IN THE COURT OF THE HON’BLE PRINCIPAL DISTRICT AND SESSIONS

JUDGE AT: ADILABAD

Crl. M. P. No. /2024

In
Crime No. 215 /2024
BETWEEN:

1. Ananth Kumar Samnani, S/o.

2. Md. Naveed, S/o.
... Petitioner/Accused No.3 & 4

//AND//

STATE OF TELANGANA THROUGH

SHO Police Station Adilabad Rural
Rep. by the Public Prosecutor
.... Respondent/Complainant
PETITION FILED UNDER SECTION 482 OF BNSS

May it please your Honour:

U/Sec. 318 (4), 336 (3), 340 (2), 316

Offences: (5) R/w. 3 (5) of BNS Act 2023 &
Section 82 of Registration Act-1908
Date & Time of
01.10.2024 & 08.10.2024
Offence:
JFCM: Spl. JFCM (PCR) Adilabad
Date of Arrest: Not Arrested (Anticipatory Bail)

1. That the Police Adilabad Rural registered a case in Crime No. 215/2024
U/Sec. 318 (4), 336 (3), 340 (2), 316 (5) R/w. 3 (5) of BNS Act 2023 &
Section 82 of Registration Act-1908 against the petitioners and others.

2. The brief facts of the case are that, on 02-11-2024 at 1800 hrs the
complainant Bodegum Praveenn s/o Narender, age: 42 yrs, Caste:
Mangali, Occ: Sub Register at Adilabad, R/o: Gajulapet Nizamabad district
Came to PS and lodged a Telugu written report in which he stated that he
 is working as Sub registrar at SRO Adilabad since 01.08.2024. Four
Pattedars 1. MD Azeem 2. MD Qumeni Ahmed 3. Ananth Kumar Samnan
4. MD Naveed they prepared a Lay out at Bhuktapur shivar in Sy.No. 67
and 64 without taking prior permission from the concerned authorities.
They along with one agent namely Musheer Khan Prepared a forged
document of DTCP approval thereby they cheated the Govt. And the
Vendees and on 01.10.2024 they fraudulently submitted forged DTCP
approval order and make them believe to be a genuine order. And they
executed registerations vide Doc.No.s 6888/2024,6889/2024,6901/2024,
6904/2024 and on 08.10.204 again they executed registerations vide
Doc.No. 7026/2024, 7027/2024, 7028/2024,7029/2024,
7030/2024,7031/2024, 7032/2024,7033/2024. Latet on 25.10.2024 the
complainant received a letter from the Municipal office, Adilabad vide
Lr.No. G1/1070/2024 dated 24.10.2024. in which it is came to know that
the DTCP approval order is Fake. Musheer Khan is doing as document
writer besides the complainant's office and with fraudulent intension to
cheat the common people and Municipal department and Registration
department, they breaches the trust of this offence. Further he request to
take necessary action against the above said persons who cheated and
committed breach of trust.

3. That the concern police has been arrested the accused No.1 & 2 and
produced before Learned Spl. JFCM PCR court at Adilabad. Accordingly
the Learned lower court has pleased to granted the bail to the accused
No.1 & 2 at the time of remand with condition to furnish the personal bond
of Rs. 20,000/- with two sureties.

4. That according to Complaint and RCD the Accused No.5 is created the
Fake DTCP Approval order and handover the said order to the Accused
No.1 to 4 and they were register the same to other persons.
5. That the Section 316 (5) of the BNS act is not applicable to petitioners
herein and they were no way concern with DTCP Approval order. The fact
is also not known whether the DTPC order is fake or not. The Accused
No.5 has cheated the Petitioners herein.

6. That the above allegations made against the Petitioners are false and
baseless.

7. That the petitioners herein are innocent and they are not committed any
offence as alleged in this case. The petitioners are law abiding citizens with
no prior criminal antecedents or records so the question of committing the
alleged offence does not arise but they have been implicated in this case
without any fault on their part but to defame them in the society they have
been implicated.

8. That the Petitioners are responsible persons and the sole breadwinner to
their family. If they are arrested, their families will suffer immensely.

