SURANA & SURANA NATIONAL TRIAL ADVOCACY MOOT COURT

& JUDGMENT WRITING COMPETITION COMPETITON - 2014

IN THE COURT OF SESSIONS, BAMBI THANE
State of Bambi
Vs
1. Panna, 2. Saba & 3. Jaimil
S.C. No. 123 of 2014
1. In 1993, Panna Boy, popularly known as Hero Panna was arrested under the provision of Terrorist
and Disruptive Act (TADA) for illegal possession of arms, a 9 mm pistol and an AK-56 assault
rifle. After serving about a year and half in jail, he was released on bail. The case was tried in
various courts and finally in March 2013, the Supreme Court of Barata held him guilty and
sentenced him to 5 years rigorous imprisonment under Arms Act, 1959.
2. Panna Boy belonged to a very illustrious family in the movie industry who were also members of
the ruling party and were very active in politics. Panna Boy had a tumultuous adolescent period due
to his association with friends dealings in drugs. He himself used drugs earlier and was arrested and
served a short sentence of 6 months for possession & drug abuse and was released. Since then he
was a reformed person and took to acting profession seriously.
3. Hero Panna accepted the verdict in all humility and was lodged in the State prison. His conduct was
good and he endeared himself to all inmates and the prison staff. In the prison he spent a lot of time
reading about national leaders, particularly Bapu Ji, who was the Father of Nation of Barata. He
would hear the inmates narrate their problems and try to help them as much as possible. In this
manner, he was known as a kind hearted prisoner. But the stigma of being branded a terrorist and
linked to the communal riots that took place refused to die down. Few in the industry believed that
he was innocent, in spite of the verdict, but there were many who thought he was guilty and has
been lucky only due to his position and family connections.
4. While serving the sentence, a prominent newspaper named Express of Barata reported that he was
let out on furlough 3 times, and on parole two times in continuous succession. The evidence cited
for this was photographs of Panna Boy attending the shooting of his fathers movie, who was a
prominent Actor turned Producer. It is said that when journalists from Express of Barata tried to
click his photograph, he sought to run away and sped in a jeep with his friends. However, three
chickens were killed in this process which made Panna Boy very sad. There are no official records
to conform this event or show any misuse of furlough or parole. Also, the official communiqu from
the Agent of his father disputed all such allegations, and called them efforts to gain publicity by
Express of Barata.
5. Between 2005 and 2009 four movies of Hero Panna were big hits. Many top movie makers and
directors wished to work with him and signed him up for their projects. In at least three movies,
major portion of the shooting were completed and only some scenes with Panna were pending. The
movie industry had invested heavily in Panna and huge advances had already been paid to him. One
movie titled Hit-factory was almost complete. The producer , Mr. Saba had borrowed heavily and
had invested lot money on the lead actress Ms Naika. A few scenes with the lead actress that were
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supposed to be intimate scenes for which Ms. Naika had declined earlier, w ere to be shot and a few
scenes at a big hospital was also remaining to be shot.
6. After the controversy broke, Ms Naika avoided being in the company of Panna. Many overtures by
the film producer Mr. Saba to contact Ms. Naika proved futile. After the conviction by Supreme
Court, Ms. Naika made it known tacitly in an interview to a film magazine that she has an
impeccable name in the industry and do not wish to tarnish it by associating with actors of dubious
character and anti social elements. She also outlined that she belonged to a family of freedom
fighters and her father was a Major in the armed forces. Express of Barata attributed the reason to
the fact that Ms. Naika has been the celebrity-representative of Barata to the Counter-Terrorism
Implementation Task Force (CTITF) of the United Nations and spends all her leisure time to
forward its motto. This message put an end to the hopes of Mr. Saba on completing the film. His
bankers and creditors were pressuring him to refund the loan taken.
7. The major financier Mr. Shaikh told Mr. Saba that if he finished the movie and hand him over all
the rights, he would take care of his creditors and will also give him a decent sum for all his pains.
Mr. Shaiks name was linked to the rumours of the underworld financing of the movie in dustry of
Bambi. Mr. Saba informed this to his Director Jaimil and requested to do something about it.
Incidentally Jaimil also did the story and the script for this movie. On 14 August 2013 Mr. Jaimil
along with Mr. Saba met Ms. Naika at her residence dem anding cooperation for completing the
remaining scenes. Ms. Naika categorically refused and ordered them to leave and requested not to
meet her again. When they showed some resistance, she called her security guard and requested to
show the visitors the door.
8. Due to his political connections and his good conduct, even before he could complete a year in
prison, Panna was allowed parole for a month during December 2013, citing his wife s ill health and
yearnings of his little daughter, who had to be taken car e of during his wifes stay in the hospital.
The print and electronic media lead by Express of Barata covered the event extensively and the
premise was that he could do this only because of his connections and status. But by and large it did
not break into a big controversy.
9. There were demands also from prominent people for pardoning him as he innocently got embroiled
with the anti-social elements. There were bitter criticism for this demand from an equal number of
prominent people who thought he was guilty and this courtesy is being extended only because of his
connections and also the demand from the big wigs of the film industry who were patrons of the
ruling party. He went back to prison after the parole.
10. Within two months i.e. in February, he again applied for parole citing his wifes ill health that
needed constant care. His daughter also needed his presence at this juncture. Much to the surprise of
everybody, he was granted parole for another month on February03, 2014.
11. Panna and his daughter visited the Star hospital regularly almost every day, where his wife was
allegedly taking treatment for an illness that was serious, about which the public had no idea. He
also took his daughter out to shopping to keep her good humour.
12. Star hospital catered to high end clients and had five star facilities. The premises of the Hospital
were also rented for movie and TV serials of reputed production houses that ensured minimum
discomfort to the inmates. The hospital monitored through CCTVs all movements of people in its
premises, so that no untoward incidents happen. They also kept a constant vigil so that media
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persons do not enter and be a nuisance to its VIP and celebrity inmates. But outside the hospital
building there were always some media persons and fans waiting to get a glimpse of their favourite
stars and also if they were lucky a few pictures.
13. On February 6, 2014, Jaimil complained of chest pain and uneasiness and got himself admitted in
Star Hospital. The movie industry was shocked as he was a star director and there were many
projects pending. But a communiqu from his team informed that there was nothing serious and
doctors have advised him 2 weeks complete rest. There were steady stream of visitors from the
tinsel town. At the same time there was a shoot going on for a supposedly new project. Cameras and
lights were discreetly placed and security was increased not to allow any strangers.
14. Panna as usual came everyday with his daughter and sat next to his wifes bed. Later his daughter
was sent out with her care taker/nurse. Then after an hour, he entered another room, where there
was an old woman lying in the bed, which on closer scrutiny would reveal that she was a reputed
actress Smt. Mashal, of yesteryears who is now donning mothers role for top stars in the movies.
There was another young actress, who had a striking resemblance to Ms. Naika, but a closer
scrutiny would reveal that she is Ms. Poonam, a starlet. And the room had readied for a shoot.
15. On 8 August 2014, Panna was seen in Central Mall along with his daughter. He was wearing a
colourful outfit; His daughter made fun of him and asked when he changed his dress. He just smiled
and asked, whether it is good nor not? She replied that the design was old and out of fashion. She
was asked to go with her nanny and he would join her later.
16. After a while a crew of movie starlets led by Ms. Poonam descended in the mall followed by Mr.
Jaimil. Lights were on for the shoot.
17. On 14 Feb 2014, on Valentines Day there were full page ads of Releasing Shortly the movie Hit
Factory an explosive love story, in popular newspapers and magazines. At the same time, a
controversy also broke on the regular release of Panna on Parole due to his political connections.
There were rumours that he was shooting in secret for movies, though no details were given.
18. On hearing the rumours and on seeing the ads, on 16 Feb 2014, Ms Naika filed a suit in the High
Court of Bambi for permanent injunction of the movie as she has acted only in a few scenes and has
categorically stated to the producers that she has completely dissociated from the movie and had
returned the advance taken. But now there is some conspiracy and they have used a look alike to
complete the movie. If the movie is released with her in the lead role, casting alongside a convicted
terrorist, it would cause irreparable damage to her image and career. That evening she received two
anonymous phone calls on her mobile threatening of dire consequences to her and family, if she
does not withdraw the suit.
19. Next day, she filed a criminal complaint in the Bambi Central police station against Mr. Saba, and
Mr. Jaimil and named Hero Panna as a co-conspirator. She alleged that the trio has conspired and
used a body double impersonating her, for the shoot with Panna, a convict who was on parole. This
has maligned her image and career and also maligned the image of her family. They have also
threatened her and her family members with dire consequences if she does not withdraw the suit
against them. She also questioned the propriety of his acting in movies while on parole. The
Assistant Commissioner took cognizance of the complaint filed an FIR and ordered for enquiry. Mr.
Pannas parole was cancelled and he was sent back to prison. A warrant was obtained from the

