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True Colors of a Vile Wife

Category: Sandeep Pamarati

Sandeep Pamarati Vs State of AP (Release of Passport)

Posted on November 5, 2022 by ShadesOfKnife

My passport was deposited at 3rd Junior Civil Judge Court, Ongole as (illegally) directed by the AP High Court while granting me (unwarranted) Anticipatory Bail. Here is the Bail Order in Crl.P No. 3886 of 2017…

2017-07-18 Bail Application ALLOWED to A1 in HC

To have this released, I was advised to file an IA in above long-disposed-in-2017 Crl.P. So I got the IA filed in Feb 2022. Then the IA case was numbered as IASR 3300/2022 but NOT listed. Because, the section staff at AP HC do not have the original bundle here at Amaravati. On this ground, the IA was kept lying. On top of this, I get to know in October 2022 that, APHC staff sent a requisition to Telangana HC in April 2022 seeking this bundle, but it has not come. Hmm..


Struggle didn’t end there. After discussions with staff from 3 sections at APHC, I decided (they advised me!) to file a new Crl.P seeking Quash of earlier Order (actually just the illegal condition to deposit my passport), ignoring the earlier filed IA. I wrote said petition and went ahead with it. Here is the Petition copy. The case number is Crl.P No. 8571 of 2022.

2022-10-20 Release my passport in 498A IPC Case v0.5

The first question raised by the bench during cause list motion hearing was, tell me the authority of this Court to quash an earlier order of this same Court, only after that I will proceed with merits, admitting that the facts indicate I suffered genuinely. Since I had no answer to that question at that time, I decided to withdraw the petition with liberty to refile.


Now, the next step I would like to take is to mention the IA before appropriate Court and pray for listing the IA, not insisting for Original case bundle… Coming Monday…

Posted in Sandeep Pamarati | Tagged Sandeep Pamarati Vs State of AP (Release of Passport) | Leave a comment

Sandeep Pamarati Vs State of AP and Anr on 29 Sep 2022 (Disposal of DVC in 60 days)

Posted on September 29, 2022 by ShadesOfKnife
So as per revised strategy here, I filed the Crl.P. at AP High Court seeking quash of DVC (i know DVC won’t be quashed on the ground of induced delay) or alternatively order for early disposal as per Sec 12(5) of PWDV Act 2005. This is listed for Cause list Motion Hearing before Court-19 Justice Ninala Jayasurya at Serial No.29 for 29-Sep-2022. Once this is decided (hopefully at admission stage itself), the WP(PIL) will be filed with 15 Respondents.

The copy of the Petition is here.
2022-09-22 Quash or Speedy Trail in my DVC v0.6

2022-09-29
I got a wonderful audience before the Hon’ble Justice Ninala Jayasurya for about 5 mins. I spoke about
  • my role in the HC case and the trial court case
  • what was the stage of the trail court case
  • how the dvc complainant absented herself from Feb 2020 and her counsel absented himself from Dec 2021 in the case
  • stated the time limit mandated in the law and the actual elapsed time in the dvc
  • prayed from quash of dvc due to abuse of process of law and in the alternative, pass directions for time-bound disposal of dvc

 

The Hon’ble Justice Ninala Jayasurya heard me patiently and asked the PP if any objections. PP politely said they are only seeking early disposal and there is no objection to the same. Judge then asked me is early disposal okay and I said, yes your honour and then he asked me is 3 months okay, i answered in affirmative. The Judge proceeded to dictate the order. Ufffffffffff!


2022-10-01

Here is the order online. So very happy with the findings and reasonings given in the order. Seems I made a good argument before the High Court judge with proper supporting material papers… Learnt some very important lessons in the way…

Sandeep Bhavan Pamarati Vs State of AP and Anr on 29 Sep 2022

Now, to shoot the PIL on the endless delays in disposal of DV cases in the State of AP… Now, head back here.
Posted in Sandeep Pamarati | Tagged PWDV Act Sec 12(5) - Dispose In 60 Days Sandeep Pamarati Vs State of AP and Anr Success Story | Leave a comment

Sandeep Pamarati Vs Ungrateful Knife (Bigamy under 494 and 495 IPC)

Posted on July 18, 2022 by ShadesOfKnife

After lot many delays, I moved forward on the Bigamy complaint against the disgruntled knife at Ongole.

2022-07-18

Went to Ongole to attend the Spandana Programme to submit my complaint of Bigamy against the Knife. The Staff at the SP Office directed me to the Taluka PS which is adjacent to the SP Office. The Writer heard me and took me to the CI. Questions raised are as follows:

  1. Why complain now after a gap of many years?
  2. Why here and not in Hyderabad or Pune?
  3. Why not talk and settle matter?
  4. Why for a NC (non-cognizable case), came to Ongole all the way from Vijayawada?
  5. Without taking legal opinion, how can we register FIR immediately?
  6. Why evidences are attached?

