श्री जानकी वल्लभो ववजयते
Before the :
HON’BLE ADDITIONAL DISTRICT AND SESSION JUDGE
MAHENDERGAH @ NARNAUL
Case No: SC-163/2023
[CNR: HRNR010081662023]
Re:
STATE OF HARYANA
…Prosecutor
Versus
HEMANT KHURANA
…Accused
[FIR: 217 Dated 11-07-2023
u/s 341,354,365,506,511 IPC..
..& 3(1)(R.)3(1)(s) SC-ST Act
P.S. : CITY MAHENDERGAH]
ADJOINDER TO THE APPLICATION UNDER SECTION 94 BNSS, 2023
MOST RESPECTFULLY SHOWETH:
1. That the present adjoinder is respectfully submitted in response to the Hon’ble
Court’s inquiry during today’s proceedings, i.e., 08-01-2025, fixed for
consideration of the interim application seeking the production of crucial
documents and records.
2. Details of Mobile Numbers and Their Relevance:
a) Mobile No. +91-7015570355: Registered to the accused, Hemant Khurana,
and used to report the incident of “संदिग्ध परिदथिदि में िेखे जाने पि झूठे मुकिमों में
फंसाने की धमकी दिए जाने बािे ” at approximately 11:30 PM on 10-02-2023.
CNR: HRNR010081662023 Page 1 of 3
Adjoinder to the Application under section 94 BNSS, 2023
o Calls were made to:
➢ Vijay Mahayach (Ex-Councillor) at +91-8901085660.
➢ Narender Khanna (Ex-Councillor) at +91-9416994422.
o Both individuals are prominent witnesses to the events at the first
scene of the alleged crime
b) Mobile Nos. +91-7419354791 and +91-8053329500: Threat calls were
received by the accused from these numbers on 11-02-2023, substantiating
his claims of harassment.
c) It has since emerged that:
➢ Mobile No. +91-7419354791 is registered to Tanuja, daughter of
Bhagwan Singh (the Complainant)
➢ Mobile No. +91-8053329500 is registered to Vinod (the alleged
independent witnesses of the FIR)
o On 08-07-2023, at approximately 6:00 PM, the then Investigating
Officer, Ravi Kumar SI, called these numbers, leading to the
appearance of Tanuja, Naresh (police employee), and Vinod at the
Mahendragarh Police Station.
3. Statements of Witnesses and Their Suppression:
Independent witnesses recorded by the investigation agency include:
• First Scene (10-02-2023, 11:30 PM):
➢ Kapil Yadav, Avinash Arora, Narender Khanna.
• Second Scene (11-02-2023, 9:00 AM):
➢ Anjali, Rajesh.
CNR: HRNR010081662023 Page 2 of 3
Adjoinder to the Application under section 94 BNSS, 2023
Despite their critical relevance, these statements have been suppressed in
the charge-sheet, depriving the accused of essential evidence for his defense.
PRAYER:
In light of the above, it is most humbly prayed that this Hon’ble Court may
kindly:
1) Direct the production of the following materials by the investigating
authorities:
A. Verified Call Detail Records (CDRs) of mobile numbers +91-
7015570355, +91-8901085660, +91-9416994422, +91-
7419354791, and +91-8053329500 for 10-02-2023 to 11-02-
2023.
B. Statements of the independent witnesses recorded during the
investigation of the First complaint of the incidences i.e .PG-
314.
C. Any relevant electronic evidence, including CCTV footage.
2) Pass any other order(s) deemed fit in the interest of justice.
ALL OF WHICH IS MOST HUMBLY PRAYED.
Accused:
Hemant Khurana
(In Person)
Date: 08-01-2025
Place: Narnaul, Judicial Complex
CNR: HRNR010081662023 Page 3 of 3
Adjoinder to the Application under section 94 BNSS, 2023