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metropolitan magistrate for the arrest of Mr. Saba and Mr. Jaimil for engaging in prohibited activity
with a convict. Inspector Sunder was entrusted with the investigation.
20. On completion of the investigation the police forwarded the Final Report (Charge sheet) to the
Magistr ate Court. The Court took cognizance of the report and thereafter committed the case to the
Court of Sessions in Bambi Thane. After complying with the statutory requirements the Court of
Sessions framed charges against the accused under Sections
a. Mr. Panna Boy under sections 120 B read with 34, 227, 501 & 502 of BPC
b. Mr. Saba under sections 120 B read with 34, 385, 501 & 502 of BPC
c. Mr. Jaimil - 120 B read with 34, 385, 501 & 502 of BPC
The case is now posted for trial. The laws of Barata are analogous to the laws of India.
It is presumed that State of Bambi has adopted the Model Prison Manual for The
Superintendence and Management of Prisons in India prepared by Bureau of Police Research
and Development Ministry of Home Affairs, Government of India, New Delhi 2003 as its Central
Prison Manual. Hitherto State of Bambi had followed Bambi Prison Manual which is similar
to Maharashtra Prison Manual, 1979.

List of Witnesses
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

Mr. Williams, Superintendent, Star Hospital (PW 1)

Inspector Mr. Sundar, Investigating Officer (PW 2 )
Ms. Kushboo, Secretary, Panna Boy Fan Club (PW 3)
Ms. Naika, Actress (PW 4)
Mr. Ganesh, Camera Man (PW 5)
Mr. Panna Boy (DW 1)
Mr. Jaimil (DW 2)
Mr. Saba (DW 3)
Ms. Poonam (DW 4)
Smt. Mashaal, actress (DW 5)

[For the purposes of the competition it is to be presumed that Mr. Panna Boy (A 1) Mr. Saba (A2) and Mr.
Jaimil (A3) have consented to be examined as witnesses during the trial. However, as per the rules of the
competition the teams may examine all or some (a minimum of 4) of the ten witnesses within the time
allotted to them.]
List of Exhibits
1. Security CD, Star Hospital
2. Security CD, Central Mall
3. Audio recording of call received on Ms. Naikas, mobile
4. Transcript of call details from Cello mobile company records (corroborated with voice
recording).
5. Advertisement of the movie Hit Factory

