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IN THE COURT OF THE HON’BLE VII ADDL. CHIEF METROPOLITANMAGISTRATE: : AT HYDERABAD

CC No. OF 2012

Between:Kashimshetty Karunasagar S/o K. KrishnaiahAge:33 yrs, Occ: Practising Advocate,R/o. H.No. 9-4-35/2, Mahnakli thota, ChampapetHyderabad ... Complainant

AND

Akbaruddin Owaisi S/o Late Sultan Salahuddin OwaisiAge: 42 Yrs, Occ: MLA ChandrayanguttaConstituency, Hyderabad.R/o 8-2-686/B/A, Road No.12, Banjara Hills,Hyderabad. … Accused

Place of Offence : Complainant’s office H.No. 17-2-481/1,1st Floor, Beside ICICI ATM, SaidabadMain Road, Kurmaguda, Hyderabad.

Date of Offence : 26.12.2012

Nature of Offence : Offence U/Sec. 295-A, 298, 153-A of IPC

Name of P.S. : P.S. Madannapet

Witnesses : 1. Complainant himself.

COMPLAINT FILED U/SECTION 200 OF Cr.P.C

The complainant humbly submits as follows:

1. The Complainant submits that the complainant is orthodox Hindu and

is practicing advocate and hails from respectable family of the society.

2. The Complainant further submits that on 26.12.2012 at about 1930

Hrs, while the complainant was browsing internet at his office situated at

H.No. 17-2-481/1, 1st Floor, Beside ICICI ATM, Saidabad Main Road,

Kurmaguda, Hyderabad., saw a video in YouTube site wherein the accused is

addressing a public meeting (MIM Jalsa) at Nirmal town of Adilabad Dist. in

Urdu language using inflammatory and derogatory words against the

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complainant’s religion and Hindu gods and goddesses by saying “HINDUON

KE KAYIE KUDHA HAI, KITNE RAM, LAXMAN, DURGA, LAXMI KYA

KYA HAI, KITE HAI BYE, HAR AAT DIN MEIN EK NAYA PAIDA HO

JATHA HAI” and so. And further the accused addressed “LAXMI MALLOM

THI, YE BHAGYA LAXMI AAJ TAK NAYI SOONE, YEH KOUN SI NAYI

HAI BHAI, BARAAL MAIN KYA BOLU KAISE KAISE NAAMA HAIN, YEH

MUBARAK MEHFIL MAIN WHO MANHUS NAMONKO LEKAR KHARAAB

KARNA NAHI CHAHATA” hurting the religious feelings of the complainant

insulting the Hindu gods and godesses.

2. The complainant further submits that in the address the accused also

used derogatory language towards Lord Sri Rama and Devi Kousalya,

regarding the birth of the Lord Sri ram, by saying “AYODYA MEIN TEEN

MARTABA AISA HAIN KI JAHAN KE LOG KEHETE HAIN KI RAM YAHA

PAIDA HUAIN, RAM YAHA PAIDA HUAIN, RAM YAHA PAIDA HUAIN,

HARYANA KE KOUSALAYPURAM KE LOG KEHETE HAIN KE

KOUSALAYA WAHAN KI THI AUR RAM WAHAN PAIDA HUVE, AREY

ADVANI VAJPAYEE, UMA BHARATI, MODI BATA AAKAR RAM KI MAA

KAHA KAHA GAYI KIDAR JANAM DIYEETHI RAM KO”

3. The complainant further submits that Lord Shree Rama is worshipped

by crores of Hindus across the globe, Rama is referred to within Hinduism as

MARYADA PURUSHOTTAMA literally the Perfect Man or Lord of Self-

Control or Lord of Virtue. Rama's life and journey is one of perfect adherence

to dharma despite harsh tests of life and time. He is pictured as the ideal

man and the perfect human, the legend of Rama is deeply influential and

popular in the societies of the Indian subcontinent and across South East

Asia. Rama is revered for his unending compassion, courage and devotion to

religious values and duty. And this not the first time the accused has

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insulted the Lord Rama, in a public meeting addressed by the accused at

Nanded also the accused insulted the religious feeling of Hindus and a case

is filed against the accused for the same.

4. The complainant further more submits that the accused has resorted

to insult and annoy complainant by giving statements on Hindu gods and

goddesses openly without having any fear of law. More concerned is. The

accused in most regardless manner gave hatred speech and instigated the

audience present their by saying “AREY HINDUSTHAN HUM PACHIS

KAROD HAIN NAA, TUM SOU KAROD HAIN NAA, TEEK HAIN TUM THO

HAMARE SE ITNE JYADA HAIN, PANDRA MINUTE KE LIYE POLICE KO

HATALO BATADENGE, KISMEIN KITNA HIMAT HAIN KOUN

TAAKATWAR HAIN, PANDRA MINUTE HATALO POLICE KO”.

5. The Complainant has further more submits that the complainant also

used derogatory words against the Holy Gou Mata, and the speech of the

accused has caused annoyance to complainant who has faith in Hindu gods

and goddesses, and the Antecedents of accused are against the interest of

the State.

6. The complainant further submits that The Constitution Of India 1949,

under Article 14 : EQUALITY BEFORE LAW: The State shall not deny to

any person equality before the law or the equal protection of the laws within

the territory of India Prohibition of discrimination on grounds of religion,

race, caste, sex or place of birth. But the accused gave deliberate and

malicious speech commenting Hindu gods and Goddesses and lord Rama

intended to outrage complainants religious feelings and religious beliefs by

provocative words of the accused, which were spoken insulting the

Goumata, and Hindu gods and Goddesses thereby the is promoting on

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grounds of religion, causing feelings of enmity, hatred and ill-will between

Hindus and Muslims.

7. The complainant further more submits that the complainant is put to

lot of trouble and mental agony after seeing the video and is put to mental

shock, that the accused being an MLA has acted in such a way that it hurt

the religious sentiments of complainant. Deliberate and malicious speech

commenting on the Hindu Gods and Goddesses intended to outrage Hindu

religious feelings by insulting religion and religious beliefs and have by his

provocative words.

8. The Complainant submits that this Hon’ble court has got wide

jurisdiction to try the accused and as the office of the complainant is situated

in the jurisdiction of P.S. Madannapet and hence this Hon’ble court has got

vide jurisdiction to try the accused.

Therefore the complainant prays that this Hon’ble Court may be

pleased to take cognizance against the accused u/Sec. 295-A, 298, 153-A of

IPC summon to stand trial and suffer punishment for the offences in

accordance with law in the interest of justice.

Hyderabad

Dt. -12-2012 COMPLAINANT

VERIFICATION

I, the above named complainant herein, do hereby declare that the

above mentioned facts are true and correct to the best of my knowledge,

belief and information, hence verified the same on this the day of

December, 2012 at Hyderabad.

COMPLAINANT

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LIST OF DOCUMENTS

1. CD of the accused speech.

oCOMPLAINANT

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IN THE COURT OF THE HON’BLEVII ADDL. CHIEF METROPOLITAN

MAGISTRATE:AT HYDERABAD

CC No. OF 2012

Between:Kashimshetty Karunasagar

… COMPLAINANT

AND

Akbaruddin Owaisi… Accused

COMPLAINT FILED U/S 200 OFCr.P.C.

Filed on: 28.12.2012

Filed by:

KASHIMSHETTY KARUNASAGARComplainant

Cell: 9848030704

(PARTY – IN – PERSON)