criminal appeal
TRANSCRIPT
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....... …..Appellant/accused
AND The State of Punjab Rep by its P.P.
High Court of Punjab and Haryana …..Respondent
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 Hon’ble 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 Hon’ble 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 Hon’ble Court may deem fit and proper in the circumstances of the case.
Place: Dated : Counsel for the Petitioner