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Annexure: 1
Statement of Witnesses
Persons examined:
1. Mr. Williams, Superintendent, Star Hospital
2. Inspector Mr. Sundar, Investigating Officer
3. Ms. Kushboo, Secretary, Panna Boy Fan Club
4. Ms. Naika, Actress
5. Mr. Ganesh, Camera Man
6. Mr. Panna Boy
7. Mr. Jaimil
8. Mr. Saba
9. Ms. Poonam
10. Smt. Mashaal, actress
1. Mr. Williams, Superintendent, Star Hospital
I am the superintendent of Star Hospital. The hospital caters to health care of high class people with 5star
comforts. Mostly VIPs, celebrities and rich people take the services of the hospital. We have full security
facilities in place considering the important people who take our services. Occasionally we allow the
facility for shooting of films taking care that it does not intrude into the normal course of rendering of
services. Our clients and customers are aware of this. We have CCTV installed in the common area of the
premises. We take adequate care that the privacy of the customers is not violated. From 5 10 Feb 2014,
the premise was booked for shooting. I do not know the full details as it was finalised by the directors of the
hospital, who are abroad being permanent residents of Republic of Somaliland.
2. Ms. Kushboo, Secretary, Panna Boy Fan Club
I am Khushboo, fan of Panna Boy and also secretary of the fan club. I had a small bout of Anomalous
trichromacy (of the nature Protanomaly and Deuteranomaly) in 2003, but it is cured now. I went to the
hospital for a review and was lucky to see my idol Panna Boy. I go the hospital daily to have a view of my
favourite actor. I would not miss a chance to watch the shoot of my hero. I waved to him and he waved me
back on 8 Feb 2014 at the Star Hospital gate. He was wearing a white kurta and pyjama on that day. Later I
came to know from a friend of mine that there will be a shoot at Central Mall that day. So I rushed to the
Central Mall immediately and was not disappointed. It was a very informal shoot kind of thing that there
were some regular customers too. Pannaji was wearing a colourful retro outfit and looked cute. Probably it
was a shoot as bright lights were on and cameras were placed. I had taken a picture of Pannaji with my
mobile and sent it to my friend by whatsapp.
3. Ms. Naika, Actress
I am Naika, leading actress and model for top production companies. I signed up for a movie with Mr. Saba,
directed by Mr. Jaimil. The lead actor was Mr. Panna Boy. I had reservations acting with him and since Mr.
Jaimil had given me chances during my early days, I agreed. Mr. Panna, though a good actor had lot of
personal problems. He was arrested for drug abuse. He did not keep up with his schedules. This had upset
my other schedules many a times. I had put up with it because of Mr. Jaimil. But when Mr. Panna got into
anti national activities, I had cut off all ties with him and had categorically informed Mr. Jaimil and Mr.
Saba that I cannot continue with the project Hit Factory and had returned the advance taken. On 5th
February 2014 Mr. Saba and Mr. Jaimil came to my house. They made a request to complete the movie and
promised to pay my fee in full. I refused and said that I do not have time as I am fully booked. Moreover,
Mr. Panna is in prison for anti national activities. They said it can be arranged discreetly for a shoot of
important scenes and the rest can be used by editing techniques with the footages already shot. I refused and
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said it will not be good for my career to be associated with him. When they persisted with their demand, I
had to call my security guard to make them leave. On 14 Feb 2014, I saw the ads in the prominent
newspaper and magazines about the release of the movie with me in the lead. I had sought injunction from
High Court of the release of the movie. That evening I had received threatening calls from Mr. Saba and
Mr. Jaimil that I have to face dire consequences if do not withdraw the case. The calls came in my personal
phone. The number is known only to very few people. Mr.Jaimil and Mr. Saba are among them. I also
received a call from my friend that she has come across some information in whatsapp that Panna Boy is
shooting for a movie at the Star Hospital, and told me to please check up whats happening. So I lodged a
complaint with Bambi Thana police station. I cannot say if non-terrorists can also be convicted under some
provision of TADA. I am also not a legal person to know if a convict under Arms Act will be called a nonterrorist. It creates disgust in me when I hear about people who get involved in violence of any manner and
innocent people including children and women are killed.
4. Mr. Ganesh, Camera Man
I am Ganesh and I am a cinematographer. I have worked in a few movies. I am not the regular cameraman
for this movie. I was asked to take a few shots which were explained to me. I was not told about the actors.
I was only mentioned it is an unnamed movie and the characters were mentioned as hero, heroine and
mataji. It was shot in the Hospital, then a VIP guest room drawing hall and in the bed room and later next
day in Central Mall. I was surprised to see Pannaji. I could recognise madam Mashaalji. There were some
intimate scenes shot with Ms. Poonam, a budding starlet who has in some angles close resemblance to Ms.
Naika. I was told by the director to concentrate on those angles more in the shots. I thought it was a good
career opportunity for me to work with Mr. Jaimil.
5. Mr. Panna Boy
I am Panna Boy and I am an actor. I am on parole due to the ill health of my wife. I visit Star Hospital
everyday to attend to her. I visit with my daughter mostly. I had also visited central Mall with my daughter
as she asked that I buy her a few things. Everybody knows that Star Hospital also shooting of movies and
TV serials. There was some program going on when I visited the hospital. I had seen a few people whom I
had known earlier. I waved to a few people who greeted me. I had taken photograph with few people who
knew me. I had also met Smt. Mashaal in the Hospital. Probably she had come for a shoot. I spent some
time with her. Yes, I met Ms. Poonam too. I think I have seen her earlier in one of the movies in a small
role. She wished me well and enquired about my wife and expressed a desire to work with me in future. I
nodded. Then she asked me whether I can be photographed with her and I said, why not? Thats it.
6. Mr. Jaimil
I am Jaimil and I am a movie director. I had signed up Pannaji and Naikaji for a movie produced by Mr.
Saba. I handle the script for the movie too. Most of the shoot of the movie is over and only a few scenes are
left. It is very unfortunate that Pannaji got into trouble and the movie was stalled. If you ask me, I totally
believe he is innocent and wrongly being framed. He is such a pure person, totally following Bapu jis
ideals. Even Supreme Court can go wrong; has it not happened before? Are there not reviews and curative
petitions filed, and sometimes allowed? We wanted to complete the film by adopting editing techniques and
Sabaji and me approached Naikaji to help complete the film. She refused. So we trie d superimposing her
earlier shots and completing the movie. I was admitted in Star Hospital for heart problems but now I am
fine. There was some shooting going on Star Hospital which is quite normal for us. I met Pannaji and
greeted him. He inquired about my health and I spent some time with him. The people who were shooting
were happy to see us and probably they have taken a few footage of shoot of Pannaji. I categorically deny
that I threatened Ms. Naika over phone. The court will decide whether the movie will be released or not. I
have not done any wrong.