2022-08-22

Came to Taluk PS to ask for FIR and give my 161 CrPC Statement, if FIR was done. Of course, as expected the responsible persons were on Bandobast duty and hence not available at Police Station. So with this, CrPC 154(1) is complied and completed. Next CrPC 154(3) and the follow it up with another visit to Ongole SP Office on a Spandana-Monday.


2022-09-05

Went to SP office straight and waited for my turn. First time experiencing a public grievance system. My issue was documented into a template and I was asked to appear before a DSP. I wanted for my turn and when it was time, I went in and sat before the DSP. After a lot of questions and answers (from me, obviously), the DSP directed (both orally on the phone) and on the template to register an FIR and investigate. Hurrraaayyyyyyyyy!

I got successfully registered my complaint at Spandana (weekly once public grievance program in all Govt offices of AP)

The interaction was interesting and I found another lead to pursue my other goal. Conduct free legal awareness sessions.

DSP: Being advocate, don’t you know that Police cannot directly register a 494 IPC case? (I did not hear the work ‘Cognizable’)
SP: It is made cognizable in AP sir.
DSP: (Surprised) Is it?
SP: Yes sir, here is the 2-page copy of the State amendment.
DSP: Immediately dials the Assistant Direction of Prosecutions to confirm. Call ends in 15 seconds with positive news.
SP: Not many are aware of this amendment sir. Even I came to know about this only from AP High Court judgments (like here and here).
DSP: This is news to me, it was not covered in the training imparted to the Police attendees.
SP: (Flash lights in my mind) Not just this sir, another issue in PWDV Act is also horribly implemented in AP and I filed petitions before the AP High Court.
DSP: Calls the CI of the Taluka PS, Ongole. No response. Calls the Writer in the Taluka PS. Comes to know the regular CI is on leave and only in-charge is in the Station. Call in-charge and orally directs that a case has to be registered for 494 IPC and the victim is an advocate and it will be difficult for you (in-charge/regular CIs) if he goes to High Court.
SP: Thanked the DSP profusely and offered to send the case laws to him over phone. Obtained his contact and immediately sent both the case laws. Later offered to take up any issue, with his support and guidance.

Overall, a good day, indeed!


2022-09-17

  • Received a call from a Head Constable asking me to appear before CI, Taluka PS, Ongole. After a quick conversation, informed him that I will appear on Saturday for the same.
  • Went to Taluka PS, Ongole at 11AM and waiting until 1.30PM. Then had lunch and went to meet DSP DTC, Shri G Rama Krishna garu. Had a worthwhile conversation and requested him to remind the CI, Taluka PS to register FIR and inform me to record my statement u/s 161 CrPC. If no FIR done, then I am to appear before SP, Prakasam District on a Monday (in the Spandana Program), Sep 26, 2022.

Hope this time around the FIR will be registered.


2022-09-26 (if necessary)

 


Index of all cases laid on me is here.

Posted in Sandeep Pamarati | Tagged IPC 494 - Marrying again during life-time of husband or wife IPC 495 - Same offence with concealment of former marriage from person with whom subsequent marriage is contracted Sandeep Pamarati | Leave a comment

Being Farmer

Posted on January 7, 2019 by ShadesOfKnife

1. Device to detect hailstorm or rains and deflate protective shade to crops.

Multiple small umbrellas deployed automatically

Posted in Sandeep Pamarati | Leave a comment

My LLB Journey…

Posted on May 14, 2018 by ShadesOfKnife

In continuation from the About Me page… here are the interesting events… as usual… this will be updated regularly/weekly/ (currently on monthly basis)…

