CRIMINAL APPEAL MEMORANDUM OF CRIMINAL APPEAL UNDER SECTION 374 OF CRPC

IN THE HIGH COURT OF PUNJAB AND HARYANA CANDIGARH Crl. A. C. No of 2011

Between: ABC, son of........., aged about........ years, resident of....... AND The State of Punjab Rep by its P.P. High Court of Punjab and Haryana ..Respondent ..Appellant/accused

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 Appeal to this Honble Court against the judgment made in S.C No. of 2011 on the file of the Court of Sessions judge,.dated for the following among other grounds. Grounds 1. That the judgment of the lower Court is contrary to law, weight of evidence and probabilities of the case. 2. That the prosecution failed to appreciate that the prosecution has not complied the mandatory provisions of sections . Of the . Act. 3. That the prosecution has not proved the offence against the accused beyond all reasonable doubts.

4. That the lower Court has violated the well established principles of law that justice should not only be done but must also 5. That the conviction and sentence awarded are bad in law and improper in that they are based on erroneous assumptions not warranted by the material available on the record. 6. Any other grounds that may be urged at the time of hearing of the main appeal. It is therefore prayed that this Honble court may be pleased to set aside the sentence and conviction passed in S.C. No. on the file of the Court of the Sessions Judge,. Dated. and release the petitioner on bail pending disposal of the main Criminal appeal by suspending the sentence and pass such other order as this Honble Court may deem fit and proper in the circumstances of the case. Place: Dated :

Counsel for the Petitioner