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7. Mr. Saba
I am Saba Karim. I am just known as Saba to everybody. I am a movie and TV serial producer. I have done
few commercials too. I am the producer for the movie Hit Factory starring Pannaji and Naikaji. The
movie direction and script is being handled by Jaimilji. I have invested a lot of money in the movie and I
have borrowed money from various sources for the project. I approached Jaimilji to somehow complete the
project. We both approached Naikaji to cooperate and complete the movie. She was rude, refused to help
and unceremoniously sent us out. I did not make any threatening calls to her. I heard that the calls were
made from a public phone. Anybody could have done it. Pannaji has lot of fans. They must have been upset
by Naikajis move. I am now just in the process of beginning a new TV serial. I have roped in some
celebrities of yesteryear and some budding starlets who could not make it big in the movies. One has to earn
his bread you know.
8. Ms. Poonam
I am Poonam and I am a budding actress and a model. People say that I somewhat resemble Ms. Naika. I
have been used as a dupe for Ms. Naika for few earlier movies when shots were risky. I am also used when
the scenes are a little more intimate and lead actresses avoid this many a times. This is very common in
movie industry. I dont know why so much fuss is made now. On 8 and 9 February 2014, I was in Star
Hospital shooting for a new TV serial which is yet unnamed. I was happy to meet Pannaji at the Hospital.
There was an unusual amount of noise that day, due to several celebrities admitted in the Hospital and their
fans making ruckus. I barely managed to make myself audible to enquire about him and his wifes health. I
asked whether it is okay with him if I take a few pictures or a video clip with him. He was so kind and
generous that he simply nodded to say yes, and happily posed with me.
9. Smt. Mashaal, actress
I am Mashaal. I am an actress. I have acted in many films in lead roles. Now I am 65 years old. I act in the
role that befits my age. I was in Star Hospital for a TV serial shoot. Mr. Pannaji was so kind to meet me
there and enquired about me and my family. We spent some time together. The camera man enquired
whether he can take a few shots of me with Pannaji. I said you are most welcome. He must have taken some
shots of us together the way he thinks fit. I had worked earlier with Pannaji in 3 movies. I have played the
role of his mother. So what is the big deal?

