Sunday, November 6, 2016

APPEAL UNDER S. 417(2-A), Cr.P.C. AGAINST ORDER ACQUITTAL DATED PASSED BY

IN THE COURT OF SESSIONS JUDGE/HIGH COURT
ABC S/o           , Description of the convict
… APPELLANT
Vs.
(1)   Accused
(2)   State
… RESPONDENTS
APPEAL UNDER S. 417(2-A), Cr.P.C. AGAINST ORDER ACQUITTAL DATED           PASSED BY     
Respectfully Sheweth:
1)      That the respondent No. 1 was charged in the commission of offence u/s 302, P.P.C., he was nominated in the F.I.R., which was lodged by the complainant, the mother of the deceased lady. The accused absconded for a pretty long time, and was arrested after more than a year of the date of the offence. He was accused of murder his own wife by throwing kerosene oil and setting her on fire resulting causing brutal injuries of burn which resulted her death.
2)      That the postmortem report which was obtained promptly shows the cause of death by burn injuries.
3)      That the prosecution produced 5 witnesses including a mid-servant who had seen the occurrence coupled with circumstantial evidence of obscondence there was sufficient material on record for awarding capital sentence as provided in law.
4)      That the trial Court has Passedorder of acquittal of the accused ignoring the cogent and confidence inspiring evidence on record hence this appeal inter alia on the following:
GROUNDS:
i)              That it is admitted on record that the victim, the deceased lad was the wife of the accused acquitted.
ii)            That it is further admitted that she died out of burn injuries caused by setting her on fire.
iii)          That the delay in F.I.R. has been sufficiently explained, there was no one at site of occurrence who could approach the police for recording F.I.R. the deceased was admitted in the hospital in a very precarious condition, her parents remained posted at the hospital to safe the life of her beloved daughter.
iv)          That the deceased remained in the hospital being seriously injured and died after a fortnight of the occurrence.
v)            That no doubt the victim was hospitalized by her husband the accused, and her dead body was brought by him in house where burial ceremony took place but soon after the F.I.R., was lodged he absconded and went away to an unknown place. This is a material circumstance the long absence of the accused remained unexplained throughout.
vi)          That the maid servant of the house of the accused deposed clearly that there is no one in the kitchen where the incident took place except the deceased lady and her husband i.e., the accused.
vii)        That the defence version of the accused that the deceased caught fire by burst of the stove where kerosene oil was burning is just after thought.
viii)      That the accused did not produce the alleged stove or reported the matter to the police till the burial of the deceased victim.
ix)          That the trial Court has committed error in law in reading the evidence in its true perspective there is direct evidence available on record connecting the accused with the commission of the offence.
x)            That the impugned judgment is result of glare non reading and misreading of evidence, the acquittal of accused is manifestly wrong.
xi)          That the order of acquittal passed by the trial Court is speculative and artificial, the finding are based on no evidence, it is result of misinterpretation of evidence the only conclusion which could be drawn from the evidence is the guilt of the accused inference of innocence is reverse resulting miscarriage of justice.
xii)        That in the presence of independent witness available at relevant time sufficient to connect the accused with the commission of offence charged, the Court has legally erred to acquit the accused.
xiii)      That it is wrong to suggest that the whole prosecution case was shrouded in mystery and of full doubt. The evidence of record dispels the inference as drawn by the trial Court.
In view of the above it is therefore respectfully prayed that this Hon’ble Court may be pleased to accept this appeal, the impugned order may kindly be set aside, and the accused be dealt with according to law and punished for the offence charged as provided in law.

APPELLANT

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