  • Been providing legal counseling from Jan 2018 on wards to distressed husbands and their families in dealing with the false cases
  • Wrote the AP LAWCET 2018 exam on 19-04-2018 (Thursday)
  • Got 293 rank in AP LAWCET 2018 exam on 14-05-2018 (Monday)
  • Wrote the TS LAWCET 2018 exam on 25-05-2018 (Friday)
  • Got 636 rank in TS LAWCET 2018 exam on 14-06-2018 (Thursday)
  • Got admitted to a local college, Sri Vijayanagar Law College, Anantapur into 3 years LLB (General) course on 17-10-2018 (Wednesday) Durgaashtami
  • Week #1 (Wk Ending 03 Nov 2018)
    • First week of college started on 29-10-2018; It felt funny to be among classmates who are 10+ years younger to me.
    • First week ended with a good note on 03-11-2018. I am adjudicated at First place in a ‘Pick (a topic) and Speak’ competition at College along with a woman classmate.
      • I wanted to participate in this event for one single objective: Folks of my college should know me with this. I have achieved that objective. No need to participate in it again. Set and Reach new objectives now.
  • Week #2 (Wk Ending 10 Nov 2018)
    • This week, I learnt about ‘Para-Legal Volunteer’ scheme from NALSA and gave my name to register as PLV. Am excited and looking forward for the paralegal work to begin soon.
  • Weeks #3 and #4 (Wk Ending 24 Nov 2018)
    • These two weeks were turning point, so to speak. Tried to introduce legal news into class whatsapp group and got myself kicked out. LOL. I pity their ignorance & childishness (by forming their own groups and ‘gangs’, idiots, haha) and as the saying goes, Ignorance of Law is not excusable. Hope they will realize this after beginning their law practice, which I highly doubt, considering their histrionics in class.
  • Week #5 (Wk Ending 01 Dec 2018)
    • Noon classes began and stopped as fast as they started, as the faculty got over-burdened. College re-opens for my batch on Dec 12th, literally.
    • Got RR series Quick Reference guides for all 5 subjects. Started with Essay-type question answer in IPC subject.
  • Week #6 (Wk Ending 08 Dec 2018)
    • Have targeted to read essay type questions from IPC, Torts and Constitution Law from previous exam papers. Listed them here.
    • Have Setup a WhatsApp group for people who are fighting their cases on their own, Party-in-person (PIPs). Contact me here, if you are a PIP, operating anywhere in India, and want to join this group.
  • Week #7 (Wk Ending 15 Dec 2018)
    • Per target last week, did complete studying few large answer questions.
    • College started on the prescribed date this week.
    • Bought the Internship Diary. Now only thing pending to complete the circuit is a Senior Advocate. Hahaha
  • Week #8 (Wk Ending 22 Dec 2018)
    • Writ material is gathering a shape. Happy about it that got inputs from a dear friend. Thanks 498aNlr
    • Even faculty when heard about the writ’s objective were dismissive about the writ. Have to face much more negativity.
  • Week #9 (Wk Ending 29 Dec 2018)
    • Got one more book for 2nd semester. Cancelled the remaining order and requested refund for remaining books. Bought the Contracts-1 book (Rega Surya Rao, no option left)
    • Got busy with judgments upload and neglected studies.
    • Preparing for the debate program on Jan 11th 2019 on the topic of, ‘Abolishment of Capital Punishment’. Have some solid points ready.
  • Week #10 (Wk Ending 05 Jan 2019)
    • Attended the Fresher’s party function at College on 31 Dec 2018, organized by the 2017 batch seniors. It was a very-well planned and conducted event. Appreciated by one and all.
    • Lecturers informed that first semester exams are fast approaching and positively will be conducted by 3rd week of February. Started explaining the ways to write various types of questions. Still folks in class are dumb.
  • Week #11 (Wk Ending 12 Jan 2019)
    • All students getting ready for impending examinations. Folks making photocopies of text books, altogether. HAHA
    • Extra classes also being scheduled this week for one subject. Soo much subject and soo little time to study. Law student life!!
  • Week #12 (Wk Ending 19 Jan 2019)
  • Week #13 (Wk Ending 26 Jan 2019)
  • Week #14 (Wk Ending 02 Feb 2019)
  • Week #15 (Wk Ending 09 Feb 2019)
  • Week #16 (Wk Ending 16 Feb 2019)
  • Week #17 (Wk Ending 23 Feb 2019)
  • Week #18 (Wk Ending 02 Mar 2019)
    • Few students in the class resisted to go down the route of copying from micro-xerox photocopy ‘booklets’; I was one of them.
    • Wrote exams well to the best of the efforts of my brain cell !! LOL
  • Week #19 (Wk Ending 09 Mar 2019)
    • Began writing notes for all subjects
    • Got ‘Harassed Husbands’ delivered.
  • Week #20 (Wk Ending 16 Mar 2019)
  • July 2019
    • Came to know the results of first Semester. All Pass. 49.1% Aggregate score. Happy. No backlog
    • Participated in my first Moot Court competition at GITAM School of Law. Details here.
  • August 2019
    • Serious preparation for 2nd Semester examination… sort of.
    • Drafted post related to 2nd PIL here.
  • September 2019
    • Getting ready for 2 upcoming Moot Court competitions. With a novice and learning team. Challenging? Let’s see
    • Unfortunately, this got cancelled, for now, with a promise that they will reschedule the event on a later date. Details here.
    • 3rd Semester began. As if nothing new happened, Quietly.
    • Got hold of all necessary study guides in one bunch at Library itself for a reasonable price.
  • October 2019
    • Attended college regularly.
    • Prepared a draft policy document with necessary changes to various aspect of College ecosystem and presented to Principal. He promised to take action on few of them at least.
  • November 2019
    • Went to Vizag to seek Expert Legal opinion on my first PIL here.
    • Then went to Amaravathi and filed the PIL. It got reviewed and a SR issued [WP(PIL)SR 29833/2019]. Awaiting numbering of PIL, after an Interview by a team of Registrars.
  • December 2019
    • Preparing for 3rd Semester Examination… again, sort of.
    • Came to know the results of second Semester. All Pass. 51% Aggregate score. Happy. Again no backlog
    • Got a call to appear before the Committee of Registrars regd the PIL I filed last month.
  • January 2020
    • Finished off the exams. I told myself, you did well; will clear all this semester too. I hope I told myself correct.
    • Received an Order from the Committee of Registrars. They rejected my request to appear PIP. Reason: I never appeared before any Court as PIP. They lied. Good that I have electronic evidence to prove them wrong, if required in a Court hearing. I will keep that option open. My Trump card.
  • February 2020
    • Went to High Court and took back my petition (all sets). As will everything first time with me, this too failed. Won’t be failing next time though. Not sure when is the next time.
    • Supposed to appear for the judgment pronouncement in the Discharge Petition I filed. Not sure why, but I didn’t appear in the Court. Also something called as epidemic was said to have started causing panic.
  • March-June 2020
    • The epidemic was declared pandemic n-COVID19.
    • Entire 4th semester classes (except for a couple of weeks), went online mode.
    • Due to COVID-19, the final exams for 4th semester got scrapped. So I am deemed to have passed the 4th Semester. Kind of… Yippeeee… 2nd Year too cleared. All Pass and some washout. FINAL YEARRRRR, here I come. 1 year closer to my immediate goal of getting LL.B. degree
  • July 2020
    • Came to know the results of third Semester. Collected marks-list for 3rd Semester.
    • All Pass. 47.2% Aggregate score. Happy. No backlog. I was a good motivator for myself.
  • August 2020
    • Paid Fee for final year LL.B. Ufff… no more BIG payments for academic purposes. Promise to myself. Naa meedottu.
    • Some painful conversations and decisions taken later
    • Online classes for 5th semester started. Am I attending regularly?
  • 14-August-2021
    • That day came, wherein all activities at one’s Law college will end for you. Today I submitted the last record (incidentally my favorite topic: Public Interest Litigation) and my Internship diary at college; No questions were asked.
    • Quietly ended the day with plans for next day, 15-Aug-2021 (74th Independence Day)
    • Motivated myself to change my lifestyle gradually.
    • No more updates to this page.
  • 14-August-2022 (Exactly one year later…)
    • One WP filed (Questioning Dowry giver is a criminal or not) and is next listed on 30-Sep-2022
    • One IA filed (Seeking release of my passport) in a earlier closed Crl.P.
    • Opened Vijayawada Office at Machavaram Down from Jan 2022
    • Worked out an understanding with Suprajaa Rajan to open Bengaluru officer as well. WIP. Not yet there.
    • Earned Rs.1,21,500/- from the date of enrolment 17-Mar-2022.
    • 104 goals setup for myself (and my team, if it ever materializes) here.