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Annexure: 2
FIRST INFORMATION REPORT

1. District: Bambi

PS: Bambi Thane PS Year: 2014

2. Act: B.P.C.

Section 385, 501 & 502

FIR No: 101

Date: 17 Feb 2014

3. Occurrence of Offence: 16 Feb 2014

Time from: 6:00 p.m.
Time to: unknown
Information recorded by: Inspector Sundar
4. Type of Information: Written / Oral: Oral and written
5. Place of Occurrence: Direction/Distance from PS: Residence of Ms. Naika, No. 15, Park Street,
Sherwood Avenue, Bambi - 20 about 1.5 Km North from Police Station.
Beat No: 61B
6. Complainant/Informant, Name: (self) Ms. Naika,
Date of Birth: 21.10.1991
Date of Issue: 17.03.2010

Nationality: Barat

Passport No: K2536464

7. Basis on which FIR is lodged: 1. Oral and written complaint by Ms. Naika
8. Details of Known/Unknown/Suspected accused with full particulars: Suspected persons
Mr. Panna Boy, Age 50, S/o Mr. Heera Boy
Mr. Saba, Age 55, S/o Late Mr. Musa Karim
Mr. Jaimil, Age 52, S/o Mr. Kabir
Unknown Persons - N A
9. Reasons for delay in reporting by the complainant/informant: NA
10. Particulars of Injuries sustained: NA
11. Particulars of Post Mortem Report : NA
12. Post Mortem report done by: NA
13. Inquest report/ Unnatural death Case No. if any .. NA

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Annexure: - 3
Report of police officer on completion of investigation
(Under Section 173 of Cr.Pc.)
Filed on 30/03/2014
a) The Name of the Accused:

