FIRST INFORMATION REPORT

T.S.P.M. Orders 470,500

(Under Section 154 and 157 Cr.P.C)

1. District Hyderabad P.S. CHILKALGUDA Year 2023 FIR No. 811/2023 Date 29-12-2023

2. Acts & Section(s): 405,407,409,417,418,420,467,468,406 IPC,156(3) CrPC

3. a) Occurrence of Offence: Day Thursday Date & Time From

Date & Time To Prior To 30-06-2022 11:00:00 Time Period

b) Information Received at P.S.: Date & Time 29-12-2023 18:30:00

General Diary Reference: Entry No 26 Date & Time 29-12-2023 18:30:00

4. Type of Information: Through Post

5. Place of Occurrence:

a) Distance and Direction From P.S.: 1 km, East Beat No.

b) Address Place Seethafalmandi Area/Mandal Street/Village SEETHAPHAL MANDI

City/District Hyderabad State Telangana PIN

c) In case, outside the limit of this Police Station, then

Name of P.S. District

6. Complainant / Informant:

a) Name Pradeep Kumar

b) Father's /Husband's Name M.Kistaiah

c) Date/Year of Birth Age 37 Years

d) Nationality India e) Caste

f) Passport No Date of Issue Place of Issue

g) Occupation Private Employee Mobile No. 9948156396

17-
44/3/306,Thirumala
h) Address House No Ashok arcade, Sri Area/Mandal Medipally Street/Village
venkateshwara colony,
Medipally, Ghatkesar

City/District MEDCHAL MALKAJGIRI State TELANGANA PIN

7. Details of known/suspected/unknown accused with full particulars:

Serial No : 1

a) Name M/s Sri Laxmee Narsimha Swamy constructions

b) Father's /Husband's Name

c) Occupation d) Caste e) Gender Male

f) Age Nationality India

g) Address

-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No

i) Email

Serial No : 2

a) Name A. Harinath
b) Father's /Husband's Name Late A Bikshapathi

c) Occupation d) Caste e) Gender Male

f) Age 47 Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No 9059558499

i) Email

Serial No : 3

a) Name M. Rangaiah Gound

b) Father's /Husband's Name Late M Sataiah Goud

c) Occupation d) Caste e) Gender Male

f) Age 55 Nationality India

g) Address

8-5-95/1, Road
No.1, Mallikarjuna
House No Colony, Old Street/Village Area/Mandal
Bowenpally,
Secunderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No 9849201376

i) Email

Serial No : 4

a) Name Rajeshwari Devi

b) Father's /Husband's Name A. Harinath

c) Occupation d) Caste e) Gender Female

f) Age 45 Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadiguda,
Hyderabad

City/District State PIN

h) Phone(Off) Phone(Resi) Cell No

i) Email

Serial No : 5

a) Name A Harshavardhan

b) Father's /Husband's Name A Harinath

c) Occupation d) Caste e) Gender Male

f) Age Nationality India

g) Address

1-3-183/39/A/B
Gandhinagar,
House No Street/Village Area/Mandal
Kavadguda,
Hyderabad
City/District State PIN

h) Phone(Off) Phone(Resi) Cell No 6304649070

i) Email

Physical features, deformities and other details of the Suspect:

S. No. Sex Date/Year of Birth Build Height (cms) Complexion Identification Marks(s)

1 2 3 4 5 6 7

1 Male

2 Male

3 Male

4 Female

5 Male

Deformalities/
Teeth Hair Eyes Habbit(s) Dress Habit(s) Languages/ Dialect
Peculiarities

