Dear experts,
Since I have no experience in trial court, I submit herewith a draft of List of Witnesses which may please be examined and valued opinion be given for which I would be much grateful.
In one format of High Court Rules, I have seen the List of Witnesses in fabular form.
(DRAFT)
1. The Complainant CW-1 (address on record)
Facts Sought to be proved by the evidence of the witness:
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Intentional insult [S-504 IPC] by Accused No. 1 by returning consignment after pilferage and cello-taped by
her which at the time of delivery to her weighed 300 gms evidenced by speedpost receipt and after pilferage
by Accused-1 weighed 68 grams [exhibit CW-1/A]; and whereas Accused No. 2 (Postman) for extraneous
considerations after delivery took back the pilfered consignment after 6 days and in conspiracy with Accused-
1 sent it back after another 10 days marking it as “refused”.
Documents sought to be proved by the evidence of the witness:
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Reliance on attested copy of Delivery Slip: [1] Ex CW-1/A & [2] pilfered consignment weighing 68 gms
marked as Ex CW-1/B submitted vide statement dated: 14/08/2019.
2. Mr. ______ Senior Supdt. of PO/CPIO
Naraina I.E. Head Post Office
New Delhi-110028
Facts Sought to be proved by the evidence of the witness:
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The witness has provided attested copy of Delivery Slip, which is in response to RTI application sent to
Accused No. 3 [Post Master] who “intentionally” aided the commission of the crime by Accused No. 2 in
fabricating false evidence for extraneous
considerations. It is judicially noticeable that the signature of actual recipient was camouflaged by stapling a
piece of paper with a forged signature over it and then photocopied and attested [CW-1A].
Documents sought to be proved by the evidence of the witness:
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Witness to give oral evidence & to produce original Delivery Slip fabricated (S-192 IPC) by Accused-2
Postman & Accused-3 wilful abettor of crime (S-107 IPC).
3. Mr. -------
(address)
Father of Accused-1
who took delivery of consignment
Facts Sought to be proved by the evidence of the witness:
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Witness had initialed* the Delivery Slip (CW-1/A) and handed over the consignment to Accused-1
(addressee) on 13.07.2016 who resorted to intentional insult in collusion with Accused-2 pilfered the consignment
and Accused No.2 took it back after 6 days and sent it back after another 10 days as evident from CW-1/B.
[* admitted/authentic specimen of initial is available].
Documents sought to be proved by the evidence of the witness:
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It proves that the consignment was delivered to Accused-1 at her residence.
4. I/O F.I.R. No. ----------
P.S: C.R. Park
New Delhi
5. Any other relevant witnesses as per the outcome.
Witnesses required to give oral evidence and also to produce documents
Filed by COMPLAINANT IN PERSON
Filed on.....................
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