 

 

Posted in Sandeep Pamarati | Tagged AP LAWCET Sandeep Pamarati TS LAWCET Work-In-Progress Article | 2 Comments

Sandeep Pamarati Vs Ungrateful Knife (IPC 498A Case)

Posted on April 7, 2018 by ShadesOfKnife

Hi Folks, Sharing with you all, how I dealt with the false 498A IPC case put on me and my innocent parents, along with timelines. I have also shared my petitions (obviously, totally redacted) along with below timelines, in PDF format.

Take little pains to have them drafted for your cases.

Do NOT ask me word versions. Even if you ask, I will NOT give 😉

 

All credit goes to one organization named and styled as MyNation Foundation. Hundreds of exceptionally knowledgeable members have spend thousands of hours selflessly just to guide, motivate, support another of their brother from another mother (that is myself) who has been facing a false matrimonial case in India.

Thank you Rudy, for giving us MyNation.net.

NOTE: My DV case is available here. India is here.

 


Detailed Timeline of the case under IPC 498A


On 07-April-2017,

Compliant filed with Women Police Station, Ongole;
Same day FIR is also registered under IPC 498A and u/s 3 and 4 of D.P.Act

On 08-April-2017,

FIR sent to 3rd Additional Judicial Magistrate of First Class, Ongole

On 01-May-2017,

Regular Bail granted by 1st Additional Sessions Judge, Ongole to Parents

On 01-June-2017,

Application filed for Anticipatory Bail with High Court of AP u/s 438 of Cr.P.C

On 18-July-2017,

High Court of AP granted Anticipatory Bail

On 31-October-2017,

Charge sheet filed with 3rd Additional Judicial Magistrate of First Class, Ongole

On 20-September-2018,

First appearance in the Court along with parents. Collected accused copies of all prosecution documents, 1 set per accused person. We were three, we got 3 copies of below documents.