8 9 10 11 12 13 14

Place Of

Burn Mark Leucoderma Mole Scar Tattoo

15 16 17 18 19

8. Reasons for delay in reporting by the complainant / informant:

Delay from complainant

9. Particulars of properties stolen/involved (Attach separate sheet, if necessary):

10. Total value of property stolen:

11. Inquest Report/ U.D. Case

12. Contents of the complaint / statement of the complainant or informant:

IN THE COURT OF HON’BLE X ADDL. CHIEF METROPOLITAN MAGISTRATE AT SECUNDERABAD. Honored Sir, Brief facts of the case are that on
29.12.2023 at 18.30 hrs, received a complaint from Pradeep Kumar, S/o. M.Kistaiah, Age: 37 years, Oce: Private Employee, R/o H.No. 17-44/3/306,Thirumala
Ashok arcade, Sri venkateshwara colony, Medipally, Ghatkesar Mandal, M.M. Dist. Ph.No. 9948156396. In the year 2019 he have seen a house under
construction at Seethaphalmandi, Secunderabad and accordingly he made a phone call to the builder and approached A-1) M/s Sri Laxmee Narsimha Swamy
constructions having Office at flat No.501, H.No. 1-3-183/39/A/B Gandhinagar, Kavadiguda, Hyderabad, A-2) A. Harinath S/o Late A Bikshapathi, Aders 49
YEARS flat No.501, H.No. 1-3-183/39/A/B Gandhinagar, Kavadiguda, Hyderabad Mob. No. 9059558499, A-3) M. Rangaiah Gound S/o Late M Sataiah Goud,
AREA 55 YEARS R/o 8-5-95/1, Road No.1, Mallikarjuna Colony, Old Bowenpally, Secunderabad 500011, Mob. No.9849201376, A-4) A Harshavardhan S/o A
Harinath, Age: 30, Yrs Ro. flat no. 501, H.N. 1-3-183/39/A/B Gandhinagar, Kavadguda, Hyderabad Mob. No. 630464070, A-5) Rajeshwari Devi, W/o A.
Harinath Age: 45 Years, R/o. flat No.501, H.No. 1-3-183/39/A/B Gandhinagar, Kavadiguda, Hyderabad It was agreed that the builder i.e. A2 would sell the
house for Rs.44,50,000/- and that he have to pay 30% of the amount initially. he have paid an amount of Rs. 14,00,000/- in June, 2020. he have paid the
remaining amount in the same month in 4 to 5 installments. After he paid the entire amount the accused has executed an agreement of sale in his favour. Later the
accused has stopped receiving my calls as the accused promised to get a loan for him. They have stopped receiving his calls as the accused promised to get a loan
for him. he have also approached A3 regarding the said house and the payment made by him and he promised to talk with A2 and settle the matter but due to
COVID-19 he could not contact any of them and he was not handed over the said house by the accused persons. By the end of the 2019 A2 has issued legal notice
to complainant claiming that as he have taken cheques from him and that he failed to make the payment and for the said notice he have sent reply. Hence he
requested to take necessary action. -:Original English typed complaint is enclosed herewith:- Received on 29.12.2023 at 18.30 hrs: Basing on the contents of the
above petition, I, P. Balaraju, SI, registered a case in Cr.No. 811/2023, U/s 405, 407, 409, 417, 418, 420, 467, 468, 406 IPC & 156 (3) Cr.P.C. and case file
entrusted to Smt. K.Sabitha, SI for further investigation. Sd/- (Sri P. Balaraju, Sub-Inspector of Police, Chilkalguda PS, Hyd)

13. Action taken:

Since The above information reveals commission of offence(s) U/s as mentioned at item No:

1) Registered the case and took up the investigation or Name KARUPPAIAH SABITHA

2) Directed to take up the Investigation or Rank: SI No. 8443

3) Refused investigation due to

4) Transferred to P.S District on point of jurisdiction.

F.I.R. read over to the complainant / informant, admitted to be correctly recorded

and a copy given to the complainant /informant, free of cost. R.O.A.C

Signature / Thumb impression of the Signature of Officer in charge, Police Station

14.
complainant / informant.
Name PACHCHU BALARAJU

Rank SI No --

15. Date and time of dispatch to the court:

IN THE COURT OF THE HON'BLE X ADDL. CHIEF
METROPOLITIAN MAGISTRATE, HYDERABAD DISTRICT
AT SECUNDERABAD
13
C.C. NO. OF 2023

(H&b3 Between:
(31\K M. Pradeep
FE1123
Kumar,
S/o M. Kistaiah aged 35 years
Occ: Private service, R/o 17-44/3/306
(51ob3 Thrimula Ashok Arcade, Sri Venkateswara colony,
Medpally, Ghatkesar Mandal, M.M. District. T.S.
Mob. No. 9948156296
311D3 ..Complainant

AND

M/s Sri Laxmee Narsimha Swamy constructions

Having Office at flat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 9059558499

2 A. Harinath
S/o Late A Bikshapathi,
flat No.501, HNo. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 9059558499

3. M. Rangaiah Gound
S/o Late M Sataiah Goud,
R/o 8-5-95/1, Road No.1,
Mallikarjuna Colony,
Old Bowenpally, Secunderabad 500011,
Mob. No.9849201376

M-Pndup h n
4.4. A Harshavardhar
S/o A Harinath
R/o. flat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 6304649070

5. A. Rajeshwari Devi
Wlo A. Harinath
R/o. flat No.501, H.No. 1-3-183/39/A/B
Gandhinagar, Kavadiguda, Hyderabad
Mob. No. 6304649070
.. Accused

COMPLAINT UNDER SECTION 200 OF Cr.P.C.

