BEFORE THE ADDL.

CHIEF JUDICIAL MAGISTRATE COURT ,

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CC ===/16

State : Complainant

Vs.

Salam : Accused

Notes arguments submitted by ====== counsel for the

accused in the above case u/s 314 of Cr.P.C.

The above case is filed against the accused for an offence

punishable u/s 341,323 IPC.

The case of the prosecution is that on 23/12/13 at about

11.30 the accused was beaten by the defacto complaiant on his face and
stomach and there by he had committed the offences punishable under
section 341 and 323 of IPC.
In this case the accused was exempted from personal appearance.
On the side of the prosecution PW1 to pw7 were examined and exhibits P1
to 6 were marked.
Case put forwarded by pw4 is not supported by independent witness. Cw 2
ad Cw 3 are the independent witness. Cw3 was not examined before this
court. Cw2 examined as Pw7 deposed before this honble court that he has
no knowledge of the alleged incident. Independent witness did not support
the prosecution case.
As per the deposition of Pw4 there is dislocation of the tooth which is denied
by the Pw6 , as per the wound certificate also there is no such injuary. If the
ocular evidence and medical evidence is not collaborating the accused is
entitled to acquittal.
According to the accused he had falsely incorporated in the above case.
There are no independent evidence available in the instant case. Further to
accused prove the guilt of the accused there are no materials available and
there are no incriminating evidence against the accused.

Only on the basis of the evidence of the pw 4 the accused cannot

be found fault with and that cannot be believed for a moment.

Hence the memorandum of arguments

It is there for respectfully submitted that this Hon’ble court may

pleased to entertain this memorandum of arguments on file and accused
may be acquitted and orders may be passed accordingly.

NAME OF THE
COUNSEL
Counsel for the accused