1. Panna Boy
2. Mr. Saba
3. Mr. Jaimil

b) Nature of information: FIR registered by the Police Inspector/Investigating Officer on the basis
of information received from known sources.
c) The Names of persons who appear to be acquainted with the circumstances of the case:
Mr. Williams, Mr. Ganesh, Ms. Poonam, Smt. Mashaal, Ms. Khushboo.
d) Whether any offence appears to have been committed and, if so, by whom : Yes. Threat of dire
consequences issued to Ms. Naika, actress over phone for withdrawing an injunction in High
Court for release of the Movie Hit Factory by producer Mr. Saba and Director Mr. Jaimil.
Movie shot with Ms. Poonam using her as a body double for Ms. Naika along with Mr. Panna
Boy, a convict, who is on parole for attending to his allegedly ailing wife. Prima facie case
exists under sections 120 B read with 34, 227, 501 & 502 of Barat Penal Code.
1. On 5 February 2014, Mr. Saba, a movie producer and Mr. Jaimil, a prominent director and
playwright visited Ms. Naika, a leading actress at her residence in 15, Park Street, Bambi to
persuade her to complete the movie Hit Factory. They had signed Ms Naika with Mr. Panna
Boy, a leading actor who is in prison convicted under Arms Act. He was charged under TADA
along with many other associates who were declared terrorists. The Supreme Court dropped the
charges under TADA and sentenced to 6 years RI which was reduced to 5 years as he had
already served 15 months in prison. Due to this background of Mr. Panna, Ms Naika refused to
act in the movie Hit Factory for which she had signed earlier. Both of them met her earlier in
August 2013 requesting her to complete the movie. She had to seek her guards help to send
them out. She informs that she had returned the advance taken for the movie. On Feb 16 2014,
seeing the advertisements given in various newspapers and magazines regarding the release of
the movie Hit Factory, with her in the lead role, she approached the High Court for permanent
injunction. That evening she received two threatening callas on her mobile (No. 12345678),
which she thinks are from Mr. Saba and Mr. Jaimil. And immediately she preferred a complaint
at this police station on 17 Feb 2014.
2. As I knew that Mr. Panna Boy is out on parole, I went to Star Hospital and met the
superintendent. On enquiry, he admitted that Mr. Panna Boy regularly come to the hospital to
look after his wife. He also said that it is true that Star Hospital lets it premise for shooting films
and TV serials. He also admitted that Mr. Jaimil was also under treatment at the hospital for
some heart problems and advised rest by doctors. On further enquiry he admitted that Mr. Saba
was also present on many occasions. He was not aware which movies shoot was on as this was
agreed and permitted by the directors of the hospital who are abroad. He also said that the
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hospital was CCTV enabled in the public areas. I have given the request for the copies of the
recording from 6 17 Feb2014, which he said would be given as obtaining the requisite
permission. Accordingly I have collected the same.
3. After viewing the video, I have come to the conclusion that some kind of shooting for a movie
was on progress and I could see Mr. Jaimil interacting with the camera man and another woman,
whom I found out to be Ms. Poonam, a starlet, who is also playing some role in the movie. The
video recordings of the cameras outside the hospital shows, people waiting to have a glimpse of
Mr. Panna Boy. In one shot Mr. Panna Boy is also seen waving back. Panna Boy was mostly
wearing white kurta and pyjamas. But on 8 Feb 2014 shots, I could see at some time, he was
wearing a colourful shirt, which was somewhat old fashioned. When I questioned the
cameraman, what is the project he was shooting, he replied that he was not aware of that. On
further questioning about the colourful dress of Mr. Panna Boy, he said it may be for continuity
from the previous scenes. Also I could see a woman almost on all days at the gate. I enquired
and found out that she was Ms. Khushboo, a diehard fan of Mr. Panna Boy. I could also see
another man with Mr. Jaimil, whom I later come to know as Mr. Saba, the producer of the film.
4. On questioning Ms. Khushboo, I learnt that she is also the secretary of Panna Boy fan club. She
also said that she had been to Central Mall where she had taken a picture along with Pannaji.
She also thinks that there was some kind of shoot going on at the Star Hospital and Central Mall
but do not know the details. She said that she has seen Mashaalji at the hospital. But she does
not know the full details.
5. With this information I went to Central Mall and spoke to the Mall superintendent. He
confirmed that there was a shoot at the Mall and Mr. Panna Boy and Ms. Poonam were present.
He said there were some technicians, camera man and few others during the shoot. He also
accepted to provide the CCTV coverage on 8 & 9 Feb 2014. On viewing the same I could see
Mr. Panna Boy and Ms. Poonam and a camer aman and a few others. I could also spot Ms.
