FIRST INFORMATION REPORT

T.S.P.M. Orders 470,500

(Under Section 154 and 157 Cr.P.C)

1. District Hyderabad P.S. CHILKALGUDA Year 2023 FIR No. 812/2023 Date 29-12-2023

2. Acts & Section(s): 405,407,409,417,418,420,467,468,406 IPC,156(3) CrPC

3. a) Occurrence of Offence: Day Friday Date & Time From

Date & Time To Prior To 30-04-2021 11:00:00 Time Period

b) Information Received at P.S.: Date & Time 29-04-2023 18:50:00

General Diary Reference: Entry No 28 Date & Time 29-12-2023 18:50:00

4. Type of Information: Through Post

5. Place of Occurrence:

a) Distance and Direction From P.S.: 1 km, East Beat No.

b) Address Place Seethafalmandi Area/Mandal Street/Village SEETHAPHAL MANDI

City/District Hyderabad State Telangana PIN

c) In case, outside the limit of this Police Station, then

Name of P.S. District

6. Complainant / Informant:

a) Name Md. Hameeduddin

b) Father's /Husband's Name Mohd. Shamshuddin

c) Date/Year of Birth Age 34 Years

d) Nationality India e) Caste

f) Passport No Date of Issue Place of Issue

g) Occupation Business Mobile No. 9966474790

12-11-1113,
h) Address House No Boudhanagar, Area/Mandal Musheerabad Street/Village
Warasiguda

City/District HYDERABAD State TELANGANA PIN

7. Details of known/suspected/unknown accused with full particulars:

Serial No : 1

a) Name M/s Sri Laxmee Narsimha Swamy constructions

b) Father's /Husband's Name

c) Occupation d) Caste e) Gender Male

f) Age Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State TELANGANA PIN

h) Phone(Off) Phone(Resi) Cell No

i) Email

Serial No : 2

a) Name A. Harinath

b) Father's /Husband's Name Late A Bikshapathi

c) Occupation d) Caste e) Gender Male

f) Age 49 Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State TELANGANA PIN

h) Phone(Off) Phone(Resi) Cell No 9059558499

i) Email

Serial No : 3

a) Name M. Rangaiah Gound

b) Father's /Husband's Name Late M Sataiah Goud

c) Occupation d) Caste e) Gender Male

f) Age 55 Nationality India

g) Address

o 8-5-95/1, Road
No.1, Mallikarjuna
House No Colony, Old Street/Village Area/Mandal
Bowenpally,
Secunderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No 9849201376

i) Email

Serial No : 4

a) Name Rajeshwari Devi

b) Father's /Husband's Name A. Harinath

c) Occupation d) Caste e) Gender Female

f) Age 45 Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No

i) Email

Serial No : 5

a) Name A Harshavardhan

b) Father's /Husband's Name A Harinath

c) Occupation d) Caste e) Gender Male

f) Age 30 Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadguda,
Hyderabad

City/District State PIN

 h) Phone(Off) Phone(Resi) Cell No 6304649070

i) Email

Physical features, deformities and other details of the Suspect:

S. No. Sex Date/Year of Birth Build Height (cms) Complexion Identification Marks(s)

1 2 3 4 5 6 7

1 Male

2 Male

3 Male

4 Female

5 Male

Deformalities/
Teeth Hair Eyes Habbit(s) Dress Habit(s) Languages/ Dialect
Peculiarities