9. That the petitioners are entitled to anticipatory bail in the above said
circumstances.

10. That the police personnel are trying to effect the arrest of the
petitioners and if so happened, the petitioners will be put to practical
difficulties, hardships, and defamed in the society.

11. That no other bail petition is filed or pending in the matter at any other
court of law.

12. That the other grounds will be argued at the time of arguments.

13. That the petitioner are ready to face the trial and ready to furnish
adequate sureties to the satisfaction of this Hon’ble Court in the event of
granting anticipatory bail.
 Therefore it is prayed, that the Hon’ble court may kindly be pleased to
allow this petition by granting anticipatory bail to the Petitioners/Accused No.3
& 4 herein, in the interest of justice.

Date: 05.11.2024
Place: Adilabad.
Counsel for Petitioners/A3 & 4

NOTE: The Petitioners/Accused No. 3 & 4 have them self signed on the
Memo of Appearance and engaged Sri. Ghanshyam Singh Chauhan, Sri.
Avula Maneendranath Yadav & Ahmed Abdul Naseem Advocates to move this
bail petition.

Date: 05.11.2024
Place: Adilabad.
Counsel for Petitioners/A3 & 4
IN THE COURT OF THE HON’BLE
PRINCIPAL DISTRICT AND
SESSIONS JUDGE AT:
ADILABAD

Crl. M. P. No. /2024

In
Crime No. 215 /2024
BETWEEN:

1. Ananth Kumar Samnani, S/o.

2. Md. Naveed, S/o.
... Petitioner/Accused No.3 & 4

//AND//

STATE OF TELANGANA
THROUGH
SHO Police Station Adilabad Rural
Rep. by the Public Prosecutor
.... Respondent/Complainant

PETITION FILED UNDER

SECTION 482 OF BNSS ACT

Filed on: 05.11.2024

Filed by:
Counsel for petitioners

Address for service:

GHANSHYAM SINGH
CHAUHAN,
AVULA MANEENDRANATH YADAV
&
AHMED ABDUL NASEEM
ADVOCATES, ADILABAD
 FORM NO.61
(171 PAYMENT INTO COURT OF CASH/PROCESS FEE DEPOSIT)

IN THE COURT OF THE HON’BLE PRINCIPAL DISTRICT AND SESSIONS

JUDGE AT: ADILABAD

Crl. M. P. No. /2024

In
Crime No. 215 /2024
BETWEEN:

Ananth Kumar Samnani and another

... Petitioner/Accused No.3 & 4

//AND//

STATE OF TELANGANA THROUGH

SHO Police Station Adilabad Rural
Rep. by the Public Prosecutor
.... Respondent/Complainant

Nature of Name and description Village Distance in Travelling Class of AMOUNT Process Expenses of
process to be of person on whom or taluqa miles from allowances to allowances
issued or onwhose property the district the court and from the Fee sale or
purpose for process is to executed munsiff house court house commission
which money is where
deposited and process is
order if any to be
under which executed
deposit made
Notice to
PP

Process 1/-
paid

It is requested that the sum or Rupees 1/- may be received for the purpose above mentioned

Date this the 05.11.2024 ADVOCATE FOR PETITIONER

 MEMO OF APPEARANCE
(UNDER 41(1) CRIMINAL RULE OF PRACTICE)

IN THE COURT OF THE HON’BLE PRINCIPAL DISTRICT AND SESSIONS

JUDGE AT: ADILABAD

Crl. M. P. No. /2024

In
Crime No. 215 /2024
BETWEEN:

Ananth Kumar Samnani and another

... Petitioner/Accused No.3 & 4

//AND//

STATE OF TELANGANA THROUGH

SHO Police Station Adilabad Rural
Rep. by the Public Prosecutor
.... Respondent/Complainant

GHANSHYAM SINGH CHAUHAN,

A MANEENDRANATH YADAV
&
AHMED ABDUL NASEEM
ADVOCATES, ADILABAD
Hereby declare that I have been duly instructed on by the Accused/ Interested
person to appear for the accused by
1. Ananth Kumar Samnani, S/o.
2. Md. Naveed, S/o.

The Petitioner himself authorized to defend/ prosecute/ her/them Pending

before this Hon’ble Court

Signature of Accused/persons in instructed

Place: Adilabad
Date: 05.11.2024
Advocate