IN THE COURT OF THE HON’BLE ADDITIONAL JUDICIAL

MEGISTRATE OF FIRST CLASS AT BODHAN

C.C. NO. OF 2024

Between:-
Sri. Vemula Pramod Reddy.
...Complainant.
AND

Sri. Shubham Madav Singh Thakur & 3 Others.

…Accused.

:: AFFIDAVIT ::
I, VEMULA PRAMOD REDDY, S/o. Rajeshwar Reddy, Caste: Reddy,
Aged: about 40 Yrs., Occ: Govt. Teacher (Primary School, Siddapur Thanda
Village of Varni Mandal), C/o. Pullaiah Main Road, Chandoor (V&M), Dist.
Nizamabad-T.S., do hereby solemnly affirm and state on oath as follows:-

1. That I am the Deponent herein and Complainant in the above case,

as such I know the facts of the case, the facts mentioned in the Complaint
are true and correct.

2. That the Accused No. 1 working in Venkys’s Charity Trust situated

at Varni as a Cook. The said Venkys’s Charity Trust was supplying food
daily to the Piligirms at Badapahad Dargha and Accused No. 1 & 2
resides in the ground floor of Venkys’s Charity Trust Building at Varni.
That I also reside with my family in the 1 st floor of the said building, I
and Accused No. 1 & 2 having good acquaintance with one another.
Therefore, because of that acquaintance the Accused No. 1 came along
with Accused No. 2 (Wife of Accused No. 1) approached me on 29-07-
2023 and requested me to arrange Rs.1,00,000/- (Rupees One Lakh Only)
for their family need. Therefore, on the same day I issued a Cheque of
 Rs.1,00,000/-, Dated: 29-07-2023 bearing Cheque No. 035127 of State
Bank of India, Subash Nagar, Nizamabad Branch in the name of Accused
No. 2, in evidence the Accused No. 1 executed a Promissory Note and
Accused No. 2 stood as guarantor of the said borrowed amount, the
Accused No. 1 & 2 agreed to pay the said borrowed amount with interest
@24% P.A. on my demand or order. The said Promissory note was
scribed the Accused No. 1 and Javahar Sing in their own handwriting by
mentioned Cheque No. 035127 and attested by one Sri. Javahar Singh
and Sandeep who are also working at Venkys’s Charitable Trust as
witnesses.

3. That after received the Cheque, on 30-07-2023 when I was busy in

funerals of my grandfather, the Accused No. 2 deliberately with an ill
intention and ill motive presented the Cheque on 03-08-2023 when the
funds were insufficient in my account to dishonor the Cheque.

4. That on the same day when the Cheque was dishonoured the
Accused No. 2 along with her husband i.e., Accused No. 1, Javahar Singh
and Sandeep came to my house and stated that the Cheque issued by me
was dishonoured due to insufficient funds and also requested to arrange
the Cheque amount with a promise to return the dishonoured Cheque as
soon as receive from Bank Manager. That on the request of Accused No.
1 on 14-08-2023 I paid dishonoured Cheque amount of Rs.1,00,000/- in
shape of cash to Accused No. 1 towards amount borrowed by the
Accused No. 1 & 2 through the said Cheque from me, the same was
 received by the Accused No. 1 & 2 in presence of said Javahar Singh and
Sandeep.

5. That subsequently when I demanded the Accused No. 1 & 2

through the witnesses Javahar Singh, Sandeep and Sundhar Singh to
repay the borrowed amount with agreed interest to me and return the
dishonoured Cheque, then the Accused No. 1 & 2 bore-grudged on me
and postponed the matter with one or other pretext. That on 16-08-2023
the Accused No. 1 along with his friend attacked on my car and caused
damage, then I made a phone call to 100 Dial, but the Police, Varni did
not take any action. That finally on 18-08-2023 the Accused No. 1 & 2
with ill intention and ill motive to extract more money from me,
blackmailing to file false cases against me as I being a Govt. Employee
and also to avoid the repayment of borrowed amount with agreed interest
to me.

6. That again on 03-10-2023 at 11:31A.M. when I was discharging

my duties of taking class to the students in school, the Accused No. 1 & 2
along with Accused No. 3 and Accused No. 4 (Brother of Accused
No.2) came to the school premises, attacked on me and abused in filthy
language in presence of school students and scavenger of the school.
Thereafter, the Accused No. 1 to 4 had been awaiting in school premises
for a chance to kidnap the Complainant and obstructed me from
discharging my duties in school and also threatened to kill me on that day
or on any other day, then I with a fear made a phone call to 100 Dial,
upon which I lodged a complaint to the Police, Varni and also to the
 Commissioner of Police, Nizamabad, but the Police failed to take any
action against the Accused No. 1 to 4.

7. There is ample evidence to prove the case against the Accused No.
1 to 4.

8. The Hon’ble Court has got wide powers to refer the Complaint to
S.H.O., Varni and enquire and laid charge sheet.

IT IS THEREFORE, PRAYED, that this Hon’ble Court may be

pleased to refer the Complaint to the S.H.O., Varni, U/s. 175 (3) of
B.N.S.S. and enquire and laid Charge Sheet after conclude investigation
in the ends of Justice.
Hence, this Affidavit.

DEPONENT
Sworn and Signed before me
on this the day of July, 2024
at Bodan.
(Vemula Pramod Reddy)
Advocate
 SWORN STATEMENT OF THE COMPLAINANT

IN THE COURT OF THE HON’BLE JUDICIAL FIRST CLASS

MAGISTRATE AT BODHAN
C.C. NO. OF 2024

Name of the Complainant : Vemula Pramod Reddy.

