IN THE COURT OF MS. PARINIDHI GUPTA LD.

M.M., DWARKA COURTS, DELHI

IN THE MATTER OF:-

STATE VERSUS SUBHASH & ANR.

F.I.R. 706/2017

U/S. 324,452,506 IPC.

P.S. BINDA PUR

APPLICATION FOR ALTERATION OF CHARGE

UNDER SECTION 216 CR.P.C. ON BEHALF OF
APPLICANTS/ACCUSEDS.

MOST RESPECTFULLY SHOWETH:-

1. That the above case is pending before Hon'ble

Court and fixed for evidence on dated

28.11.2019.

2. That the applicants/Accuseds are neither a

previous convict nor involved in any criminal

cases.

3. That the in the medical of the complainant

neither such type injured that could be proved.

4. That the at the time of incident

applicants/accuseds were not there.

5. That the Hon'ble Court has been charged frame

against Applicants/Accuseds on dated

21.07.2018.

6. That the Applicants/Accuseds have no any

criminal record.

7. That the PW-1 has been chief/cross examine on

dated 30.10.2018 and PW-2 has been cross

examine on dated 30.10.2018 but PW-1 and PW-

2 has been contradiction in chief/cross

examination.

8. That the in the charge sheet have no any such

type documents as could be prove for this

offence. Neither such type any medical

documents.

9. That the applicants/accuseds

PRAYER

It is therefore most respectfully before this

Hon'ble Court may kindly passed the order for

alteration of charge against

Applicants/Accuseds, in the interest of justice.

APPLICANTS/ACCUSEDS

THROUGH

DELHI

DATED COUNSEL