  1. Complaint
  2. FIR
  3. Printed Charge sheet
  4. 161 CrPC statements of all witnesses
  5. Rough sketch of scene of offence
  6. and few more documents/evidences

On 02-April-2019,

Filed Party-in-person petition in 498A IPC case. All three accused (myself, my daddy and my maa) are PIP !!!

Sample Petition below

Application to go PIP in IPC 498A Case (Without Auth)

Sample Affidavit below

Affidavit - Petition to go PIP in IPC 498A Case (Without Auth)

Sample Docket below

Docket Sheet for 498A Case PIP Petition

On 02-April-2019,

Parents filed 205 CrPC petition praying for exemption from personal appearance during this false case proceedings.

Sample Petition below

Exemption from Personal Appearance under CrPC 205 in IPC 498A Case

Sample Affidavit below

Affidavit - Exemption from Personal Appearance under CrPC 205 in IPC 498A Case

Sample Docket below

Docket Sheet for 205 CrPC Petition in 498A Case

 

Authorization under Rule 37 filed in the case proceedings.

Sample Authorization below

Authorization from one PIP in IPC 498A Case (under Rule 37 CRP and CO of AP HC) SAMPLE

No sample form or format is available anywhere on the Internet or High Court of AP website. Hence prepared the template myself. You may copy it. 😉

 

IMPORTANT ASPECT: If you and your parents wanna go PIP, file separate PIP petitions for each accused and separate Rule 37 authorization. Do NOT file 205 CrPC in such case. During the proceedings, one accused can file absent petition or any other petition for other accused. So PIP+Rule 37 is the combination to utilize. Not 205 CrPC, as 205 CrPC mandates, in the absense of accused, their advocate should represent them. In PIP, there is no advocate at all.

Obviously, I filed another memo, seeking permission to withdraw my 205 CrPC petition filed on behalf of my parents. Now, I am free to file any number of absent petitions for them in Court. I also attach any medical certificate or prescriptions in support of the absent petitions. Magistrate cannot deny them.

 

On 02-April-2019,

Filed Discharge petition in 498A IPC case for all three accused myself, my daddy and my maa

Sample Petition below

Discharge Petition under Sec 239 CrPC in Sec 498A case

Sample Affidavit below

Affidavit - Discharge Petition under Sec 239 CrPC in Sec 498A case

Sample Docket below

Docket Sheet for 239 CrPC Petition in 498A Case

On 22-April-2019, 25-April-2019 and 09-May-2019,

APP sought more time to file Counter to the Discharge petition

On 30-May-2019,

APP finally filed a 1-pager Counter to the Discharge petition

zCounter of APP against Discharge Petition

Take time to laugh at it. Contact me to know why APP has filed such worthless Counter and the back story.

 

On 14-June-2019,

Court allows the absent petitions sent via Registered Post with Acknowledgement due. Interesting !!!

Sample covering letter to be sent to the Superintendent of the Filing Section of the Court where the Case is pending, along with duly filled and stamped absent petitions.

Covering Letter - SAMPLE

Absent Petition for absence from a Court hearing date is filed under section 317 Cr.P.C. Sample available here.

 

From July 2019 to December 2019, Magistrate goes on training!!! 6 Months of training…

 

On 12-February-2020,

Hearing in the Discharge Petition

Hearing in the Discharge Petition happened. This is otherwise called as Hearing Before Charge framing (HBC)

I introduced the genesis of the case and then the discharge petition and swiftly moved onto the 8 grounds, one by one. Magistrate kept interrupting me by way of clarifications. Took around 15 mins to finish. APP was asked if she got anything to say to the 8 grounds (Note: Magistrate noted down 4 grounds only in her notes). As expected, APP denied the grounds as invalid and not applicable at this stage of case. APP amused me with 1-page Counter earlier (scroll up and read above) and now said very funny and weird reasonings to invalidate my grounds.

After this ruckus, Magistrate asked me for Judgments that I cited in the Discharge Petition. I said, all the judgments are reported judgments and are picked from Law reporters. Still Magistrate and APP also insisted that I produce judgments. I said, I will bring them in the next date. Finally, Magistrate said, she is moving the proceeding, For Orders.

I am glad, at last, I will have a Judicial order soon, that I can go against for Revision in Sessions Court u/s 397 Cr.P.C read with 399 Cr.P.C. with an additional prayer to stay the Trail Court proceedings and for this I have 90 Days of time.

 

On 24-February-2020,

Order in the Discharge Petition was not passed.

 

On 02-March-2020,

Order in the Discharge Petition was passed. I was absent.

On 12-March-2020,

I got a CA filed via a advocate friend (yes, i made friends with advocates)

Dismissal Order in Discharge petition

Now working on Criminal Revision Petition to file against above dismissal order at Sessions Court, at the earliest, along with PIP petitions at Sessions Court.