8 9 10 11 12 13 14

Place Of

Burn Mark Leucoderma Mole Scar Tattoo

15 16 17 18 19

8. Reasons for delay in reporting by the complainant / informant:

Delay from complainant

9. Particulars of properties stolen/involved (Attach separate sheet, if necessary):

10. Total value of property stolen:

11. Inquest Report/ U.D. Case

12. Contents of the complaint / statement of the complainant or informant:

IN THE COURT OF HON’BLE X ADDL. CHIEF METROPOLITAN MAGISTRATE AT SECUNDERABAD. Honored Sir, Brief facts of the case are that on
29.12.2023 at 18.50 hrs, received a complaint from Sri. Md. Hameeduddin, S/o Mohd. Shamshuddin, Age: 34 years, Oce: Bangle store business, R/o. H.No. 12-
11-1113, Boudhanagar, Warasiguda. Ph.No. 9966474790. In which he stated that in the year 2019 he have seen a house under construction at Seethaphalmandi.
Secunderabad and accordingly he made a phone call to the builder and approached to A-1) M/s Sri Laxmee Narsimha Swamy constructions having Office at flat
No.501, H.No. 1-3-183/39/A/B Gandhinagar, Kavadiguda, Hyderabad, A-2) A. Harinath S/o Late A Bikshapathi, Aders 49 YEARS flat No.501, H.No. 1-3-
183/39/A/B Gandhinagar, Kavadiguda, Hyderabad Mob. No. 9059558499, A-3) M. Rangaiah Gound S/o Late M Sataiah Goud, AREA 55 YEARS R/o 8-5-
95/1, Road No.1, Mallikarjuna Colony, Old Bowenpally, Secunderabad 500011, Mob. No.9849201376, A-4) Rajeshwari Devi, W/o A. Harinath Age: 45 Years,
R/o. flat No.501, H.No. 1-3-183/39/A/B Gandhinagar, Kavadiguda, Hyderabad, A-5) A Harshavardhan S/o A Harinath, Age: 30, Yrs Ro. flat no. 501, H.N. 1-3-
183/39/A/B Gandhinagar, Kavadguda, Hyderabad Mob. No. 630464070, It was agreed that the builder i.e. A2 would sell the house for Rs.47,00,000/- and that he
have to pay 30% of the amount initially. He have paid an amount of Rs. 10,00,000/- in April, 2021. He have paid the remaining amount in the same month in
three installments. After he paid the entire amount the accused has executed an agreement of sale in his favour. Later the accused has stopped receiving his calls
as the accused promised to get a loan for him. They have stopped receiving his calls as the accused promised to get a loan for him. He have also approached A3
regarding the said house and the payment made by him and he promised to talk with A2 and settle the matter but due to COVID-19 he could not contact any of
them and he was not handed over the said house by the accused persons. By the end of the 2019 A2 has issued legal notice to me claiming that as he have taken
cheques from him and that he failed to make the payment and for the said notice he have sent reply. Hence he requested to take necessary action. -:Original
English typed complaint is enclosed herewith:- Received on 29.12.2023 at 18.50 hrs: Basing on the contents of the above petition, I, P. Balaraju, SI, registered a
case in Cr.No. 812/2023, U/s 405, 407, 409, 417, 418, 420, 467, 468, 406 IPC & 156 (3) Cr.P.C. and case file entrusted to Smt. K.Sabitha, SI for further
investigation. Sd/- (Sri P. Balaraju, Sub-Inspector of Police, Chilkalguda PS, Hyd)

13. Action taken:

Since The above information reveals commission of offence(s) U/s as mentioned at item No:

1) Registered the case and took up the investigation or Name KARUPPAIAH SABITHA

2) Directed to take up the Investigation or Rank: SI No. 8443

3) Refused investigation due to

4) Transferred to P.S District on point of jurisdiction.

F.I.R. read over to the complainant / informant, admitted to be correctly recorded

and a copy given to the complainant /informant, free of cost. R.O.A.C

Signature / Thumb impression of the Signature of Officer in charge, Police Station

14.
complainant / informant.
Name PACHCHU BALARAJU

Rank SI No --

15. Date and time of dispatch to the court:

 CHIEF
IN THE COURT OF THE HON' BLE X ADDL.
DISTRICT
METROPOLITIAN MAGISTRATE, HYDERABAD
AT SECUNDERABAD

C.C. NO. OF 2023

Between:

Mohd. Hammiuddin
S/o Mohd. Shumshuddin
Aged about 34 years, Occ: Business
R/o H. No.12-11-1113, Boudhanagar,
Warsiguda, Secunderabad 500061
...Complainant

AND

1 M/s Sri Laxmee Narsimha Swamy constructions

1-3-183/39/A/B
Having Office at flat No.501, H.No.
Gandhinagar, Kavadiguda, Hyderabad

2 A. Harinath
Aákn 41 yCns
S/o Late A Bikshapathi,
1-3-183/39/A/B
flat No.501, H.No.
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 9059558499

YEAPA
Asen
3 M. Rangaiah Gound
S/o Late M Sataiah Goud,
R/o 8-5-95/1, Road No.1, Mallikarjuna
Colony,
Old Bowenpally,
Secunderabad 500011,
Mob. No.9849201376

4. A. Rajeshwari Devi
AKEn AS YEM
W/o A. Harinath
1-3-183/39/A/B
R/o. flat No.501, H.No.
Gandhinagar, Kavadiguda, Hyderabad
 A Harshavardhan
30 i t r
S/o A Harinath A i
R/o. flat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 6304649070
. Accused

SWORNSLEN SN AFFIDAVIT FILED BY

THE COMPLAINANT

I the above named complainant, do hereby swear on oath that the contents of the
complant in para No. I to 8
given below, that is filedby me are true to the best of
my knowledge and belief. In the event of
any facts stated by me being false or
untrue I am liable to be
prosecuted under the relevant provisions of law.
1. I the
Complainant, respectfully submit that this is a case
Trust. Criminal Breach of of Criminal Breach of
Contract, Misappropriation, cheating, and falsification of
records in which the
complainants is put to wrongful loss by accused No. l to 5.
2 I the
complainant submit that the facts
are that the
Accused No.1 to 5 herein
have committed the offences of
section 405, 407, 409,
406 IPC, it is submitted 417,418, 420, of IPC and
that since the cause of
action of all the
herein is one and the same, I am complainants
filing single petition.
a
it is submitted
that this
petition is being filed questioning the inaction of the
respondent police in not
registering and investigating the complaint of the
petitioner dated 17-03-2023 as
illegal contrary to law and judicial
precedents. It is submitted that all the accused
No.l to 5 in our
complaint dated 17-03-2023 have connived,
falsified documents submitted to the conspired, and
petitioner on several occasions in the
presence
HdApa
Nd
stead
 of third parties was with reference to the Registered documents vide no,

NO.2375/2018 and registered D.G.P.A vide doc. No.1570/2019, with property tax
eeglocument, as the accused was having the sole intention to usurp the petitioner's
family funds for their personal gain and benefit, knowing fully well, they had no
intention of utilizing the funds for the purpose for which it was placed in the hands

of the accused. No.1 to 5.

3. The facts are that the Accused No.l to 5 herein have committed the offences of
section 405, 407, 409, 417,418, 420 of IPC and 406 IPC, it is submitted that since
the cause of action of all the complainant herein is one and the same, I am filing a
single petition. it is submitted that this petition is being filed questioning the

inaction of the respondent police in not registering and investigating the complaint
of the petitioner dated 17-03-2023 as illegal contrary to law and judicial
precedents. It is submitted that all the accused in our complaint dated 17-03-2023

have connived, conspired, and manipulated the Registered property document

submitted to the petitioner on several occasions with reference to the Registered
Sale deed and Registered Development cum General Power of Attorny in

executing a sale agreement with the petitioner on 30-04-2021, with the sole
intention to usurp the petitioner family funds for their personal gain and benefit,

the apartment was formed to cater to the needs of residential

knowing fully wellI,
enjoyment of their family life.
families in need of economical support for

and the builder, were present at the

4. It is relevant to state that the land
owner

they jointly made

of apartment transaction, and
time of negotiating the purchase
sale deed of the unfinished flat to avail a loan of 47 lakhs.
statement of executing a

towards which 10% (Ten percent) margin money was to be deposited in the bank

HdA
 for availing 90% Housing loan that would pay for the total
cost of the
apartm.
amounting to
Rs.47,00,000/- The said apartment had men
be handed over
to
within two
months from the date of
making the advance
payment of
made on 30-04-2021 with
a written
Rs.6,00,00
agreement made 30-04-2021 and as per tha
on
agreement further payment made
on
the
mutation of the flat,
towards, The payment for
GHMC Taxes and
electricity deposit, water and HMWSSB
registration charges and fees towards deposit and charges,
execution of sale deed of
were made
by us, towards which said unfinished flat
amount of Rs. understanding and oral agreements, a
10,00,000/- ten lakhs waspaid to the accused, who collected
total
same and promised to deliver the unfinished apartment into
the
period of two months from the date of my custody within a

fulfilled my part of the receipt of amounts demanded.

Wherein I
agreement. Copies of the land
No.2375/2018 and registered owners sale deed vide doc.
D.G.P.A vide doc.
dues alongwith the written agreement is filed No.l570/2019 and property tax
herewith.

5) Believing and trusting their

commitments, with the oral and written
undertaking given by Builder and the landlord
in the
party purchasers present at the presence of several other third
time of
accused no.1 to 4 negotiation, I was made to believe the
promises made in
presence of other third party
confirming their intentions of being honest and purchasers also,.
law abiding Indian
by the accused citizens, going
professing to have the local
construction in competency execute the
to
abiding by Indian laws, rules and apartment
payment of Rs. regulations made a further
I
4,00,000/ -

(Rs. four lakhs .) i.e. from March

2021 to June 2021
Details of the payment made to the accused, with acknowledgement of the funds

collected by the accused is filed herewith.

6). The complainants further submit to this Hon'ble Court that the Accused have
intentionally misappropriated, cheated and swindled the funds which were meant
for the sole purpose of construction and compliance with the authorities concerned
and to obtain the financial assistance needed to complete the execution of the
unfinished construction. By way of making payment to the authorities concerned
for perfection of the title with the concerned departments, and for obtaining
financial assistance from the financial institutions based on the margin money
deposited with the accused to be kept in the bank account alongwith the title deeds
of the property held by the accused No.1 to 5 for obtaining funds to complete the
execution of the multi storied residential complex. Inspite of having received the
funds of Rs. Ten lakhs, between the period of March 2021 to June 2021 the
project remained as it was in the same stage of completion that was seen in the
month of March and June 2021 prior to the entry of the transaction with the
Accused, wherein all the Accused No. I to no.4 were present at the apartment site
located at Seethphalmandi. Secunderabad.

7 The Complainant submit that the accused has dishonestly and fraudulently
induced the complainants to come and join as a flat owner member of the

apartment, only in order to usurp, cheat and swindle the petitioner of their family

with the sole aim to wrongful loss to the

savings and personal funds cause

No. 1 to 5 personal gain and benefits, by

petitioner herein for the accused
adopting fraudulent means thereby the accused has committed offence Usee
40
407, 409, 417,418, 420,of IPC and 406 IPC
inspite of the several visits to
the s
and to the residence of the Accused no.l to
5, the Accused No.1,2, 4
absconded from their premises and became contact less
from the period of Ma
2022 till date. Letters sent to the accused
were returned
by the postal department a
no such
person available at the address. The accused no.3
received the letters sen
by the petitioner but failed to
respond. It is pertinent to mention that the
got issued a notice to the accuse
petitioner giving the same wrong addresses mentioned in
the agreements registered with the authorities vide
letters and notice received is filed
registered deeds. copy of the
herewith.

8. The
petitioner fearing the adverse response and non
visited the site and residences of the communication, and having
accused were shocked and pained to see
the Accused No.1 to 5 had that
deliberately given false address, subsequently fearing
the worst of the
absconding builder, the petitioner traced the land
for owner and asked
an execution of the
unfinished apartment towards which
lakhs) was paid and received by the accused
10,00,000/- (Rs. Ten
no.I to 5. The accused
the petitioner that the no.3 informed
payments were received by accused no. 1, 2 and
the accused no.3 refused to 4, 5. Hence
co-operate and
expressed his inability to assist the
petitioner. The petitioner having no other option were
constrained to inform the
police authorities on 17-03-2023 to
investigate
into the unlawful activities of
the
accused no.1 5, the accused no. 1,2 and 4,5
to
declined to respond to the
enquiries, and accused no.3 refused to communicate to police
the police to answer
said above transaction. Hence for the
the police authorities have instructed the
petitioner
 to approach the Hon'ble Courts, for directions to proceed against the accused No. I

o5. Hence this petition. Copy of the complaint filed and numbered as 0034l with
e police alongwith the acknowledgement by the commissioner of police is filed
herewith

Hence this Affidavit

COMPLAINANT

Date :02/05/2023

Place: Secunderabad
AL Per t a
diyetioms ot o HTn ble
XACMM Cout vide Ok No. 2638 ZAL
hM Se bed |2Da,Dt 22 |2o3, sR
No.2193/n, 3, P balavaju, s p v-asen

0 1u 409, 97,41&,420,44 7, 46, 406TP

2 | os|202a IS(2) CNe and tase file eextaute
tokut Labi ho, 3 tu
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 SR a 1 p
IN THE COURT OF THE HON BLE
XADDL CHIEF METROPLITIAN
HTR INDIA MAGISTRATE, HYDER 3 D
DISTRICT
AWO RUPEES
AT SECUNDERABAD

C.C. NO.
oesea Between:
OF 2023

Mohd. Hammiuddin
.Complainant

AND
ol

M/s Sri Laxmee Narsimha Swamy

l o n n diud uyDeope constructions And others
prour Moribla.cawt to ...Accused No.I to 44

Cnpe AoA A,toA COMPLAINT UNDER SECTION 200

OF Cr.P.C.

Filed On: 02/05/2023

Filed By: Counsel for Complainant

Swem odast adluobhd
tdit Ppad Address for Service

J.C. Francis
M.B. Laxmikala
3-3-389/B, Chappal Bazar,
Kachiguda, Hyderabad 500027

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