Khusboo in some frames for a few minutes. I could also spot Mr. Saba in the frames.
6. On 25 Feb 2014, I met Smt Mashaal at her residence and enquired about her movements and
activities on 8 & 9 Feb 2014. I also qu estioned about her presence at Star Hospital. She was
rather embarrassed and was hesitant to share the details. She first said that she went to the
hospital for a routine check up. On questioning her further on her health conditions and which
doctor she met, she came out openly and said that she met Mr. Panna Boy and Mr. Jaimil. They
asked whether they could take a few shots with her with Panna Boy and Ms. Poonam and she
agreed.
7. Later in the evening I met Ms. Poonam at MM studios. When I confronted her with the details,
she accepted that she was shooting with Pannaji and also some scenes with Pannaji and
Mashaalji. She says that she does not know the full details but could guess that she was used as
a dupe kind of role in the place of Ms. Naika. She did not object because she has been used to
play her role in risky and other scenes (she was not willing to discuss what kind of scene it is) in
her absence, at least twice in her earlier movies.
8. Next I met the camera man Mr. Ganesh. He confirmed that there was a shoot of a film the
details of which he is not aware of. He agreed that he shot Mr. Panna Boy and Ms. Poonam in
the VIP guest house drawing hall and bed room. He also shot some scenes with Mashaalji. He
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agreed that Ms. Poonam in certain angles resembles Ms. Naika. Mr. Jaimil the director,
instructed him to take the shots at an angle that this particular trait of Ms. Poonam is best
brought out. He is happy for this work, as Mr. Jaimil is a very popular director and has promised
him further work in the future. This is a good break for a budding cinematographer like him.
9. On 26 Feb 2014 I met Mr. Jaimil at MM studios. I enquired about his health as he was admitted
in the Star Hospital for a week. He could sense the import of my enquiry and directly asked
what I needed. I told him that I had the details of the activities that took place in Star Hospital
and Central Mall. I requested him to come out with all details regarding Panna Boy, Ms. Naika,
Smt. Mashaal and Ms. Poonam. I also asked him for what movie he was shooting. He replied
that he did not shoot for any movie but had shot a few scenes with Panna and Poonam as he was
lucky that some TV serial is being shot at the Hospital. He had used the services of the new
camera man Ganesh. He was under pressure to fin ish the movie Hit Factory that led to his ill
health. He intends to finish it with super imposing some frames from the previous scenes he had
shot. He said with the present day technology such things have become possible.
10. When I was speaking to Mr. Jaimil, Mr. Saba came by and when he saw me, he was about to
leave. But I noticed him and gestured to come. He came and I said that I need to question him
on certain matters. If he was free we could do it then and there. Mr. Jaimil left us. We went to
the can teen nearby and had coffee together. He appeared to be cool, but could notice, he was
tense inside. After I told him that I had met all concerned and know the details and needs a little
more to fill in the gaps. He could help me do it. He agreed.
11. He said that he had burnt his hands in producing the movie Hit Factory He had borrowed
heavily and under pressure to return it. He had to finish it. He approached Jaimil and requested
his help to complete. They approached Ms. Naika to help and cooperate with Panna Boy, which
she flatly refused and drove us out of her residence through her security guard. He was presently
producing a TV serial to earn his livelihood. They had a few shots planned at Star Hospital and
Central Mall. He did not expect to meet Panna Boy at the Hospital and was happy to know that
he was out on parole. This only prompted him to approach Ms. Naika and seek her help to
complete the movie as there were only a few scenes important scenes pending. The less
important ones can be finished with editing and super imposing of earlier scenes and with
dupes. He just took some shots of Panna Boy and Ms Poonam as they were available at that
time and for old times sake. He was thankful that Pannaji obliged. He vehemently denied
having threatened Ms. Naika over phone.
12. On analysing the meeting with all the above persons and a few phone calls to clear certain
doubts, It is my submission
a. Mr. Saba and Mr. Jaimil had foreknowledge that Mr. Panna Boy will be out on Parole
b. Or they could have influenced Mr. Panna to try and obtain parole
c. Mr. Pannas wifes ailment was not as serious that requires his personal constant attention.
But in her absence, his daughter was alone with the matron.
d. With Pannas parole, if Ms. Naika cooperated they could easily complete the important
scenes and with editing techniques, they talked about, they could safely complete the movie.
e. It is true that Mr. Saba is under extreme pressure to complete the movie. His creditors were
exerting this pressure.
f. Mr. Jaimil was pressurised by Mr. Saba

