AND The State of Punjab Rep by its P.P. High Court of Punjab and Haryana
Respondent/Complainant Respondent/Complaina nt
The address for service to the petitioner is that of his counsel M/s. D. N. Goyal & Associates, Advocates, Patiala
The above named petitioner begs to present this memorandum of Criminal Petition being aggrieved by entertaining a Criminal Complaint by the Court of Session, Patiala and registered an FIR against the Petitioner and under FIR No,….dated… for the following among other grounds. Brief facts of the Case:
1. 2. 3.
Grounds
1. That the learned Session Judge ought to have rejected the Criminal Complaint filed by the third respondent under section 200 of Cr. P.C for the reasons that the matter in issue is purely a Civil dispute and the same does not constitute the alleged offences of Cheating or Criminal Breach of trust. 2. The said FIR under No…. does not establish prima facie that the petitioners have committed the offences under section…. Of …Act 3. The learned Session Judge ought to have rejected the Complaint for the reason that it has no jurisdiction jurisdiction to entertain entertain the Complaint. Complaint. 4. The FIR is liable to be quashed on the ground that the allegations of the Complainant are purely of civil nature and it does not establish even prima facie the alleged offence. 5. The FIR is liable to be quashed as the Complainant is not entitled to claim the amount until the payments. 6. The other grounds will be urged at the time of hearing of the revision Petition. Pending disposal of the main Petition the Petitioner herein prays that this Hon’ble Court may be pleased to grant stay for all further proceedings of the impugned FIR bearing No….. dated…. against the Petitioner and to pass such other order orders as this Hon’ble Court deems fit and proper in the circumstances of the case. Therefore the Petitioner prays that the Hon’ble Court may be pleased to quash the Criminal Case Proceedings before the Session Judge, Patiala and also the FIR No…..dated…… registered at SHO….. against the Petitioner and to pass such other order or orders as this Hon’ble Court deems just and proper in the circumstances of the case. Place: Dated :