1. Nature of
Offence :Under Sec. 405, 407, 409, 417,418, 420, 467,
468 of IPC and 406 IPC.,
2. Place of Offence
Seethaphalmandi, Secunderabad
3. Jurisdiction of Police Station: P.S. Chilkalguda
4. Date of Offence 30-06-2022 continued.
5. List of Witnesses 1. Mithilesh Rai

2. S. Srinivas

3. Mohd. Hammiuddin

4. K. Srinivas

The Complainant humbly begs to state and submit as follows:

The address of the parties are correctly set out in the foregoing cause title. The
Complainant may also be served through its counsels, M/S J.C.Francis, M.B.
Laxmikala and Sumalatha Advocates having office at 3-3-389/B Chappal Bazar,

MPadupkna
higuda, Hyderabad S00027, Telangana for the purpose of Court Summons,
Notices etc., from this Hon'ble Court.

1. The Complainant respectfully submit that this is a case of Criminal Breach of

Trust, Criminal Breach of Contract, Misappropriation, falsified Documentation and

cheating, in which the complainants was put to wrongful loss by accused no.1 to 4.

2. The facts are that the Accused No.1 to 5 herein have committed the offences of

section 405, 407, 409, 417,418, 420 of IPC and 406 IPC, it is submitted that since
the cause of action of all the complainants herein is one and the same, I am filing a

single petition. it is submitted that this petition is being filed questioning the
inaction of the respondent police in not registering and investigating the complaint
of the petitioner dated 14/03/2023 as illegal contrary to law and judicial
precedents. It is submitted that all the accused in our complaint dated 14/03/2023
have connived, conspired, and manipulated the Registered property document
submitted to the petitioner on several occasions with reference to the
Registered
Sale deed and Registered Development
General Power of Attorney in
cum

executing a sale agreement with the petitioner on 15-06-2020, with the sole
intention to usurp the petitioner family funds for their personal gain and benefit,
knowing fully well, the apartment was formed to cater to the needs of residential
families in need of economical support for enjoyment of their family life.
3 It is relevant to state that the land owner and
the builder, were present at the
time of negotiating the purchase of apartment transaction, and they jointly made
statement of executing a sale deed of the unfinished flat to avail a loan of 44 lakhs,
towards which 10% (Ten
percent) margin money was to be deposited in the bank

M Radup huma
for availing 90% Housing loan that would pay for the total cost of the apatment,

be handed over to ne
amounting to Rs.44,00,000/- The said apartment had to

within two months from the date of making the advance payment of Rs.2,00,000/
that was made on 18-03-2020 and Rs. 1,00,000/- paid on 18-03-2020, and

Rs.1,00,000/- paid on 19-03-2020. and Rs.2,00,000/-. paid on 03-06-2020 and

Rs.2,00,000/- paid on 04-06-2020 and Rs.60,000/- paid on 05-06-2020 and

Rs.40,000/- paid on 04-06-2020 and Rs.5,00,000/- paid on 15-06-2020 totaling

Rs.14,00,000/- having a written agreement made on 15-06-2020 and as per the

agreement on further payment made towards, The payment for GHMC Taxes and

mutation of the flat, electricity deposit, water and HMWSSB deposit and charges,
registration charges and fees towards execution of sale deed of unfinished flat,
were made by us, towards which said understanding and oral agreements, a total
amount of Rs. 14,00,000/- (Rs. Fourteen lakhs ) was paid to the accused's, who
have collected the said amounts and promised to deliver the apartment into my

within period of two months from the date of receipt of amounts

custody a

demanded. Wherein I have fulfilled my part of the agreement. Copies of the land
owners sale deed vide doc. No.2375/2018 and registered D.G.P.A vide doc.

No.1570/2019 and property tax dues alongwith the written agreement is filed

herewith.