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g. Mr. Panna played along. Ms Poonam thought it as a good opportunity to be in the good
books of Mr. Saba, Mr. Jaimil and above all Mr. Panna as they promised her some good
roles in the future projects.
h. They arranged for the shoot in Star Hospital and Central Mall. On the pretext of shooting a
TV serial, they had shot the scenes for the movie Hit Factory. The dress which Panna
wore was the same as was seen in the previous scenes of the movie. I had verified it in an
old film magazine. Mr. Panna was wearing the same shirt. This has been corroborated by the
camera man Mr. Ganesh as he has hinted it could be for continuity purpose.
i. The release of the advertisement in prominent newspaper and magazines confirms this.
j. They could have issued some kind of threat to Ms. Naika to this end.

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Annexure: 4
Call record of Phone No. 4800084000 (Ms. Naika)
Provided by Mr. Sinha of ExTel
Transcript
Phone No 12345678 (Public Booth) time: 6.05 p.m. on 16 Feb 2014
Male voice1: Hello Naikaji
Naika: who is this? How did you get this number?
Male voice1: We know everything. Heard that you refused to cooperate in completing the film. It is not
good for you. Not good at all.
Naika: Who are you?
Male voice1: That does not matter. Better cooperate or face the consequences. Keep in mind you have
a big family.
Naika: hello hello (call is cut)

Phone No 56781234 (Public Booth) time: 6.15 p.m. on 16 Feb 2014

Male voice 2: Hello Naika
Naika: Who are you?
Male voice2: Ha.. Ha. Ha... you must be nave to ask such silly questions. Were you expecting my
call ha.. ha.. ha
Naika: I will report to the police
Male voice2: By all means. Finish the movie dear. Just two days shoot very discreet.. Else.Results
will be very tragic
Naika cuts the phone
It was informed that the distance between the two public phones were about1.5 kms. It can be assumed
that there are two persons who made the calls.

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Annexure: 5
POSTERS / ADVERTISEMENT RELEASED IN NEWSPAPERS AND FILM MAGAZINES

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