Husband’s Name : Rajeshwar Reddy.
Caste : Reddy.
Age : About 40 Yrs.
Occupation : Govt. Teacher (Primary School, Siddapur
Thanda Village of Varni Mandal)

Resident of : C/o. Pullaiah Main Road, Chandoor

(V&M), Dist. Nizamabad-T.S.

Dated this the day of July-2024, at Bodhan.

=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-
I, VEMULA PRAMOD REDDY, S/o. Rajeshwar Reddy, Caste: Reddy,
Aged: about 40 Yrs., Occ: Govt. Teacher (Primary School, Siddapur Thanda
Village of Varni Mandal), C/o. Pullaiah Main Road, Chandoor (V&M), Dist.
Nizamabad-T.S., do hereby solemnly affirm and state on oath as follows:

1. That I submit that I am the Deponent herein and Complainant in

the above case, as such I know the facts of the case, the facts mentioned
in the Complaint are true and correct.

2. That I submit that the Accused No. 1 working in Venkys’s Charity

Trust situated at Varni as a Cook. The said Venkys’s Charity Trust was
supplying food daily to the Piligirms at Badapahad Dargha and Accused
No. 1 & 2 resides in the ground floor of Venkys’s Charity Trust Building
at Varni. That I also reside with my family in the 1 st floor of the said
 building, I and Accused No. 1 & 2 having good acquaintance with one
another. Therefore, because of that acquaintance the Accused No. 1 came
along with Accused No. 2 (Wife of Accused No. 1) approached me on
29-07-2023 and requested me to arrange Rs.1,00,000/- (Rupees One Lakh
Only) for their family need. Therefore, on the same day I issued a Cheque
of Rs.1,00,000/-, Dated: 29-07-2023 bearing Cheque No. 035127 of State
Bank of India, Subash Nagar, Nizamabad Branch in the name of Accused
No. 2, in evidence the Accused No. 1 executed a Promissory Note and
Accused No. 2 stood as guarantor of the said borrowed amount, the
Accused No. 1 & 2 agreed to pay the said borrowed amount with interest
@24% P.A. on my demand or order. The said Promissory note was
scribed the Accused No. 1 and Javahar Sing in their own handwriting by
mentioned Cheque No. 035127 and attested by one Sri. Javahar Singh
and Sandeep who are also working at Venkys’s Charitable Trust as
witnesses.

3. That I submit that after received the Cheque, on 30-07-2023 when I

was busy in funerals of my grandfather, the Accused No. 2 deliberately
with an ill intention and ill motive presented the Cheque on 03-08-2023
when the funds were insufficient in my account to dishonor the Cheque.

4. That I submit that on the same day when the Cheque was
dishonoured the Accused No. 2 along with her husband i.e., Accused No.
1, Javahar Singh and Sandeep came to my house and stated that the
Cheque issued by me was dishonoured due to insufficient funds and also
requested to arrange the Cheque amount with a promise to return the
dishonoured Cheque as soon as receive from Bank Manager. That on the
request of Accused No. 1 on 14-08-2023 I paid dishonoured Cheque
 amount of Rs.1,00,000/- in shape of cash to Accused No. 1 towards
amount borrowed by the Accused No. 1 & 2 through the said Cheque
from me, the same was received by the Accused No. 1 & 2 in presence of
said Javahar Singh and Sandeep.

5. That I submit that subsequently when I demanded the Accused No.

1 & 2 through the witnesses Javahar Singh, Sandeep and Sundhar Singh
to repay the borrowed amount with agreed interest to me and return the
dishonoured Cheque, then the Accused No. 1 & 2 bore-grudged on me
and postponed the matter with one or other pretext. That on 16-08-2023
the Accused No. 1 along with his friend attacked on my car and caused
damage, then I made a phone call to 100 Dial, but the Police, Varni did
not take any action. That finally on 18-08-2023 the Accused No. 1 & 2
with ill intention and ill motive to extract more money from me,
blackmailing to file false cases against me as I being a Govt. Employee
and also to avoid the repayment of borrowed amount with agreed interest
to me.

6. That I submit that again on 03-10-2023 at 11:31A.M. when I was

discharging my duties of taking class to the students in school, the
Accused No. 1 & 2 along with Accused No. 3 and Accused No. 4
(Brother of Accused No.2) came to the school premises, attacked on me
and abused in filthy language in presence of school students and
scavenger of the school. Thereafter, the Accused No. 1 to 4 had been
awaiting in school premises for a chance to kidnap the Complainant and
obstructed me from discharging my duties in school and also threatened
 to kill me on that day or on any other day, then I with a fear made a
phone call to 100 Dial, upon which I lodged a complaint to the Police,
Varni and also to the Commissioner of Police, Nizamabad, but the Police
failed to take any action against the Accused No. 1 to 4.

7. That I submit that there is ample evidence to prove the case against
the Accused No. 1 to 4.

8. The Hon’ble Court has got wide powers to refer the Complaint to
S.H.O., Varni and enquire and laid charge sheet.

In view of the above facts and circumstance, the Hon’ble Court

may be pleased to refer the Complaint to the S.H.O., Varni, U/s. 175 (3)
of B.N.S.S. and enquire and laid Charge Sheet after conclude
investigation in the ends of Justice.
DEPONENT

(Vemula Pramod Reddy)

 IN THE COURT OF THE
HON’BLE JUDICIAL FIRST
CLASS MAGISTRATE
AT BODHAN

C.C. NO. OF 2024

Between:-

Sri. Vemula Pramod Reddy.

…Complainant.

AND

Sri. Shubham Madav Singh Thakur & 3

Others.

…Accused.

COMPLAINT FILED U/S. 223 OF

B.N.S.S.

Filed On: -07-2024.

Filed By:

S. Gangadhar Goud &

K. Laxman,
Advocates-Bodhan.