5) Believing and trusting their commitments, with the oral and written
undertaking given by Builder and the landlord in the presence of several other third
party purchasers present at the time of negotiation, I was made to believe the
accused No.1 to 5 to being honest and law abiding Indian citizens, going by the

MPadup kornas
accused professing to have the local competency to execute the apartment
construction in abiding by Indian laws, rules and regulations I made a payment of
Rs. fourteen lakhs twenty thousand. (Rs.14,00,000/-) i.e. from March 2020 to June
2021. Details of the payment made of the funds collected by the accused is filed
herewith.

7). The complainants further submit to this Hon'ble Court that the Accused have

intentionally misappropriated, cheated and swindled the funds which were meant
for the sole purpose of construction and compliance with the authorities concerned
and to obtain the financial assistance needed to complete the execution of the

unfinished construction. By way of making payment to the authorities concerned

for perfection of the title with the concerned departments, and for obtaining

financial assistance from the financial institutions based on the margin money
deposited with the accused to be kept in the bank account along with the title deeds
of the property held by the accused No.1 to 5 for obtaining funds to complete the
execution of the multi storied residential complex. In spite of having received the
funds of Rs.14,00,000/- (fourteen lakhs ) between the period of March 2020 to
June 2021 the project remained as it was in the same stage of completion that was
seen in the month of May and June 2020 after the entry of the transaction with the
Accused, wherein all the Accused No.l to 5 were present at the apartment site
located at Seethaphalmandi. Secunderabad..

8. The Complainants submits that the accused has dishonestly and fraudulently
induced the complainant to come and join as a flat owner member of the
apartment, only in order to usurp, cheat and swindle the petitioner of their family

Madup humes
savings and personal funds with the sole aim to cause wrongful loss to the
petitioner herein for the accused No.l to 5 personal gain and benefits, by
adopting fraudulent means thereby the accused has committed offence U/sec.
405,
407, 409, 417,418, 420,of IPC and 406 IPC
inspite of the several visits to the site
and tothe residence of the Accused no.l to
5, the Accused No. 1,2, 4 & 5
absconded from their premises and became
contact less from the period of
2022 till date. Letters sent to the May
accused were returned by the
postal department as
no such person available at the address. The accused no.3 received the
letters sent
by the petitioner but failed to
respond. It is pertinent to mention that the accused
got issued a notice to the petitioner
giving the same wrong addresses mentioned in
the agreements
registered with the authorities vide registered deeds. copy of the
notice received is filed herewith.

9. The petitioner fearing due to the

adverse response and non
communication, after
having visited the site and residences of the accused, the
petitioner was shocked
and pained to see that the Accused No.I to 5 had deliberately
given false address,
thus fearing the worst with the
absconding builder i.e. accused No.1, 2, and 4,5. the
petitioner traced the land owner and asked for an execution of the unfinished
apartment towards which Rs. 14.00,000/- paid and received by the accused
was

no.1 to 5. The accused no.3 informed the petitioner that the

payments were
received by accused no. 1, 2 and 4 & 5. Hence the accused no.3 refused to co-
operate and expressed his inability to assist the petitioner. The petitioner
having no
other option were constrained to inform the
police authorities on 14-03-2023 to
investigate into the unlawful activities of the accused no.l to 5, the accused no.1,2

MRadphumat.
and 4& 5 declined to respond to the police enquiries, and accused no.3 refused to
communicate to the police to answer for the said above transaction. Hence the
police authorities have instructed the petitioner to
approach the Hon'ble Courts, for
directions to
proceed against the accused No.1 to 5. Hence this petition. Copy of
the complaint filed and numbered
as 795 with the
police along with the
acknowledgement by the commissioner of police is filed herewith.
10. JURISDICTION: The apartment location and site office of the accused
1
in Chilkalguda zone of Seethphalmandi, Secunderabad District, which falls under
Chilkalguda Police Station, hence this Hon'ble Court is having ample and
territorial jurisdiction to try the case.

11. PRAYER:

It is therefore prayed that this Hon'ble Court may be pleased to refer U/sec. 156(3)
CrPC to the P.S. Chilkalguda for requesting a FiR under Sec. 405, 407, 409,
417,418, 420, of IPC and 406 IPC against the accused and initiate prosecution
against accused and to pass such other order or orders as may deem fit and proper
in the circumstances of the otherwise, the
case as
complainant would be put to
severe hardship and irreparable loss.
Madup ko
COMPLAINANT

Date 08/05/2023 DCetoou ase

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