IN THE COURT OF XXXX, MM, TIS HAZARI COURTS, DELHI

CASE NO. ______

IN RE:

XXXXX                                                    ...  COMPLAINANT 

                                            VERSUS

XXXXX                                                      ...  ACCUSED

APPLICATION U/S 315 OF Cr.P.C ON BEHALF OF ACCUSED APPLICANT

RESPECTFULLY SHOWETH:-

1.   THAT the present case was heard before this hon’ble today and this hon’ble court was pleased to allow the application of the applicant/accused filed U/s 311 read with 315 subject to the cost of Rs. XXXX/-to the complainant.

2.   That After the application allowed by the Hon’ble court, the applicant/accused has got his examination in chief recorded in this hon’ble court today itself after paying the cost of Rs. XXXX/- to the complainant, thereafter the counsel for the complainant has crossed the applicant/accused. It is pertinent to mention here that while getting in examination in chief of the applicant/accused recorded, due to some advertant and bonafide mistake on the part of the counsel for the applicant/accused accidentally, slip the applicant /accused could not put the Exhibit Mark on the bank statement, ledger, cash receipt and other documents filed in the hon’ble court today with the application u/s 311 Cr.P.C. These statements and other documents are very much essential to be part and parcel of the evidence of the applicant/accused. The whole case of the applicant/accused is based on the substantial evidence mentioned in the said statement, receipt, and other documents, however, it is important to mention here that DW1 has specially mentioned the said statement in the examination in chief and only the Exhibit Marks have not been place on the said documents.

3.   That in view of the afore narrated facts and circumstances, the applicant/accused has been seeking leave and intervention of this hon’ble court placing the Exhibit Marks on the documents, and statements in the hon’ble court with the application filed u/s 311 read 315 Cr.P.C, all the documents are already on record.

4.   That these documents are extremely essential for the just and fair decision of the present case.

5.   That the mistake & accidental slip of not putting the Exhibit Marks on the said documents was bonafide & was neither intentional nor deliberate.

PRAYER:-

It’s therefore most respectfully prayed that this hon’ble court may kindly be pleased to grant permission to the applicant/accused to put the Exhibit Marks on the documents i.e. Bank Statement, Cash receipt by the complainant, Ledger document, etc. in additional statement (Examination in chief).

In the interest of justice, any other relief may be granted in the favour of the applicant/accused.

Delhi                                                          Applicant

Dated:

                               Through

                                                                  Counsel