WRITTEN STATEMENT — VIS 145 CR. P. C.
IN THE COURT OF............................ SDM/MAGISTRATE............................
Case No............................. 2002
In Re: -
AB................................................................. First Party
versus
mCD............................................................ Second Party
Written statement by second party. 
Most respectfully showeth: -
1. That the orchard being Plot No............................. in question under the proceeding is exclusively in possession and in charge of second party since last ............................ years and the orchard in question had never been in possession of first party.
2. That the continued possession of the orchard in question can never be disturbed by first party and cannot be challenged in the proceeding adopted by First party in an illegal method is a misleading in nature.
3. That First party instead of taking proper recourse to civil court if any can not resort to section 145 Cr. P. C. for possession.
4. That present case is not covered by proviso to Section 145(4) Cr. P. C. for the rightful owner is second party.
PRAYER
It is most respectfully prayed that the application of First Party under Section 145 Cr. P. C. being misconceived in Law and contrary to actual fact of possession be dismissed and peaceful possession of orchard by second party be maintained.
Second party
Date: 															Through Counsel
Place: