Appeals and Revisions
277
Model Form No. 64
———_?: 84
MEMORANDUM OF CRIMINAL REVisfon PETITION
(UNDER SECTIONS 397 AND 401 OF Cy ¢)
1X THE HIGH COURT OF JupIcATy Ne
RE OF
PRADESH: AT HYDERABAD ANDHRA
CRL.R.C. NO. .. - OF 2004
Between:
Boda Rao,
S/o. Rama Rao, Hindu,
Aged about 25 years,
Occu: Business
Petitioner
Appellant
Accused
AND
State of Andhra Pradesh,
Rep. by its Public Prosecutor,
High Court of Andhra Pradesh,
HYDERABAD. Respondent
Respondent
Complainant.
The address of the petitioner for
Process etc. is that of hi:
service of all notices and
is Counsel M/s. Sri Ram Associates,
Advocates, Nampally, Hyderabad.
The above named petitioner begs to present this Memorandum
of Criminal Revision Petition to this ‘Hon'ble Court against the
Judgment made in Crl.A.No. .......... of 2002 on the file of the
Court of the Metropolitan Sessions Judge, Hyderabad, dated ..........
of + 2004 as confirmed the Judgment made in C.C. No.
on the file of the Court of the Metropolitan Magistrate,
Hyderabad, dated .. of . 2002 for the following
among other:—SES -
278 Lectures on Drafting, Pleading & Convey: neing (Penny
Lees
1) That the judgment of the lower appellate Court is
; ° m con
to law, weight of evidence and probabilitics of the ca: Mary
Se.
2) That the leamed Magistrate erred in law
cognizance of the case and as such the conviction is
be set aside.
N takin
Nable to
3) That the Lower Appellate Court failed to appreciate 4
testimony of the investigation of the Investigation Officer ‘c
unbelievable one and unreliable one. as
4) That the lower appellate Court erred in confirming th
order of the trial court. c
5) That the trial Court and the appellate court ought to have
seen that the complainant and the Investigating Officer is one ang
the same.
6) That the trial Court and the appellate court failed to
appreciate that no independent witnesses examined by the
prosecution to prove their case.
7) The Lower Appellate Court has not properly looked into
judgment of the lower court and went wrong in dismissing the
appeal.
8) The trial Court and the Appellate Court failed to observe
that there are so many discrepancies in the evidence of PW-1 and
PW-2.
9) That the Lower Appellate Court has not been considered
of any point of the petitioner herein, and dismissing the appeal
on climsy grounds.
10) The Prosecution failed to prove their case beyond all
reasonable doubts. Even then the trial court convicted the petitioner
herein and confirming the order of the trial court by the Lower
Appellate Court.Pelll.Lee-Xil} Appeals and Revisions n9
ROM Lee MM}, a4, +: Appomts anda Reystongy 3. nenn | UM
11) The other grounds that may be urged at the time of
hearing of the Criminal Revision case.
Hyderabad: Counsel for the Petitioner.
Date: