IN THE COURT OF DISTRICT AND SESSION JUDGE, SHEIKHPURA

BIHAR

S.T.NO 111/2017

IN THE MATTER OF:-

State of Bihar

VERSUS

Bholi Singh @ Shiv Shankar Singh

WRITTEN ARGUMENTS ON BEHALF OF THE ACCUSED BHOLI SINGH

@ SHIV SHANKAR SINGH

That the main accused as well as main complainant died

A. Police investigation.

That the humble submission regarding police investigation

 That neither the alleged gun nor the bullet shell was recovered from the
alleged incident place.

 That police further failed to recover the alleged blood stain vest of the
complainant.

B. Evidence and Cross-Examination of Dr. Satish Chandra Bose.

That the humble submission regarding Evidence and Cross-Examination of Dr.

Satish Chandra Bose.

That in his Evidence dated 15.09.2018 he stated that “Lacrated wound with
irregular inverted margine bleeded, blakish red colour wound of entry and exit
is not distinguish size of wound 3” diameter up to bone deep”

 In his evidence it is no where mentioned that the alleged wound on the

complaint hand is from the gun shot.
 Further there is no any fired bullet taken out from the complainant’s alleged
left hand.

 In his Cross-Examination he stated that there was neither any gun powder
found in the wound nor any multiple burn injuries found on the complainant
alleged left hand.

 He further state that is no any entry or exit point in the complainant alleged
left hand.

 He further stated that just because of his experience he make the report of
the alleged wound is of gun shot.

It is most respectfully and specifically submitted that accused Bholi Singh

allegedly shot the complainant and it is very crystal clear form the evidence and
cross -examination of Dr. Satish Chandra Bose that there is no gun powder ,
there is no any entry or exit point of bullet and no any bullet found in the
complainant alleged left hand.

C. REGARDING OFFENCE U/S 307 IPC

That the humble submission in regards to the allegation of attempt to murder
(Section 307 IPC) is here below
 That in the complaint FIR dated 11.08.2015 if the version of the
complainant is believed to be true, victim told that he was allegedly shoot by
the accused.
 That on 20.08.2019 in evidence of his brother Indradev Singh regarding
alleged shooting incident his brother allegedly shoot by the complainant in
his left hand he took his brother directly to the police station instead of
taking him to the hospital.
 That in the statement under section 161 dated 12.08.2015 of the complainant
to SI Surender Prashad Yadav that he went directly to Govt. Hospital
Sheikhpura.
 the statement of the complainant is also disputed where it is recorded as per
inderdev singh he took his brother to the PMCH Patna for better treatment
and complainant was admitted therefore 8-10 days.