1 IN THE COURT OF THE HONBLE VII ADDL. CHIEF METROPOLITAN MAGISTRATE: : AT HYDERABAD CC No.

OF 2012

Between: Kashimshetty Karunasagar S/o K. Krishnaiah Age:33 yrs, Occ: Practising Advocate, R/o. H.No. 9-4-35/2, Mahnakli thota, Champapet Hyderabad ... AND Akbaruddin Owaisi S/o Late Sultan Salahuddin Owaisi Age: 42 Yrs, Occ: MLA Chandrayangutta Constituency, Hyderabad. R/o 8-2-686/B/A, Road No.12, Banjara Hills, Hyderabad. Place of Offence :

Complainant

Accused

Complainants office H.No. 17-2-481/1, 1st Floor, Beside ICICI ATM, Saidabad Main Road, Kurmaguda, Hyderabad. 26.12.2012 Offence U/Sec. 295-A, 298, 153-A of IPC P.S. Madannapet 1. Complainant himself.

Date of Offence Nature of Offence Name of P.S. Witnesses

: : : :

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

2 complainants 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 SelfControl 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

3 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

4 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 Honble 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 Honble court has got vide jurisdiction to try the accused. Therefore the complainant prays that this Honble 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 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 December, 2012 at Hyderabad. day of COMPLAINANT

COMPLAINANT

5 LIST OF DOCUMENTS 1. CD of the accused speech. oCOMPLAINANT

6 IN THE COURT OF THE HONBLE VII ADDL. CHIEF METROPOLITAN MAGISTRATE: AT HYDERABAD CC No. OF 2012

Between: Kashimshetty Karunasagar COMPLAINANT AND Akbaruddin Owaisi Accused

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

Filed on: 28.12.2012

Filed by: KASHIMSHETTY KARUNASAGAR Complainant Cell: 9848030704 (PARTY IN PERSON)