BEFORE THE COURT OF HONORABLE XIX METROPOLITAN

MAGISTRATE, CYBERABAD AT MALKAJGIRI

Cri. M.P. No. of 2022

In
Cri.
M.P. No. Of 2022

In
Crime.
No. 629 of 2020

Between:-
Sukanya Kapuria W/o Abhijit Kapuria
Aged About 40 Years, Occ: Private employed
R/o Plot No. 27, Door No. 29-1357/1/A
Deen Dayal Nagar, Naredmet
Malkajgiri- Medchal District
…..Petitioner/ Complainant

Vs
1. The State of Telangana
Through PS Neredmet, Rachakonda Rep.
by its Public Prosecutor.
2. The Commissioner of Police, Rachakonda,
Vayupuri, Hyderabad 500094.
3. The SHO Neeredmet Police Station,
Rachakonda, Neeredmet, Hyderabad.
…Respondents

Affidavit

I. Sukanya Kapuria W/o Abhijit, Aged About 40 Year, Occ: Private

employed, R/o Plot No. 27, Door No. 29-1357/1/A, Deen Dayal

Nagar, Naredmet, Malkajgiri- Medchal District, do hereby Solemnly

affirm on oath and state as follows: -

Witness No. 1 -

Ayub Mouinuddin Ansari, Lawyer by Profession, Resident of

Santosh Nagar Colony is a witness to prove that on the said

incident i.e 17 September 2020, there was no such heavy rain in

that area of the incident, West Deendayal Nagar, Neredemt. As

he was present at Deendayal Nagar, Road No. 2, with Mr. Abhijit

Kapuria, the father of Deceased Sumedha Kapuria from afternoon

2:00 PM to evening 6:45 PM.

Witness No. 2 -
Pavan Kumar, News Reported by Profession, Resident of —-, who
record a few videos for reporting purposes, and those are already
submitted in court as video evidence. His witness will prove three
points maintain by police in their final report as false.
1. When on 18th September 2020 the next day after the incident
he reached the location and found sand, stones, and other
dust particles which should not there if there was huge rain
that cause the Road was overflowing with drain water. At the
same time, the road should be filled with sewage from the
drain but apparently, the road was clean.
2. In the final report page 5, the police maintained that “No
Repair was required for the Nala as it was duly safeguarded by
chain link fencing” which is again a false statement given by
the police department. As in the video it is clearly seen that
there was no such chain link fencing available there or even
no structure is also there which can prove that GHMC installed
chain link fencing earlier which was removed by local people.
3. One of the videos was recorded by Mr Pavan, and submitted
to the court as evidence to prove that the MLA Mynampally
 Hanumanth Rao was discussing with the local people saying
that he is aware of the Open Nallah issue which is a long listing
problem in this area and he is working towards resolving it.
Which means there was a problem that was known by the
administration. But the Police are trying to hide the fact in their
report.
Hence this affidavit

Deponent

Sworn and signed before me

On this 20 Day of April 2023

Advocate/ Malkajgiri
 BEFORE THE COURT OF
HONORABLE XIX
METROPOLITAN MAGISTRATE,
CYBERABAD AT MALKAJGIRI

Cri. M.P. No. of 2022

In

Cri. M.P. No. Of

2022

In

Crime. No. 629 of

2020

Between:-

Sukanya Kapuria

…..Petitioner/ Complainant

Vs
The state of Telangana,
Represented by Public
Prosecutor and another

……Respondent/ Respondent

Affidavit
 Filed on

Filed by:

Mekala Srinivas Yadav

Advocate and Associates