On 08-October-2020,

I got the Criminal Revision filed via the advocate friend; Awaiting numbering and subsequent initial hearing

Revision petition against Discharge Dismissal in IPC 498A Case (SAMPLE)

On 10-February-2021,

The Criminal Revision is numbered and notices sent to Respondent. Call on 12 March 2021

On 12-March-2021,

Nothing actually happen on the Bluejeans session. Since Notice to R2 had returned as party not available’, Court allowed serving of Notice to correct/alternative address. If this too fails, next step is to go for Newspaper publication.

On 12-April-2021,

Awaiting hearing…

On 07-August-2022,

Just updating developments…

  1. Stopped pursuing the Criminal Revision at Sessions Court, till date. But will proceed with newspaper publication.
  2. Initiated a IA (IA 1/2022 on 10/02/2022), in the long-disposed matter of Crl.P. No. 3886/2017 which was filed seeking Anticipatory Bail from AP HC), seeking release of my passport from the custody of Ongole Trial Court, where my newly renewed passport has been locked up from 2017 July… i.e., just over 5 years! Half the time for which the passport was renewed went in Court itself.
    • The SO of criminal section (B Satyanarayana) says, this 2017 file is not here at Amaravathi but may be at Hyderabad for which his office sent a requisition note to Telangana High Court in February itself but surprisingly the staff at TS HC says they never received any such note!! Interesting!
    • Also went to the New Filing section counter asking why my NOC was not reflecting on the Case Status portal. It is revealed that it was never taken up for processing because the person was on leave. My NOC-Vakalatnama was just lying there in a bundle of to-do items, for 4 full weeks!


On 10-October-2022,

Came to know that Requisition Note was sent to TS HC from AP HC but there is no response on my case bundle. More details here.


On 14-October-2022,

Appeared before the Magistrate for Charge-framing circus and Millions Thanks to God, THAT happened.


On 16-November-2022, 07-December-2022 and 12-December-2022,

Business: The Complainant must turn into Prosecution Witness-1 and file her Chief Examination/Evidence Affidavit and serve a copy to me. As I expected this did not happen.


On 13-December-2022,

First Listed Witness LW-1 turned First Prosecution Witness PW-1 and sat for Chief Examination by Assistant Public Prosecutor. Finished the drama on same day.

I cross examined the PW-1, in part and sought adjournment for continuation of Cross on NDOH.


On 19-December-2022 and 20-December-2022,

Nothing happened.


On 21-December-2022 and 22-December-2022,

I cross examined the PW-1, in part on 21-Dec-2021 and sought adjournment for continuation of Cross on NDOH. Finished the Cross examination of PW-1 on 22-Dec-2022.


On 04-January-2023,

 

 

 


LEGAL PROCEDURE TO FILE PETITIONS IN TRIAL COURTS and COMMON PITFALLS TO AVOID:

  • One petition per accused to be filed those that are going to defend their cases as Party-in-person. If you file one petition for 3 accused’s party-in-person, some idiots at Court will ask for rule which states that 3 accused can file one petition seeking party-in-person. Be aware of this.
  • All petitions (along with it’s affidavit and covering docket sheet) given to Court should be in green-colored Conquest paper, in legal size only.
  • Petitions can be submitted in the Court to the Magistrate (via the Court attendant) or filed at the Bench Clerk’s office to Supervisor/Clerk there. Go with first option always.
    • IMPORTANT: Obtain signature of the APP/PP on the petition that is going to be submitted to Court and then submit. Else, petition may be taken in, but then you will have to file a memo with signature from APP/PP. To avoid this double work, find out on what days (Mon-Sat) does the APP/PP of that Court come to Court. Then give a copy to APP/PP for their perusal and get received copy signature on the Original petition that will be submitted to Court.
  • For every petition submitted to Court, one copy should be given to PP/APP in Criminal Cases (like 498A IPC etc) and to Prosecution advocate in Civil Cases (like DVC, 125 CrPC etc). This can be in regular white paper, in legal size only.
  • Copy of petition to be served on OP advocate/A.PP before providing a copy to Court, preferably. Otherwise, OP Advocate can create ruckus and this can lead to another date.
  • Each petition we submit to Court should have Rs.2/- Revenue stamp (in Andhra Pradesh) on it. Check your Court procedure, where should it be attached. Even check amount of stamps necessary. To be on safer side, many attach more valued stamp than necessary.
  • No stamps necessary to stick on replies given by us such as Counter, Written Statements etc
  • Ensure the proper sections are cited on the petition’s cause title. There will be objections raised by APP/PP on this technicality itself.
  • Ensure verification section is there on your affidavits. And signed.
  • If there are a bunch of documents along with the petition, tie them together with a strong thread/tag.
  • Use Memos to convey information to Court. I used a memo to convey that I be exempted from Daily hearing for a certain week time due to personal emergencies. Magistrate did consider my memo/request and delayed the NDOH to another date.

The strategy to win in this case is as mentioned here.


