1. Charge Sheet
Ex-01: The Presenting Officer takes Article I of the charge (“Violation of Rule 3(1) of Conduct Rules - absence from duty without sanction for 30 days”) and cites the specific dates and periods from the charge sheet in his brief.
Ex-02: The Charge Sheet mentions that the Charged Officer submitted a false LTC claim. The PO uses this as the opening point in his brief, establishing the basis of the case.
Ex-03: The PO refers to the annexures of the Charge Sheet (Statement of Imputations, List of Documents, List of Witnesses) to build the Charge-Fact-Evidence co-relation in his brief.
2. Statement of defence given by CO at various stages
Ex-01: The CO’s initial statement: “I deny all charges” is contrasted with his detailed defence statement filed after reviewing documents. The PO uses this to show inconsistency.
Ex-02: During the inquiry, the CO submitted an additional written statement after the prosecution evidence. The PO uses this to show new arguments raised belatedly.
Ex-03: The CO’s defence in response to the mandatory question is quoted in the PO’s brief to show that his explanation contradicts documentary evidence.
3. Evidence led by parties - documentary and oral
Ex-01: The PO refers to documents marked as PE-1 to PE-15 (prosecution exhibits) and DE-1 to DE-8 (defence exhibits) to establish facts in his brief.
Ex-02: The PO quotes the oral evidence of State Witness No. 3: “I saw the Charged Officer signing the attendance register on 15th May even though he was not present in office.”
Ex-03: Defence Witness No. 2’s statement: “The Charged Officer had applied for leave orally” is contrasted with the written record showing no leave application.
4. Daily Order Sheet
Ex-01: The PO cites DOS entries showing the Charged Officer was granted 5 adjournments on his request, to counter the CO’s potential argument of “denial of reasonable opportunity.”
Ex-02: The DOS records show that the CO was permitted to inspect all documents. The PO uses this to prove that no opportunity was denied.
Ex-03: The PO refers to the DOS entry where the CO admitted the genuineness of 7 documents, which were taken on record without formal proof.
5. Interlocutory Orders passed by IA
Ex-01: The IA’s order rejecting the CO’s request for a document on grounds of privilege is quoted to explain why the PO did not produce it.
Ex-02: The IA’s order allowing the CO to engage a Defence Assistant from another station is referenced to show that the IA was fair to the CO.
Ex-03: The IA’s order disallowing the PO’s request for new
evidence is cited to show the IA’s impartiality and adherence to rules.
