the ingredients of the offence are not made out and this
is the first application for direction being moved before this
Hon’ble court.
The petitioner therefore prays that this Hon’ble court may be
pleased to pass an order directing the Learned Special Judge
for Communal Violence, Villupuram dt. to accept the surrender
of the petitioner(A14) herein concerned in Cr.No.118/2016 on
the file of the respondent police on pending trial before the
Special Court for Communal Violence, Villupuram – in No…….
and consider the bail petition on the same day itself and pass
such order or other orders as this Hon’ble court may deem fit
and proper circumstances and thus render justice.

Dated at Chennai on this the 8th Day of August 2019.

COUNSEL FOR THE PETITIONER

 IN THE HIGH COURT OF
JUDICATURE AT MADRAS

[Criminal Jurisdiction]

Crl.O.P.No. of 2019

ABC
w/o CAB ,
Kanavaipudhur-post,
Omalur Taluk,
Salem District.

….PETITIONER

/VS/

The State represented by.

The Inspector of Police,

Ercaud Police Station,
Salem District.
(Cr.No-78/2016)

….RESPONDENT

PETITION U/S 482 of Cr.P.C

M/S. DAM

MR. J.S.YAM

MR. D.PAM

COUNSEL FOR PETITIONER

 MEMORANDUM OF CRIMINAL ORIGINAL PETITION

[Under Section 482 of Cr.P.C]

IN THE HIGH COURT OF JUDICATURE AT MADRAS

(Criminal Jurisdiction)

Crl.O.P.No. of 2019

ANJAL MARRY (F/ 48 yrs)

W/o Arul Devadoss,
Maiyanur– village,
Kanavaipudhur-post,
Omalur Taluk,
Villupuram District.

….PETITIONER/A 14

/VS/
The State represented by.

Inspector of Police
Pagandaikuttusalai police station
( in crime number: 118/2016)
….RESPONDENTs

INDEX TO THE TYPED SET OF PAPERS

S.No Page
Date Description of documents
. No.

05.05.201 Copy of the complaint

1
6

05.05.201 Copy of FIR.No.78 of 2016

2
6

05.05.201 Mahazar and Rough Sketch

3
6
 05.05.201 Postmortem Certificate
4
6

05.05.201 161(iii) Cr.PC Statements of

5 6 Complainant and other

witnesses

08.02.201 161(iii) Cr.PC Statement of SSI

6
7

27.06.201 Statement of Accused

7
6

10.05.201 Alteration of Sections from

8 6 174(III) Cr.PC(Hanging) to

498(A) and 306

27.06.201 Arrest Memo

9
6

27.06.201 Arrest Report under Section 58

10
6 Cr.PC

27.06.201 Remand Report

11
6

08.02.201 Final Form/Report

12
7

27.06.201 Forensic Report

13
6

14.06.201 Record Sheet of the deceased

14
3
 This is to certify that the above documents are true copies of

their respective originals.

DATED AT CHENNAI ON THIS THE 8th DAY OF AUGUST 2019

COUNSEL FOR PETITIONER

IN THE HIGH COURT OF

JUDICATURE AT MADRAS

[Criminal Jurisdiction]

Crl.O.P.No. of 2019

S.Krishnaveni (F/ 48 yrs)

w/o Pazhanisamy,
Kanavaipudhur-post,
Omalur Taluk,
Salem District.

….PETITIONER

/VS/

The State represented by.

The Inspector of Police,

Ercaud Police Station,
Salem District.
& 6 others
(Cr.No-78/2016)

….RESPONDENTS
 TYPED SET

M/S. D.MARIO JOHNSON

(338/1997)
J.S.YASMEEN (2112/15)
D.MANOJ PRABHAKAR (2970/17)

COUNSEL FOR PETITIONER

80566 81577