 

Posted in Sandeep Pamarati | Tagged CrPC 239 - Discharge CrPC 239 - Discharge Rejected IPC 498A - Husband or relative of husband of a woman subjecting her to cruelty Sandeep Pamarati | 2 Comments

Sandeep Pamarati Vs Ungrateful Knife (DV Case)

Posted on March 27, 2018 by ShadesOfKnife

Similar to the 498A IPC case timeline available here, in this current post, I am sharing timelines and redacted petitions that I filed in the DV Case.

Take little pains to have them drafted for your cases.

Do NOT ask me word versions. Even if you ask, I will NOT give 😉


Timeline of my DVC under DV Act

—————————————————————————————–

On 08-August-2017,

Court orders for Counseling and DIR reports from Protection Officer

On 17-August-2017,

Notice from Protection Officer to attend Counseling at Sakhi Center, Ongole

On 04-September-2017,

First Counseling session at Protection Officer, Sakhi Center, Ongole – Attended

On 16-September-2017,

Second Counseling session at Protection Officer, Sakhi Center, Ongole – Didn’t attend

On 01-December-2017,

Notice for appearance u/s 13(1) a of PWDV Act 2005 in front of Addl JMFC – Attended

On 08-December-2017,

First hearing – Attended – Vakalatnama filed by Advocate

On 08-February-2018,

Fourth hearing – Attended – Counter filed

Counter against DV Case Feb 8th

Please scroll down a little and read the Counter I filed in opposition to the IM application from OP. It will help draft a better Counter/Written Statement, as I learnt a lot about drafting legal documents, in this one year.

On 12-April-2018,

Sixth hearing – Attended – Judge ordered for examination


Scroll down to bottom of the page, to see what transpired from April 2018 to April 2019.

I kicked out the fraud advocate I had engaged for the DV case and became PIP. I started to Take Control of My Case.


 

On 02-April-2019,

Filed PIP Petition for myself

PIP Petition

Memo to go PIP in DV Case

PIP Affidavit

Affidavit - Petition to go PIP in DVC Case

PIP Docket

Docket Sheet for DVC PIP Memo

On 02-April-2019,

Filed Expedite proceedings Petition

Expedite Proceedings Petition

Expedite proceedings under Section 12(5) in PWDV Case

Affidavit

Affidavit - Petition to Expedite in DVC Case

Docket

Docket Sheet for DVC Expedite Memo

On 02-April-2019,

OP/PW1 filed Chief Examination Affidavit, in lieu of Chief Examination in the witness box

On 22-April-2019,

Filed Removal of Names Petition for parents

Sample Removal of Names of Parents Petition

Removal of Names of Parents in PWDV Case

Sample Removal of Names of Parents Afidavit

Affidavit - Removal of Names of Parents in PWDV Case

Sample Removal of Names of Parents Docket

[pdf-embedder url=”https://www.shadesofknife.in/wp-content/uploads/2018/03/Docket-Sheet-Removal-of-Names-of-Parents-in-PWDV-Case.pdf” title=”Docket Sheet – Removal of Names of Parents in PWDV Case”]

UPDATE: Magistrate advised (rather told) me to bring out the truth in Cross Examination, instead of allowing this petition.

On 22-April-2019,

Crl.MP 655/2019 is allowed – PIP petition allowed


On 25-April-2019,

Filed (Revised and Final) Counter against the Interim Maintenance along with supporting electronic/digital evidences (in Paper and DVD formats) via a Receiving/List of Documents petition

Sample Counter against Interim Maintenance application in DV Case

Counter against Interim in PWDV Case - NEW

Sample Affidavit for Counter against Interim Maintenance application in DV Case

Affidavit - Counter against Interim in PWDV Case - NEW

Sample Docket for Counter against Interim Maintenance application in DV Case

Docket Sheet - Counter against Interim in PWDV Case - NEW

Sample Receiving documents Petition in support of Counter against Interim Maintenance application in DV Case

List of Documents to support Counter against Interim in PWDV Case

Sample Receiving documents affidavit in support of Counter against Interim Maintenance application in DV Case

Affidavit - List of Documents to support Counter against Interim in PWDV Case

Sample Receiving documents docket in support of Counter against Interim Maintenance application in DV Case

Docket Sheet - List of Documents to support Counter against Interim in PWDV Case

On 25-April-2019,

OP/PW1 sworn the Chief Examination Affidavit;

2 Exhibits P1 and P2 were marked. Marriage Invitation Card and Single Marriage photo.


On 09-May-2019,

OP Absented and We Present. I prayed for Cost levy on OP.

PW1 is directed to appear by next adjournment without fail

On 30-May-2019,

OP Absented and We Present. I prayed for Cost levy on OP.

PW1 is directed to appear by next adjournment without fail. Otherwise the next step will be follows.


