IN THE COURT OF THE 2nd ADDL MUNSIF MAGISTRATE GURNAZALA

C.C. NO. /2023

BETWEEN:-
*** …Complainant
AND
No. 1.
No. 2. …Accused

COMPLAINT FILED ON BEHALF OF THE COMPLAINANT U/S 200 OF Cr.PC

1. Date of offence : 25-05-2005

2. Time of offence : at about 9 A.M.
3. Place of offence : in front of the fertilizers shop of Accused.
4. Nature of offence : U/s 307, 420,506, r/w 34 ipc & U/s 3(1) 9 of sc/st
Atrocities on (prevention) Act-1989

5. BRIEF FACTS OF THE CASE:

The complaint and the 2nd accused are the residents of gottimukkala, but whereas the
Accused no.1 is the resident of palligunta Village and the Accused no. 1 and 2 are the
closest relatives to each other.

The Accused have been running a fertilizers and pesticides shop in gottimukkala Village
under the name and style of sri Krishna chitnya traders since long back jointly previously
the complainant opened khatha in that particular shop by purchasing pesticides and
fertilizers either on credit or on cash basis occasionally. After completion of the
consumer transaction with the shop, finally, the complainant debt amount were also
settled for a sum of Rs. 13,000/- after the settlement, the Accused no.1 on the guidelines
of the accused no.2 obtained a pronote in his favour executed by the complainant for an
amount of Rs 13,000/- subsequently, the complainant has sold away his cotton weighing
of 10 quintals to the Accused consisting at the rate of rs.1850/- per quintal but on the day
cotton sold away, the Accused never pay any amount to the complainant. Really the
Accused has to pay the remaining balance of amount o Rs.5.500/- by deducting the debt
amount of rs 13,000/- from the cotton purchase amount of rs18,500/- the complaints
asked the accused with the regard of return of pronote and return of balance amount but
with a fraudulent manner, both the accused postponed the return of pronote and balancing
amount by saying on some other pretest there after intentionally by having a mutual
conspiracy both the Accused kept the pronote executed by the complainant for some
time, and suddenly the accused no.1 in order to get the amount again from the
complainant by way of illegal means has filed the a suit as os.no 142/2005 against the
complainant on the file of prl .junior civil judge court, gurazala, basing on the pronote
 executed by the complainant in favour of the accused no. 1 and also the accused no.1
obtained attachment order against the landed property of the complainant. The complaint
came to know with regard of filing of the suit by accused no 1 and attachment of the
landed property of the complainant through court amina, who served attachment notice
and on the day i.e, 24-05-2005 tom-tom was also made out in the village.
Really the complainant came from the respectable family, then he heard the news from
court amina, the complainant mentally shocked and he suffered a lot there of.
While the matter should thus the next day morning on 25-05-2005 about 9 A.m. the
complainant went to the Accused fertilizer shop along with one peripogu yasob and
sukkaih inorder to get the information.

At that occasion, both the accused were there in their shop the complainant asked the
accused instead of payment of the remaining balance and return of pronote why that you
have filed the suit against me? For which the accused suddenly prorogated and abused
the complainant in filthy language with the name of the caste yendira malanakodaka
memu neeku bakiraa neeku thinadaniki thindileni nakodaka asalu neevu nee prathini mau
yeppudu vesinavu? meemu ekkada neeku tanthe, champithe neeku dikku yevadaraa …?
And also the accused warranted the complainant as that they will see until the end of him
and his family members, if he reports the matter to the police. The entire occurrence was
witnessed by one perupogu yacobu and some other villagers who gathered there. Without
any alternative steps, the complainant went to his house. The next day morning i.e, on 26-
05-2005 the complainant along with perupogu yacobu who witnessed the occurrence
went to gurazala police station and informed the same by lodging a written report. The
police authorities for which replied as they will take proper action against the accused
and provide the justice to the complainant. Even today, any kind of action not to be taken
over against the accused and provide the justice to the complainant and the accused
presently also proclaiming in the village to take severe action against the complainant in
future for the sake of reported the matter to the police.

The complainant belonging to scheduled caste and helpless one, but whereas the accused
persons are not scheduled caste and scheduled tribe and the accused persons are having
strong followers of telugu desam party but whereas the complainant belongs to mal\a
community innocent and helpless one and also has no capacity to resist the brutal
activities of the accused, the accused no 1 and 2 with a common insertion to commit the
offences 3(1)9 of sc/st atrocities (prevention) act 1989 thus the accused are guilty for the
offences mentioned above as such they are liable for punishment.
6. Therefore, the complainant prays that the Hon’ble court may be pleased to take the case
on file directly by examining the complainant and witness and issue process to the
accused and punish in accordance with law. The complainant (lti of) pidathala
Venkateswarlu (so) of **** advocate for one complainant .the facts state above are true
and correct to the best of my knowledge, sir, I registered the above CFR as a case in cr no
67/2006 u/s 307,420,506 r/w ipc and se 3(1)(xi) of sc /st atrocities (prevention) Act 1989
 r/w 156(3) crpc of gurazala ps on 21-09-2006 at 9 am original FIR along with CFR
submitted to 2nd AM gurazala copies of FIR submitted all concerned officers.

ADVOCAT FOR THE COMPLAINANT COMPLAINANT

The facts state above is true and correct to the best of my knowledge belief and
information.
Complainant

LIST OF EITNESS:
1. Perupogu Jacob, s/o
2. annamola subbaiah s/o Saindulu

7.