On 03-June-2019,

Conducted Cross-examination of PW1/OP – Day 1

Actual base questions used prepared from Chief Examination affidavit of PW1/OP

Cross-Examination Sample Questions

On 04-June-2019,

Conducted Cross-examination of PW1/OP – Day 2

On 17-June-2019,

Conducted Cross-examination of PW1/OP – Day 3

On 18-June-2019,

Conducted Cross-examination of PW1/OP – Day 4

Original questions asked and the responses (already prepared to get these answers) from PW1/OP

Cross examination QnA in DVC IM for Upload

On 19-June-2019,

Cunning knife sought adjournment for some reason and ran away from Cross-examination

On 05-July-2019, 02-08-2019 and 29-08-2019

I filed absent petition via RPAD, since Magistrate went on for a 6-month long training.

On 17-09-2019, 14-10-2019, 11-11-2019 and 02-12-2019

I did not file the absent petition.

On 17-01-2020,

I filed the absent petition and it got allowed. On next date, I was fully prepared to pose my final set of Cross examination questions to PW1 and end this stage. If permitted, getting ready to finish Oral Arguments and file written arguments as well.

On 07-02-2020,

Conducted Cross-examination of PW1/OP – Day 5

As expected, posed final set of Cross examination questions to PW1 and finished this stage. That’s when I understood and realized that, there are other PWs.. Hmm. I should have sought for and got List of Witnesses even before beginning the Cross of PW-1. Lesson (known, but forgotten) learnt. Hence, Arguments stage is few more dates away.

Here are the final set of Cross questions that I posed to PW-1 and few that I couldn’t ask.

Cross examination of PW-1 in DVC IM as on 2020-02-07

Now to prepare questions for PW-2. Who will that be? Father, Mother or Brother of Cunning ungrateful knife? Let’s wait for 27-Feb-2020

On 27-02-2020,

Awaiting entry of PW-2

On 01-04-2021,

Awaiting entry of PW-2 ; Going to pray for close of Further evidence of Petitioner as last 4 hearing the party as well as Advocate was absent. Seems they are no more interested in the lis.

On 30-09-2021,

Still Awaiting entry of PW-2


On 29-09-2022,

Exactly after one year from last date, I took things to Hon’ble High Court in a Criminal Petition seeking directions to the trial Court for early disposal of this case and the Hon’ble Judge has been kind enough to grant my prayer.

Detailed post here.


On 17-10-2022,

Going to the Court, with a memo to receive the High Court order and comply with the direction.

2022-10-17 MEMO submitted HC Order to expedite


At the lassst stage of this false DV case…

 


COUNTER ATTACK –>

Perjury in PWDV Case (if any adverse orders get to pass)

Petition

 

Affidavit

 

Docket

 


The necessary judgments to win this case are listed here.


SUMMARY of the CASE HISTORY

 

 

Posted in Sandeep Pamarati | Tagged Protection of Women from Domestic Violence Act 2005 Sandeep Pamarati | 2 Comments

Sandeep Pamarati Vs Ungrateful Knife

Posted on March 27, 2018 by ShadesOfKnife

This post lists all the false cases filed on me and my family, by the Ungrateful Knife. I filed a few…

  1. Criminal case under IPC 498A read with sections 3 & 4 of Dowry Prohibition Act (Read bare acts by clicking here and here)
      • Discharge Petition filed. And dismissed. Filed Revision at Sessions Court. News paper publication pending.
    • A Writ Petition seeking declaration of Dowry Givers also as Criminals in a criminal case filed u/s 3 of DP Act 1961 here.
    • An IA was filed before APHC seeking relaxation of the condition of depositing my passport with trail court but it got struck here.
      • Then a Quash petition was filed before APHC seeking quash of the condition of depositing my passport with trail court here. It was withdrawn because High Court can not quash an order passed by itself, even if abuse of process is happening because of the said order. Now I have to pursue the above IA route.
  2. Quasi Civil case under section 12 of Protection of Women from Domestic Violence Act (Read bare act by clicking here)
    • Interim Maintenance application filed. But due to my strong Written Statement, Magistrate skipped the Interim application totally, and proceeded with Examination stage. Finished Cross of PW-1, after which the petitioner absented herself from Feb 2022 and her Counsel also absented totally from Dec-2021… Not sure if they will ever return to this Court.
    • A Criminal Petition seeking disposal of the DV Case in 60 days here. First WIN at AP High Court!
  3. Criminal case under under 494 and 495 IPC (Read the text of sections here and here)

 

 


MASTER SITEMAP here.

Posted in Sandeep Pamarati | Tagged Dowry Prohibition Act 1961 IPC 498A - Husband or relative of husband of a woman subjecting her to cruelty Protection of Women from Domestic Violence Act 2005 Rules of the Act/Ordinance/Notification/Circular Sandeep Pamarati Summary Post Work-In-Progress Article | Leave a comment

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